• Bisunzu Mining Company

Anti-child labour policy



This policy applies to the Bisunzu Mining Company (“SMB”) and its subsidiaries. SMB communicates this policy to its suppliers.


DR Congo and international organizations agree that child labor in the mining sector, including in artisanal operations, is a significant problem. The Bisunzu Mining Company (SMB Sarl) recognizes that child labor is also found in the production of tantalum, tin and tungsten in the Democratic  Republic of Congo (DRC), where SMB operates. Thus, SMB is committed to eliminating child labor cases in its operations and supply chains.


Ministerial order N ° 12 / CAB.MIN / TPSI / 045/08 of August 8th 2008 sets the working conditions for children. SMB adheres particularly to articles X and XIII of this order concerning the working conditions of people between the ages of 16 to 18 years old and particularly applies to the carrying of loads at a site, which are set at 15kg for boys and 10kg for girls.

SMB recognizes that the Ministerial Order number 12 / CAB.MIN / TPSI / 045/08 of August 8th 2008 stipulates that no child under 16 years of age may exercise any form of job.

SMB refrains from employing children in work that exceeds their strength, exposes them to high risks or that, by its nature or by the conditions in which it is performed, is likely to injure them ethically.

SMB undertakes, in accordance with Article XIII of the aforementioned Ministerial Decree, not to employ children under the age of 18 to:

  • Work that takes place underground, under water or in confined spaces
  • All work for driving engines, vehicles and mechanical machinery
  • Work that takes place in particularly difficult conditions; for example for long hours, or at night, or for which the child is unjustifiably detained on the premises of the employer.
  • Generally, any work prohibited because of its dangerous and unhealthy nature by the labor inspector


In accordance with ILO Conventions 138 (Concerning the Minimum Age for Admission to Employment of 1973) and 182 (Concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labor) 1999), the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition), the “OECD Practical Actions for Companies to Identify and Address;” Worst Forms of Child Labor in Mineral Supply Chains, ” Law No. 015/2002 of 16 October 2002 on the Labor Code of the DRC and its Law No. 16/010 of 15 July 2016 amending and supplementing Law No. 015- 2002 on the Labor Code and the Ministerial Order N ° 12 / CAB.MIN / TPSI / 045/08 of 08 August 2008 setting the working conditions of children: SMB Sarl confirms its long-term commitment to not tolerate and to work on eliminating child labor in its operations and its supply chains.

In line with our responsibility for due diligence on the supply chain, SMB Sarl is vigilant and estimates the severity of the risk of child labor, as recommended by the OECD.

Consider the work between SMB Sarl and other mining partners and the National and International Civil Society (Children Voice, ASSODIP, ETN and Pact / iTSCI) since 2016 on child labor on its mineral supply chain,


  • SMB Sarl is working with the government and other organizations to end child labor
  • SMB Sarl educates its staff and partners on child labor laws and explains how to report child labor cases if they witness or suspect it
  • SMB Sarl keeps and validates all age verification documentation for our employees as a result of their employment. If we discover that we have hired a minor under the age of 18, we check the applicable laws and adjust the hours and nature of work accordingly
  • SMB Sarl communicates its child labor policy to other organizations to which it is connected and ensures that its contracts contain appropriate clauses
  • SMB Sarl conducts due diligence on its Leading Suppliers in accordance with the OECD Guide, with a focus on child labor risks
  • SMB requests and monitors plans to eliminate child labor in cases where providers have discovered child labor instances
  • SMB Sarl consults experts on topics such as child labor
  • SMB Sarl regularly conducts workshops on the phenomenon of work, either alone or in conjunction with other actors in evaluation runs. Reports with recommendations are drafted for this purpose. These recommendations constitute updates to this policy. 

Updated: February 2019