103086 The Republic of Burundi Final Report Transparency in Revenues from Artisanal and Small- Scale Mining of Tin, Tantalum, Tungsten and Gold in Burundi The Republic of Burundi Final Report Transparency in Revenues from Artisanal and Small-Scale Mining of Tin, Tantalum, Tungsten and Gold in Burundi © 2016 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW, Washington, DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org This work is a product of the staff of The World Bank with external contributions. The findings, interpre- tations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. Nothing herein shall constitute or be considered to be a limitation upon or waiver of the privileges and immunities of The World Bank, all of which are specifically reserved. Attribution—Perks, Rachel and Karen Hayes. 2016. Transparency in Revenues from Artisanal and Small- Scale Mining of Tin, Tantalum, Tungsten and Gold in Burundi.  Washington, DC: World Bank. The data used in this report is reproduced, with credit to the sources, in good faith as to its accuracy and validity. Where possible, cross references have been made to triangulate data. Where data is based on estimates and calculations with variables, this is clearly stated. The research was conducted by Pact Institute under the management of the World Bank. The artisanal mining and mineral trading sector is complex and has many sensitivities. Information reported by actors in the sector is reproduced with a recognition of, and intent to mitigate, the risks that sharing of such sensitive data may create. The identities of informants have been protected. Data from individual companies or offices has been aggregated to ensure no breach of commercial confidentiality. Contents Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii 1 Artis n l nd Sm ll-Sc l Minin (ASM) nd Its Si nific nc in th Burundi n Econom . . . . . . 1 1.1 The Macro Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1.1 Mining as Part of the Solution Towards Economic Diversification in the Country. . . . . . 1 1.1.2 Geographic Scale and Scope of Burundi’s Mining Sector. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1.3 Statistics on Employment, Revenues and Exports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.2 The Local Context. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1.2.1 Organization of ASM in Burundi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1.2.2 Mineral Production and Export of 3Ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8 1.2.3 Mineral Production and Export of Gold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1.3 Mineral Prices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 2 T x Administr tion nd R v nu s: Ch ll n s nd Pro r ss . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.1 Mineral Tax Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.1.1 Mineral Taxation Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.1.2 Mine Tax Administration: Collection, Management and Distribution. . . . . . . . . . . . . . . . 17 2.1.3 Challenges Revealed in the Taxation Framework and Its Administration. . . . . . . . . . . . 17 2.1.4 Informal Payments in ASM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 2.2 Official ASM Tax Revenues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 2.2.1 Tax Revenues Generated by the 3Ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 2.2.2 Tax Revenues Generated by Gold . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 2.3 Mechanisms for Transparency in the Mining Sector of Burundi: How Can EITI and iTSCi Help? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 2.3.1 EITI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 2.3.2 iTSCi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3 R comm nd tions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 3.1 The 3Ts Sector in Burundi. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 3.1.1 Observations on the 3Ts in Burundi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 3.1.2 Recommendations for the 3Ts in Burundi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 3.2 The Gold Sector in Burundi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 3.2.1 Observations on Gold in Burundi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 3.2.2 Recommendations for the 3Ts in Burundi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 3.3 EITI and iTSCi Are Tools to Improve Transparency of Production and Revenues . . . . . . . . . .27 3.3.1 Recommendations for EITI and iTSCi in Burundi . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27 Annex 1 M thodolo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29 Annex 2 Minin Coop r tiv s nd Comptoirs Lic ns d in 2014 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36 Annex 3 Sit s Visit d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40 iii Acronyms ‘3Ts’ Tin, Tungsten and Tantalum APE Agence de Promotion des Exportations ASM Artisanal and Small-Scale Mining ATM African Tantalite Mining BMS Burundi Mining Supply BRB Banque de la République du Burundi CFSP Conflict-Free Smelter Program DGGM Direction Générale de la Géologie et des Mines DRC Democratic Republic of Congo EICC Electronic Industry Citizenship Coalition EITI Extractive Industries Transparency Initiative GeSI Global e-Sustainability Initiative GIZ Gesellschaft für Internationale Zusammenarbeit (German Development Agency) GLR Great Lakes Region ICGLR International Conference on the Great Lakes Region ITRI Global Tin Industry Association (formerly International Tin Research Institute) iTSCi ITRI Tin Supply Chain Initiative OBR Office Burundaise des Recettes OECD Organisation for Economic Co-operation and Development MEM Ministère de l’Energie et des Mines MoU Memorandum of Understanding RCM Regional Certification Mechanism RINR Regional Initiative against the Illegal Exploitation of Natural Resources SEC Securities and Exchange Commission SECOMIB Société d’Exploitation et de Commercialisation des Minerais du Burundi TAMINCO Tantalum Mining Company TIC International Tantalum Niobium Study Centre UN United Nations WMP Wolfram Mining and Processing Ltd v Executive Summary B urundi has a wide range of mineral depos- washing, transporting and other tasks. It is esti- its of which tin, tantalum and tungsten mated that there are a further 14,000–27,000 ores, along with gold, are its primary min- artisanal gold miners. With each miner probably eral exports. Burundi’s geological endowment supporting approximately five dependents, the also includes nickel, rare earths, vanadium, and study estimates that some 85,000 to 160,000 construction materials. The majority of mineral individuals may depend on ASM as a key house- extraction is carried out by artisanal and small- hold income source in Burundi. Approximately scale mining1 (ASM) which is officially structured half of the country’s 3Ts mine sites are operating through cooperatives. Tin, tantalum, tungsten without licenses. (from the minerals cassiterite, tantalite and wol- Burundi’s 3Ts sector is underperforming framite and often referred to as the ‘3Ts’) and gold with poor levels of production being recorded are the primary minerals mined and exported. in 2014. Of total mine production, wolframite Artisanal mining is an important rural live- accounts for the largest proportion (38%) of the lihood for up to 34,000 people. Some 6,000– minerals mined. Tantalite accounts for one third 7,000 men and women are working in mines (30%) of recorded mine production but is also pres- producing the 3Ts. Of these, around 75% are min- ent in the significant quantities of ‘mixed’ miner- ers with the other quarter engaged in mineral als which are produced in the mines. These mixed minerals are only separated at export level. At 1. Artisanal and Small-Scale Mining refers to mining by individu- export, tantalite accounts for approximately half als, groups, families or cooperatives with minimal or no mecha- of mixed minerals which increases overall tanta- nization, often in the informal (illegal) sector of the market. In lite production to around 38%. Cassiterite produc- some countries a distinction is made between ‘artisanal mining’ tion is at a very low level with no official exports that is purely manual and on a very small scale, and ‘small-scale in 2013 or 2014. With international prices for tin mining’ that has some mechanization and is on a larger scale. very low, there is limited immediate prospect of The local definitions vary from country to country according to the macroeconomic situation, the geological framework, the improvement. The general underperformance mining history and the legal conditions. Nevertheless, ASM is of these minerals can be attributable to several characterized by a number of conditions: lack of or limited use issues including: international reluctance to pur- of mechanization, and a lot of physically demanding work; lack chase wolframite from the Great Lakes Region of investment in technical support such as geological prospec- (GLR) due to the relatively high price of traceable tion; low level of occupational safety and health care; poor quali- ore compared to wolframite from sources outside fication of personnel at all levels of the operation; inefficiency in exploitation and processing of mineral production (low recov- the GLR; lack of a mineral traceability system ery value); exploitation of marginal and/or very small deposits, in Burundi until mid-2014; the limited number of which are not economically exploitable by mechanized mining; mines operating in the formal system from which low level of productivity; low level of salaries and income; peri- the formal market could source; and significant odic operation by local peasants by season or according to the tax increases which the Government introduced in market; lack of social security; insufficient consideration of envi- 2014 and which dissuaded business registration. ronmental issues; and chronic lack of working and investment capital. Definition adapted from the final report of the Mining, Mineral pricing is a complex process which Minerals, and Sustainable Development Project (MMSD). can be affected by a range of factors as well as vii international prices. These factors include, but enables Burundi to demonstrate that its 3T pro- are not limited to, local labor costs, mineral grade, duction is not connected to conflict in the Great the relationship between the producer and the Lakes Region and thereby to have access to inter- buyer, goods and services provided to the miner, national mineral markets. iTSCi involves a multi- the remoteness and accessibility of the site, and step mineral tagging and data collection process local market conditions such as competitiveness. which, in this study, is being used as the basis for Access to information on grade is limited and min- calculating revenues generated by the sector. ers are price-takers with little bargaining power. Informal ‘taxation’ of miners is relatively Clarity on the level of gold being produced low in Burundi. Typically the artisanal mining in Burundi remains problematic. Unlike the 3Ts, sector is subject to informal ‘tax’ regimens with there is no traceability system in place for gold. miners and traders being called upon to make In 2012 and 2013 the country reported over payments to a wide range of actors. The level of 2 tonnes of gold being exported per annum how- such payments is reported to be relatively low in ever reported exports fell significantly in 2014 to Burundi with the majority of miners not report- around 650kg. Based on interviews, the increased ing informal payments and for those that were, taxes which were introduced in 2014 were the it was mainly to buy mining equipment. Coopera- major factor in this drop as legal trade was dis- tives and comptoirs, however, are more frequently incentivized and few comptoirs were registered. required to make informal payments. Analysis shows that the Government of Burundi Burundi is undergoing a period of political was, in 2012 and 2013, losing significant revenue insecurity in relation to the 2015 elections. This on gold production. No gold revenues are reported insecurity was causing significant disruption to for 2014. However it should be noted that some the mining sector, both in terms of production and estimates of loss of state revenues through illegal export. This insecurity threatens Burundi’s ‘con- gold trading are misleading. In some reports the flict free’ status and, if the situation deteriorates market value of the gold produced (or estimated further, there is a real risk that the international to be produced) is described as ‘lost revenue’ to market will shun Burundian 3Ts as being too high the State when, in fact, the actual revenues due risk. The over-riding recommendation, therefore, are those prescribed under The Mining Code and must be for the Burundian Government to take all its accompanying legislation. necessary steps to restore stability and to main- Reforms are presently underway by the tain the country’s ‘conflict free’ reputation. Government of Burundi to improve transpar- Recommendations are made for general ency in the minerals sector which should also improvements in the sector including increasing augment the tax revenue generated by ASM. the speed of delivery of licenses which, coupled with This should assist the Government to arrive at the more favorable taxation regime promulgated a better articulation of the economic value of by the 2015 Regulations, should help to stimulate ASM. New Mining Regulations which are in force legal production and trade. Other suggestions for 2015 repeal many of the most stringent taxes include promotion of diversification when certain and should contribute to improved revenue fig- minerals are in downturn, promoting investment ures this year. The Government is simultaneously through improved business stimulants, competi- implementing the Extractive Industries Transpar- tive pricing both locally and regionally, and lever- ency Initiative (EITI) and the ITRI Tin Supply Chain ing the opportunities presented by both EITI and Initiative (iTSCi). EITI focuses on collecting and iTSCi to promote the Burundian mineral sector. collating data about the scale, scope and taxa- All of this should be considered within a strategy tion of the extractives sector while iTSCi is a due to improve ASM production efficiency, safety and diligence and mineral traceability system which access to finance. viii  Executive Summary Improvements in the gold sector are where The Government of Burundi should show- the Burundian Government stands to make the case its efforts to improve transparency and greatest gains though this is complex to achieve traceability. The next step will be to use EITI and and needs a very practical strategy which is iTSCi standards to help to meet the basic needs of grounded in market and trade realities. Taxation artisanal mining communities and to contribute is one element of this but should not be consid- to formalization. This will promote positive per- ered in isolation. Engagement with the existing ceptions and acceptance of both systems to the market and finding incentives for formalization is benefit of Burundi’s mineral sector and national essential. revenues. Executive Summary    ix 1 Artisanal and Small-Scale Mining (ASM) and Its Significance in the Burundian Economy 1.1 The Macro Context 2013 (US$280) in nominal terms, but the country is standing at the bottom of the world ranking. 1.1.1 Mining as Part of the Solution Towards The country is working on these two weak- Economic Diversification in the Country nesses to unlock its growth and poverty reduc- tion potential. Since 2010, external grants are Burundi is one of the smallest countries, most declining in share of GDP, falling from 23.4% in densely populated, and poorest countries in 2010 to 14.7% in 2014. Despite donors’ commit- Africa. It has an area of 27,834 square kilometers ment in the 2012 Consultative Group (CG) con- and just 11 million inhabitants. Around three quar- ference, foreign aid is expected to remain below ters of the population live in poverty, and 90% of 15% in the next three years (2015–2017). The the population is dependent on subsistence farm- country has to find an alternative and comple- ing. Food supplies are inadequate, as is medical mentary growth engine, which should be exports, care. The situation is exacerbated by Burundi’s while accelerating the provision of public goods high population growth of 3.1% per annum.2 and services. Since 2009, the government has Burundi is enjoying moderate economic initiated a second generation of reforms to growth since 2006, but poverty remains wide- accelerate growth and poverty reduction, with spread. GDP growth averaged 4.5% from 2003 the creation of the Burundi Revenue Authority to 2013, 1.5% above the population growth. The (OBR) to improve domestic revenue mobiliza- share of the population deprived of basic food tion, the entry in East African Community (EAC) needs declined by 6 percentage points between to deepen regional integration, and the reforms 2006 and 2012 but remains high at 60%. Inequali- of the business environment through the Doing ties between the capital Bujumbura and the rest Business Report and accompanying index. These of the country are still high but decreasing despite reforms have had positive impact, particularly in faster economic growth in urban areas where ser- the tourism and banking sectors, but the over- vices are concentrated. The share of the popu- all outcomes are below the authorities’ expecta- lation with consumption below the basic needs tions. Private investment increased recently but stood at 61.5% in rural in 2012 versus 41% in Bujum- foreign direct investment remained very low. bura. Higher rural-urban migration explains the Burundi’s main natural resources and decreasing gap between Bujumbura and the rural exports are coffee, tea, and minerals. Agriculture (35 percentage points in 2006 to 20 percentage accounts for just over 30% of GDP and employs points in 2012). Per capita gross national income more than 90% of the population. Burundi’s pri- more than doubled between 2005 (US$130) and mary exports are coffee and tea, which account for approximately 90% of foreign exchange earn- 2. www.giz.de. ings, though exports are a relatively small share 1 of GDP. Ores and concentrates of base met- operational of which 37 were licensed to oper- als account for approximately 10% of commod- ate within the formal system. 3Ts and gold are ity exports.3 Thus Burundi’s export earnings and the primary minerals produced. Exploration and its ability to pay for imports rests primarily on development of the Gakara rare earth deposit (a weather conditions and international coffee and previously operating mine from 1948–1978) has tea prices. Its undiversified economy makes it re-started. Gakara is notable for its exceedingly vulnerable to external shocks including climatic high in-situ grade of bastnaesite and monazite risks, exchange rate and commodity prices. giving rise to claims that it is the richest rare For Burundi, the transformation of its min- earth deposit in the world. Extraction of construc- eral resources into productive capital poses tion materials is also an important component of several challenges. Burundi has attracted some ASM in Burundi including the extraction of clay levels of foreign direct investment (FDI) in the min- (for bricks and tiles), kaolin, carbonate rocks (for ing sector but actual outcomes are well below the lime and cement), slate and other large stones country’s potential. The establishment of a regu- (for paving stones), gravel and sand. latory framework that meets international stan- The distribution of known mining areas is dards is essential for foreign investors. Ensuring shown on Map 1.1. Gold and the 3Ts are found pri- revenue transparency will further enhance devel- marily in the north of Burundi, in the provinces of opment outcomes from mineral extraction with Cibitoke, Kayanza, Bubanza, Ngozi, Kirundo and the recent adhesion to EITI represents a clear step Muyinga. They are also found in the province of toward improved transparency in the sector. For Ruyigi in eastern Burundi, and recently a cassit- sustained economy-wide impact, fiscal and mon- erite mining site was established in the province etary policy will need to adjust to the new context. of Gitega. 1.1.2  Geographic Scale and Scope 1.1.3  Statistics on Employment, Revenues of Burundi’s Mining Sector and Exports Burundi has a wide range of mineral deposits There is no universal definition of artisanal and which include nickel, rare earths, vanadium, gold, small-scale mining (ASM). However, consensus tin,4 tantalum5 and tungsten.6 Tin, tantalum and generally revolves around the following: “mining tungsten are often referred to as the ‘3T’s.7 At by individuals, groups, families or cooperatives with the time of writing, there were 82 3Ts mine sites minimal or no mechanization, often in the informal (illegal) sector of the market.” 8 Distinctions between 3.  State of Commodity Dependence 2014. UNCTAD. artisanal and small-scale mining are made in cer- 4. Tin metal is smelted from cassiterite concentrate. Miners tain countries whereby artisanal refers to pure produce cassiterite ore which is processed to cassiterite concen- manual mining whereas small-scale may have trate for export. fixed installations or use of mechanized equip- 5.  Tantalum metal is smelted from tantalite concentrate. Min- ers produce tantalite ore, which is often called ‘coltan’ locally. ment. However, the diversity of ASM operations is The name ‘coltan’ comes from an abbreviation of ‘colombite- vast and generalizations are easily contradicted. tantalite’ meaning an ore which contains both columbium (also ASM can be carried out by men, women, youth called niobium) and tantalite. Tantalite ore is processed to cas- and children. Worldwide, ASM is often carried siterite concentrate for export. out on an informal basis with weak or inappropri- 6. Tungsten metal is smelted from wolframite concentrate. ate regulatory frameworks that may be poorly Miners produce wolframite ore which is processed to wolframite enforced. ASM often uses poor health and safety concentrate for export. standards and inefficient methods. ASM may also 7.  The term ‘3Ts’ is used frequently in this report to refer to pro- duction of cassiterite, tantalite and wolframite ore, and export of cassiterite, tantalite and wolframite concentrate. 8.  See: http://pubs.iied.org/pdfs/9268IIED.pdf. 2  Artisanal and Small-Scale Mining (ASM) and Its Significance in the Burundian Economy MaP 1.1 IBRD 42028 BURUNDI LOCATION OF THE ARTISANAL MINES IN ACTIVITY VISITED IN JANUARY 2014 OLD SITES TYPE OF ORE: SELECTED CITIES AND TOWNS NEW SITES Au GOLD PROVINCE CAPITALS ZONE A Nb-Ta COLUMBITE–TANTALITE NATIONAL CAPITAL ZONE B Sn CASSITERITE PROVINCE BOUNDARIES ZONE C W TUNGSTEN (WOLFRAM) INTERNATIONAL BOUNDARIES 29°E 30°E 31°E Lake Kivu To Kigali Lake RWANDA Lake Cohoha Rweru Ka gera To Cyangugu Kirundo KIRUNDO Ru vuvu To RP120 Butare ru To Rulenge Ka W n CIBITOKE NGOZI Cibitoke Muyinga Au Kayanza Ngozi MUYINGA To Nyakanura 3°S Musada Ruvuvu 3°S Buhiga Bubanza KAYANZA Sn RP205 Au rus i Karuzi M we BUBANZA KARUZI CANKUZO zi RC257 Rusi RC256 Cankuzo RP121 Muramvya vu vu To MURAMVYA Ru Uvira RP101 Isale RP112 BUJUMBURA RP109 RP124 Gitega RUYIGI BUJUMBURA RP216 MAIRIE BUJUMBURA Mwaro RN18 GITEGA Ruyiga DEM. REP. RURAL To Kibondo MWARO OF CONGO RC234 u ung Bukirasazi TANZANIA mp RC439 Ru Matana RN16 RUMONGE Mutangaro RUTANA BURURI Rutana Bururi Rumonge RN17 4°S 4°S Makamba Lake MAKAMBA Tanganyika Mabanda i BURUNDI raz ga Nyanza-Lac ura M To Kasulu This map was produced by the Map Design Unit of The World Bank. 0 15 30 Miles The boundaries, colors, denominations and any other information shown on this map do not imply, on the part of The World Bank GSDPM Map Design Unit Group, any judgment on the legal status of any territory, or any 0 15 30 Kilometers endorsement or acceptance of such boundaries. 29°E 30°E 31°E DECEMBER 2015 1.1 The Macro Context 3 be characterized by social challenges including indicator of national production but this may not community disruption, environmental damage, be the case. Thus providing a reasonably reliable child labor, gender inequity and indebtedness. number for the scale of gold ASM as a livelihood is ASM is an important rural livelihood in very challenging. Burundi, as it is with other countries who have The true contribution of ASM to the econ- ASM populations. It may be a full time occupation, omy often remains obscured. The total number a supplementary income generating activity, or of individuals employed directly by the 3Ts and a seasonal activity complementing income from gold sectors may therefore be in the region of activities such as agriculture. Both men and women 14,000–27,00011 with each one likely to support are involved in production, processing, transport approximately five family members or depen- and trade of minerals which are sold to local and dents. Rare earth minerals and nickel also rep- international businesses for export. At every step resent future potential however the scale of their in the process, financial transactions occur which production at present is negligible therefore they have the potential to generate economic activ- do not represent a major employer for artisanal ity as well as revenues to the state, however the miners. Extraction is also just the first step in the nature of these transactions is poorly understood economic chain as transporting, processing, and and their cumulative value is not quantified. trading the minerals produced by miners, as well Some 6,000-7,000 miners work in 3Ts ASM as providing goods and services to the mining mines in Burundi.9 The exact number of individu- sector in general, creates a vast economic web of als involved in ASM in Burundi is unknown as there transactions and tax revenue potential. is no registration process for miners. The figure of 6,000–7,000 is based on the known number of workers at the 59 mine sites visited in this study 1.2  The Local Context (approximately 4,700 total workers) which repre- 1.2.1  Organization of ASM in Burundi sented 70% of known 3Ts mines. Around 75% of the workers are miners with the other quarter engaged The Ministère de l’Energie et des Mines (MEM) is in mineral washing, transporting and other tasks. responsible for the development of the mining The number of gold miners may be sig- sector in Burundi. Its main tasks in this regard, nificantly higher. Based on export figures for as defined in Decree No. 100/107 of 17 November 2012 and 2013 when over 2 tonnes of gold were 2005, are: (a) the design and implementation of exported per year, a reasonable estimate might Government policy relating to geology and mining; be some 20,000 miners working in gold. However, and (b) the promotion of geological research and exports in 2014 were around 650kg which would the mining industry. Support to mining, and ASM represent the production of perhaps 7,000 min- specifically, falls under the purview of the Direc- ers.10 This assumes that export figures are a good tion des Mines et Carrières (DMC), a sub-branch of the DGGM. The MEM supports the DGGM on pol- 9.  The estimate for miners working in 3Ts is based on the field icy and legislative matters. research carried out for this project including census at both for- Burundi enacted a new Mining Code in 2013. mal and informal mines visited plus estimates based on known However, at the time of publication of the present numbers of cooperatives and their members. study detailed regulations governing the condi- 10.  The first estimate of number of miners working in gold based tions for licensing of cooperatives and comptoirs on official export figures of 2,000 kg per year, assuming 300 were yet to be issued. In response to the lack of productive mining days and 0.3g produced per miner per day. regulations, two Ministerial Ordinances were The second figure is based on official export figures of 650kg assuming 300 productive mining days and 0.3g produced per miner per day. This individual production estimate is based on 11.  This is an estimate based on the assumptions described. No other studies carried out in the region. census has been carried out to arrive at this figure. 4  Artisanal and Small-Scale Mining (ASM) and Its Significance in the Burundian Economy Figure 1.1:  Relationships and Mineral Flows/Trade in the ASM Sector in Burundi Circulation of minerals and funds: cassiterite, tantalite and wolframite Miners gather production Team leader records Team leader sells on a weekly basis Week 1 production per miner to cooperatives Week 2 Transport production to Bujumbura Team leaders split Week 5 Cooperative leaders Week 4 Negotiate price Week 3 price between miners split price between with comptoir based on production team leaders issued on an interim basis at the end of December Membership of cooperatives is restricted to 2013. They effectively are abrogated once the full small groups of individuals which may include Mining Regulations are completed and adopted the land owner, financiers, mineral buyers by the Government. and others who create a financial and man- The ASM sector includes many different agement structure. In this study, at all the actors. The mine may be on land where there is a mines visited, 446 cooperative members were traditional landowner as well as a mining license counted amongst the 4,726 workers at the holder. Mines need investors who may be formal or various mines putting cooperative member- may be informal ‘sponsors’ of the operations. The ship at around 10% of the mine workforce. licensee or mine owner may create, or may work The remuneration of co-operative members with the miners in several different structures as is calculated based on the site’s productiv- described below. Miners within teams have dif- ity and the particular role of the individual. In ferent functions in terms of site clearance, ore some co-operatives, a daily food allowance is extraction, transport and processing of miner- provided to members, and this forms part of als. Mines are provided with goods and services their compensation. In most cases, individu- from machinery maintenance to food catering. als work for the cooperative on a paid basis All mines have formal or informal security on site. without being members of the cooperative Minerals are transported, processed, traded and and can come and go from one mine site to exported, all by different actors, middlemen, and another. Miners are organized into teams with service providers who may have casual or com- a leader who collects and records the produc- plex relationships to each other (see Figure 1.1). tion on a daily basis. The ASM sector has three forms of labor There are clear directives on how coop- organization in Burundi: eratives should operate. Article 94 of the 2013 Mining Code states that: ‘Only mining (a) Cooperatives: A cooperative is a formal struc- cooperatives formed under the auspices of pri- ture responsible for acquiring and manag- vate and public companies may obtain a license ing a mining site and ensuring the equitable for artisanal mining. Conditions pertaining to distribution of the proceeds from the mine. the formation of mining cooperatives and the 1.2  The Local Context  5 issuance of permits and artisanal mining cards concession. These miners are paid by the kilo- are specified by regulation.’ The Code also gram. Rainbow Rare Earths Limited is a min- specifies that ‘Cooperatives can only sell their ing company engaged in the exploration and production at approved comptoirs’ (Article 88) development of the Gakara rare earth deposit and ‘The conditions pertaining to the approval of and intends to extract 5,000 tons of ore annu- comptoirs will be set by regulation’ (Article 97). ally. It is anticipated that all operations at Cooperatives must register with the Agence de Gakara will use company employees and will Promotion des Exportations (APE)—the export not purchase materials from artisanal miners. promotion agency. Cooperatives do not Both TAMINCO and Rainbow Rare Earths hold have status as a not-for-profit organization industrial mining licenses as there is no small- (Organisation Sans But Lucrative—ASBL) there- scale license in Burundi. fore they are not tax exempt. (b) Unstructured operations: In 2014, 44% of ASM By the end of 2014, 58 cooperatives were operations in Burundi were informal though either licensed or in the process of obtaining by mid-2015 this had changed to 45% formal their license. Twenty-seven mining cooperatives and 55% informal. The informal operations had been granted artisanal mining licenses for take two main forms. Some are family orga- extraction of the 3Ts and an additional 11 licenses nized operations in which the resulting gains were granted for artisanal extraction of gold, with are usually retained and managed by the a further nine license applications for 3Ts and 11 head of the family. The other form is group for gold being processed (see Annex 2). operations in which the mine site is considered Cooperatives can only sell their production to belong to the group as a whole, and pro- at approved comptoirs. In 2014, there were five duction is shared out between the members comptoirs (or traders) licensed for the 3Ts and three of the group each evening in accordance with comptoirs for gold (see Annex 2). The changes in their established rules. the number of cooperatives and comptoirs operat- (c) Small-scale operations: Only one private com- ing in Burundi since 2009 are shown in Figure 1.2. pany, TAMINCO, is involved in the extraction Two Ministerial Ordinances of 2014 stipulated the of the 3Ts in the northern region of Burundi fees and taxes to be levied on comptoirs which (Kabarore-Kayanza and Busoni-Kirundo). may have been a contributing factor to the reduc- This company purchases production from tion in the number of officially registered traders artisanal miners working on the company’s and exporters which was seen that year. Figure 1.2:  Number of Licensed Cooperatives and Comptoirs in Burundi 2009–2014 45 40 35 30 25 20 15 10 5 0 2009 2010 2011 2012 2013 2014 No. Coops (3Ts) No. Coops (Gold) No. 3Ts Comptoirs No. Gold Comptoirs 6  Artisanal and Small-Scale Mining (ASM) and Its Significance in the Burundian Economy Multiple levels of mineral trade occur locally. the team leaders may depend on the grade of the Team leaders generally sell the production of the mineral and whether the cooperative provides any team to the cooperative on a weekly basis. The subsidy to the miners (equipment, food, medical cooperative collects production from each team aid, etc.). Formal cooperatives usually make a pay- leader, and then brings the production to comptoirs ment to the land owner as well as various official in Bujumbura. Negotiation of the price of the min- and unofficial taxes or fees applicable to get their erals depends on: if the cooperative and the comp- artisanal mining permit. These factors affect the toirs have a pre-set agreement; if the comptoir has price then given to the team leader(s). The team paid for the cooperative to have its official agree- leader then splits the payment between the team ment to operate; if the comptoir paid for equipment members. Usually miners get more money than for the cooperative; the grade of the minerals; and washers and transporters. Some mineral trade the international market price. Once the negotia- occurs outside the formal system. In that case, tion between the comptoir and cooperative is final- team leaders usually do not exist and miners ran- ized, the representative of the cooperative comes domly sell their production to a cooperative, who back to the mine(s) and pays the team leader(s). then sells the minerals to informal actors inside or The amount received by the team members outside Burundi (see Figure 1.3). varies. The amount paid by the cooperative to Figure 1.3:  Relationships and Mineral Flows/Trade in the ASM Sector in Burundi Mineral Flow Chart Mine Level Comptoir Level Formal Cooperative sell, price depends on . . . Comptoir President pay Taxes Members Equipment Taxes for Cooperative Taxes sell pay pay sell price Equipment depends Food on . . . Accommodation Team Leader Team Leader 2 Other reco re mon ion reco re mon ion ey ey rd product rd product Diggers Diggers Transporters Transporters Workers Workers sto sto Others Others price sell to depends on . . . Informal Cooperative sell sell sell to Other: Informal Buyers President Outside Country Members Miners Miners sell Miners Miners 1.2  The Local Context  7 1.2.2  Mineral Production and Export of 3Ts produced by miners before the minerals leave the mine and recorded in a log book by Gov- There are various sources of data on mineral ernment agents. Second, data is recorded production in Burundi: on entry and departure from mineral depots (a) Official export statistics: MEM statistics when the minerals are traded with a further for declared exports of minerals 2009–2014 level of tagging and log book entry. Finally, show some dramatic changes in the 3Ts sec- data is recorded in a third log book at export tor. In general terms, export of cassiterite, when the minerals enter and leave the comp- tantalite and wolframite concentrate all grew toirs. iTSCi started up in Burundi in May 2014 year-on-year from 2009 to 2012, reaching a and the data from that period to April 2015 peak of over 940 tonnes of total 3Ts exported is shown in Figure 1.5. Using iTSCi mine-level in 2012 (around 78 tonnes per month). How- data, the average monthly production at ever, this changed in 2013, and exports fell off mine level is 25,000 tonnes per month. How- dramatically to under 10% of 2012 levels with ever iTSCi is only operational at formal sites only 5.7 tonnes of tantalite and 70 tonnes of (approximately 50%). wolframite being exported and no reported (c) Anecdotal reports from miners: Production exports of cassiterite at all. In 2014, the cas- data can also be obtained from actors in the siterite situation continued with no exports field. 45% of miners report that they produce occurring, while tantalite exports made a under 250 of 3Ts per day, with a further 10% recovery (105 tonnes) though wolframite reporting producing up to 500g per day (see remained at a very low level (49 tonnes). In Figure 1.6). A third of team leaders estimated 2014, average monthly production based on that the production of their 13-worker teams official exports was around 13 tonnes per was less than 3 kg per day (confirming the fig- month (see Figure 1.4). ure of under 250g per person), while another (b) Mine level production data from the iTSCi sys- 30% thought that their team were producing tem: In this system (see Section 2.3.2), data between 3–10 kg per day (closer to the 500g is recorded at several levels, first at the mine figure). The remaining 30–40% of miners may when tracking tags are allocated to minerals produce over 1kg per worker per day. However Figure 1.4:  Exports of 3Ts from Burundi 2009–2014 600,000 500,000 Quantity Exported kg/pa 400,000 300,000 200,000 100,000 0 2009 2010 2011 2012 2013 2014 Cassiterite Tantalite Wolframite 8  Artisanal and Small-Scale Mining (ASM) and Its Significance in the Burundian Economy Figure 1.5:  Mine Level Production of 3Ts in Burundi May 2014 to April 2015 45000 40000 Mine Level Production kg/m 35000 30000 25000 20000 15000 10000 5000 0 May–14 Jun–14 Jul–14 Aug–14 Sep–14 Oct–14 Nov–14 Dec–14 Jan–15 Feb–15 Mar–15 Apr–15 Cassiterite Mixed Minerals Tantalite Wolframite Total 3Ts Figure 1.6: Daily Production of 3T Minerals Reported or wolframite is likely to be higher than that by Miners of tantalite. Reducing maximum production 3% by a third to allow for these factors, a rough 4% 4% estimate of production could reasonably be around 50 tonnes per month including pro- duction from both formal and informal sites. under 250g 250–500g There are inconsistencies in 3Ts production 23% 44% 500–1kg data reporting. Contributing factors that help to 1–2kg explain these differences include: 2–3kg (a) The scale of coverage of mineral traceability is 13% 3–4kg 9% limited. The iTSCi system started slowly in a over 4kg small number of mines which grew over time, therefore comparison between early and later months is not pertinent. Further, iTSCi does not extend to all the active mines, only the extrapolating total production figures based ones which operate under the formal system. on these reports is of questionable value. By the end of the period shown in Figure 1.5, There are myriad variables such as: the pro- approximately half of all mines were operat- portion of the workforce working full time and ing formally therefore the data only repre- present on a daily basis; downtime at mines sents perhaps half of production. or temporary closure for maintenance work or (b) Mine level production does not equal declared clearance of overburden; weather conditions; export quantities. Mine level data is for raw availability of water; availability of equip- production of ore which contains impurities. ment; etc. Also, the production of cassiterite These minerals are cleaned concentrated for 1.2  The Local Context  9 export with an inevitable loss of weight as 1.2.3  Mineral Production and Export of Gold waste material is discarded. Also, minerals Gold exports fluctuate significantly. The quan- need to be accumulated into sufficient quan- tity of declared gold exports increased from 2009 tities for export lots. There may be significant to 2013, at which point it was over 2 tonnes. This time lags between production and export to corresponds to the increase in the number of accommodate this. comptoirs and associations that were approved (c) The MEM lacks a centralized and easily cross- for the production and export of gold. However, checked database for mineral production and several sources agree that this amount represents export data. The World Bank is currently only a small proportion of the actual quantity of working with the MEM and Pact to resolve gold exported from Burundi (some informants this problem and to facilitate more accurate suggest this may be only 20% of actual, unof- data reporting. ficial exports, though there is no way to verify this estimate at present and this would indicate A challenge to the growth of Burundi’s 3Ts an overall export that would be disproportion- market is the impact of international legislation ately high in relation to estimated production for on mineral buyers and the resulting demands the region). Although the proportion of gold that passed from buyers to suppliers. In 2010, the passes through Burundi is unknown, previous United States enacted the Dodd-Frank Wall studies (specifically that of Midende, 2009) esti- Street Reform and Consumer Protection Act (usu- mate that the minimum quantity of gold actually ally called ‘Dodd-Frank’). Section 1502 of the Act, produced in Burundi was 1 tonne per year. Official accompanied by the Security and Exchange Com- export figures for 2014 were much lower at 650kg mission (SEC) Rules, requires companies traded on (see Figure 1.7). US stock markets to disclose the origin of and 3Ts and gold they use if those minerals are “necessary to the functionality or production of a product.” 1.3  Mineral Prices Any of these minerals originating from the Demo- cratic Republic of Congo (DRC) or any adjoining The prices paid for minerals in Burundi are country, including Burundi, have not been pro- highly variable, dependent on many factors, duced under conditions of conflict, nor are they and not comparable across the Region. The pur- contributing to armed conflict in the Great Lakes chase price for the 3Ts on site and via formal and Region (GLR). Added to this, the Organization for informal négociants was obtained from actors at Economic Cooperation and Development (OECD) both formal and informal sites who were willing issued Due Diligence Guidance for Responsible to respond to this question. It should be noted Supply Chains of Minerals from Conflict-Affected that these prices were typically given with no and High-Risk Areas which set out the same reference to grade as most informants at field requirements in more detail. Despite Dodd-Frank level were unaware of the metal content of the coming into force in 2011, Burundi continued to ores. Prices reported at field level were: tantalite export significant quantities of 3Ts throughout at US$10–24/kg; cassiterite at US$2–6/kg; and 2011 and 2012. It is unclear why the impact of wolframite at US$1–6/kg. The variability in price Dodd-Frank was not felt earlier in Burundi since is a function of a range of issues which includes certain smelters were less concerned about due but is not limited to: diligence and had continued to buy for a time prior to entering into the Conflict Free Smelter Program (a) Whether or not the buyer is the owner of the (CFSP) audit system. mine: If the buyer owns the mine they may 10  Artisanal and Small-Scale Mining (ASM) and Its Significance in the Burundian Economy Figure 1.7:  Official Gold Exports from Burundi 2009–2014 2500 2000 Exports kg/pa 1500 1000 500 0 2009 2010 2011 2012 2013 2014 set prices that reflect the investment made in this is a constant source of conflict. Samples managing the mine. can also be sent outside of the country (usu- (b) The grade of the material: Specific unwanted ally to Rwanda, where the appropriate infra- impurities which would increase penalty structure exists) to ascertain quality. charges at the smelters. Ores with higher (d) Pre-financing arrangements with ‘sponsors’: mineral content should, normally, command a Sponsors may provide miners with equip- higher price however in most cases knowledge ment, credit, financial support in times of low of grade is limited and few, if any, resources production, etc., all of which may be subject exist to test mineral grades at mine sites. to repayment through discounts on purchase (c) The mineral content of the ore: Very frequently prices of minerals. Most of the respondents in ores contain mixed minerals. Most of the this study said that they received some help/ respondents to the study were not aware of compensation from their buyer. The majority the grade of their minerals. Indeed, 78.5% of the of respondents received medical aid, equip- respondents were unaware of the grade of the ment, and food. Others declared that they minerals. Most of them were miners. There- received direct pre-financing (see Figure 1.8). fore, price negotiations between the coopera- (e) The remoteness and accessibility of the site: tive and the miners (usually carried out by the Sites which require higher transport costs team leaders) do not often include the quality may offer lower prices to compensate. Sites of the minerals. Mineral prices at the comp- which are hard to access may suffer from few toirs are more dependent on the quality of the buyers being willing to travel to them. mineral content. However, a lack of laboratory (f) The local cost of labor and cost of living. equipment within the relevant services of the (g) Local production and weather conditions: If a Direction Générale de la Géologie et des Mines mine owner has to transport water to a site for (DGGM) means that responsibility for deter- mineral washing (in the dry season, or for sites mining the quality of mining products rests with few water sources) this may increase pro- with the négociants and/or the comptoirs, and duction costs and lower purchasing prices. 1.3  Mineral Prices  11 Figure 1.8:  Compensation or Support Received by Miners from Cooperatives or Sponsors None Fixed salary Social security Lodging Pre-financing Equipment Medical care Food 0 10 20 30 40 50 60 70 80 90 % of Respondents (h) The local market prices, liquidity and competi- (j) International market prices: This is a critical tion amongst buyers: Local markets are highly factor. Commodity prices are on a downward volatile at present in many parts of the Great trend for many minerals with the 3Ts having Lakes Region, not just Burundi. This particu- seen significant price decreases in the last larly extends to availability of cash to pur- year. This has had a direct impact on local chase minerals. prices. When prices are low, the incentive for (i) The bargaining power of the seller: Individual miners to work is reduced, with production miners are generally ‘price takers’ and may decreasing in direct proportion. Miners may have little influence over price while coopera- shift between mines/minerals according to tives may be able to demand higher prices. prices offered, for example a downward trend in tin price may drive miners into gold mines. 12  Artisanal and Small-Scale Mining (ASM) and Its Significance in the Burundian Economy 2 Tax Administration and Revenues: Challenges and Progress 2.1 Mineral Tax Administration for mining cooperatives and comptoir trad- ing licenses are dependent on applications 2.1.1 Mineral Taxation Framework being accompanied by proof of payment of these fees (as per Article 95 of the Mining Progress has been made in streamlining the Code). ASM taxation framework however the 2013 (b) Annual surface rents are payable for ASM Ordinance significantly increased taxes pay- operations. During a 2014 consultation pro- able by actors in the ASM sector. ASM taxation cess called the Assises de Banga, it was pro- is governed by the new Mining Code. Two Ministe- posed that these annual surface rents for rial Ordinances were issued on an interim basis at ASM be eliminated however they remain in the end of December 2013 to be abrogated once place at present. the full Mining Regulations are completed and (c) Ad valorem tax and export duties are cal- adopted by the Government. Ministerial Order culated based on the value of the minerals No. 760/540/1758/2013 details the administra- being exported. This value is determined by tive and fiscal requirements for the granting and the exporter using a formula that takes into renewal of prospecting permits, research per- account both the quantity and quality (con- mits, exploitation licenses for mines and quarries, tent) of the minerals, together with interna- licenses for artisanal exploitation, and permits tional market prices. related to the purchase and sale and export of (d) Repatriation or surrender of foreign currency artisanally mined minerals in Burundi. Ministerial generated by minerals sales is included in the Order No. 760/540/770/1757 stipulates annual tax regimen. royalties in the form of an ad valorem for arti- (e) Mining sector actors are also obliged to pay sanal mines and quarries, as well as the taxes other taxes applicable under Burundi’s General and fees levied on those involved in the purchase Tax Code. Article 143 of the new Mining Code and sale and export of artisanally mined minerals. stipulates that mining companies, including A full summary of all applicable taxes and pay- those involved in ASM, ‘are subject to the tax ments to be made by cooperatives and comptoirs and customs regime of general law in force in is given in Table 2.1 which shows the increases Burundi’. Thus companies, cooperatives and that occurred. Of particular note: comptoirs involved in ASM are now subject to the payment of income taxes (this was not (a) Permit allocations known as fixed fees (‘droits the case before October 2013), and must now fixes’) are payable every two years. These fees be in conformity with Burundi’s Tax Code. are consistently paid as exploitation licenses 14 Table 2.1  Nomenclature of Taxes, Royalties and Fees Applicable to ASM in Burundi Payment Amount Amount Amount (ENG) in FBU in FBU in USD Payment (Unofficial Legal Point of Calculation (USD) (USD) Adopted (FR) Translation) Status Paid by To Payment Frequency Basis Mineral Pre 2013 Since 2013 in 201512 Droits fixes Permit fee Mining code Cooperative Treasury Mine 2 years per site Gold 8,000,000 100,000,000 600 (pre 2013), (5,200) (65,000) Ordonnance Sno2 100,000 2,000,000 600 (2013) (65) (1,300) TaO3 200,000 2,000,000 600 (130) (1,300) WO 100,000 2,000,000 600 (65) (1.300) Redevance Annual Mining Cooperative Treasury Mine Annual per ha Gold 5,000,000 20,000,000 5,000 minière surface rent code (pre (3,250) (13,000) annuelle 2013), in Sno2 100,000 5,000,000 1,000 discussion (65) (3,250) TaO3 200,000 10,000,000 1,500 (130) (6,500) WO 100,000 5,000,000 1,000 (65) (3,250) Réhabilitation Rehabilitation Mining Cooperative Treasury Mine Annual per ha ALL 500,000 1,000,000 No info13 des sites of sites code (pre (325) (650) 2013), in discussion Taxe Communal In Cooperative Treasury Mine by per kilo of Gold   No info No info communale taxes discussion transport minerals Sno2   No info No info TaO3   No info No info WO   No info No info Droits fixes Permit fee Mining Comptoir Treasury Export Annual NA Gold 16,000,000 100,000,000 35,000 code (pre (10,400) (65,000) 2013), in Sno2 300,000 50,000,000 10,000 discussion (195) (32,500) TaO3 300,000 50,000,000 10,000 (195) (32,500) WO 100,000 50,000,000 10,000 (65) (32,650) Contribution Contribution Mining Comptoir Treasury Export Annual   Gold 5,000,000 No info No info14 à la to the code (pre (3,250) réhabilitation rehabilitation 2013), in Sno2 100,000 2,000,000 No info des sites of sites discussion (65) (1,300) TaO3 200,000 2,000,000 No info (130) (1,300) WO 100,000 2,000,000 No info (65) (1,300) 12 13 14 (Continued) 12. Mining regulations were just adopted before the report was released. However, implementation measures were not yet adopted therefore all values are in US$ not yet in FBU. 13.  The Ministry of Mines stated that the amount will be fixed by an ordonnance adopted by the Ministry of Environment. The ordonnance was not adopted at the time of this report. 14.  The Ministry of Mines stated that the amount will be fixed by an ordonnance adopted by the Ministry of Environment. The ordonnance was not adopted at the time of this report. 2.1  Mineral Tax Administration  15 Table 2.1  Continued Payment Amount Amount Amount (ENG) in FBU in FBU in USD Payment (Unofficial Legal Point of Calculation (USD) (USD) Adopted (FR) Translation) Status Paid by To Payment Frequency Basis Mineral Pre 2013 Since 2013 in 201512 Obligation de Levy on the Mining Comptoir Treasury Export per export Value of ALL No info No info and No info rapatriement repatriation code (pre export (by no payment en devise of foreign 2013), in mineral) so far currency discussion Tax Ad Tax Ad Mining Comptoir Treasury Export per export Value of Gold 0.30% No info 2% Valorem Valorem code (pre export Sno2 3% No info 3% 2013), in TaO3 3% No info 3% discussion WO 3% No info 3% Droits de Export duties Mining Comptoir Treasury Export per export Value of Gold 0.20% No info No info15 sortie code (pre export Sno2 1% No info No info 2013), in TaO3 2% No info No info discussion WO 1% No info No info Prélèvement Custom Mining Comptoir Treasury Export per export Value of ALL 1% per 1% per No info sur duties on code (pre export transfer transfer rapatriements other gain 2013), in de devises discussion Les droits de Import fees Mining Comptoir Treasury Export per import Variable— ALL No info No info No info douanes à on other code (pre on value l’entrée sur goods 2013), in les autres discussion produits Impot sur le Income tax Mining Comptoir Treasury Export Annual Income of ALL Exonerated 30% if in No info revenu code (pre comptoir profit 2013), in 1% if loss discussion Import sur le Tax on Mining Comptoir Treasury Export Annual Income of ALL Exonerated No info No info mobilier movable code (pre comptoir 2013), in discussion Taxe sur la TVA Mining Comptoir Treasury Export Annual Income of ALL Exonerated No info No info valeur ajoutée code (pre comptoir 2013), in discussion Autre fiscalité Other Mining Comptoir Treasury Export Annual Income of ALL Exonerated No info No info de droit common code (pre comptoir commun duties 2013), in discussion 15 15.  The Ministry of Mines stated that the amount will be fixed by an ordonnance adopted by the Ministry of Finance. The ordon- nance was not adopted at the time of this report. 16  Tax Administration and Revenues: Challenges and Progress 2.1.2  Mine Tax Administration: Collection, lack of knowledge is compounded by poor and Management and Distribution irregular communication with the MEM. (c) OBR is insufficiently integrated with MEM DGGM was the primary collection point for min- for the effective application of other relevant eral sector taxes prior to 2014. Previously DGGM taxes to Burundi’s mining companies, coop- reviewed applications for comptoir licenses and eratives and comptoirs. OBR and the mining collected the related taxes and fees. All taxes were services need to work together to put in place paid into an account at the Central Bank, with a adequate mechanisms to audit the accounts receipt of payment required by DGGM before a of mining cooperatives and comptoirs, as pro- license could be issued. The ad valorem tax and vided for in the Mining Code. export duties were paid to DGGM and the Cus- (d) There is no reliable register of ASM operators. toms Office respectively. However, since 2014, The OBR’s registry (Tax Registration Num- DGGM does not receive anything directly. bers) does not reflect all mining operators, Under the new Mining Code, the OBR is the and the database of license holders is not reg- sole agent of the state authorized to collect ularly updated by the MEM. taxes including those from ASM cooperatives (e) Calculation of the ad valorem tax depends on the and comptoirs. All taxes and royalties must be grade and value of the mineral being exported paid at the counters of the OBR in Bujumbura, and however capacity and responsibility for this are receipt of payments given. Revenues generated challenging. Mineral content (quality) should through tax collection by OBR are transferred to usually be determined by the national testing the Ministry of Finance and eventually are found laboratory however, due to a lack of equipment, in the national budget. it currently falls to the comptoirs to determine content at the point of purchase and export. 2.1.3  Challenges Revealed in the Taxation This means that in effect it is left to the rate- Framework and Its Administration payers to determine the rates which they must pay. OBR does not have access to the calcula- There are challenges for OBR in collection of tions used and therefore has no way to verify taxes from the mining sector. Interviews with whether declarations are valid. Government and other stakeholders highlight the (f) Repatriation or surrender of foreign currency following problems: generated by minerals sales is included in the tax regimen. However legal provisions relat- (a) The tax increases introduced in 2013 were ing to foreign currency repatriation are not exorbitant and dis-incentivized participation applied at present and are unlikely to be in the formal sector. The new taxes which effective until there is adequate collabora- included increases of up to 50,000% (e.g., fixed tion between the mining services, the Central fees for wolframite comptoirs went from USD Bank, the OBR and the private banks into 65 to USD 32.650) were almost impossible to which mineral exporters receive their earnings. collect. The cost of doing legal business, set (g) The OBR is not yet present in mining areas. It against a background of falling mineral prices, is anticipated that with the national decen- became prohibitive and this hampered the tralization process which is under discussion, work of OBR. in the future payments to OBR may be made (b) The OBR lacks knowledge of the sector. This at other OBR counters in the provinces. The includes unfamiliarity with tax nomenclature establishment of local offices of the Direction as it applies to ASM operations. Further, the des Mines would also facilitate this task, by OBR does not control tax policy, especially providing OBR with an up-to-date register of as it is applied to mining cooperatives. This cooperatives in a given province. 2.1  Mineral Tax Administration  17 (h) The OBR is not yet present at all official and were not making any informal payments. For unofficial border crossings. In addition, its those that were, it was mainly to buy equipment collaboration with the other State services to carry out their mining activities. However over located at these points remains problematic. 90% of cooperative leaders reported making pay- ments for security, official taxes, contribution to communities, transport, and payments to buy At present, all revenue from ASM goes into and/or rent land. See Figure 2.1. the national treasury, as there are no official provisions for tax collection at the communal or provincial levels. In Article 151, the Mining Code 2.2  Official ASM Tax Revenues stipulates that ‘the distribution of the ad valorem tax between the State and the municipality will be Official tax revenues from the mining sector have specified by other special provisions, laws or regula- been in decline since 2012. Declared receipts from tions’. The application of this provision could help the mining sector in Burundi, as reported by to reduce the feeling that local entities have that OBR,16 are shown in Figure 2.2. In line with pro- ASM ‘only benefits the rich’. If they were to profit duction, the revenues show a downward trend directly from the ad valorem tax, local authorities since 2012. Data was not available to indicate would also be more likely to promote and regulate the specific source of this income therefore it is ASM activities in their region. not known which taxes or fees generated these These concerns are the focus of the World returns, nor which minerals. However the official Bank’s and the Government of Burundi col- MEM export figures for this period are available laboration. The Projet Multisectoriel de Renforce- (see Figures 1.4 and 1.7). The decline shown in OBR ment des Capacités Institutionnelles (Multisectoral official revenues mirrors that of 3Ts minerals but Institutional Capacity Building Project) [P149176] does not reflect the substantial volume of gold aims to improve current practices, particularly which was exported during that period. in relation to revenue collection, starting with an audit of the mining value chain. The project also 2.2.1  Tax Revenues Generated by the 3Ts includes, amongst other things, a proposal to establish a Joint Technical Commission (consist- The official reported tax revenues for the 3Ts for ing of OBR and MEM) to conduct the audit and 2014 are given in two different figures. The first, develop recommendations. was USD 523,000 as declared by OBR (see Fig- ure 2.2) and the second was USD 700,000 as declared by the MEM in the 2014 Annual Report 2.1.4  Informal Payments in ASM of the Direction des Mines et Carrières. This Annual Report provides a detailed breakdown of the Typically, there is a wide range of informal pay- source of all revenues generated by the sector ments made in the ASM sector alongside formal including ad valorem and export duty for tantalite, taxes. Payments may be demanded on the basis ad valorem and export duty for wolframite, annual of culture and traditional practices, they may surface rents, permit fees and site rehabilitation. be charged as a form of unofficial payment for Calculations to apply EITI to the 3Ts tax rev- services provided by state agents such as mine enues produce a lower income than is officially inspection, security, etc., or they may be simply reported. The known, official tax regime was taken as institutionalized or opportunistic ‘tracas- serie’, ‘baksheesh’, or bribery. 16.  Conversion rates used are approximate by year, from http:// In Burundi, the level of informal payments www.oanda.com/currency/historical-rates/ 2008: 0.00085; being made in the ASM sector by miners is rela- 2009: 0.00085; 2010: 0.00080; 2011: 0.00080; 2012: 0.00070; tively low. Over 70% of miners affirmed that they 2013: 0.00065; 2014: 0.00065. 18  Tax Administration and Revenues: Challenges and Progress Figure 2.1:  Types of Payments Paiement pour securite Cadeau Contribution pour la communaute Paiement pour autorisation de transport de minerais Paiement pour etre membre de la cooperative Taxes officielles Impots sur les revenus Paiement de dettes Paiement d’interets Aucun paiement Autre 0 20 40 60 80 100 Responses as percentage of total Figure 2.2:  Official and Estimated Tax Revenues from the Mining Sector in Burundi 2008–2014 Comparison of Official and Estimated Tax Revenues from ASM 4,500,000 4,000,000 3,500,000 3,000,000 2,500,000 USD 2,000,000 1,500,000 1,000,000 500,000 0 2011 2012 2013 2014 Estimated Total Revenues Official Total Revenues applied to the available information relating to The variance can be accounted for by several numbers of cooperatives, numbers of comptoirs factors, most notably the need for improved data, and volumes of minerals produced and exported harmonized reporting and strengthened coordina- (see Annex 1). This exercise required the use of a tion between OBR and MEM. This variance could range of assumptions and variables. Using these be accounted for in a variety of ways including: figures, calculations indicate a contribution of error or variance in estimates and assumptions, US$578,600 in 2014 on the basis of 300 tonnes time lag in payments being made or received, of minerals produced. time lag in processing applications, errors in 2.2  Official ASM Tax Revenues   19 Figure 2.3:  Estimated Tax Revenues from the Gold Mining Sector in Burundi 2011–2014 3,500,000 3,000,000 2,500,000 USD / pa 2,000,000 1,500,000 1,000,000 500,000 0 2011 2012 2013 2014 accounting, etc. Therefore the challenges in rec- This estimate peaks around USD 3,032,000 onciling tax revenue data for the 3Ts seem to pri- in 2013 when official gold exports were over marily relate to coordination, information sharing 2 tonnes. It drops to $453,000 in 2014 when offi- and harmonization of data included in calcula- cial exports were around 650kg (see Figure 2.3). tions rather than indicating any serious loss of The trend in estimates for tax income from material through the system. gold mirrors the number of licensed cooperatives and comptoirs. See Figure 2.4. This indicates a probable close relationship between the cost of 2.2.2  Tax Revenues Generated by Gold doing legal business as a licensed operator and The official Annual Report for the mining sector in the revenues generated for the state. The two 2014 does not calculate taxes received from the Ministerial Ordinances of 2013 which stipulated gold sector. However, using the official export sta- increased fees and taxes to be levied on coopera- tistics for gold, and using an average annual value tives and comptoirs is likely to have been a con- for gold, estimates of tax revenues can be made. tributing factor to the reduction in the number of Figure 2.4:  Number of Licensed Cooperatives and Comptoirs for Gold in Burundi 2011–2014 25 20 15 10 5 0 2011 2012 2013 2014 Gold coops Gold comptoirs 20  Tax Administration and Revenues: Challenges and Progress officially registered traders and exporters and the and mineral resources and revenues. The EITI resulting fall in declared exports. Standard sets the requirements and provides Increases in the cost of doing business are guidance on how to report activity in the extrac- particularly important in the ASM gold sector tives sectors and ensures that this informa- where profit margins are typically very small. tion is available to the public. The Standard also ASM gold already has a high degree of purity (typ- covers issues such as the issuance of licenses/ ically from 85% to 95% depending on its geologi- concessions and state mineral sales. cal presentation and processing techniques) and The EITI has traditionally focused on the the international price of 99.999% gold is readily formal sector. As a result, reporting on ASM has available. Transport costs are low and markets been considered a major challenge and has largely are easily accessed. Thus prices paid at mine level been ignored. There are often gaps in national are relatively high. Legal gold traders face fierce ASM data, both in terms of production statistics competition from the black market and the costs (both those disaggregated by mine site and min- of doing legal business impact negatively on the eral, and those aggregated at the national level) price they can offer. Thus compliance can easily and in terms of formal revenue streams derived become uncompetitive. from licenses and taxes. However iTSCi, the par- It should be noted that there are misleading allel initiative being undertaken by the Burundi estimates made in some reports. Many reports Government for mineral traceability, provides a focus on the market value of gold and present this means of filling some of these data gaps. figure as ‘lost revenues’ to the State. However, The Government of Burundi is committed to this is not accurate as the only revenues due are implement EITI. On 20 January 2015, the Govern- those prescribed under the tax regime. ment publically declared its intention to pursue candidacy in the EITI process. Burundi must now work towards submitting its application for Candi- 2.3  Mechanisms for Transparency dacy to the EITI Secretariat in Oslo, Norway. It has in the Mining Sector of Burundi: pledged to do so by December 2015. Once accepted How Can EITI and iTSCi Help? as an EITI Candidate country, Burundi must begin the process of EITI reporting. It is with this in mind Reforms are presently underway by the Govern- that the study was commissioned: to see how to ment to improve transparency in the minerals make reporting from an ASM country possible. sector in order to arrive at a better articulation of the economic value of ASM, Indeed, two parallel 2.3.2 iTSCi but complementary transparency processes are being undertaken by the Government, with assis- Burundi’s 3Ts sector has been impacted by tance from international partners. These are the international legislation and the resulting Extractive Industries Transparency Initiative (EITI) demands passed from buyers to suppliers. In and the ITRI Tin Supply Chain Initiative (iTSCi). 2010, the United States enacted the Dodd-Frank These two initiatives have complementary and Wall Street Reform and Consumer Protection Act mutually reinforcing objectives which strengthen (usually called ‘Dodd-Frank’) which was accompa- transparency in the ASM sector through collec- nied by the Security and Exchange Commission tion of data on production, trade and taxation. (SEC) Rules which require companies traded on US stock markets to disclose their use of certain minerals if those minerals are “necessary to the 2.3.1 EITI functionality or production of a product” manufac- The EITI is an international standard to pro- tured by those companies. The minerals in ques- mote transparency around countries’ oil, gas tion are tantalum, tin, tungsten or gold originating 2.3  Mechanisms for Transparency in the Mining Sector of Burundi: How Can EITI and iTSCi Help?  21 from the Democratic Republic of Congo (DRC) or dum of Understanding (MoU) with ITRI on 27 May any adjoining country. The objective is to ensure 2011, but it was not until May 2014 that the sys- that minerals in US supply chains are ‘conflict tem was launched in Burundi, partly due to the free’, i.e., they have not been produced under con- difficulty in securing funding for the start-up of ditions of conflict, or which are contributing to the initiative. armed conflict in the Great Lakes Region (GLR). iTSCi is a comprehensive mineral trace- Added to this, the Organization for Economic ability and due diligence system. Mineral trace- Cooperation and Development (OECD) issued Due ability under iTSCi involves a multi-step mineral Diligence Guidance for Responsible Supply Chains tagging and data collection process implemented of Minerals from Conflict-Affected and High-Risk by the Government of Burundi and designed to be Areas17 which set out the same requirements in entirely absorbed into the normal management more detail. practices of the mining services. Minerals are iTSCi was implemented as a response to traced and data is recorded at mine, processor market demands for conflict-free minerals. As and exporter levels as well as along its transport a response, the international tin industry asso- route. Added to this, due diligence assessments ciation, ITRI, and the international tantalum are carried out on all suppliers who must be mem- industry association, T.I.C., worked with the Gov- bers of iTSCi and who are subject to independent, ernments of DRC, Rwanda and Burundi, the Inter- third party audits. Risk assessments are also car- national Conference of the Great Lakes Region ried out. iTSCi is fully compliant with OECD Guid- (ICGLR), and international NGO, Pact, to develop ance and minerals from the iTSCi system can and implement a comprehensive due diligence enter into smelters which have passed their Con- and mineral traceability system which would flict Free Smelter (CFS) audit. enable ‘conflict-free’ minerals to be traded on the iTSCi membership in Burundi is increas- international market. The ITRI Tin Supply Chain ing. As of the start of 2015, there were four iTSCi Initiative rapidly became the accepted industry full members and two iTSCi provisional mem- standard to guarantee market access and, by bers operating in Burundi. WMP (Wolfram Mining 2014, covered the vast majority of 3Ts minerals and Processing Ltd), Tantalum Mining Company being produced in, and exported from, the Region. (TAMINCO), BMS (Burundi Mining Supply) and The Government of Burundi signed a Memoran- AUMERCAT were full members. SECOMIB (Société d’Exploitation et de Commercialisation des Min- erais du Burundi) and ATM (African Tantalite Min- 17. http://www.oecd.org/corporate/mne/GuidanceEdition2.pdf ing) are provisional members of iTSCi. 22  Tax Administration and Revenues: Challenges and Progress 3 Recommendations B urundi is undergoing a period of political The price of tantalite remained more robust insecurity in relation to the 2015 elec- but was also impacted. tions. This insecurity is causing significant (b) International demand: The international mar- disruption to the mining sector, both in terms of ket for wolframite was very weak through- production and export. The immediate, knock-on out the study period. This is a major issue effect of the civil disturbance on Burundi’s econ- for Burundi as wolframite is one of the most omy has been profound. During periods of eco- important minerals, proportionally, in its min- nomic stress, ASM should be a safe haven rural ing sector. The Government of Burundi should livelihood and should be a major contributor to bol- adopt an active outreach strategy to seek to ster the national economy when other activities engage buyers and to instill confidence and are imperiled. Yet the current insecurity threatens interest in the market. This can be achieved Burundi’s ‘conflict free’ status and, if the situation through participation in business forums, deteriorates further, there is a real risk that the media outreach, trade delegations, and other international market will shun Burundian miner- forms of engagement with the market. als as being too high risk. This would have a cata- (c) Price and tax differentials in the regional mar- strophic impact on the country’s mineral sector. ket: Whilst the Government cannot set com- mercial prices in a free minerals market, due consideration should be given to the pricing 3.1 The 3Ts Sector in Burundi disadvantage which is observed in Burundi and the risk that this may encourage ille- 3.1.1 Observations on the 3Ts in Burundi gal transport of minerals to obtain better Burundi’s 3Ts sector is underperforming in prices in other areas. The Government should terms of its potential delivery to the national engage with Burundian producers and traders economy. There are three key external factors to determine what incentives could be put in which are impacting on the sector: place to promote the local market and better prices. The retention of minerals within the (a) Commodity prices: The low price of tin in the legal trade is essential if their revenue contri- first half of 2015 has made cassiterite min- bution is to be realized. ing unattractive and has whittled down profit margins across the region. Whilst this is not There are also internal issues which have something which is within Burundi’s control, contributed to the underperformance, notably efforts should be made to transition cassiter- delays in issuing licenses and costs associated ite miners to other minerals during the period with formalization and the tax regimen. Delays of low prices to compensate for lost earnings. in the licensing process for cooperatives mean 24 that a large number of groups have either halted prices which contributed to the reduction in in their operations or are trading outside the for- official exports and concomitant tax revenues. mal system. iTSCi is only extended to licensed The proposed reductions for 2015 should have cooperatives (which now make up less than half of a stimulant effect. all cooperatives) and this is the only mechanism (c) Incentivize improved mineral prices: The Gov- which exists for international market access at ernment of Burundi should engage with local present. The cost of licenses for cooperatives also producers and buyers to identify what market impacts the rate of uptake. The cost increased by incentives or stimulants could be put in place a factor of 10 for tantalite licenses (from 200,000 to improve local mineral prices to ensure they FBU to 2,000,000 FBU—i.e., from US$130 to come in line with mineral prices elsewhere in US$1,300) and by a factor of 20 for cassiterite the region. Price differentials contribute to and wolframite licenses (from 100,000 FBU to illicit mineral flight and loss of revenues. 2,000,000 FBU—i.e., from US$65 to US$1,300). (d) Increase participation in the formal sector: The impact of the 2013 tax increases is repeat- Priority should be given to speeding up the edly noted as being a deterrent to formal business licensing process for cooperatives to increase in Burundi. The longer term advantages of incen- the number of productive sites as quickly as tivizing licensing and thereby having more miners possible. If the cost of licenses is a block, cre- and more mineral production inside the system ative solutions should be sought such as pay- as compared to the shorter term gains that can ment of licenses in installments, discounts on be achieved by higher license fees seems to have licenses against production, etc. been taken into consideration in the new Mining (e) Promote holistic ASM formalization: Licens- Regulations in 2015. ing of cooperatives should be coupled with Increased transparency is possible. As public an awareness/support program about ASM reporting of verified iTSCi production and export production efficiency, safety and access to figures becomes available, it will be straightfor- finance. This should be proposed to donors ward for the MEM and the Treasury to employ a and could be carried out in partnership with basic calculator to track all revenues being derived iTSCi as part of its ‘phase 3’ social and techni- from the sector. Thus the implementation of EITI cal program support. for cassiterite, tantalite and wolframite produced (f) Decentralize tax payments: The process of by artisanal miners in Burundi using iTSCi will be decentralization of OBR payment counters relatively straightforward to do. should speed up to facilitate local payment of taxes, ideally in collaboration with the estab- lishment of local offices of DGGM. 3.1.2  Recommendations for the 3Ts in Burundi (g) Diversify mineral production: Emphasis should (a) Re-establish security and stability to maintain be placed on investment in diversification Burundi’s ‘conflict free’ status: The over-riding of mineral production during periods of un- recommendation must be for the Govern- favourable pricing. As tin prices are currently ment of Burundi to take all necessary steps to depressed, incentives should be given for non- restore stability and to maintain the country’s cassiterite sites to expand to accommodate ‘conflict free’ reputation. Without this, the 3T out of work cassiterite miners and to bolster sector in Burundi will collapse. economic activity. This could be achieved (b) Follow through on proposed reductions in taxa- through further tax breaks, guarantees of tion: The 2013 dramatic increases in the tax loans, or other business-oriented incentives. regime failed to increase tax revenues to the (h) Strengthen tungsten trade: The Government state, rather they increased the cost of legal of Burundi should develop and implement a trade against a backdrop of falling mineral plan for positive market engagement with the 3.1  The 3Ts Sector in Burundi  25 tungsten industry to stimulate investment in, Dodd-Frank, there are clear drivers for the Gov- and markets for, Burundian wolframite. The ernment of Burundi to gain a better hold on its discourse should not focus on the challenges gold sector. but should promote opportunities for invest- Changing the dynamics around the gold ment, trade and partnership. trade is complex. Providing a full set of recom- (i) Expand iTSCi: The Government of Burundi mendations is beyond the scope of this report, should maintain its partnership with ITRI with however broad recommendations can be made a view to expanding the iTSCi system across based on extensive experience of working on this all 3T sites in the country as quickly as possi- subject in other countries. ble. iTSCi gives the Government visibility into the sector and provides an important tool for managing mines, tracking minerals and moni- 3.2.2  Recommendations for the 3Ts in Burundi toring revenues. (a) Carry out a baseline to obtain accurate sta- tistics on gold production and trade: This is needed to determine the actual level of gold 3.2  The Gold Sector in Burundi production in Burundi. This should be a rela- tively straightforward matter given the lim- 3.2.1  Observations on Gold in Burundi ited size of the country and the known areas The legitimate revenue flows from gold which of gold production. This data will allow a dif- should contribute to the national economy are ferentiation between gold originating from severely disrupted. Using the Government’s Burundi and that entering the Burundian own export figures from 2013, and using the new market from elsewhere. tax values promulgated that year, the shortfall (b) Engage producers and buyers in the creation in terms of revenues due to the state exceeded of a viable, profitable, legal business environ- US$3 million for that year. There are no revenues ment for gold trade in Burundi: Practical dis- at all reported for the 645kg of gold officially cussions should be held with the current gold exported in 2014. producers and buyers of gold regarding the Tax rates play a major role. The Mining Regu- key hurdles that exist to formalization of the lations of 2015 propose to reduce key taxes for gold market. Too often dialogues are held by gold (notably the permit fees for cooperatives Government, NGOs, donors and others with- and comptoirs as well as the annual surface rents) out the full and frank engagement of the pri- however the ad valorem tax for gold has increased vate sector including both formal and informal significantly from 0.3% on the value of the export operators. This discussion should include (but to 2% which is unlikely to stimulate increased legal will not be limited to): the cost and process of gold flows. accessing licenses; access to formal finance; Dodd-Frank applies to gold as well as to the taxation; the business operating environment 3Ts. However this application is much more chal- for import/export businesses connected to gold lenging in the gold sector. The international gold flows; local processing facilities/opportunities; market is structured entirely differently from cross-border and international trade issues; that of the 3Ts and the demands of gold buy- etc. This dialogue should not be framed as a ers are far more flexible than those of 3Ts buy- ‘conflict minerals’ or ‘illegal trade’ issue, rather ers. Therefore the market levers are much weaker as a business opportunity for economic pros- in gold. At present, there is no due diligence and perity. The dialogue should have a policy of mineral traceability system in place for gold in the inclusivity to bring all actors on board. Great Lakes Region and no imminent prospect of (c) Focus on formalization of ASM gold mining and one being widely available. Yet, entirely aside from trading: Licensing of cooperatives should be 26 Recommendations coupled with an awareness program about OBR and MEM should be developed with a ASM production and trade issues as part of a specific view to resolving some of the chal- larger program of formalization of ASM. This lenges that arise from OBR being the sole tax should focus on the benefits of legal mineral collector for the mining sector. This alignment trade to the country. plan should clearly specify how information (d) Improve access to finance for ASM gold min- will be shared between the services to ensure ers and traders: The Government of Burundi OBR has a full understanding of mining tax should seek donor assistance to set up ASM nomenclature, access to ASM operators, up assistance programs such as access to to date databases on licenses, etc. finance to enable ASM gold miners to have (b) Increase local awareness of EITI and iTSCi: An greater flexibility in their operations and trad- awareness raising campaign needs to be car- ing relationships (noting that, at present, ried out to increase understanding of both EITI many miners are ‘locked in’ to illegal min- and iTSCi both individually and collectively. eral circuits as these are managed by their (c) Use EITI and iTSCi as opportunities for devel- sponsors/financiers). opment: Both EITI and iTSCi are frequently (e) Set realistic objectives with regard to trace- considered by ASM operators to be tools for ability: Any investment in gold traceability increasing regulations and State revenues. As should be considered in light of the market such, these standards are thought of as con- realities and should be designed as a practi- straints rather than tools for the promotion of cal and viable sector management tool rather the industry. Instead of touting them solely as than as a mechanism to satisfy remote mar- tools of transparency and traceability, there ket demands. is a need to emphasise the ways in which the EITI and iTSCi standards can help to meet the basic needs of artisanal mining communities. 3.3  EITI and iTSCi Are Tools This will promote positive perceptions and to Improve Transparency of acceptance of both systems. Production and Revenues (d) Resolve issues around the communal tax: The payment of the communal tax should be Many of the challenges facing Burundi’s mineral tracked and a mechanism should be estab- sector relate to recording, sharing and reporting lished for transparency around the receipt data. Gaps exist in data, elements being reported and use of this tax. This can contribute signifi- are inconsistent, timings for recording and report- cantly to the sense of ASM-generated taxes ing are out of synch, and variables (such as price delivering social development in their locality. and grade) which are essential for accurate cal- (e) Share lessons learned: The Government of culations are unavailable. Both EITI and iTSCi can Burundi should showcase its progress in EITI assist in resolving many of these problems. reporting on its ASM sector through the use of iTSCi. This is groundbreaking work and wor- thy of international note. 3.3.1  Recommendations for EITI and iTSCi in Burundi (a) Address discrepancies in tax regimen: A pro- gram of alignment and cooperation between 3.3  EITI and iTSCi Are Tools to Improve Transparency of Production and Revenues  27 Annex 1 Methodology T Phase 1: Literature and Desk he research for this report was undertaken to gain an in-depth understanding of the socioeconomic factors surrounding trade Review in the ASM sector in Burundi, focusing particularly The initial phase was a literature review and stake- on the question of pricing, transfers, and revenue holder mapping of the sector. Prior to in-country collection. The research was originally designed research, national statistics and published reports as a rapid assessment to inform the Government were referenced to understand the context and of Burundi during the current discussions around the extent of previous research in the area. the adoption of new mining regulations, though Also, in order to first have an idea of the cur- delays in the research prevented this from occur- rent mineral trade and production in Burundi, ring. Nonetheless, the study is still important the study team reviewed iTSCi baseline studies given the new institutional strengthening project carried out in the mining sites within the iTSCi led by the World Bank in which the MEM is a key program in Burundi. The literature review results beneficiary. The study will inform further reforms were used to inform the research questions and envisaged under this Project to increase revenue interview tools for the field research. collection and efficient administration. Further- The study was also informed by data col- more, by tracing the flow of the mineral trade, and lected during two other recent studies of ASM transfers of payments, the EITI process in Burundi in Burundi, the ‘EITI Scoping Study for Burundi’, could be established. conducted between January and April 2014, and This study was built on the data regarding approved by the Government in June 2014 by production of 3Ts minerals collected through the the World Bank, and the ‘Study on Artisanal and implementation of the iTSCi program in Burundi. Small-Scale Mining in Burundi, 2009–2013’ con- Thus the research was mainly focused on 3Ts ducted by Professor Gilbert Midende from Janu- minerals as iTSCi is restricted to tin, tantalum ary to May 2014, also under the auspices of the and tungsten. Some discussion of the gold sector World Bank. The latter was a sub-set of the EITI is included in the report, however without iTSCi or Scoping Study. any similar program in place for gold, it was dif- ficult for the research team to obtain raw data for gold sites, production and trade. Phase 2: Elaboration of Research The research for the study was conducted in Tools complementary phases that combined qualita- tive and quantitative methods over a six-month The second phase was the creation of research period (July–December 2014). tools for this study which responded to the 29 complexity and sensitivity of the subject. The complexity is a result of the multiple relationships •  Information on payments made either formal or informal (including name of which can arise between actors along the supply payment, who makes the payment, who chain and the mix of formal trading with barter collects the payment, who receives the and credit relationships. The sensitivity arises payment, payment method, amount and as ASM activities are often carried out clandes- frequency of the payment, receipts deliv- tinely if the operators are not licensed, mineral ery, and if the payment is respected). trade may be carried on outside the formal trad- n Survey to collect information at the comptoir ing channels, information such as production and level: Since the objective of the study was to pricing can be commercially sensitive, and per- understand the mineral and revenue flow, it sonal information regarding income and trading was necessary to follow up the mineral supply relationships can be protected for fear of security chain and to collect similar information from risks. the comptoirs. At the comptoir level, similar The research employed four specific tools: information was collected and compared as for the mine level: n Summary table on Burundi’s fiscal provisions for ASM: In order to easily compare past, cur- •   Location of the comptoir; rent and future legislation under discussions, •   Information on the interviewee; an Excel table was set up. This table was also •   Information on the mineral trade (type of mineral traded by the comptoir, suppliers of use in calculating the amount of payments to the comptoir, price paid to the suppliers, that should be perceived by the Government potential agreement with the suppliers); of Burundi, compared to the actual level of payment. •   Information on payments made—both formal and informal—was collected n Survey to collect information at the mine level: (including name of payment, who makes During the first stage of data collection, the the payment, who collects the payment, study team used paper-based iTSCi baseline who receives the payment, payment study data collection forms in order to col- method, amount and frequency of the lect information on actors, mineral trade, and payment, receipts delivery, and if the pay- revenue collection. While the baseline studies ment is respected). include questions in relation to the collection n Survey of actors in the EITI process in Burundi. of revenues, after a first analysis round of the The objective was to gather updated informa- results obtained, it was decided to change tion on the current implementation process the research method and turn towards more of EITI in Burundi, challenges in this aspect specific questions on the topic, using an elec- as well as recommendations for the future of tronic data collection system. The research EITI for ASM in Burundi. questions at this level included: •   Location of the site; •   Information on the interviewee and their Phase 3: Field Data Collection role in the mineral supply chain; •   Information on the minerals produced After collecting information pertaining to the at the site including level of production, mineral tax regime, and setting up tools described price, buyers of minerals, and internal above, the research team did data collection in arrangement at the mine which could the field. The research team consisted of two Pact impact price and/or level of production of team members, two geologists from the Depart- the mine (e.g., equipment provided to the ment of Geology within the MEM, and a geolo- miners, food given to the miners, etc.) gist from the University of Burundi. The team 30  Annex 1 Methodology worked under the supervision of Professor Gilbert which were in the process of registration (thereaf- Midende, also from the University of Burundi. ter counted as formal for analysis purposes) (see Data collected from individual mines was Table 1). done through two baseline surveys carried out As of mid-2015, 82 3Ts sites (37 formal and in two different ways. In September 2014, the 45 informal) were identified by the MEM. There- field data collection team carried out iTSCi base- fore the study visited 72% of all 3Ts sites in line studies on the mines, both those already in Burundi (89% of the formal sites and 58% of infor- the system and those not yet incorporated. This mal sites).18 first round of data collection was followed up by a second round in December 2014, using electronic 18.  It should be noted that in the first six months of 2014, the balance had tipped to fewer formal sites (45%) compared to data collection and a questionnaire more specific informal sites (55%). These may be accounted for by a range of for the study. Photographs were also taken. factors including discovery of new resources, improved identifi- In total, 59 mines were visited, including cation of informal sites, or simply a time-lag in the processing 31 formal sites, 26 informal sites plus two sites time for licenses. Table 1:  Distribution of Sites Visited and Informants Interviewed Communes Sites Number of Province Visited Visited Mineral Type Respondents Cibitoke Buganda 4 Cassiterite & Tantalite  16 Bukinanyana 1 Tantalite Murwi 1 Tantalite Kayanza Kabarore 6 Cassiterite & Tantalite  22 Kirundo Busoni 6 Cassiterite & Tantalite & Wolframite  36 Bwambarangwe 3 Wolframite Gitobe 1 Wolframite Ntega 9 Cassiterite & Tantalite Vumbi 2 Wolframite Muyinga Butihinda 2 Wolframite  56 Gashoho 2 Wolframite Gasorwe 1 Wolframite Giteranyi 10 Wolframite Ngozi Busiga 5 Cassiterite & Tantalite  38 Kiremba 1 Cassiterite Marangara 4 Cassiterite & Tantalite Tangara 1 Wolframite Other — — —   4 TOTAL 59 172 Phase 3: Field Data Collection  31 In total, 172 respondents were included in all refused to officially identify themselves and to the second round. Most of the respondents were sign the interview records. miners, followed by team leaders and heads of cooperatives. Four to five people were interviewed per mine site. The tasks undertaken at the mine Calculations of Tax Revenues include: digging (75%), washing (10%), other tech- Estimates of tax revenues were made in the report nical tasks (6%) and mineral transporting (9%). using the following estimates and assumptions The study analysed the tasks where possible to based on the results of field research for this determine the division of labor at the mine. report, official statistics, iTSCi raw data, and other At the export level, four comptoirs were visited sources (these are referenced where relevant): and interviewed using the survey instrument/ questionnaire. n Estimate 36 cooperatives for the 3Ts (as per Interviews with actors and/or research- end of 2014 when there were 27 licensed and ers for EITI were also carried out by Pact during 9 in process of obtaining licenses); the research. Including individuals from differ- n Assume 1 site per cooperative; ent backgrounds (civil society, government, and n Assume 1 ha per site; companies). n Assume 38% (i.e., 10) of 27 cooperatives producing tantalite (relevant as there are differential rates for tantalite compared to Challenges Encountered cassiterite and wolframite for some taxes); Certain difficulties were encountered when using n Estimate 5 comptoirs for the 3Ts (as per end the various tools in the field. of 2014) of which, 3 comptoirs licensed for Although a number of cooperatives are cassiterite and 2 comptoirs licensed for cas- already licensed and several others are in the siterite, tantalite and wolframite; process of establishment, the scale of the n Estimate average annual production of all ASM sector in Burundi remains predominantly minerals to be 300 tonnes at mine level; unquantified. There is no registration of individ- n Estimate average annual export of all min- ual miners. Information relating to négociants, erals to be 270 tonnes (allowing for 10% loss transporters and customs authorities is difficult in cleaning raw material to export-ready to extract and often unreliable. This is due to a concentrate); number of factors including that respondents n Estimate average annual production of cas- operating without licenses are wary of becoming siterite as 22% of total (14% of known produc- ‘visible’ to the authorities when their operations tion and estimated half of mixed minerals), are outside the formal system, as well as protec- i.e., 66 tonnes of production and theoretically tion of information that could be commercially/ 60 tonnes at export however there were no competitively sensitive. The same applies to fig- official exports of cassiterite in 2014; ures relating to production and the remuneration n Estimate average annual production of tan- of diggers, as well as estimates of their spending talite as 38% of total, i.e., 114 tonnes of pro- as this is sensitive data. Disclosure of financial duction and approximately 102 tonnes at information has security implications therefore export; cross-checks and triangulation has been used n Estimate average annual production of wol- wherever possible. framite as 38% of total, i.e., 114 tonnes of Attempts to interview people from the public production and approximately 102 tonnes at services, including the police, agents of the Office export; Burundaise des Recettes (OBR), and communal n Estimate average value of cassiterite administrators, were largely unsuccessful. Almost exported to be US$5 per kg; 32  Annex 1 Methodology n Estimate average value of tantalite exported n Some taxes were not applied, notably those to be US$30 per kg; in relation to repatriation of foreign currency, n Estimate average value of wolframite customs duties on other gains and import exported to be US$5 per kg; duties on other goods used in the mining n Use exchange rate of 0.00065 FBU : 1 US$. sector. Calculation of All Taxes Due on 3Ts Production and Export 2014 Amount Tax Number Value Frequency Amount FBU US$ Notes Artisanal mining 27 2,000,000 0.5 27,000,000 17,550 Fixed fees paid by 27 cooperatives license fee for every 2 years, paid per site regardless of cooperatives mineral Surface rent for 10 10,000,000 1 100,000,000 65,000 Annual mining royalty paid by tantalite 10 cooperatives with tantalite licenses assumed to be 1 ha each Surface rent for 17 5,000,000 1 85,000,000 55,250 Annual mining royalty paid by cassiterite & 26 cooperatives with cassiterite and/ wolframite or wolframite licenses assumed to be 1 ha each Rehabilitation of 27 1,000,000 1 27,000,000 17,550 Annual contribution by all cooperatives sites per site regardless of mineral, assumed to be 1 ha each Communal tax for 114,000 1,000 1 114,000,000 74,100 Mine level production of 114,000 kg tantalite paid at 1,000 FBU per kg Communal tax 186,000 500 1 93,000,000 60,450 Mine level production of 186,000 kg for cassiterite & paid at 500 FBU per kg wolframite Permit fee for 5 50,000,000 1 250,000,000 162,500 Fixed fees paid by 5 comptoirs every comptoirs license year, regardless of mineral Rehabilitation of 5 2,000,000 1 10,000,000 6,500 Annual contribution by all comptoirs sites Ad valorem on 0 3% 1 0 0 No cassiterite exports (despite cassiterite production there were not cassiterite exports therefore no ad valorum tax) Ad valorem on 3,420,000 3% 1 0 102,600 3% on 114 tonnes with export value of tantalite US$30/kg Ad valorem on 570,000 3% 1 17,100 3% on 114 tonnes with export value of wolframite US$5/kg TOTALS 578,600 Phase 3: Field Data Collection  33 Calculation of All Taxes Due on Gold Production and Export 2014 Number of Value of Amount Tax Units Units Frequency Amount FBU US$ Notes Permit for 11 8,000,000 0.5 44,000,000 28,600 Fixed fees paid by cooperatives 11 cooperatives every 2 years, paid per gold site Surface rent for 11 5,000,000 1 55,000,000 35,750 Annual mining royalty paid cooperatives by 11 cooperatives with gold licenses assumed to be 1 ha each Rehabilitation of 11 500,000 1 5,500,000 3,575 Annual contribution by all sites cooperatives per site, assumed to be 1 ha each Communal tax 649,725 500 1 324,862,500 211,161 Mine level production of 649,725g paid at estimate 500 FBU per g Fixed fees for 3 16,000,000 1 48,000,000 31,200 Fixed fees paid by 6 comptoirs comptoirs every year Rehabilitation of 3 5,000,000 1 15,000,000 9,750 Annual contribution by all sites comptoirs Ad valorem 26,638,725 0.30% 1 79,916 VAT of .3% on 649.725 kg with export value of US$41,000/kg Export duties 26,638,725 0.20% 1 53,277 Export duties of 0.2% on 649.725 kg with export value of US$41,000/kg TOTALS 453,229 34  Annex 1 Methodology Annex 2 Mining Cooperatives and Comptoirs Licensed in 2014 3Ts Cooperatives Licensed in 2014 (from DGGM: Report 2014) N° Nom de la Coopérative Site Minerai N° D’agrément 1 CESAGE MINING Mpehe Cassitérite 15/2014 du 20/03/2014 2 DUKOREREHAMWE Rutanganika Cassitérite 25/2014 du 23/03/2014 3 Coop. Minière de Busoni Mpinga Cassitérite 30/2014 du 13/05/2014 4 TUBANE NEZA Murambi-Ruyaga Cassitérite 39/2014 du 02/06/2014 5 Coop. Minière de Cibitoke Murambi Cassitérite 51/2014 du 12/08/2014 6 DUTEZANYIMBERE Buvyukana Coltan 08/2014 du 03/03/2014 7 Société Burundi Minerals Supply Senyamisange Coltan 35/2014 du 26/05/2014 8 ISI YACU N’ITERAMBERE Mushanga-Rwako Coltan 36/2014 du 26/05/2014 9 UMUCO IWACU Giti Coltan 40/2014 du 05/06/2014 10 ISI YACU N’ITERAMBERE Ruhagarika-Muhetso Coltan 41/2014 du 10/06/2014 11 CODEMIBU Muhuhuri Coltan 44/2014 du 22/06/2014 12 Coop. Minière de Cibitoke Ruhagarika Coltan 47/2014 du 11/08/2014 13 CDP Kidunduri Coltan 53/2014 du 11/09/2014 14 AUMERCAT MINING Gitete Coltan 55/2014 du 02/10/2014 15 Coop. Minière E.R.M. Mugera Coltan 56/2014 du 02/10/2014 16 COGECOM Nyamarobe Coltan 58/2014 du 15/10/2014 17 COREMIBU Rwamirambo II Wolframite 18/2014 du 01/04/2014 18 SECOMIB Musaza Wolframite 22/2014 du 17/04/2014 19 SECOMIB Kuwinkona Wolframite 23/2014 du 17/04/2014 20 Data Mining Budahunga-Ngomo Wolframite 32/2014 du 08/05/2014 21 Data Mining Murama Wolframite 33/2014 du 19/05/2014 22 TWIYUBAKE GISOZI Gisozi Wolframite 34/2014 du 26/05/2014 23 DUKEREBUKE MW’ITERAMBERE Rwamirambo I Wolframite 38/2014 du 26/05/2014 24 HEMA Nyarundende Wolframite 48/2014 du 11/08/2014 25 Coop. Minière de Vumbi Kabuye-Shororo Wolframite 49/2014 du 11/08/2014 26 Coop. Minière de Gashoho Cumba Wolframite 50/2014 du 11/08/2014 27 Coop. Minière de Busoni Bonero Wolframite 59/2014 du 15/10/2014 36 Gold Cooperatives Licensed in 2014 (from DGGM: Report 2014) No Nom de la Coopérative Site Minerai N° d’agrément  1 ABAHUZA BIKORWA Ruhororo Or 04/2014 du 19/02/2014  2 TWIKENURE Bukurira 2 Or 05/2014 du 03/03/2014  3 KOZOZA KEZA Bukurira Or 06/2014 du 03/03/2014  4 DUSHIRE INGUVU HAMWE TURONKIBINTU Rugogo Kinga Or 07/2014 du 03/03/2014  5 DUKOREREHAMWE DUSOZE Butare Or 09/2014 du 03/03/2014  6 TWIYUNGUNGANYE de Kinyinya Munazi Or 11/2014 du 13/03/2014  7 Cop. Des Exploitations Minières du Moso Munyinya Or 21/2014 du 16/04/2014  8 Cop. KOMEZAKAZI Gakerekwa Or 27/2014 du 06/05/ 2014  9 Cop. MOTRACO Rutoke Or 29/2014 du 13/05/2014 10 Cop. Data Mining Nyaruyaga Or 31/2014 du 19/05/2014 11 C.T.E.E.A.O. Munaz-Gifunzo Or 37/2014 du 26/05/2014 Cooperatives in Process of Being Licensed 2014 (from DGGM: Report 2014) N° Nom de la Coopérative Site Province Substance  1 SECOMIB Kirenge Kayanza Cassitérite  2 Coopérative Minière de Rugazi Nyagatobo Bubanza Coltan  3 Coopérative Minière de Cibitoke Remera Cibitoke Coltan  4 Coopérative Minière de Ruyigi I Migege Ruyigi Or  5 Coopérative Minière de Ruyigi II Migege II Ruyigi Or  6 Data Mining Twaruyeri Buja-Rural Or  7 DUKORANE NEZA Bukurira IV Muyinga Or  8 DUSHIRINKOMEZI HAMWE Muhira Cibitoke Or  9 KOMEZA IBIKORWA DUTERIMBERE Ndera Muyinga Or 10 RABIYUJA Nyarunazi Ruyigi Or 11 TERIMBERE NIHEZA Gahararo Muyinga Or 12 TWISUGANYE Musito Kirundo Or 13 TWIYUNGE Gitenge Cibitoke Or 14 VAHASI DUKORE Gahararo Muyinga Or 15 COGECOM Burundi Nzewe Kayanza Wolframite 16 Coopérative Minière de Busoni Bucanka Kirundo Wolframite 17 Coopérative Minière de Vumbi I Gashara Kirundo Wolframite 18 Coopérative Minière de Vumbi II Buhorana Kirundo Wolframite 19 TUNYWANE KIBAZI Kibazi Kirundo Wolframite 20 YAGA TWUBAKE Kijumbura Muyinga Wolframite Annex 2 Mining Cooperatives and Comptoirs Licensed in 2014   37 Comptoirs Licensed for Purchase and Export of the 3Ts and Gold (2014) N° Name of the Coopérative Site Mineral License Number, Date 1 AUMERCAT Bujumbura Tantalite 10/2014 du 13/03/2014 2 BMS Bujumbura Tantalite 12/2014 du 13/03/2014 3 WMP Bujumbura Tantalite 42/2014 du 30/06/2014 4 SECOMIB Ngozi Tantalite, Cassiterite, Wolframite 45/2014 du 22/07/2014 5 ROSS INTERNATIONAL Bujumbura Tantalite, Cassiterite, Wolframite 52/2014 du 25/08/2014 6 BURUNDI GOLD EXPORT Bujumbura Gold 01/2014 du 23/01/2014 7 HIGH SPEED COMPANY Bujumbura Gold 13/2014 du 20/03/2014 8 AMEX Bujumbura Gold 26/2014 du 26/04/2014 38  Annex 2 Mining Cooperatives and Comptoirs Licensed in 2014 Annex 3 Sites Visited Statut Nbre Substance Province Commune Nom du Site Coopérative Type d’entité N° d’agrement du Sit Artisans Latitude Longitude Extraite Cibitoke Buganda Murambi Coop. Minière de CibitokeCoopérative 51/2014 du 12/08/2014 Formel 2°54’06,8’’ 29°08’15,3’’ Cassitérite Cibitoke Buganda Murambi-Ruyaga TUBANE NEZA Coopérative 39/2014 du 02/06/2014 Formel 2°53’36,5’’ 29°08’02,1’’ Cassitérite Cibitoke Buganda Ruhagarika Coop. Minière de CibitokeCoopérative 47/2014 du 11/08/2014 Formel 2°55’17,8’’ 29°09’22,1’’ Coltan Cibitoke Buganda Ruhagarika-Muhetso ISI YACU N’ITERAMBERE Coopérative 41/2014 du 10/06/2014 Formel 15 2°55’10,3’’ 29°09’22’’ Coltan Cibitoke Bukinanyana Muhuhuri CODEMIBU Coopérative 44/2014 du 22/06/2014 Formel 60 2°50’52,5’’ 29°22’10,5’’ Coltan Cibitoke Murwi Mushanga-Rwako ISI YACU N’ITERAMBERE Coopérative 36/2014 du 26/05/2014 Formel 15 2°53’32,0’’ 29°08’37,3’’ Coltan Kayanza Kabarore Kibuba TAMINCO Société minière Formel 72 2°47’34,0’’ 29°35’29,3’’ Cassitérite Kayanza Kabarore Ryamukona TAMINCO Société minière Formel 60 2°44’42,1’’ 29°35’40,5’’ Cassitérite Kayanza Kabarore Kidunduri CDP Coopérative 53/2014 du 11/09/2014 Formel 150 2°50’14,6’’ 29°31’56,6’’ Coltan Kayanza Kabarore Mugera Coop. Minière E.R.M. Coopérative 56/2014 du 02/10/2014 Formel 2°51’35,4’’ 29°32’04,9’’ Coltan Kayanza Kabarore Kivuvu TAMINCO Société minière Formel 119 2°49’21,6’’ 29°34’0,05’’ Coltan+Cassitérite Kayanza Kabarore Munege TAMINCO Société minière Formel 192 2°50’01,3’’ 29°33’05,0’’ Coltan+Cassitérite Kirundo Busoni Mpinga Coop. Minière de Busoni Coopérative 30/2014 du 13/05/2014 Formel 70 2°29’44,1’’ 30°13’14,4’’ Cassitérite Kirundo Busoni Murehe TAMINCO Société minière Formel 278 2°23’04,8’’ 30°13’56,1’’ Cassitérite Kirundo Busoni Gatete TAMINCO Société minière Formel 30 2°22’49,2’’ 30°15’04,3’’ Coltan Kirundo Busoni Gitete AUMERCAT MINING Coopérative 55/2014 du 02/10/2014 Formel 30 2°28’08,0’’ 30°20’38,9’’ Coltan Kirundo Busoni Nyarundende HEMA Coopérative 48/2014 du 11/08/2014 Formel 50 2°34’50,3’’ 30°12’59,3’’ Wolframite Kirundo Busoni Nyabisaka Groupe d’Individus Informel 2°32’04,3’’ 30°14’37,5’’ Wolframite Kirundo Bwambarangwe Budahunga-Ngomo Data Mining Coopérative 32/2014 du 08/05/2014 Formel 10 2°33’27,1’’ 30°19’4,2’’ Wolframite Kirundo Bwambarangwe Kibazi I Groupe d’Individus Informel 5 2°31’10,3’’ 30°24’03,0’’ Wolframite Kirundo Bwambarangwe Rupfuha Groupe d’Individus Informel 36 2°34’27,7’’ 30°19’28,1’’ Wolframite Kirundo Gitobe Cumba Coop. Minière de Gashoho Coopérative 50/2014 du 11/08/2014 Formel 100 2°38’59,8’’ 30°09’45,1’’ Wolframite Kirundo Ntega Rwarama TWITEZIMBERE Association Informel 6 2°34’19,8’’ 29°58’18,6’’ Cassitérite Kirundo Ntega Buniha Groupe d’Individus Informel 20 2°40’21,8’’ 29°58’58,4’’ Cassitérite Kirundo Ntega Buringa I Groupe d’Individus Informel 40 2°37’46,7’’ 29°58’14,3’’ Cassitérite Kirundo Ntega Buringa II Groupe d’Individus Informel 2°37’47,1’’ 29°58’23,9’’ Cassitérite Kirundo Ntega Buringa III Groupe d’Individus Informel 42 2°37’48,8’’ 29°58’29,0’’ Cassitérite Kirundo Ntega Rugese Groupe d’Individus Informel 100 2°35’22,5’’ 29°57’47,4’’ Cassitérite Kirundo Ntega Buvyukana DUTEZANYIMBERE Coopérative 08/2014 du 03/03/2014 Formel 50 2°38’26,1’’ 29°57’47,0’’ Coltan Kirundo Ntega Bugorora Groupe d’Individus Informel 2 2°40’06,0’’ 29°59’54,1’’ Coltan Kirundo Ntega Runyankezi Groupe d’Individus Informel 7 2°39’49,5’’ 29°58’16,6’’ Coltan Kirundo Vumbi Canika Groupe d’Individus Formel 7 2°37’33,5’’ 30°09’52,6’’ Wolframite Kirundo Vumbi Kabuye-Shororo Coop. Minière de Vumbi Coopérative 49/2014 du 11/08/2014 Formel 11 2°46’13,3’’ 30°06’28,0’’ Wolframite Muyinga Butihinda Buhorana Groupe d’Individus Informel 2°38’10,9’’ 30°21’23,8’’ Wolframite Muyinga Butihinda Rurembo II Groupe d’Individus Informel 2°42’10,9’’ 30°19’30,2’’ Wolframite Muyinga Gashoho Bonero DUFATANE MUNDA Coopérative 59/2014 du 15/10/2014 Formel 50 2°44’12,8’’ 30°14’02,7’’ Wolframite Muyinga Gashoho Murama Data Mining Coopérative 33/2014 du 19/05/2014 Formel 100 2°43’15,0’’ 30°12’13,2’’ Wolframite Muyinga Gasorwe Butirabura Groupe d’Individus Informel 15 2°51’07,8’’ 30°12’32,1’’ Wolframite Muyinga Giteranyi Gisozi TWIYUBAKE GISOZI Coopérative 34/2014 du 26/05/2014 Formel 30 2°30’48,6’’ 30°24’16,7’’ Wolframite Muyinga Giteranyi Kuwinkona SECOMIB Coopérative 23/2014 du 17/04/2014 Formel 200 2°26’02,8’’ 30°29’48,3’’ Wolframite Muyinga Giteranyi Rwamirambol DUKEREBUKE MW’ITERAMBER Coopérative 38/2014 du 26/05/2014 Formel 260 2°25’52,2’’ 30°29’54,3’’ Wolframite Muyinga Giteranyi Rwamiramboll COREMIBU Coopérative 18/2014 du 01/04/2014 Formel 65 2°25’28,1’’ 30°30’08,7’’ Wolframite Muyinga Giteranyi KagatiI Groupe d’Individus Informel 12 2°20’37,8’’ 30°27’28,5’’ Wolframite Muyinga Giteranyi KagatiII Groupe d’Individus Informel 10 2°20’17,7’’ 30°27’28,5’’ Wolframite Muyinga Giteranyi Kijumbura Groupe d’Individus Informel 30 2°20’13,5’’ 30°27’21,6’’ Wolframite Muyinga Giteranyi Rucikiri I Groupe d’Individus Informel 6 2°24’44,1’’ 30°30’29,2’’ Wolframite Muyinga Giteranyi KagatiIII Groupe d’Individus Informel 15 2°20’14,2’’ 30°27’29,2’’ Wolframite Muyinga Giteranyi Rucikiri II Groupe d’Individus Informel 80 2°25’22,7’’ 30°30’11,9’’ Wolframite Ngozi Busiga Myansi-Mihama TURIKUMWE Association Informel 7 2°49’46,7’’ 29°43’31,4’’ Cassitérite Ngozi Busiga Nyamahubwe I Groupe d’Individus En cours 100 2°50’25,9’’ 29°42’51,6’’ Cassitérite 40 Statut Nbre Substance Province Commune Nom du Site Coopérative Type d’entité N° d’agrement du Sit Artisans Latitude Longitude Extraite Ngozi Busiga Nyamahubwe II Groupe d’Individus En cours 31 2°49’50,5’’ 29°43’05,6’’ Cassitérite Ngozi Busiga SenyamisangeI Société Burundi Minerals Su Coopérative 35/2014 du 26/05/2014 Formel 100 2°49’26,8’’ 29°43’53,1’’ Coltan Ngozi Busiga SenyamisangeII Groupe d’Individus Informel 20 2°49’09,0’’ 29°43’56,2’’ Coltan Ngozi Kiremba Nyamarobe COGECOM Coopérative 589/2014 du 15/10/2014 Formel 27 2°46’41,8’’ 30°01’26,6’’ Cassitérite Ngozi Marangara Kimana Groupe d’Individus Informel 100 2°44’40,4’’ 30°01’08,6’’ Cassitérite Ngozi Marangara Muhona Groupe d’Individus Informel 15 2°43’57,0’’ 30°00’52,6’’ Coltan Ngozi Marangara Santa-Maria Groupe d’Individus Informel 10 2°44’25,1’’ 30°00’52,0’’ Coltan Ngozi Marangara Burenga-giti Groupe d’Individus Informel 7 2°44’43,1’’ 30°01’06,0’’ Coltan+Cassitérite Ngozi Tangara Musaza SECOMIB Coopérative 22/2014 du 17/04/2014 Formel 50 2°56’10,3’’ 30°01’26,3’’ Wolframite Muyinga Butihinda Bukurira KAZOZKEZA Coopérative 06/2014 du 03/03/2014 Formel 630 2°42’58,7’’ 30°19’23,7’’ Or Muyinga Butihinda Bukurira 2 TWIKENURE Coopérative 05/2014 du 03/03/2014 Formel 630 2°43’21,8’’ 30°18’46,7’’ Or Muyinga Butihinda Bukurira 4 Association Informel 120 2°43’02,8’’ Or Cibitoke Mabayi Ruhororo ABAHUZABIKORWA Coopérative 04/2014 du 19/02/2014 Formel 100 Or Annex 3 Sites Visited  41