Mica Mining: Formal and Informal Sources

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Experts estimate that approximately 70% of the mica production in India is the result of illegal mining in forests and abandoned mines. The majority of these activities take place in rural districts in the states of Jharkhand and Bihar and are driven by poverty among families. Every family member is needed in order to survive.

Not surprisingly, child labour is often observed at illegal mines or mica dumps in the neighbouring forests. Children have been found engaged in mica, sorting, processing and carrying mica from mines to villages.

Through a dense network of local and regional traders the illegal mica ends up at exporters and gets mixed up in the formal supply chain. From that point onwards, the required traceability and transparency gets really difficult.

From a broader perspective, the issue of illegal mining and child labour is neither limited to mica mining nor to India. In extremely poor but resources rich regions all around the world – whether it is in Asia, Africa or South-America – it has proven to be very difficult for authorities and sustainable companies to fully ban child labour. Without proper education, healthcare and sufficient jobs, families still do whatever it takes to make a living.

in India, law prohibits illegal mining. in addition, the country’s strong child labour laws prohibit anyone under 14 working in mining. however, enforcement of all regulations proves to be very difficult in these poor, volatile districts with a history of brutal violence from rebels.

Sudarhan’s Action Plan Against Child Labour

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To minimize risks in our supply chain and to fight child labour in general, Sudarshan has developed a 5-step action plan against child labour.

1. Clear vendor requirements

Sudarshan’s mica vendors contractually must meet the following requirements.

• They must have a recruitment policy to enforce a minimum employee age of 18 year at mines and processing units.
• Their employees should be informed and trained to ensure full understanding of the child labour policy and adherence to all preventive measures.
• Mines and processing units must be gated and adequately cordoned off. During working hours a security guard must be present at the main entrance of the worksite.
• They must provide a crèche facility for young children who accompany their parents at the worksite.
• They must assign a compliance officer to ensure that the agreed child labour policies are implemented.
• An independent third party will audit the vendor’s operations regularly on adherence to all guidelines.

In case a vendor is unable to comply with our requirements, Sudarshan identifies the gaps and executes a change program to ensure this vendor implements the necessary improvements. However, if we then encounter non-compliance or inadequate control, we immediately terminate the vendor contract.

2. Tracking Mica

Sudarshan is implementing a fully transparent tracking system to ensure that all lots of mica that arrive at our production facilities are from the designated controlled suppliers. This system ensures full control over the mica supply chain.

In compliance with government regulations, Sudarshan’s mica vendors must adhere to the following procedures:

• Vendor should daily record all mined mica that is shipped to processing units.
• Identically, formal records should be kept from all mica entering and leaving a processing unit.
• Sudarshan monitors and crosschecks these records on a monthly basis.

3. Independent Audits

Sudarshan has engaged an internationally accredited auditing firm to verify and document that no child is employed in our entire mica supply chain. In addition, we work closely together with NGO Association for Stimulating Know-how (ASK) to further strengthen our efforts to keep our mica supply chain free from child labour.

More precisely, the following aspects and procedures are monitored and audited multiple times a year, un-announced and at irregular intervals:

• Daily logs of mined and shipped mica;
• Employment records;
• Age verification records;
• Working conditions.

4. Local and International Co-operation

Sudarshan is fully committed to combat child labour. We welcome an international joint approach over fragmented activities of individual companies. Therefor we participate actively in discussions with organizations across the globe.

Acknowledging the complex Indian mica supply chain and the need for more collaborative action across it, a Responsible Sourcing of Mica summit was organized in New Delhi on February 2016 by the National Resources Stewardship Circle (NRSC), its partners and NGO Bachpan Bachao Andolan (BBA). Stakeholders from mica mining communities, NGOs, suppliers, government representatives and final buyers came together to reiterate their commitment to India by developing a mica sourcing strategy relevant to local needs.

The group, now called the ‘Responsible Mica Initiative’ reached an agreement to focus on three key aspects:

• Implement fair and sustainable mica collection, processing and sourcing practices and improve traceability along the Indian mica supply chain
• Empower local communities to ensure long lasting change
• Work together with the Indian government and local authorities

Further details can be found at www.responsible-mica-initiative.com

5. Social investment

A quick solution is rather difficult if not impossible as widespread poverty in the state of Jharkand and Bihar is driving child labour. Given the complexity of the socio-economic context of these regions, an effective approach would need to involve government and industry as well as civil society.

We believe that a long term, sustainable solution calls for a collective social investment from all these stakeholders, focusing on community-based interventions, economic development and (collective) interventions in the supply chain. Again, Sudarshan is committed to play an active role in discussions about the way to go forward.