Evaluating Due Diligence Programs for Conflict Minerals: A Matched Analysis of 3T Mines in Eastern DRC

Darin Christensen* (Editor), J. Sebastian Leiva-Molano, Erik Gobbers* (Editor), Antoine Heuty* (Editor), Timo Makori, Geoffrey Kimani

*Corresponding author for this work

Research output: Book/ReportReportProfessional

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The 2010 Dodd-Frank Act requires that US-listed companies sourcing so-called
“conflict minerals” from Africa’s Great Lakes region conduct due diligence. (The
EU now imposes similar requirements.) Due diligence programs (DDP), following
guidelines from the OECD, provide ongoing monitoring of mineral production and processing to ensure that suppliers respect human rights and do not contribute to conflict. A decade later, we still have limited evidence about whether DDP impacts economic and security conditions.
To help fill this gap, we evaluate the impacts of DDP on mining communities in
the eastern Democratic Republic of Congo (DRC). Combining statistical matching
with new data from over one hundred 3T (tin, tantalum, and tungsten) mines
and one thousand households, we report several findings:

1. DDP areas see less interference by the Armed Forces of the Democratic Republic of Congo (FARDC). Households in DDP areas report 27% less FARDC
presence and taxation relative to households in non-DDP areas.
2. DDP areas see a heightened presence of government regulators. Households
in DDP areas report over 58% more tax collection and service provision by
government regulators; they do not, however, report feeling more secure than
households in areas without DDP.
3. Mines in DDP areas do not have significantly lower rates of child labor. Some
child labor is reported at roughly one third of mines in DDP areas, a rate that
is not statistically distinguishable from mines in non-DDP areas.
4. DDP areas show hopeful, if statistically inconclusive, evidence of greater economic well-being than non-DDP areas.

How one regards these impacts depends on the benchmark for success. We
detect meaningful progress toward several goals in DDP areas; yet, we also find
that DDP does not eliminate all of the harms associated with 3T mining in the
eastern DRC. We uncover reasons to applaud these efforts, but also room for
improvement, particularly with respect to labor practices and miners’ livelihoods.

Our results rely on the analysis of original survey data collected from 104
mine sites and 1,054 households in nearby villages in South Kivu and Maniema at the end of 2019. We employ a matching technique that compares mining areas with and without DDP that have similar geographies, histories of conflict, and development trajectories. This statistical approach helps us isolate differences that can be attributed to DDP.
Original languageEnglish
Place of PublicationAntwerp
PublisherInternational Peace Information Service
Number of pages49
Publication statusPublished - Nov 2020
Externally publishedYes


  • Due Diligence Programmes, Conflict Minerals, Democratic Republic of Congo, Matched Statistical Analysis


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