External evaluation of Extending Fairtrade Gold to Africa project Jan Joost Kessler, Aidenvironment (Amsterdam), in collaboration with: Thomas J. Ndaluka, The Mwalimu Nyerere Memorial Academy, Tanzania, and Eleanor Fisher, School of Agriculture, Policy and Development, University of Reading, UK Commissioned by The Fairtrade Foundation 3rd floor Ibex House 42-47 Minories London, EC3n 1 DY September 2015 Aidenvironment, Barentszplein 7, 1013 NJ Amsterdam, The Netherlands www.aidenvironment.org
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External evaluation of Extending
Fairtrade Gold to Africa project
Jan Joost Kessler, Aidenvironment (Amsterdam), in collaboration with:
Thomas J. Ndaluka, The Mwalimu Nyerere Memorial Academy, Tanzania, and
Eleanor Fisher, School of Agriculture, Policy and Development, University of Reading, UK
Commissioned by
The Fairtrade Foundation
3rd floor Ibex House 42-47 Minories
London, EC3n 1 DY
September 2015
Aidenvironment, Barentszplein 7, 1013 NJ Amsterdam, The Netherlands
www.aidenvironment.org
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ii
Table of contents
Abbreviations i
Executive Summary ii
1. Introduction 1 1.1 Evaluation scope and purpose 1 1.2 Project objectives, scope and partners 1
2. Approach and Methodology 2 2.1 Evaluation phases 2 2.2 Evaluation framework 3 2.3 Evaluation methodology 3 2.4 Limitations of the methodology 4
3. Results 5 3.1 Theory of change 5 3.2 Context changes 6 3.2.1 Kenya 6 3.2.2 Tanzania 7 3.2.3 Uganda 8 3.2.4 Main similarities and differences between the three countries 9 3.3 Results achieved per project component 10 3.3.1 Objective 1: Small-scale miners mine gold in a fair manner 10 3.3.2 Objective 2: Creation of African knowledge network on ASGM 17 3.3.3 Objective 3: Influenced policy and decision-making towards ASGM 20 3.3.4 Objective 4: Jewellers commit to source Fairtrade certified gold from Africa 22 3.3.5 Objective 5: Increased awareness of consumers on Fairtrade gold 23 3.4 Project management 24 3.4.1 Project organisation 24 3.4.2 Monitoring and evaluation 25 3.4.3 Reporting 26
Appendix 3: Questionnaires and checklists 47 Level 1: Gold miners 47 Level 2: Community level 48 Level 3: ASMO level 48 Level 4: Local Support Organisations and network 50
iii
Level 5: Gold sector key stakeholders and context 51
Appendix 4: Community wellbeing Analysis Tool 53
Appendix 5: Ethical considerations 55
Annex 6: Theory of change 56
Appendix 7A: Case study report Kenya (in separate file) 59
Appendix 7B: Case study report Tanzania (in separate file) 59
Appendix 7C: Case study report Uganda (in separate file) 59
i
Abbreviations
ARM Alliance for Responsible Mining
ASM Artisanal and Small-scale Miner
ASGM Artisanal and small-scale gold mining
ASMO Artisanal and Small-scale Mining Organisations (supported by this project)
CANCO Community Action for Nature Conservation
CR Comic Relief
EWAD Environmental Women in Action for Development
FGD Focus Group Discussions
FT Fairtrade
FT / FM Fairtrade / Fairmined
FTA Fairtrade Africa
FTF Fairtrade Foundation
KII Key Informant Interviews
LSO Local Support Organisations
SECEAC Solidaridad East & Central Africa Expertise Centre
SGI Structured Group Interviews
Sol NL Solidaridad Netherlands
STI sexual transmitted infections
MTL MTL Consulting Ltd
ii
Executive Summary
In 2009, Fairtrade International set up a program for Fairtrade Gold and Precious Metals (hereafter
‘Fairtrade gold’) and developed a Fairtrade and Fairmined standard and corresponding consumer
label. The consumer label empowers miners to improve their livelihoods and contribute to the social,
economic and environmental development of their communities. A three year project has been
funded by Comic Relief ‘Extending Fairtrade Gold to Africa project’ with the overall objective to
improve livelihoods and working conditions among artisanal and small-scale gold mining (ASGM)
communities by testing the application of the Fairtrade Standard for Gold and Precious metals in
East Africa. The project started in May 2012. The project has supported a total of nine Artisanal and
Small-scale Mining Organisations (ASMOs) in three countries in East Africa: Kenya, Uganda and
Tanzania. The project was managed by the Fairtrade Foundation and Fairtrade Africa, and worked
with several partners: Solidaridad Netherlands, Solidaridad East & Central Africa Expertise Centre,
MTL Consulting Ltd and Environmental Women in Action for Development.
The evaluation covered the activities executed by the project from May 2012 until July 2015,
following a no-cost extension of the project by a few months. The evaluation was carried out in
accordance with the Terms of Reference (see Appendix 1) and the inception report. The purpose of
this evaluation was two-fold:
1. Accountability to donors: evaluate relevance, effectiveness, efficiency, impact and sustainability
of the project.
2. Institutional learning and continuous improvement: identify lessons learned for project partners
and recommendations for future engagement in the ASM sector in East Africa.
The evaluation was carried out from May to September 2015. Field visits took place in July-August
2015, during which ASMOs were visited in Kenya, Tanzania and Uganda and interviews were held
with relevant stakeholders. Three types of methods were used to acquire information during
interviews and field visits:
1. Key Informant Interviews: individual interviews with key persons, mainly public officers and
community workers.
2. Structured Group Interviews: interviews with the leadership of ASMOs and ASM networks.
3. Focus Group Discussions, with members of ASMOs, using a Mining Livelihoods, Skills and
Employment Analysis Tool, conducted separately with men and women. Where possible miners
were sampled randomly for inclusion in the FGD based on ASMO membership lists.
Apart from these qualitative methods, use was made of quantitative data as provided according to
monitoring and reporting by the project. The mix of methods allowed conclusions to be drawn on the
contribution of the project and on plausible impacts, as well as success factors, lessons and
recommendations, taking into account the variable context. It was not possible to replicate the
evaluation methodology with comparison groups, at ASMO or community level, as this was found to
be inappropriate given that alternative miners’ organisations are not present in the ASMO
communities, and that the ASGM context is characterised by conflicting relations and lack of trust.
Instead comparisons were made through interviews with community leaders and individual miners.
The following conclusions are structured by the main criteria of the evaluation framework.
Relevance
The activities undertaken by the project are highly relevant, as based on: (i) the positive potential of
ASGM as a generator of rural employment, household income, and local economic development;
(ii) the current negative social, health and environmental impacts of gold mining, both direct (on
miners) and indirect (on the wider communities); (iii) the receptiveness of miners to most of the
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improved practices proposed by the project; and (iv) the changing national policy/legislative
contexts where government representatives start to become more open to ASM issues (notably in
Kenya and Uganda, in Tanzania a positive attitude to ASM is already more established).
Efficiency
The process of selection of countries and ASMOs included in the project has been good. Moreover,
despite important country-level contextual differences, project implementation in three East
African countries simultaneously has created beneficial synergies and successful knowledge
exchange.
The Project’s management system was disrupted by the fact that the organisation Alliance for
Responsible Mining (playing a key role in the project) pulled out at an early stage. The project
adequately responded to this disruption.
The process of building up expertise has been partly one of learning-by-doing, in close interaction
with the ASMOs, as would be expected from a pilot study. Feeding into this has been the fact that
experience on ASM gold mining had to be transposed and applied from Latin America to East
Africa; we believe that the difference between these two regions was seriously under-estimated at
the project start.
The project partners made efficient use of resources to train and support ASMOs. The collaboration
between partners was effective and efficient, with use being made of mutual expertise. However, it
is uncertain whether this leads to building up capacity in each of the 3 countries on all issues
related to sustainable mining. For instance, knowledge on productivity aspects may still be less
developed.
The quality of training provided is appreciated by the ASMOs, and also by many other
stakeholders. The M&E system is difficult to understand. Considerable resources have been spent
on a baseline measurement but the resulting data has not been used. The current M&E system
generates some useful results, but does not provide easy insight into progress per ASMO, and does
not capture critical issues such as ASMO leadership and internal cohesion. Many indicators are not
very useful, for instance what does it mean that 39 stakeholders are engaged in the ASGM network?
The annual reports are very informative and the narratives provide useful information on
processes, learnings and new insights that have emerged.
We have doubts about the usefulness of continuing the need for quarterly reports, which puts a
high burden on limited human resources.
Annual conferences have been useful and appreciated by all project partners, and were important
in order to streamline experiences and thinking on how best to achieve the project objectives. Peer
learning and follow-up visits by respective leaders to ensure practices have been applied have been
effective. Workshop-based learning also has been effective and welcomed.
The time horizon of 3 years is appropriate for a pilot phase. The project has achieved value for
money in terms of acquiring a wealth of knowledge on this new theme for Fairtrade in East Africa,
as well as capacity building for the selected ASMOs, commitment among several jewellers to
purchase Fairtrade gold, and organised advocacy in the 3 countries on ASGM issues. Nevertheless,
beyond piloting, a longer time horizon is essential to sustain the results and realise more full-
fledged impacts and upscaling.
Effectiveness
Overall, progress has been slower than expected because the expectations for this project were
based on experiences in Latin America and the assumption that in East Africa conditions would be
similar, which is not the case: small-scale gold mining in East Africa is more informal and
unorganised, within a wider institutional context that has severe resource and capacity constraints.
Expecting ASMOs to get organised, trained and certified in only 3 years is unrealistic.
The project has contributed to an increase on the ground in awareness and change of practices
reducing the risks and unsustainable practices related to ASM. Training by the project has met with
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a good response, and has led to several changes in attitudes and practices by ASMO members,
especially among ASMOs that already have a history of being organised.
A mock audit was conducted in November 2014 and 4 ASMOs were found to be ready for being
audited.
There are three optional conclusions on effectiveness which depend upon the defined expectations:
o The project has successfully piloted an approach of building up an ASMO with internal
governance and introducing practices to improve livelihoods and working conditions for artisanal
and small-scale gold miners, based on the FT standard on gold, with awareness and knowledge
generated, capacities built and several practices being applied.
o The project will likely realise FT certification with two ASMOs (and possibly four) within the
coming months, however there are questions about whether these two ASMOs can be considered
as representative since they are also the ones that existed and had capacity development well
before the project started.
o The project has not been able to respond to the demand by ASMOs to improve their productivity
and access to finance, which is a critical remaining gap with respect to the business model that is
required to assure sustainability of mining, the status of certification and the ASMOs. The subject
of productivity is important, because where production is low and revenues from gold mining are
meagre, groups are seen to disintegrate as miners go to work in other non-ASMO mines or focus
on other sources of income.
In relation to the work with ASMOs, the main conclusion is that although many successes have
been achieved, it would be too early to conclude that proof of concept has been achieved in terms of
the project having developed a model for sustainable artisanal and smallscale gold mining.
The project is recognised as a leading reference for responsible mining in the region and as
contributing to development of a regional network by offering a practical solution to some of the
issues that are being raised at regional and international levels.
The project has set up the foundation for advocacy into mining issues in the region through the
established networks in Kenya, Uganda and Tanzania. A critical reflection is needed on how these
structures will sustain and consolidate themselves without external (project) funding.
The project has significantly contributed to build up awareness among European-based jewellers
(traders) and generated commitment to purchase FT gold from East Africa as soon as it becomes
available.
Lessons learned
It takes time (at least 3 years) for a group of miners to build an organisation with internal cohesion,
trust and leadership, as a foundation to adopt measures to improve livelihoods and eventually
achieve certification;
There are constraints even for a well established ASMO to adopt the various measures to improve
their livelihoods; most easily adopted are those with immediate effects on health and safety;
Some improved practices are being copied by other ASMOs and communities, which is promising;
Productivity increases are critical for sustaining improvements of livelihoods and maintaining
cohesion within the ASMO; to achieve this investments are required to purchase equipment;
savings and credit schemes as promoted by the project are insufficient to cater for this level of
investment;
ASMOs are small and vulnerable to productivity dips by natural factors, including problems with
mine construction, with a consequence that to acquire incomes miners are highly mobile,
membership therefore fluctuates and also the number of casual/daily workers may vary
considerably;
There is a significant difference between selling gold and trading gold, it remains to be seen under
what conditions trading gold (to overseas jewelers, based on trading conditions) will be successful;
The project has so far not been able to develop an adequate response to the need for pre-financing
for the ASMOs (removing a function currently provided by local gold buyers), although initiatives
are being taken to address this issue.
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Impacts
There is evidence that incomes have increased for ASMO members, and it is also suggested that
productivity has increased as a result of the fact that pits remain productive for longer periods.
There is evidence of less casualties due to better safety measures, of less child labour and of
improved health due to more controlled use of mercury and less labour intensive techniques, such
as the use of an ore chrushin machine, sluive box, electric pumps.
The project has significantly reduced mercury use and thus environmental impact; use of retorts
and improved practices has been adopted leading to reduced mercury purchases.
In terms of environmental rehabilitation promising results have been achieved, through tree
planting, covering and in-filling of pits, but these results are not widespread.
There is evidence of some improvement in terms of women’s roles and gender-based power
relations in mining, but there is also evidence that improvement to gender roles is more tokenistic,
with control over key areas of decision-making, such as finance, remaining under the control of
male members.
The Fairtrade project has successfully contributed to preventing children under 18 working in the
ASMO pits. However, several health, education and safety problems remain at community level.
The project has just started to affect this issue, for instance through a Child labour Monitoring
Programme in a wider ASMO community.
Future plans for Fairtrade gold mining should ensure that more synergies are created between
Fairtrade and other initiatives, including getting local government officers to attend meetings and
making linkages with relevant NGOs.
The project has contributed to advocacy at local government level on behalf of artisanal miners,
with some concrete results. There are opportunities for contributions to future policy dialogue on
behalf of artisanal miners. The project needs a public engagement strategy to know how best to
pursue these opportunities at different policy levels and in collaboration with partners.
The ASMOs supported by the project are seen as models for good mining practice. There is
evidence of practices being copied outside the ASMOs, especially those on immediate health and
safety; but it is fair to say that bad practices / lack of knowledge remain extensive in the wider
community.
Although the project is commended by district governments, ‘crowding in’ effects by government
agencies that feel strengthened by the project to improve the ASM sector are not taking place due to
institutional capacity and resource constraints within the wider governmental context.
Casual/daily labourers will remain a significant part of the workforce within the ASMOs and plans
for ASMO capacity building need to adequately recognise their rights and specific needs.
Sustainability
There is a real concern that the results will not sustain if the public policy context does not improve
(mainly in Kenya and Uganda).
The legal context varies significantly per country, but is generally becoming more favourable,
leading to opportunities for policy engagement.
Leadership and mutual trust are keys to a good functioning ASMO, and regular monitoring, peer
visits and exchanges help strengthen and maintain these. It is unrealistic to expect formation and
consolidation of ASMOs in just three years.
Financial incentives or equipment are required to increase and sustain mining productivity.
There is need to continue capacity building efforts, as so far only relatively few miners have been
reached, and improved practices have not yet been well established.
Land disputes can undermine security and sustainability of the ASMOs. In Kenya and Uganda land
issues are not resolved through mining licensing because land and mineral rights remain separate.
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Recommendations
The main recommendation is that we are dealing with ‘unfinished business’; currently the ASMOs
are in an initial pilot phase, vulnerable to shocks if unsupported. If the project activities do not
continue, being adjusted or expanded to take into account recommendations, there will be a major
risk of fall-back and many of the current results will not be sustained.
There is need to differentiate between a first phase of building up a coherent ASMO, with sufficient
level of internal leadership, governance and management systems, and a second phase of bringing
about changes in terms of more sustainable mining practices that can lead to successful Fairtrade
certification and gold trading. If one starts out with unorganised miners working in an extremely
challenging policy, institutional and legal environment, as is the case in East African countries, the
first phase already takes a minimum of 3 years. There is need for a system of assessing
organisational maturity to know when an ASMO is ready for the second phase.
The second phase would be one of realising a minimum of social and environmental requirements
to be met for an ASMO to get pre-certified. Also, during the second phase there is need to improve
productivity (including the reliability of production through improved mine construction), because
where production is low and revenues from gold mining are meagre, groups are seen to disintegrate
as miners will focus on other sources of income. This requires pre-financing or other ways of
assuring access to finance.
There is need for collaboration with existing governmental and non-governmental organizations
working in the same areas, which would require a Fairtrade policy engagement strategy and
financial resourcing.
There is need for an (improved/streamlined) M&E system to assess the positive socio-economic
and environmental effects following pre-certification, for accountability to the companies willing to
make investments in pre-certification, with both quantitative and qualitative indicators.
Indicators need to be significantly revised making them fit-for-purpose.
Before pre-financing is provided, there is need for an improved internal book keeping system and
savings and banking mechanisms for ASMOs; this will require further capacity building.
There is need to address wider community welfare effects through collaboration with relevant
governmental and donor initiatives, because otherwise there is a risk that the expected gold
production increase and associated cash earnings will lead to increased spending in irresponsible
activities such as alcohol, drugs and sexual relations without building longer term livelihood
investment.
There is need to explore the option of working with larger production units or partnerships (e.g.
larger gold producing companies), because small units are too vulnerable to production stoppages
due to natural factors and current mine construction techniques, can make use of costly equipment
and have better potential to meet the demands of jewelers (international traders) for large
quantities of (certified) gold. These larger units could be linked to the centers of excellence that
have been suggested.
Since casual/daily labourers will remain a significant part of the workforce within the ASMOs,
plans for ASMO capacity building need to adequately recognise their rights and specific needs.
This includes putting better mechanisms in place for extending take-up of training by casual/daily
wage labourers, many of whom have worked in mining and at the ASMO mines specifically for
significant time.
1
1. Introduction
1.1 Evaluation scope and purpose
In 2009, Fairtrade International set up a program for Fairtrade Gold and Precious Metals (hereafter
‘Fairtrade gold’) and developed a Fairtrade and Fairmined standard and corresponding consumer
label. The consumer label empowers miners to improve their livelihoods and contribute to the social,
economic and environmental development of their communities. A three year project has been
funded by Comic Relief ‘Extending Fairtrade Gold to Africa project’ with the overall objective to
improve livelihoods and working conditions among artisanal and small-scale gold mining (ASGM)
communities by testing the application of the Fairtrade Standard for Gold and Precious metals in
East Africa. The project started in May 2012. The project has supported a total of nine Artisanal and
Small-scale Mining Organisations (ASMOs) in three countries in East Africa: Kenya, Uganda and
Tanzania. The evaluation covered the activities executed by the project from May 2012 until July
2015, following a no-cost extension of the project by a few months.
This evaluation was carried out by J.J. Kessler as the team leader from Aidenvironment, in
collaboration E. Fisher of the School of Agriculture, Policy and Development, University of Reading,
UK, and T. Ndaluka of the Mwalimu Nyerere Memorial Academy , Tanzania. The evaluation
primarily included field visits to ASMOs in the three different countries, as well as participation in
the end-of-project conference in Kenya (3 days), and interviews with relevant staff of Fairtrade
Foundation (FTF), Comic Relief and the different project partners, in the period of July-August 2015.
The evaluation was carried out in accordance with the Terms of Reference for this evaluation (see
Appendix 1) and the inception report. The purpose of this evaluation is two-fold:
3. Accountability to donors: evaluate relevance, effectiveness, efficiency, impact and sustainability
of the project.
4. Institutional learning and continuous improvement: identify lessons learned for project
partners and recommendations for future engagement in the ASM sector in East Africa.
1.2 Project objectives, scope and partners
The overall project objective is to improve livelihoods and working conditions among ASMOs by
piloting the application of the Fairtrade Standard for Gold and Precious metals in East Africa. In
order to achieve this objective the project works on five objectives and related outcomes:
1) In 3 countries, 1,100 small-scale miners are enabled to mine gold in a fair and responsible
manner in compliance with the FT standard for gold and precious metals
2) Creation of an African knowledge network that promotes responsible ASM practices, including
capacity building of Local Support Organisations (LSOs) in each of the project countries
3) Key stakeholders in governmental and non-governmental sectors are influenced in their policy
and decision-making towards ASGM
4) At least 5 jewelers commit to sourcing Fairtrade certified gold from Africa
5) Increased awareness of consumers in the UK and Netherlands on ethical and Fairtrade issues
related to gold.
The project covers three countries, with nine ASMOs located in:
Kenya: Migori and Narok Counties: 2 ASMOs
Tanzania: Geita District: 3 ASMOs
Uganda, Busia District: 4 ASMOs
2
The organizations involved as project partners in this project are the following (the indicated
abbreviations are used throughout this report):
Fairtrade Foundation (FTF)
Fairtrade Africa (FTA)
Solidaridad Netherlands (Sol NL)
Solidaridad East & Central Africa Expertise Centre (SECEAC)
MTL Consulting Ltd (MTL)
Environmental Women in Action for Development (EWAD)
The programme was established in 2009 in partnership with the Alliance for Responsible Mining
(ARM), with whom the joint ‘Fairtrade and Fairmined’ Standard and corresponding consumer label
was launched in 2011. The Fairtrade and Fairmined partnership ended in 2013, with both
organizations committing to continue with stand-alone certification and labeling schemes.
2. Approach and Methodology
2.1 Evaluation phases
Phase 1: Inception phase and report
The inception report was approved by FTF 29 June 2015. The inception report is based on a study of
available documentation sent to the evaluation team, skype meetings with FTF and FTA, meeting
with Solidaridad Netherlands and interactions with FTA. The inception report includes the project
theory of change, planning, methodology with questionnaire and checklists.
Phase 2: Field visits and interviews
The following table gives an overview of conducted evaluation activities - field visits and interviews.
An extensive list of all interviewed persons can be found as Appendix 2.
Table 1: Main evaluation activities
Field visits and interviews Date Evaluation
team member/s
Interview Solidaridad Netherlands June JJ Kessler
Participation end-of-project conference Migori, including interviews
with LSOs, FTA, FT International, jewelers and relevant consultants
July 13-15 JJ Kessler and
T Ndaluka
Field visit ASMOs Kenya, various interviews July 16-18 JJ Kessler and
T Ndaluka
Field visit LSO and ASMOs Tanzania, various interviews Aug.10-22 T Ndaluka
Field visit LSO and ASMOs Uganda, various interviews Aug.10-18 E Fisher
Interviews with Comic Relief (donor), FTF, FTA, Steering Committee August JJ Kessler
Phase 3: Reporting
The draft report including separate field reports of the country visits was finalized early September.
Feedback from the project steering committee and partners was received during the next two weeks.
The report was finalized and approved before the end of September.
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2.2 Evaluation framework
The following framework (Figure 1) shows the evaluation criteria that were used and the relation with
the result chain and logframe logic. Detailed questions are available for each of the evaluation criteria
and will be answered in chapter 4. Note that the theory of change is at the basis of this framework.
Figure 1: Evaluation framework with criteria
2.3 Evaluation methodology
Contribution analysis
The project has an approach that simultaneously operates at different levels, with its 5 components:
Strengthening small-scale miners in 3 countries to mine gold in a fair and responsible manner
Creation of an African knowledge network that promotes responsible ASGM practices
Influencing key stakeholders in governmental and non-governmental sectors towards ASGM
Ensuring commitment of jewellers (5) to source Fairtrade certified gold from Africa
Increasing awareness of consumers in UK and Netherlands on ethical and Fairtrade issues of gold.
The evaluation team aimed to understand the relations between these different components, and how
these interact to realize impact. Given the range of external factors influencing the project outcomes
and impacts, we can assume that the project will at best contribute to certain changes. Therefore, we
adopted principles of contribution analysis, with the following key elements:
Understanding the theory of change and the impact pathways that lead to expected impacts;
Defining indicators for the elements of the impact pathways and finding supportive evidence (both
quantitative data and qualitative evidence) for changes of these indicators;
Understanding the linkages between critical elements of the impact pathways, i.e. changes in
behaviour, institutions, policies, etc.;
Understanding the ASGM sector and value chain (problems, driving forces, key actors, markets) in
the 3 producer countries and the UK and Netherlands markets;
Adopting evidence-based learning, especially focused at triple-loop learning which implies that the
validity of the underlying theory of change and its assumptions are assessed.
Mix of methods
Apart from interviews with project partners and stakeholders, site visits were made to the mining
operations of selected ASMOs: one in Kenya (Micodepro), four in Uganda (BUSMO, TIISMA, SAMA
Extending FT gold project
Results:
Impact
Context of ASGM in East Africa
Th
eory
of ch
an
ge
(To
C)
Inputs
(e.g.
funds,
expertise)
Process
(management
mechanisms,
approach)
Results:
Outcomes
Results:
Outputs
- Relevance: adequacy and coherence of design, added value in context - Effectiveness: relation results and set objectives, stakeholder involvement - Efficiency: management systems and mechanisms, results in relation to costs - Impacts: benefits for producers, producer organizations, networks, sector - Sustainability: capacity building and system changes to sustain results
Evaluation
criteria
4
and BAASIMA) and two in Tanzania (Nsangano and Umoja Lwamgasa). The mock audit report and
other project documents were used to check the extent of progress made and improvements since the
mock audit was conducted in November 2014.
During the site visits, a mix of methods was used to collect data and information from ASMOs and
relevant stakeholders, as follows:
1. Key Informant Interviews (KII): individual interviews with key persons, mainly public officers and
community workers.
2. Structured Group Interviews (SGI): interviews with the leadership of ASMOs and ASM networks.
3. Focus Group Discussions (FGD), with members of ASMOs, using a Mining Livelihoods, Skills and
Employment Analysis Tool, conducted separately with men and women. Where possible miners
were sampled randomly for inclusion in the FGD based on ASMO membership lists (by implication
FGD excluded workers because they are not on these lists).
Apart from these qualitative methods, we made use of quantitative data as provided according to
monitoring and reporting by the project. The mix of methods allowed us to draw conclusions on the
contribution by the project and plausible impacts. We compared the results in Kenya, Tanzania and
Uganda, to identify success factors, lessons and recommendations in relation to the variable context.
Using above methods, the evaluation team worked with indicators, questionnaire and checklists at
different levels. The data collection and sampling approach for each level can be observed in the
following table 2. For each level, a set of questions and a checklist was developed – see Appendix 3.
In addition, in Tanzania and Uganda, use was made of a community wellbeing analysis tool – see
Appendix 4. During all field work, we adopted our ethical considerations, especially when working
with vulnerable and disadvantaged groups – see Appendix 5. In both Uganda and Tanzania use was
made of local research assistants with local language skills. Care was taken that ASMO management
was not present with member interviews or FGD.
Table 2: Research approach at different levels
Level Selection Method/s
1. ASMO leadership At least 1 ASMO per country, leadership at management level SGI
2. ASMO members Members of at least 1 ASMO per country (men and women
separately); if possible non FT gold miners for comparison
FGD, SGI
3. Community and
public service
representatives
Selected community leaders, local health worker, teacher,
government representative; if possible non FT gold miners
community for comparison
KII, SGI
4. Local support
organisations (LSO)
Coordinator and possibly field workers KII
5. National and local
government
Selected 3-5 local and national public stakeholders, from
mining, environment and social sectors
KII
2.4 Limitations of the methodology
Following are some limitations of the methodology that was applied:
It took quite some time to understand the current monitoring and evaluation system, which has
changed half-way implying that a baseline is not available;
The Year 3 annual report (from 1 May 2014 to July 2015, being the end of the project) was not
available by August 2015, which is unfortunate because it would have provided the opportunity of
validating and completing the findings of the field visits. The evaluation team now used the
available quarterly reports;
5
It was not possible to replicate the evaluation methodology with comparison groups, at ASMO or
community level, as this was found to be inappropriate given that alternative miners’ organisations
are not present in the ASMO communities, and that the ASGM context is characterised by
conflicting relations and lack of trust. Instead comparisons were made through community
observations and, where feasible (e.g. Busia district, Uganda), KII with non-ASMO miners.
3. Results
3.1 Theory of change
There is an initial theory of change as elaborated by ARM. After ARM left the project and to ensure
shared understanding of the project and project document, it was decided in 2013 to elaborate one
overall TOC including all information and indicators of previous documents.(see schemes Annex 6)..
This final version was shared amongst learning group and approved as point of reference for the
project. Current monitoring and reporting takes place based on this theory of change. Following are
its key elements in a narrative form:
Artisanal and small-scale mining (ASM) offers employment to an estimated 15 million people
globally (AS gold mining estimated at 685,000 in Tanzania, 25,000 in Kenya and 50,000 in
Uganda1, directly and indirectly, according to the project scoping reports);
ASM has serious environmental and social consequences, involving the use of mercury,
deforestation, child labour, poor working conditions and unfair supply chains.
The project aims to improve the livelihoods and working conditions of ASGM in East Africa by
applying the FT standard to increase sustainable trade.
Expected benefits are related to responsible mercury use, health and safety and the use of personal
protective equipment, employment rights, good governance, and a higher price for FT gold mines.
To realise these benefits, LSOs will be trained to deliver training sessions to the mining
communities to apply better, safer and more efficient practices in line with the FT standard.
FTA coordinates the sharing of knowledge between LSOs and other stakeholders with an interest in
and knowledge of ASGM. The resulting African knowledge network will be able to support the
ASGM sector in the region on responsible practices in line with the Fairtrade standard.
FTA will convene a Public Policy Committee made up of experts in the sector and policy making, to
influence public stakeholder views on ASGM. By inviting key stakeholders from governmental and
non-governmental organisations to meetings and dialogues, the aim is to inspire policies to be
more supportive to ASGM activities.
Through market development, FTF and Solidaridad NL raise interest among supply chain actors
like jewellers, importers and refiners to source African gold produced under good conditions, in
turn resulting in miners to apply more responsible practices in line with the Fairtrade standard.
FTF and Solidaridad NL will roll out a campaign in the UK and the Netherlands to inform
consumers on ethical and fairtrade issues related to gold, which will support market uptake, as
companies identify a new market they want to tap into.
Critical in the theory of change are three upscaling mechanisms to realise greater impacts:
copying by other (non targeted) mining communities who directly apply more sustainable practices
if they see the benefits among neighbouring (targeted) miners;
copying by other (not involved) market players, buying responsible gold if available on the market;
1 Given the informal nature of artisanal mining, global and national statistics are notoriously poor. . For Kenya the scoping report says
10,000 direct and 15,000 indirect. A World Bank baseline of 2005 cited in a UNEP report of 2012 says in Uganda 20,000 direct so we
estimate 30,000 indirect making 50,000 in total.
6
‘crowding in’, whereby other (not involved) actors become interested to join the initiative by also
offering services for responsible ASGM communities, because they believe this will also be in their
own interest.
Concerning the timing of above process, the project proposal states that “1,100 small-scale miners
and their communities in the 3 countries will be able to mine gold in a fair and responsible manner
according to the FT/FM standard, as pilot groups will undergo trial audits in year 3 to assess their
compliance with FT/FM standards (experience in Latin America showed the pre-certification process
to take 2-3 years).” This will lead to increased capacity to achieve FT/FM certification, enabling them
to command a higher gold price. Thus, ASMOs getting certified was not a goal to be achieved within
the project period. There will be 11,000 indirect beneficiaries. This lays the foundations for more
miners in addition to those directly targeted to improve livelihoods through FT/FM (estimated
500,000 miners in East Africa with up to 5,000,000 indirect beneficiaries).”
To achieve these targets, the proposal refers to the importance of coordinated policy change: “a
fundamental lesson from the experience in Latin America is that the formalisation process for ASM
communities is a multi-dimensional and multi-actor process, requiring integration of policies, strong
coordination between institutions, and in some areas (particularly the area of tax regimes)
harmonization of policies between countries.”
3.2 Context changes
The ASGM context in the three countries differs and therefore experiences cannot be simply
extrapolated. This is important because crucial differences in the governance contexts for ASM at
national and local levels have affected differential impacts of the project with respect to ASMO
formalization, wider upscaling and policy advocacy. Following are the main recent changes, based
on the project scoping study, the public policy strategy paper prepared by the project, and interviews
with public sector agencies during the evaluation. The case studies (Appendices 7A-7C) provide more
elaborate information.
3.2.1 Kenya
Gold mining history in Kenya is focused at Nyanza province, where in the early 1920 there was a gold
rush. Gold mining is done underground, in pits as deep as 100 feet, along a system of veins which
bear some gold. There are about 10,000 direct and 15,000 indirect ASM miners operating in the gold
sector in Kenya. The mining sector has a limited importance to the economy of Kenya.
In Kenya the current Mining Act is silent on ASM, there are no provisions and it is not very clear
what ASM are supposed to pay in licenses and taxes. Micodepro ASMO has the following licenses:
a prospecting right license, since 2005 (national government), to renew annually, cost 5,000 KSh;
a milling license, since 2013 (from the County), to renew annually, cost 10,500 KSh;
an environmental license, since 2014, to renew every 2 years, cost 10,000 KSh;
Thus total costs only for renewal of licenses would be around 20,000 KSH per year (US$ 200).
Micodepro does not yet have an export license, which has a high cost (around US$ 4000). However,
the Ministry has recently informed the project that an export license is not necessary; unless one is a
dealer an ASMO can export using the location license.
To-date the national government has had a hands-off approach to the artisanal mining sector as they
are mainly interested in large scale mining initiatives. However significant and as yet uncertain
change is taking place in respect to national policy and law on the extractive industries, with likely
impact on government approach to ASM in future. Moreover, importantly, enactment of Kenya’s
new constitution post-2010 placed fiscal decentralization at the center of policy reform, transferring
7
revenues and tax raising powers to county governments. The ongoing process of devolution has
started to open up a new vehicle for community negotiation with local government; it is stimulating a
‘crowding in’ effect of development actors at local government level, alongside unintended
consequences such as boundary disputes over land with county government revenue raising potential
(mining, wildlife, etc.)
The Nyanza province recognizes ASGM and efforts are being made to eliminate illegal miners by
pushing for their recognition in the new Mining Act. While awaiting the acceptance of this new bill,
changes are already taking place to shift responsibility to local governments. These changes are also
triggered by the increasing awareness of the negative effects of ASGM, notably child labour,
HIV/Aids and other health effects, as evidenced by the community health officer.
Land where mining takes place is mainly privately owned. Land owners can charge high fees
(payment in ore) and often change the contract regulations in their favor. This includes increasing
the monthly fees or increasing the percentage of ore payable and also the tailings that can be
recycled. Also, the pits are not under the jurisdiction of the ASMOs and land owners often insist that
the pits remain open for possible future tenants. Nyatike sub-county is an exception because this is
trust land (owned by government). A sub-county administrator from Nyatike has taken the initiative
to develop a booklet on ASM, with the aim to generate an inter-ministerial forum to support the
development of a mining location for artisanal and small-scale miners in Nyatike.
3.2.2 Tanzania
Artisanal and small-scale gold mining in Tanzania is estimated to employ about 685,000 people
according to analysis by the World Bank in 2012. Unlike Kenya and Uganda, Tanzania is amongst an
‘early wave’ of African countries that embraced the formalization of artisanal mining in the 1990s
following World Bank prescriptions for mining sector liberalization.
The 1998 Mining Act provided for the presence and development of a small-scale mining sector and
prescribed co-existence between small-scale and large-scale mining. It provided small-scale miners
with the opportunity to acquire Primary Prospecting Licenses (PPL) and Primary Mining Licenses
(PML). A PPL was granted for a period of one year, could be renewed, and authorized the owner to
prospect for minerals, provided that the selected prospecting area had not been occupied by other
mineral right holders. A PML gave the owner the right to exploit an area of up to ten hectares. It
conferred on the holder the exclusive rights, subject to compliance with safety and environmental
regulations, to carry out mining activities in the area (unlike in Kenya and Uganda where rights to
surface land are held separately, creating conflicts with land-owners)
The Mineral Policy of 2009, a statement of intent shifting mining interests towards greater
ownership by Tanzanian citizens, promoted increased integration between the mining sector and
other sectors of the economy in order to improve mining’s contribution to the national economy. The
policy also prescribes the development and increased formalization of the small-scale mining sector
in order to facilitate sustainable development.
With regards to small-scale mining, the Mining Act of 2010 constitutes few changes. It defines a PML
as ‘a licence for small scale mining operations, whose capital investment is less than US$100,000 or
its equivalent in Tanzanian shillings’. A PML is acquired subject to payment of Tanzania Shilling
(Tsh) 10,000 (US$6) each plus an annual rent of Tsh 10,000 (US$6) per hectare. It is granted for
seven years. The new mining act has a maximum of 20 PMLs or 200 hectares per PML holder.
Administrative responsibility for many sectors has been devolved to district level; however
responsibility for mining - including fiscal control of taxation and revenue generation - remains
centralized under the Ministry of Energy and Minerals, with representation through zonal mines
8
offices. The assistant commissioners of minerals seated in each of Tanzania’s eight mining zones
have the mandate to sign PMLs. Holder of PML can at one point upgrade his PML status to ML by
applying to the Minister of Energy and Mineral who signs the license. Once granted, a PML can be
mortgaged, renewed or transferred to another holder. Another relevant change is the fact that
artisanal miners are now required to submit an Environmental Protection Plan (EPP) together with
an ‘environmental investigation’ and ‘social study report’. The EPP should mitigate the
environmental effects to be caused by mining operations in the licensed area’. PPLs have been
abolished in the new act, as it was claimed that many artisanal miners used the PPL to mine instead
of prospecting.
Geita region is one of the areas in Tanzania where ASM has been in operation for many years, found
in almost all its districts. More than 50% of the Geita population depends on mining activities, with
significant in-migration from outside the region. In 1993 exploration by large mining company were
resumed in the region and in 1999 Ashanti Gold Fields Mine currently called Geita Gold Mine (GGM)
owned by AngloGold Ashanti started operation in Geita Region. GGM is now the second largest open
caste gold mine in Africa and alongside the other large and medium scale companies operating in the
region, provides significant stimulation to the local economy. The allocation of land for large-scale
mining, together with formalization of AS mineral claims, has decreased the availability of remaining
mineral-rich land suitable for ASM. These mining interests are at the heart of a series of conflicts
between local communities, artisanal miners, and mining companies – over land, resources and
compensation for resettlement.
Mineral extraction methods used by AS miners in Geita is based on labour intensive techniques,
although over time there has been increasing mechanization and skills learning, albeit remaining at a
rudimentary, artisanal level (crushers, pumps, diggers, etc.). But poor knowledge of improved
production techniques, contributes to significant environmental, public health and safety risks.
3.2.3 Uganda
The number of people working in artisanal and small-scale gold mining (ASGM) is between 11,000
and 13,000, but may be estimated at 50,000 direct and indirect beneficiaries. Currently ASM is
covered by the Mining Act (2003), the Mining Regulations (2004) and the Mineral Policy of Uganda
(2001), although legislation is being revised ASM can license their activities through a location
license, which is “a license for prospecting and mining operations by methods which do not involve
substantial expenditure and the use of specialized technology”. A location license is for 2 years but
can be renewed for periods of 2 years at a time. Costs for licensing: Location license UGX 850,000
(USD 228); mineral right UGX 250,000 (USD 68); gazettement fee UGX 300,000 (USD 80); per
month returns 5% royalties; small company returns UGX 75,000 annually. Operations must be
conducted in accordance with the National Environment Statute of 1995, which also requires an
Environmental Impact Assessment certificate to be renewed annually (UGX 50,000; USD 15).
Historically artisanal mining was viewed by government in profoundly negative terms. Lack of ability
to formalize until the 2000s meant that by default artisanal miners have worked illegally, with
extremely low skill and capacity levels, and weak organizational development. This extends to the
institutions governing the sector. There has also been an absence of non-governmental organizations
supporting artisanal miners or undertaking policy advocacy on their behalf (although in the west of
the country, unlike Busia district, mining NGOs are growing up, influenced by NGO advocacy in the
nascent petroleum sector). However change is occurring, as government makes constructive moves
towards greater formalization of artisanal mining; by implication 2012 – 2015 has been an ideal time
for the Fairtrade project to seek national policy influence. The Mining Act of 2003 is at present being
reviewed, with legislation intended to be presented to Cabinet by December 2015 before being passed
to the Ministry of Justice to draw up the revised legislation (i.e. before the national elections in
February 2016). The proposed legislation presents a more favorable legislative and policy approach
9
to small-scale mining in Uganda, reflecting change from the view that artisanal miners are ‘no-good
illegals’ to recognizing the value of organized small-scale mining in terms of royalty collection,
economic development, and rural employment.
Proposals in the revised mining legislation include royalty payments, with the following breakdown:
80% to central government; 10% to local administration; 7% to the sub-county administration; 3% to
land owners. Providing a royalty allocation to sub-county level and to land-owners has potential to
create a more conducive environment for artisanal mining at the local level, reducing land and
community conflicts. Land conflicts are a significant issue because ownership of land is separate from
ownership of minerals; therefore even with a valid location license, ASM must enter into agreements
with land-owners to mine on their land, with potential for conflict. While nationally there are positive
moves to addressing the artisanal mining sector, there are also tensions between institutions with
potential to destabilize ASM planning.
3.2.4 Main similarities and differences between the three countries
Similarities:
The historical legacy of ASGM is of a sector associated with illegality and problems for government
administration, rather than employment and economic opportunities for rural populations.
East Africa is a focus for rapid, large-scale extractive industries development, with governments
seeking to formalize artisanal mining as part of wider sectoral rationalisation based on models of
economic development incorporating mineral and petroleum investment.
In general, civil society and trade union support to and advocacy on behalf of artisanal miners are
extremely weak, although stronger in Tanzania than in Kenya or Uganda.
Very few opportunities exist for artisanal miners and mining communities to access finance,
whether formal (loans through banks) or informal (community banking). This extends to mining
communities that are avoided by micro-finance initiatives.
Government extension to support ASGM improvement is limited (Tanzania, Kenya) or non-
existent (Uganda).
Revenue generation and taxation from artisanal mining is limited; local government does not have
resources to address the scale of ASM-related need (health, environment, community
development) in mining communities.
Differences:
Stages of formalization differ: Tanzania started formalizing artisanal mining from the early 1990s,
whereas in Uganda and Kenya moves towards formalization are recent and not well-established.
ASGM in Geita Region has been the focus on many different donor and government initiatives to
improve the sector, whereas very little work has been done in Kenya or Uganda.
ASGM is of major economic and employment importance in Tanzania, increasingly recognised as
such in Uganda, and of relatively limited importance in Kenya.
Relevant policies recognise ASGM as of major interest for employment and for local economy in
Tanzania, less so in Uganda, and only locally in Kenya. In practice government in each country
embraces large-scale mining interests to the detriment of development in the ASGM sector.
In Tanzania, mineral sector governance remains centralised, regional mines offices function well,
but revenue allocation to district-level is limited. In Kenya there is an ongoing change towards
devolution of ASGM to county level, which alongside wider fiscal decentralisation, shifting the
locus of control over ASGM. In Uganda, governance for ASGM is centralised and weak, with no
budget allocation or capacity building at district level.
Regarding land ownership, it is private in Kenya, public in Tanzania, and mixed in Uganda. In
practice there is a separation between land rights and mineral rights in Uganda and Kenya that
creates conflict between land-owners and ASGM, whereas in Tanzania once a mineral right is
conferred this takes precedence.
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3.3 Results achieved per project component
In the following are presented the main results per project objective / component separately, as has
also been done in the project reports. Subsequently are presented:
A. Tabular results according to the project M&E system and reporting (see section 3.4.2), referring to
achievements in year 2 (Yr2: March 2013-April ‘14), and year 3 (Yr3: March 2014 - current);
B. Selected narrative according to project M&E system (with comments of the evaluation team);
C. The findings of the evaluation team with respect to these results;
D. Analysis and main conclusions on achievements and remaining challenges.
3.3.1 Objective 1: Small-scale miners mine gold in a fair manner
A. Table 3: Results according to project M&E system for objective 1
Indicators Target Achieved
Number of Fairtrade certified ASMOs Yr3: 0
Miners are aware of the harmful effects of mercury on human health and the
environment and know that methods exist to minimize its use (retorts, pre-
concentration, burning outside human habitats, etc (% participants per country)
90% Yr2: 90%
Yr3: 95%
Miners are aware of principal methods of personal protection and know how to
avoid the main work hazards (% of participants per country)
90% Yr2: 90%
Yr3: 95%
The number of small-scale gold miners who have implemented and applied
measures for occupational health and safety as defined as responsible by the
Fairtrade standard (% of participants per country)
50% Yr2: 16%
Yr3: 60%
The number of small-scale gold miners who have employment rights which meet the
requirements in the Fairtrade standard and local law (% of participants per country)
50% Yr2: 24%
Yr3: 60%
Small scale gold miners are organised in a democratic governance structure as
required by the Fairtrade standard (% of participants per country)
50% Yr2: 82%
Yr3: 80%
Economic empowerment of miners and their families (% of participants taking part
in a savings scheme)
50% Yr2: 24%
Yr3: ??
B. Selected from project reporting narrative:
With respect to certification, 1 ASMO in Kenya (Micodepro), 1 ASMO in Tanzania (Nsangano) and
2 ASMOs in Uganda (Busia and Syanyonja) submitted relevant documents for the audit application
by FLOCERT, carried out in 2015. The LSOs played an important role in getting this organised.
A bottleneck for getting certified is that ASMOs commonly are not operational for some time if
mine shafts cannot be used (due to flooding or land title problems) so that the operations cannot be
audited. This has been the case for Micodepro, MaweMeru, Syanyonja, and Umoja Lwangasa.
The majority of members of Buteba ASMO left with only 7 members remaining and consequently
its status as a pilot ASMO is ambiguous, leaving the total of pilot ASMOs to 8.
It can be observed that some of the scores on the above indicators have increased significantly in
the third year, so that by now all scores exceed the set targets. On health and safety, the use of PPEs
remains a problem, as many workers are not using these because they are found to be
uncomfortable (and associated with external inputs that need to be provided by a donor, without
enough for existing workforce). In the ASMOs in Uganda, on average only 40% of the workers are
using PPEs.
Important challenges raised in the Yr 2 report to realize the indicators under this objective were:
Access to finance – some ASMOs started a saving scheme for household level finance
Weak leadership
Weak formalisation, internal cohesion and mutual trust
Understanding of the local institutional and legal requirements
Access to more efficient equipment.
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C. Findings of the evaluation team (also see case study reports Appendices 7A to 7C)
1. Main findings Kenya
Kenya was added as the third country to the set of targeted countries. ASGM in Kenya has low
importance, both in terms of numbers of people involved and economic value (see context).
Of the two ASMOs supported by the project, Micodepro is well established, registered since 1999
and having a mining prospecting licence since 2005. It is being lead by a bishop with clear
leadership skills and good contacts with local public agencies. He knows the rights and duties of an
ASMO and can negotiate with government officers. He has also been elected the chairperson of the
newly established ASM network for Kenya, and has been employed for one year by the project to
train and support the other ASMO in Kenya.
The baseline survey at the start of the project showed that Micodepro had 6 criteria with a low level
of compliance. The mock audit showed that Micodepro has a limited number of core compliance
criteria that are not yet met. The ASMO seems to be working on these issues. However, it currently
does not have a productive pit available since 3 productive pits were closed last year due a decision
by the landlord and the new pit is not yet ready; it is expected to be ready for production soon.
The other ASMO supported by the project, being Lolgorian ASMO, has 52 members of which 32 are
female. Their main current problem seems to be one of leadership. This was stated to be mainly
due to the fact that there are many immigrants that move in and out depending upon the mining
situation but also the political situation. This makes leadership weak and difficult. Lolgorian ASMO
has not yet acquired all of its licenses and is less advanced in this process as compared to
Micodepro. Lolgorian projected an annual production of 3.5 Kgs of gold for 2014/15.
The baseline survey at the start of the project showed that Micodepro had 5 criteria with a low level
of compliance. The mock audit showed that Lolgorian has several core criteria that are not yet met,
as compared to Microdepro. We did not check to what extent the ASMO is working on these issues;
it seems the leadership constraint is a priority as the ASMO was considered ready for certification.
The following findings are for Micodepro and the wider community effects:
Micodepro has most of the required licenses, of which total annual costs only for renewal would be
around 20,000 KSH (US$ 200). Micodepro does not yet have an export license, but it was recently
confirmed by the Ministry that this is not required as long as one is not a dealer.
Micodepro has an up to date system of production (SYSPRO) and internal control system (ICS)
since 2013, but according to the mock audit the ICS needs further improvement.
In 1999 Micodepro had 10 members, it now has 31 permanent members (20 men, 11 women). The
management team of 3 persons has one woman (wife of the chairperson). The level of trust
between members is high. Members are being paid in cash.
Micodepro management requests additional training on entrepreneurship, accounting and
bookkeeping, and advise on developing one integrated ASMO policy including gender issues.
Micodepro gold production from November 2013 to July 2014 was 2.5 kg (triple that of the year
before). Then the 4 productive pits were closed as the lease had expired. It was expected that the
production could further double if the group owned at least a compressor by its own. For
2014/2015 Micodepro projected an annual production of 1.8 kg of gold per year.
On mercury use, Micodepro has managed to stop whole ore amalgamation, now using sluicing
boxes and centrifugal concentrator. This system has proved that besides low usage of mercury it
also yields more gold. In amalgam burning, retorts are used as a recovery technique and the
burning takes place in designated areas to protect human, animals and the environment.
The members claim that the incomes from gold mining have increased, which is probably due to
the high production in 2014.
As the main positive changes due to the project during last 3 years women and men mention:
o awareness of side effects and more careful use of mercury including use of PPE;
o no more use of motor pumps inside pits (this caused suffocation and death due to carbon
monoxide poisoning, which was a shock to the community);
12
o improved timbering – this is commonly done and copied by other groups;
o being more careful in using mercury polluted wastewater for watering cattle (women only);
o first aid knowledge and kits – used maybe once per month, also for other workers; as an
unexpected effect was mentioned that first aid knowledge was also used with a car accident;
o no more child labour – this is said to be respected.
During the field visit we did not observe signposts and also no fencing around the mine pits. The
recently abandoned pits were covered (as recommended) but not refilled (as this was opposed by
the landlord). On the use of PPE, the women admit that it takes time to adapt to their use as they
may be warm and difficult to use. The mock audit mentioned remaining safety issues.
As the main additional training needs the members mentioned:
equipment that can increase productivity and reduce labour load (crushing machines,
compressor, detector, shaking table, …);
savings and credit training;
supportive equipment to detect productive veins (this may be an illusion as such equipment is
complex and very expensive as far as we know).
Both women and men perceive copying of above mentioned ‘good practices’ by others, especially
those of timbering the mining shafts. There is also exchange of equipment, such as the retort for
recapturing mercury. The women refer to exchange of information in their SACCO (savings and
credit) group. The community perception of Micodepro is positive.
In the wider community, in recent years school attendance has improved and the school
headmaster claims there is less evidence of children attending school after having worked in mines.
This suggests that child labour in mining has declined, which is probably due to a combination of
the project and active engagement by Micodepro with the area assistant chief who is also very
proactive in eradicating child labour. Further improvement is still required as non-attendance is
still around 15% in high seasons.
In the wider community, there is evidence (by records) of other problems related to ASGM,
especially high incidence of HIV, malnutrition, sexual transmitted infections (STI), casualties and
criminal abortion. The health officer does not know what the project can do about this. The
government has a strong intention to tackle these problems.
The root cause is the fact that young uneducated miners may earn large amounts of money and
then splash it in a short time on irresponsible activities. One solution could be to assure proper
education and install a savings and credit scheme.
2. Main findings Tanzania
The project targeted three ASMOs namely Nsangano, Mawemeru (formerly Golden Hainga) and
Umoja Lwamgasa. These were willing to work towards Fairtrade certification. In Geita region
ASGM is long established, formalized, involves many people and has a high economic value (see
context).
Of these three ASMOs, by August 2015 only Nsangano was actively engaged in mining operations
and has submitted a request for the certification audit. The other two ASMOs had setbacks:
Mawemeru had internal conflicts causing one of the shareholders Golden Hainga to withdraw and
sell his shares. Umoja Lwamgasa has not had any mining operations due to lack of capital and weak
leadership..
The baseline survey at the start of the project showed that Nsangano had only 1 criterion with a low
level of compliance, and Mawemeru met all criteria (for Umoja Lwamgasa the baseline survey is
not complete).
Nsangano is an exceptional ASMO as it was established already in the early 1990s and has long
been formalised with relevant licenses and government requirements. It has strong leadership and
has good relations with public agencies. Good relations with the local community were established
by the late father Nsangano (recognised by UNEP as environmentalist of the year) who insisted
that the income derived from mining should be invested and a certain % should be taken to the
community and/or the church. Members are constantly reminded to invest their revenues in
13
productive assets. In 2005 they received a government certificate as recognition for their
environmental protection efforts. The mock audit showed that Nsangano has a good system in
place but there are some gaps in the area of organizational structure and safety aspects. They will
soon receive their FT certificate.
The mock audit showed that Mawemeru and Umoja Lwamsaga both have several remaining gaps,
but do not have running operations since 2013. Neither of them have been addressing the gaps
identified in the mock audit. For both ASMOs weak leadership appears to be a main problem,
although technical problems (of non productivity and lack of investment capital) are mentioned as
the primary causes. These two ASMOs do mention as benefits of the project the fact that they have
become more aware of mercury use, use of safety equipment and better spending of the gold
revenues. However, it is unclear to what extent these learning are being applied.
More specifically, Umoja Lwamgasa failed to raise enough capital to fix broken machinery and the
mine has subsequently been out of operation since August 2013, resulting in non-participation in
the project. MTL organised training on community banking and they have since raised the capital
to restart operations. A section of the group has started mining while others have moved to other
income generating activities as a result of training on community banking.
The following findings are for Nsangano and the wider community effects:
Nsangano has for long acquired all necessary licenses, of which total annual costs are USD 372
excluding tax and levy. Nsangano pays taxes and levies required by the government and village
authority. For the last payment in June 2015 it paid around USD 6000 as government tax, 140 as
annual mining land rent fee and 35 being 4% of the profit obtained from mining paid to TMAA.
Nsangano still sells gold and ores to local traders (brokers and ore buyers); they do not trade to
international buyers.
Nsangano received support from several projects and donors before the FT project intervened, by
UK DFID, UNIDO, UNDP, amongst others covering training, productive/processing improvements
and equipment, as well as how to engage with external experts to understand project expectations.
From 2010 to 2014 they entered into a mining collaboration with a mining company from Korea,
but this seems to have failed. They receive university students for field training on gold mining and
have informed many international academic and consultancy studies.
Nsangano has a board of directors comprising of 5 directors, out of which 2 are female. It has 75
permanent and 20 casual workers. Members are being paid in ore, which they seem to prefer.
Payment is according to the set contracts, which is not the case for many other miner groups.
In 2012 Nsangano was not productive, in 2013 there was one pit (0.5 kg of gold per month), by now
there are 4 pits with a monthly production of 1.5 kg. This increase in production is partly due to the
FT project which has rationalised pit construction and safe mining hence making mining constant
and increasing working morale. Nsangano has improved record keeping and strengthened ICS.
At Nsangano amalgamation is done in built ponds which protect mercury from spilling. The use of
mercury has declined. Environmental protection has increased and mercury controlled from
spreading to the environment. The project has introduced internal controls which provide
monitoring and checks, which has not been the case with other projects, where awareness is
created with no internal enforcement mechanisms.
In the wider community miners are still using a lot of mercury without safety measures.
The members claim that the incomes from gold mining have increased, as a result of increased
production. There has also been a diversification of incomes, which was supported by
entrepreneurship training by the project. Contrary to other mining groups, workers with Nsangano
are more permanent due to better conditions being provided.
Project training has been received on safe mining, entrepreneurship, child labour and mercury use.
These have contributed to eradicate accidents and injuries in the mine. In the past the ASMO
would experience 2 to 3 accidents annually.
In 2014 they used their equipment (e.g. compressors, pump and pipe) and labour force to rescue
those who were stuck in a neighbouring pit. They also contributed in cash.
14
Nsangano is also involved in community development initiatives: they contributed 40 bags of
cement and cash in the construction of two secondary school buildings, donated desks and
contributed to a village health centre.
Nsangano members state that the impact of the training could have been more noticeable if there
had been pre-financing support. The ASMO now lacks modern equipment such as jack hammers,
submersible pumps, crushing machine, wheel roller and geological knowledge and skills, which
require major investment.
As the main positive changes due to the project during the last 3 years women and men mention
the use of protective gear. The ASMO bought PPE for its workers who are all obliged to use while at
mining site – this is an improvement as compared to the mock audit stating that workers did not
use the PPE and their were no safety measures taken.
As the main subjects with remaining training needs the members mentioned:
o Although entrepreneurial skills have been mentioned as a positive contribution, it is also
mentioned as a remaining demand, including book keeping, savings and writing business plans
o Skills on marketing gold, knowing what are good markets
o Equipment to increase productivity (crushing machines, compressor, detector, shaking table, …);
o Training from mining engineers on how to detect productive veins.
Other gold miners in the region copy the new skills, e.g. safe mining skills, the use of PPE, first aid
skills. But they mention as a barrier to copying these measures the lack of capital and the instability
of mining groups due to movement of workers.
There is no evidence of ‘crowding in’ effects, meaning that other support organisations join the
efforts of the project, which is understandable as in fact there were already many ongoing projects.
In the past there was more free mining land, but currently most mining land has been allocated.
The scarcity of mining land has forced people to learn other skills and get involved in other income
generating activities. There are claims that the position of women in the mining business has
improved but there remain many inequalities.
In the wider community, the interviewed school teachers claim that school attendance has
improved recently, now up to 70-80%, and truancy and dropouts are also lower. Child labour has
declined due to joint efforts by many different actors (government and non-governmental),
including during recent years the FT project.
In the wider community, there is evidence (by records) of other problems related to ASGM,
especially high incidence of HIV, malaria, sexual transmitted infections (STI) and casualties (only
in July and August 10 casualties). The health officer would expect the project to do more about this.
3. Main findings Uganda
Initially the project sensitized communities in both Karimoja and Busia but for logistical and
security reasons turned to focus on 4 ASMOs in Busia region (1 of which is dominated by women).
One of these 4 ASMOs has only 7 members remaining and its mine is not productive. Members who
left undertook training but became disillusioned due to the equipment needs and lack of resources,
others simply dropped out of the ASMO but remain locally. At present the ASMO is not functional
although they have a potentially rich gold mine. If a mechanism had been established to enable
miners to access inputs, ASMO ‘implosion’ may have been prevented by the project.
The evaluation focused at two ASMOs (although visits were made to all 4 ASMOs): BUSMO
because the mock audit showed it to be moving significantly towards realizing certification
requirements in Uganda. Secondly, TIISMA, being within the same 13.2 hectare location license
held by BUSMO but identified by the mock audit as less advanced towards certification, therefore
it was considered a good basis for comparison. Syanyonja had a collapse of its main pit in 2015 due
to flooding, which is a common practice in the locality. The ASMO members are working hard to
open up a new mine and get back on track.
Compared to Tanzania, and Kenya, the Mine Doctor baseline scores for the 4 selected ASMOs are
by far the poorest, with low level scores for 13 to 47 (!) criteria (BUSMO was scoring best). This
shows that the organisation of ASGM in Uganda was lagging behind the other two countries, very
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unsurprisingly given how recently the ASMOs have been established, the negative institutional
context for ASGM, and lack of capacity building prior to the Fairtrade project For the two visited
ASMOs the mock audit showed remaining gaps, which could be addressed. It appeared during the
evaluation field visit that one of ASMOs was not making significant progress in addressing these
gaps (BUSMO) so that it would be too early to carry out a certification audit. TIISMA had made
good improvements since the mock audit, and as an ASMO has good leadership and democratic
principles. Members are inexperienced dealing with government and relevant mining actors.
Bookkeeping and office management skills need significant capacity development.
The following findings are indicated for both BUSMO and TIISMA, and the wider community:
BUSMO’s organizational structure includes 3 male directors. There is internal division with a
fourth director who is in charge of a currently non-operational pit and has gone to mine elsewhere.
A fifth director left due to ‘financial irregularities’. They started mining at the site in 1998. They
were registered as an association in 2011. A location license is held for 13.2 Hectares, it was first
obtained in 2012, renewed in 2014, with plans to apply for a 21 year mining lease in 2016. The costs
associated with a location license and productive mine were around USD 450. For annual renewals
the costs would be around 1 million UGX.
BUSMO has 37 male and 13 female members, and in the dry season the number of daily labourers
can rise to 25-30 (although many have long experience of working there). ASMO members are
divided into 3 groups (according to the pit they mine). Members in the 3 groups share dividends
and the costs of work. At present one group/mine is not operational due to the exit of its director.
The directors are the landowners for land across the site, they accrue 20-30% of profit from
members, which is lower and better controlled than it is for many other miner groups.
In 2014 BUSMO reported gold production was 3kg (although there is also unreported production,
quantities not known). The gold is being sold to Indian buyers in Kampala. They do not trade gold
nor do they have an export license.
BUSMO leadership appreciated the training provided through the project, especially on mercury