Thank you for your invitation to respond.

We have carefully read the report and believe that the report has a significant problem in its methodology: it didn’t make a clear distinction between the LSM and ASM workers. Furthermore, when Referring to LSM, the report didn’t clearly distinguish between workers engaged in industrial production, and workers engaged in illegal ASM activities within industrial mining parameters. The risk profiles related to forced labor of these groups of workers are completely different, as well as the mitigation measures. The fact that the report mixed them up, significantly reduced its capability to provide insights in mitigating/remediating the risk of forced labor in various scenario, and induced its readers to stigmatize the DRC cobalt industry as a whole.

CMOC’s DRC based Tenke Fungurume Mining is a large-scale industrial mine with a mature management system to prevent and mitigate human rights risks, including child labor and forced labor. It prevents such risks through zero-tolerance policies, human resource management processes, extensive training and communication, and an easily accessible grievance mechanism. Tenke Fungurume Mining is a RMAP conformant facility for its mineral due diligence system (https://www.responsiblemineralsinitiative.org/facilities-lists/active-conformant-facilities-list/active-conformant-facilities-list-search/). In 2024, Tenke Fungurume Mining also received its first audit for The Copper Mark, and got “fully meet” in the criterion of forced labor (https://coppermark.org/participants-home/participants/).