Kamoto Copper Company (KCC)

Responsible Mineral Supply Chains Report

2021
Introduction
This report provides information on supply chain due diligence for Kamoto Copper Company (KCC). It is based on the
Responsible Minerals Assurance Process (RMAP) Public Due Diligence Report Writing Guidance, by the Responsible
Minerals Initiative (RMI) and focuses on cobalt and the scope of the OECD Due Diligence Guidance for Responsible
Supply Chains from Conflicted-Affected and High-Risk Areas, Third Edition (the ‘OECD Guidance’).

1. Company Information
KCC is one of the world’s largest copper and cobalt producers with mining and processing facility located in the
western end of the Katangan Copperbelt. KCC is situated west of Kolwezi, in the Lualaba province of the Democratic
Republic of Congo (DRC).

KCC is a joint venture, with 75% held by Katanga Mining Ltd (wholly owned by Glencore, one of the world’s largest
globally diversified natural resource companies) and 25% held by the state-owned Général des Carrières et des Mines
SA (Gécamines).

KCC extracts ore containing copper and cobalt from its open pit and underground operations and refines it to produce
copper cathodes and cobalt hydroxide within an integrated operation. KCC does not purchase any third party feed. KCC
only has one customer, Glencore International (GIAG), a Glencore trading company, who purchases 100% of KCC’s
production.

KCC’s RMI identification number is CID003261.

2. Responsible Minerals Assurance Process (RMAP) Assessment Summary

KCC is listed on the Conformant Cobalt Refiners list and has an annual assessment cycle. In February 2021, RCS Global
conducted KCC’s most recent RMAP against the Cobalt Refiner Due Diligence Standard 1.0. The Assessment Summary
Report is available here.

3. Supply Chain Policy and Management System

3.1 Group Supply Chain Policy
Glencore’s Code of Conduct sets out the key principles and performance expectations that all Glencore assets follow,
including KCC. Group policies relevant to responsible supply chain management include those on Human Rights, Anti-
corruption and Bribery, Anti-Money Laundering, Sanctions, and Whistleblowing. The Code of Conduct and many of the
policies were updated in 2021 as part of overarching policy review.

Glencore also has defined expectations for suppliers specified in the Supplier Standards. These standards cover all of
the risks identified in Annex II of the OECD Guidance. They apply to all of Glencore’s suppliers, are global in geographic
scope and are incorporated into supplier contracts. The Supplier Standards are reviewed and updated periodically.

More information on the Glencore sustainability framework and implementation of the Supplier Standards is included
in the annexe.

3.2 KCC approach

As KCC does not have any third party suppliers of cobalt, the risks within the scope of the OECD Guidance are within
KCC’s own operations. KCC manages these risks through its own policies and management systems which align with
Glencore’s Group policies and the Code of Conduct while reflecting its operational context. Following the update to
Glencore’s Code of Conduct in 2021, KCC revised its Code of Conduct (‘Code’) and publicly launched the revised version
at an event in Kinshasa in December 2021. KCC’s Code is the overarching reference on KCC’s commitment to uphold
responsible business practices. It covers the full scope of OECD Guidance risks including human rights, fraud, bribery,
sanctions, money laundering, as well as raising concerns and KCC’s commitment to the Extractive Industries
Transparency Initiative. Specific KCC policies underpinning its Code include those on anti-corruption and bribery, anti-

Page 2 of 7
money laundering, sanctions, whistleblowing and human rights. KCC also has standalone procedures for these
standards such as those on payment and assistance with public agents, conflicts of interest, security and human rights,
and artisanal and small-scale mining (ASM).

To additionally ensure the effective implementation of the Glencore compliance programme, KCC has a compliance
team whose role is to support employees in day-to-day business considerations, particularly those seeking advice on
ethical, lawful behaviour or policy implementation.

3.3 Training
All of our permanent and temporary employees, directors, officers and suppliers must comply with Glencore and KCC
compliance policies, procedures and guidelines. All employees must have an initial induction and annual refresher
compliance training. In addition, there is ongoing, specific training within departments with identified high risks. KCC
carries out a comprehensive compliance training programme on all the topics within both Glencore’s and its Code of
Conduct. This includes:
 Annual online training for all KCC employees, which includes modules on conflicts of interest, interaction with
public agents, sanctions, and anti-corruption.
 Face-to-face compliance training for all KCC executive committee members
 Tailored face-to-face training with employees from identified higher-risk departments (such as finance,
security, legal and tax, and community development programme), with ‘deep dives’ into the particular risks
they face.
 Reinforcing of messages on compliance issues during shift pre-start talks, through regular reminders via emails
and through visible signage throughout the site and on KCC’s intranet.

3.4 Internal Systems of Control – chain of custody

KCC maintains direct custody and control over all its source material. Ore is extracted from open pits and underground
operations and transported via trucks and conveyor belts to its concentrator (KTC) where the ore is crushed and
concentrated and then transferred to its Luilu metallurgical plant (or crude refiner). The Luilu plant processes the ore
through concentrate leach technology followed by solvent extraction and electrowinning for the copper production,
and by selective precipitation for cobalt hydroxide production.

KCC tracks the movement of its material at every step using sampling and measurement systems for mass and metal
content (weightometers, flowmeters, densitometers and sampling). The data inputted into a ‘metals accounting’
system produces an on-going metal/commodity balance for the operation. This accounting is subject to daily and
monthly reconciliation exercises and a third party annual verification.

Page 3 of 7
Before leaving KCC for export, each individual
cobalt bag is sealed and tagged with bar codes. KCC Blockchain
securely locks and covers the truck’s cargo with The use of blockchain technology for traceability is being
tarpaulins. A tracking system monitors the truck’s piloted by Glencore in the DRC through the Re|Source project.
journey to export and subsequent shipping port. The project aims to develop a solution to trace responsibly
Appropriate security escorts and checks along the produced cobalt from the mine to the electric car and is a
road ensure a secure chain of custody. collaboration between major mining companies, refiners,
battery manufacturers and leading electric vehicle companies.
The end-to-end collaboration between cobalt industry players
3.5 Grievance mechanism deploys various technologies, including blockchain and Zero-
Glencore’s approach to ‘Speaking Openly and Knowledge Proofs, to link digital flows with physical material
Raising Concerns’ is available to suppliers, flows on the ground.
customers and stakeholders. KCC also has a local
level complaints and grievance process which has
been designed to be legitimate, accessible, predictable, equitable, transparent, rights-compatible, a source of
continuous learning, and based on engagement and dialogue. The process is available to employees and contractors
and core to the approach is zero tolerance for retaliation against those raising concerns and the ability to raise
concerns anonymously. KCC regularly reports the concerns received through this mechanism to senior operational and
departmental management as well as to the Board Health Safety Environment and Communities (HSEC) Committee on
a quarterly basis.

Employees and contractors are encouraged to first report their concerns to their relevant supervisors, or the KCC
nominated Whistleblowing Contact who is a member of the senior management team. When concerns are not
resolved at this level they are escalated to the corporate programme managed in Switzerland. Concerns can also be
made directly to the corporate programme (via web platform, telephone or email). See the Glencore website for
further information.

3.6 Record Keeping System

KCC requires that all records relating to its due diligence programme are maintained for a minimum of five years. Many
documents must be maintained for 10 years in accordance with DRC law.

4. Risk Identification
The Glencore Supplier Standards apply to all suppliers, this includes any individual, organisation or company that
provides, sells or leases materials, products or services directly to Glencore companies, including contractors. The
programme to implement supply chain due diligence on mineral suppliers across the Glencore group is described in
the annexe. At KCC there are no third-party sources of minerals, and therefore no mineral suppliers upon which to
apply this approach. Risks connected to mineral origin are entirely related to KCC’s own operations and managed
directly through own management systems.

Risk identification at KCC stems from the Glencore policies and management systems (described in 3.1 above). The
scope of risks included in these documents was reviewed as part of the recent Group policy review. This was informed
by a Group materiality assessment and review of external commitments through membership organisations and
support for external organisation such as:
 UN Global Compact
 International Labour Organization Declaration on Fundamental Principles and Rights at Work
 UN Guiding Principles on Business and Human Rights.
 ICMM’s Performance Expectations

KCC actively engages on issues relevant to this report and an update on 2021 activities is summarised below. Please
also see the risk identification section from KCC’s 2020 Due Diligence Report which continue to apply: security and
human rights, ensuring no child labour, and anti-corruption.

In 2022, KCC will continue its commitment to risk management in these areas. A key part of that is the implementation
of new Glencore standards around human rights and security management, aligned with the performance
Page 4 of 7
expectations of the International Council on Mining and Metals (ICMM) and other international best practices. This
work will include performing a baseline review against the standards and subsequent action plan to meet the
requirements within a defined timeframe.

4.1 Artisanal and small-scale mining (ASM)

In its 2020 Due Diligence report KCC reported on several measures specifically aimed at managing the risk of ASM
intrusions on active mining areas including perimeter controls. During 2021, KCC built 38 km of T-wall construction
around its active operations which has resulted in a significant reduction in the number of ASM intrusions. KCC
continues to monitor and manage intrusion incidents in line with KCC’s security procedures, which align with the
Voluntary Principles on Security and Human Rights.

KCC’s ASM management plan includes ASM community engagement strategies to address some of the local context
factors that cause ASM related issues. A key part of this is KCC’s projects on children’s education and alternative
livelihoods. Some milestones include:
 Since 2016, over 55,200 children participated in KCC’s summer camps programme. The camps aim to keep
children out of mining during school holidays by providing them with meals and activities. During the camps,
KCC highlights the dangers of mining.
 Provision of equipment for 18 schools, construction of 10 schools and renovation of 14 schools.
 Building of a boys’ home for orphans and abandoned children to deter them from ASM activities.
 Provision of support (equipment and finance) for alternative livelihoods to various organisations benefiting
over 2,000 individuals with more than 12,000 dependents. For example:
o The creation of cooperatives to provide goods and services to mining companies in Kolwezi including
Glencore and its contractors
o Training and development in skills such as carpentry, mechanics, building and welding
o Provision of equipment, seeds, fertilisers and training to farming cooperatives.
 Temporary projects targeting ex ASM miners, including drain clearance in Kapata in 2021 that employed over
150 people.

Glencore also continues to support international initiatives and forums aimed at developing a responsible ASM cobalt
sector in the DRC. It is a founding member and an active participant in the Fair Cobalt Alliance (FCA) which brings
together supply chain actors and stakeholders to drive the development of fair cobalt by supporting the
professionalisation of ASM site management: making mines safer, minimising environmental impact and creating
dignified working conditions for men and women working at the mines. For more information, see the FCA website

4.2 Payments to governments

As reported in last year’s Due Diligence Report, KCC pays all relevant and applicable taxes, royalties and levies required
by local and national regulation in the DRC. The payments that KCC makes to the DRC government include local,
national, sales and employment taxes, government royalties and licence and permitting fees. KCC is a supporter of the
Extractive Industries Transparency Initiative (EITI) and its principles of transparency and accountability and participates
in in-country forums supporting the EITI. Glencore’s annual payments to governments report includes the information
on KCC required by the EU Accounting Directive, and details payments by country, project and recipient. In addition,
reflecting external stakeholder interest, this report includes additional information on KCC’s specific tax payments.

Page 5 of 7
Annex 1
Overview of Glencore Sustainability Framework

Glencore’s Board sets Group policies that are central to the strategic health, safety, environment, community and
human rights (HSEC-HR) programmes. Oversight and ultimate responsibility for the Group sustainability strategy and
framework as well as its implementation rests with the senior management team.

In 2019, we initiated a cross-functional project to develop and implement a more streamlined and consistent approach
to our Group policy architecture and the underlying policies, standards, procedures and guidelines. The project
considered the commitments we are required to meet through our membership and support for external organisations
such as the UN Global Compact, International Labour Organization Declaration on Fundamental Principles and Rights
at Work, and the UN Guiding Principles on Business and Human Rights. It also took into account the ICMM’s
Performance Expectations

See the Glencore 2020 Sustainability Report for further information.

Page 6 of 7
Annex 2
Glencore Supply Chain Due Diligence Programme

The Supplier Standards form the base of the Glencore risk-based supply chain due diligence programme. Key
characteristics of the programme are described below:
 All suppliers are required to adhere to the Glencore Supplier Standards, with contractual language to this
effect included in standard terms and conditions.
 Glencore has a dedicated Group Supply Chain Due Diligence team who is responsible for identifying, assessing
and managing supplier risks. We use a risk-based approach requiring red-flagged suppliers to complete a
supply chain due diligence questionnaire. The team reviews this information against Glencore’s Conflict
Affected and High Risk Areas (CAHRAs) list, and carries out open source desktop research for consistency and
plausibility. The questionnaire includes information on the origin of material, human rights practices (including
risks from OECD Guidance Annexe II) and other HSEC risks. Our suppliers are also subject to ‘Know Your
Counterparty’(KYC) questionnaires.
 A Thomson Reuters Accelus Screening (supported by additional open source searches) is also independently
undertaken by Glencore’s Regional Compliance Officer, to screen suppliers against sanctions, law
enforcements, regulatory enforcements and politically exposed person (PEP) watch lists for compliance with
Anti-Money Laundering, Know Your Counterparty, Counter Terrorist Financing and PEP regulations.
 Glencore’s Supply Chain Due Diligence Guideline uses the following resources to determine CAHRAs with input
from independent third parties:
o Heidelberg Institute (Conflict Barometer) – an annual report covering political conflicts worldwide.
o The Fund for Peace (Fragile State Index) – an annual assessment of 178 countries based on a
measurement of the social, economic and political pressures that each country faces.
o Institute for Economics and Peace (Global Peace Index) – an annual measure of national peacefulness,
ranking 163 countries according to their level of peace.
o WGI – Worldwide Governance Indicators as maintained by the World Bank Group – reports aggregate
and individual governance indicators for over 200 countries and territories over 1996-2019 for:
 Political stability and absence of violence
 Control of corruption
 Rule of law
 Government effectiveness
 Voice and accountability
o Freedom House (Freedom in the World Index) – assesses the condition of political rights and civil
liberties around the world. For each country and territory, Freedom in the World analyses the electoral
process, political pluralism and participation, the functioning of the government, freedom of
expression and of belief, associational and organizational rights, the rule of law, and personal
autonomy and individual rights.
o Cato Institute/Fraser Institute/Friedrich Naumann Foundation The Human Freedom Index (HFI)
presents a broad measure of human freedom, understood as the absence of coercive constraint and
uses 76 distinct indicators of personal and economic freedom in its assessment.
o Walk Free Foundation (global Slavery Index) – Provides a country-by-country ranking of the number of
people in modern slavery, as well as an analysis of the actions governments are taking to respond, and
the factors that make people vulnerable.
o Global Rights Index (ITUC) – Labour rights specific – depicts the world’s worst countries for workers by
ranking them according to the degree of respect for workers’ rights.
 Any concern identified through the Questionnaire or the screening is reviewed by the Supply Chain Due
Diligence team and escalated for review to a senior management as needed.
 Glencore may continue to contract with at risk suppliers subject to mutually agreed corrective action plans and
appropriate timeframes being in place. Corrective actions may include more stringent contract clauses, more
frequent review of supplier systems, development of respective policies and procedures and onsite audits.
Where zero tolerance risks are identified through our due diligence process, we will disengage with a supplier
until such risks are satisfactorily addressed and following a ‘cooling off’ period. At all times Glencore reserves
the right to suspend, discontinue or terminate relationships with suppliers where we determine that a supplier
poses zero tolerance risk.

Page 7 of 7