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Case Study
ASM Management Plan for CMOC-TFM


In response to challenges related to unregulated artisanal and small-scale mining (ASM) in and around its Tenke Fungurume Mining (TFM) concession area in the Democratic Republic of Congo (DRC), CMOC Group Limited (CMOC) prioritised proactively managing and addressing these risks. TFM aimed to develop a response which aligned with market expectations and good practice requirements, and effectively tackled the various risk factors associated with unregulated ASM activities.


RCS’s teams conducted a comprehensive baseline study focusing on ASM risks in and around the TFM concession to identify, describe, and analyse the general conditions of ASM operations, key actors and the impact of these activities.

  • The baseline study laid the foundation for informed decision-making in the subsequent project phases.

Next, RCS’s teams developed TFM’s ASM policy, designed as a comprehensive framework articulating the company’s public commitment to the effective management of risks linked to unregulated ASM. The policy aligned with applicable national laws and regulations, OECD Guidance, and the Voluntary Principles on Security and Human Rights.

As a third step, RCS’s teams developed TFM’s ASM Management Plan providing formalised implementation procedures, contextualised risk mitigation measures and KPIs.

  • A child labour detection and a stakeholder engagement procedure were also developed to enhance the effectiveness of the ASM Management Plan.
  • Notably, the stakeholder engagement procedure was developed for the entire company, providing a unified approach to engaging with external stakeholders.

Finally, training sessions were conducted for managers within the company to introduce the newly developed documents and procedures, offering guidance on their implementation.


The project results have enabled the client to gain a deeper understanding of the dynamics of unregulated ASM in and around the TFM concession area, encompassing data insights into the key players involved, associated risks, and impacts across four prioritised categories.

  • This data has played a pivotal role in developing internal policies and procedures tailored to the specific needs of the company.

The developed documents allowed CMOC TFM to better navigate and mitigate ASM-related risks and serve as a foundation for collaboration with various internal units and external stakeholders.

In June 2024, CMOC TFM officially received The Copper Mark certification, recognising its responsible production practices. TFM has become the first mine in Africa to obtain this certification, underlining its commitment to high environmental, social and governance standards. Read more on CMOC TFM’s Press Release.

Maria Yassin-Jah
Head of Responsible Sourcing Advisory