‘No excuse for poverty pay’: NGOs call out mining companies during DRC Mining Week 2025

New research reveals ongoing labour abuses in DRC mines as demand for critical minerals surges with the green energy transition

Pour la version francais, cliquez ici. 

As hundreds of mining executives and government officials gather this week in Lubumbashi, Democratic Republic of Congo, for DRC Mining Week, new field research reveals that mine workers in the country’s industrial copper and cobalt operations remain trapped in poverty and face systematic labour rights abuses – despite growing global demand for critical minerals to power the green energy transition.

The new research by UK corporate watchdog RAID and Kolwezi-based Centre d’Aide Juridico-Judiciaire (CAJJ) is based on interviews with over 30 workers across six major mining operations, and follows on from in-depth research conducted in 2021 which exposed widespread exploitation of Congolese workers.

The updated research reveals that widespread labour rights abuses continue, particularly for subcontracted workers who make up the majority of the labour force, including:

• Wages well below the Kolwezi living wage, leaving workers unable to afford food or education for their children;
• Unsafe conditions and inadequate healthcare, with some workers reporting exposure to toxic substances and being denied treatment after accidents;
• Gruelling shifts and excessive hours, with some workers on back-to-back shifts for 30 days straight;
• Union suppression and discrimination, including sexual misconduct, racial abuse, and retaliation against workers who try to organise.

The mining operations included in the study are Glencore’s Kamoto Copper Company (KCC), Eurasian Resources Group’s Metalkol RTR, China Molybdenum’s Tenke Fungurume Mining (TFM), China Nonferrous Metal Mining Company’s Somidez mine, Zijin Mining Group’s COMMUS mine and Sicomines, the joint venture between Gécamines and a consortium of Chinese companies and investors.

One worker involved in ore processing at a large-scale mine said he and others are routinely exposed to toxic substances. “Every week I cough up blood,” he said. “I’ve been told it’s normal.” Another worker said: “They force us to do dangerous jobs, and if you refuse, you’re punished. If there are accidents at work, they put a bit of pressure on us [not to report it].”

Many subcontracted workers spoke of their despair, trapped in exploitative conditions with no other job options. “Here, we say if there’s no tree to hold onto, you grab the snake,” one worker said.

“Global demand for Congo’s minerals is soaring, and so are corporate profits,” said RAID’s Executive Director, Anneke Van Woudenberg. “There is no excuse for Congolese mine workers to be living in poverty or coughing up blood in unsafe mines. Paying a living wage and upholding basic rights is not charity – it’s a test of whether the transition to green energy will be just and fair.”

To help set a realistic benchmark for fair pay in the industrial mining sector, RAID and CAJJ today released their updated living wage calculation for Kolwezi, marking the fourth year in a row the groups have published this figure. For 2025, the monthly living wage for a decent standard of living in Kolwezi has been set at $520, reflecting an increase from last year’s amount.

The calculation is based on a ‘Minimum Expenditure Basket’ approach, which estimates the monthly cost of essential goods and services for a typical household of two adults and four children in Kolwezi, using locally collected market data.

The Kolwezi living wage

Many industrial mining companies point to their compliance with Congolese law – which requires employers pay at least the national minimum wage – but that wage remains far below what is needed to meet basic living costs.

In early 2025, the government doubled the national minimum wage for the first time since 2018, raising the daily rate to 14,500 Congolese Francs (around $5 USD per day), or roughly $130 USD per month for full-time work. While this was a long-overdue adjustment, even President Félix Tshisekedi acknowledged that it still falls short of what workers need to support themselves and their families.

RAID and CAJJ stressed that this legal floor should not be used by multinational mining companies as a benchmark for fair pay. The NGOs noted with concern that not a single industrial mine has yet committed to paying the Kolwezi living wage to all their workers, whether directly employed or hired via subcontractors, leaving the majority of mine workers trapped in a system that keeps them well below the poverty line.

“It’s abundantly clear that Congo’s minimum wage is a poverty wage,” said Josué Kashal, from CAJJ. “The failure by mining companies to commit to paying a living wage as a bare minimum raises big questions about the mining industry’s priorities and its commitment to basic human dignity of Congolese workers.”

The updated research and new Kolwezi living wage calculation comes amid heightened international scrutiny of workers’ rights in DRC. In 2024, the US government added industrial cobalt from the DRC to its list of goods linked to forced labour – a designation that affects global supply chains and underscores the urgent need for reform.

As the world shifts away from carbon-intensive energy, the drive for critical minerals such as copper and cobalt for electric vehicles, AI data centres and other components should not come at the expense of thousands of Congolese workers, the NGOs said.

For more on RAID’s research in the DRC click here.

Statues depicting mine workers in the centre of Kolwezi, DRC ©2025 RAID

Briefing Paper: Workers’ Rights Under Scrutiny

An Update on Labour Conditions in the DRC’s Industrial Mines 

In January and February 2025, RAID and CAJJ conducted a follow-up investigation into working conditions at some of DR Congo’s largest industrial copper and cobalt mines. This new research builds on our 2021 Road to Ruin report, which exposed widespread labour abuses, hazardous work environments, and stark disparities between directly employed and subcontracted workers.

Four years on, our findings show that labour rights violations remain deeply entrenched. While some directly employed workers have seen modest improvements, such as collective agreements which have increased wages and conditions, subcontracted workers continue to endure exploitative conditions. These include unsafe workplaces, exploitative wages, excessive working hours, inadequate or non-existent healthcare, suppression of union activity, discrimination and even physical mistreatment.

Despite three years of reporting from RAID and CAJJ on the calculation of a living wage in Kolwezi – the bare minimum required for workers to lead a dignified life – not a single industrial mine has committed to paying a living wage to all workers, whether directly employed or subcontracted. The fact that a living wage is still not the baseline for remuneration raises serious concerns about the industry’s priorities and its commitment to basic human dignity for its workers. Workers earning below the living wage – calculated at $520 per month for 2025 – means thousands of cobalt and copper workers continue to live below the poverty line.

Many of these labour rights abuses we have documented contravene both Congolese labour law and international labour standards – standards that mining companies claim to uphold. Yet across the sector, enforcement to uphold labour law is weak and accountability remains scarce.

This briefing outlines the most pressing violations.

Research methodology

To update the 2021 research findings on labour rights abuses and assess any changes since then, RAID and CAJJ conducted new field research in Kolwezi and Fungurume between January and February 2025. The team interviewed over 30 workers across six industrial cobalt and copper mining operations owned or operated by multinational mining companies. Together these mining operations produced over half of the global supply of cobalt in 2023. They include (i) Glencore’s Kamoto Copper Company (KCC), (ii) Eurasian Resources Group’s Metalkol RTR, (iii) China Molybdenum’s Tenke Fungurume Mining (TFM), (iv) Zijin Mining Group’s COMMUS mine, (v) China Nonferrous Metal Mining Company (CNMC)’s Société minière de Deziwa (Somidez), and (vi) Sino-congolaise des mines (Sicomines) a joint venture between Gécamines and a consortium of Chinese companies and investors.

While experiences varied and not all abuses were reported at every site, the research revealed a pattern of persistent labour rights violations across the sector, especially for subcontracted workers. The team also met labour inspectors, as well as judges of the judiciary and labour courts, union leaders, lawyers and medical staff.

A two-tier employment system

At the heart of many labour rights abuses in the DRC’s industrial mining sector lies the widespread use of subcontracted workers – an outsourcing model whereby workers are not hired directly by the mines, but instead are employed indirectly via subcontracting firms. Mine workers, truck drivers, cleaners, catering staff, construction workers and security personnel, among others, are frequently hired through labour agencies or subcontractors rather than being employed directly.

The result is a two-tier employment system with many direct and indirect hires typically doing the same job, but those employed through a subcontractor are subjected to lower pay, minimal or no benefits, and precarious job security.

In 2024, the Lualaba provincial government’s employment office reported that 424,544 people were working in industrial mining operations in the province, including both direct and indirect hires. Research by RAID and CAJJ in 2021 found that the majority of workers – at least 57%, and up to nearly 70% – at five major mines were hired through subcontractors. Experts consulted by RAID and CAJJ confirm that this heavy reliance on subcontracted labour across the industrial mining sector has persisted.

Many workers reported being employed at the same mine for years, rotated through different subcontractors, without ever receiving a full-time direct employment contract. Not only did this leave workers with more precarious work contracts and significantly lower wages, it also reduced entitlements such as educational support payments for children’s schooling, healthcare benefits and assistance for the costs of funerals of relatives. This outsourcing model leaves the majority of Congolese mine workers with significantly lower pay, few or no benefits, and little job security.

One worker reflected a common sentiment: “The difference in treatment between us and those directly hired… is night and day.”

As we found in 2021, subcontracted workers continued to endure excessive hours, unsafe conditions, and degrading treatment – including discrimination and racist abuse – and lack of access to basic healthcare. Many of the subcontracted workers we interviewed in 2025 also continued to report they received no payslips, or slips were not detailed, and that they had no employment contracts or were refused copies of their contracts. Even applying for a job has a price: several interviewees denounced that human resources personnel ask for money during the hiring process.

While subcontracting offers mining companies flexibility for short-term or seasonal work, in practice it appears to have become a long-term hiring model for Congo’s industrial mines. This model does not appear to be accidental. Previous research has shown that companies use subcontracting to reduce labour costs and limit their legal liability. The subcontracting system entrenches insecurity and inequality – shielding multinational companies from responsibility for the workforce that underpins their operations.

Failure to pay a Kolwezi living wage

Despite the mounting scrutiny on labour abuses, mining companies have failed to act on a basic responsibility: ensuring a living wage and decent working conditions for all workers, including those hired through subcontractors. This failure extends beyond Congo’s mine sites – companies across the supply chain that use Congo’s cobalt and copper should also step up and take action.

Many industrial mining companies have pointed to their compliance with Congolese law – which requires employers pay at least the national minimum wage – as sufficient, despite well-documented concerns that this is far below the bare minimum needed for a decent standard of living. In early 2025, the government doubled the rate, officially known as the Guaranteed Interprofessional Minimum Wage (SMIG), for the first time since 2018. It increased from 7,075 (approximately $2.5 USD) to 14,500 Congolese Francs ($5 USD) for a daily rate, equivalent to around 377,000 CDF per month or $150 USD for a full-time worker (based on a 30-day working month and exchange rates in June 2025). While the increase marks a step forward, even President Tshisekedi acknowledged in a speech to his Council of Ministers in April 2025 that it remains far below what is needed to meet basic living costs. In practice, it leaves most workers unable to support themselves or their families.

Subcontractors and daily labourers face the harshest conditions, often receiving the lowest pay and little or no benefits. Local activists reported that many subcontracted workers earn about $120 to $150 per month. In interviews with RAID and CAJJ, one worker reported working as a daily labourer for 7 months earning only $57 per month. His earnings were so low that he was unable to make ends meet and could not send any of his 8 children to school. Another worker, with a basic salary of $235 per month – rising to around $400 with overtime and benefits – explained that it was still not enough to cover essential expenses such as food, rent, and school fees. He had to make the difficult choice to send only two of his children to school. The others had to stay home because he couldn’t afford it.

While the government may need to keep the wage floor low to manage public sector salaries, the legal minimum wage should not be mistaken as a benchmark for fair pay. In a context of chronic job scarcity, paying the minimum wage, while knowing it entrenches poverty, has consequences. It perpetuates hardship and strips workers of economic agency. The uncomfortable truth is that even the new minimum wage falls far short of a living income. Both the Congolese State and multinational mining companies operating in the DRC are aware of this reality.

To provide a more realistic benchmark for employers in the industrial mining sector, RAID and CAJJ have, for the fourth consecutive year, calculated the amount for a living wage in Kolwezi. Using the Minimum Expenditure Basket (MEB) method, also used by the United Nations in DRC, we assessed the minimum monthly income needed to meet essential needs, including food, housing, health, education and other household costs. For 2025, the living wage in Kolwezi stands at $520 per month – or around $20 per day. The detailed information that makes up this living wage and its methodology can be found here. This is the threshold for a decent life, one that offers workers a route out of poverty for them, their spouse and children.

Many subcontracted workers earn far below this threshold. They described feeling like second-class citizens. They are paid less and excluded from benefits available to directly employed workers. Housing conditions remain inadequate and many struggle to afford transport, food or healthcare, let alone the opportunity for their children to obtain an education. The result is a system in which wages are technically legal – but structurally unjust – and entrench poverty.

Some workers spoke of despair, trapped in exploitative conditions with no other job options. “Here, we say, if there is no tree to hold onto, you grab the snake,” one worker said.

Companies that claim to support economic development in Congo cannot ignore the fact that the minimum wage deepens poverty. A genuine commitment to fairness means paying a living wage, not simply meeting the legal minimum. This is particularly urgent in the copper and cobalt mining sector, which lies at the heart of Congo’s economy. These two minerals are not only the country’s largest exports – they are also essential to the global energy transition. That transition must not be fuelled by the exploitation of underpaid labour.

Our 2021 report

Electric vehicles and workers’ rights abuses at DRC’s cobalt mines

Inadequate safety and workers’ health coverage

Congolese law requires employers to cover the healthcare costs of workers employed on permanent and fixed-term contracts, and of their dependent family members. Healthcare cover is a significant benefit of full-time work, and one that Congolese workers prize. Yet, access to healthcare remains highly unequal. While direct employees we interviewed generally reported decent coverage, subcontracted workers often face sub-standard care or no access at all.

Sometimes health coverage is capped by employers at just $10 per worker per month – far too low for clinics to provide an adequate standard of care. Workers whose employers contribute only minimal amounts report feeling neglected at clinics. Several interviewees said that once they showed their subscription card, they were given second-rate medicine or received visibly poorer treatment than other workers whose employers paid more. One worker said: “There are some illnesses that you can’t report. For example, you can’t complain about an infection, because the company will be implicated. There is a kind of agreement between the hospital and the company.” Some of the workers declared that they would rather pay for their own medicine than to go to the designated clinic.

Such minimal health coverage, which effectively denies workers access to adequate medical care, appears to be in violation of Congolese labour law.

Several workers handling toxic substances reported alarming health and safety failures, including chemical leaks and a lack of protective equipment. One worker described suffering burns on his leg after a toxic substance spilled on him while working without proper gear. “I went to the hospital and sought treatment from [a doctor], but I continued to work anyway.” Despite his injuries, he felt unable to stop work for fear of losing his job. He criticised the company’s failure to follow its own health and safety rules saying: “We’re given a set of rules that they themselves can’t comply with.”

A worker involved in ore processing said he and others are routinely exposed to toxic substances. “Every week I cough up blood,” he said. “I have been told it is normal.” Another worker, employed in the leaching process, described regular sulphuric acid leaks: “It hurts your nose, it can even take your breath away, and you can get nosebleeds.” Another worker described seeing a friend “sprayed with acid” while on the job. When the injured worker sought medical treatment, he was clocked out and had three days’ pay deducted for attending to his injuries.

Workers also raised concerns about radiation and exposure to uranium. In the DRC, uranium is often found naturally in the same rocks as copper and cobalt. A worker at one mine told us: “I left [a subcontractor company] because of my personal health. There is radiation everywhere in the [mine].  You get blood in your nose and workers are exposed to uranium-rich dust and smoke, even if you wear a mask.”

In April 2024, the DRC government suspended mining activities at the COMMUS mine due to elevated  levels detected in a cobalt shipment. The suspension was lifted in May 2024, provided COMMUS ensured the radiation levels in its products remain within national and international standards.

In interviews with RAID and CAJJ, workers also alleged that company staff deliberately sidestep official procedures to downplay or cover up workplace accidents. One worker said: “When there is an accident at work, there is no transport, no ambulance. We’re picked up and dropped off at the [entrance gate] and we then need to look for another means of transport… I think it is in bad faith. We have complained several times, but they [the company] tell us that they prefer not to spend money.”

Union rights undermined

RAID and CAJJ’s 2021 report exposed how some mining companies sought to undermine the right to freedom of association through tactics like rotating workers between short-term contracts to prevent unionisation, intimidating union leaders and retaliating against workers attempting to organise, thereby effectively suppressing collective bargaining efforts.

In 2025, union rights remain fragile and uneven. Workers report improvements such as new collective bargaining agreements and more active unions following worker elections, but many remain sceptical due to persistent employer interference and repression. In several cases, workers reported that Chinese-owned companies have appointed union representatives themselves or retaliated against active union members, including by issuing suspensions and job terminations. One worker said: “Sometimes if you try to go down the union path, you can end up losing your job.” Another interviewee reported being barred from union participation because of his activism.

While some independent unions have emerged and pushed for better conditions, including improved compensation for funerals and school fees, workers reported that the influence of the unions can be undermined by corruption and lack of enforcement. Workers expressed frustration with formal complaint channels, too. One worker stated: “We can go and see them, but we avoid it. They know the managers. We have gone to see them 20 times about our wages. What’s the point? We accept the conditions they impose on us.” Another said: “They listen sometimes, but nothing changes.” Another said, “We are exhausted by the situation, but we have no choice.”

Discrimination, violence and sexual abuse

Discrimination and culturally insensitive conduct remain a concern across mining operations in the DRC, contributing to frustration and low morale among Congolese workers. Workers have noted that preferential treatment for expatriates spans multiple nationalities and has long been embedded in the mining sector.

Workers report frequent violent altercations and a difficult relationship with their foreign managers. “We know that there is discrimination and a lot of violence,” one worker said. At one mine operated by a Chinese company, Congolese workers reported being slapped and insulted. They said that they were sworn at and physically humiliated by their foreign supervisors who sometimes “get violent easily”. One construction worker employed via a subcontractor said: “If you’re not up to it, they hit you, and the worst thing is that the contract ends. To keep our [employment] contract, we accept everything.”

In another mine, an interviewee shared the difficulties he encountered with an Arab manager at European-operated mine: “I have to resign because I am unwell. I asked the boss to sign the voucher to go to the hospital. He refused. The team leader came and said, ‘if he has to die, let him die’. I cried when I got home. I have six children, I can’t work in those conditions. So I asked for a transfer. All we get are expatriates. We’re in a third world country, so we Congolese don’t dare speak out. (…) They [foreign managers] know nothing except pressure. They have no technical knowledge. (…) You hear insults in Arabic, but you understand (despite not speaking this language).”

While cases of discrimination and culturally insensitive conduct were observed across the industrial mining sector – including, at times, among Congolese workers themselves – those working at Chinese-operated mines reported a disproportionately higher number of complaints. This has come as part of the significant expansion of Chinese investment and activity in Congo’s mining sector over the past two decades.  While some Chinese expatriates have also described facing hostility, harassment or assault by Congolese individuals, the overwhelming majority of reports relate to abuses committed against Congolese workers.

In interviews conducted by RAID and CAJJ in both 2021 and 2025, Congolese workers repeatedly described discrimination and, in some cases, physical mistreatment as part of daily life at several Chinese-operated sites. One worker described being instructed to pick up rubbish discarded by his Chinese supervisors – an experience which appeared to exemplify the daily indignities faced by Congolese staff. “The rubbish bin is near them, but they throw their rubbish on the floor and then tell the Congolese to pick it up and throw it away. Generally, there are no penalties. Our Congolese superiors always tend to agree with the Chinese.” In a separate incident at another mine, a worker said: “I am a driver. I share a vehicle with a Chinese man. When I give him the keys, he takes them with his fingertips and disinfects them. He also disinfects everything I touch in the car.”

Workers reported that facilities such as toilets and refectories remain segregated for expatriate workers and local workers in a number of the mines, with those provided for Congolese workers of noticeably lower quality. Workers also complained of inferior food quality. One interviewee said that workers do not enjoy the same quality of food as their Chinese supervisors, nor do they have access to adequate amounts of water: “Sometimes they give us items that are out of date.” He added that “Water is a big problem… Some days we have no water.” A fellow workers added: “We are served spoiled food. We sometimes vomit and have diarrhoea.”

A worker at another mine also operated by a Chinese company described similar problems saying the food quality provided for Congolese workers is markedly different than for expat workers.

Workers also denounced the lack of a proper environment for eating their meals: “There is no refectory. Normally you need one for a factory. But instead, a vehicle goes to each post to distribute the food. I eat at my desk and others eat in containers. They give everyone a bottle of water, but the Chinese [workers] get a bigger bottle.” Another interviewee from the same mine explained, “We are wary of water quality. The water for the Chinese workers is clean, whereas our water comes from the ground. Sometimes we bring our own water.”

Two male interviewees also reported sexual misconduct by male Chinese workers, such as groping and touching: “They have a game when they’re happy, which is to touch your belly and your [genitals], and tell us that it is big. When we reject them, they see us as the enemy.” When one of the workers complained, there was no action. He now fears losing his job saying he has been placed on a “red list”.

Excessive shifts and little rest

Gruelling shift schedules continue across all mining sites covered in our ongoing research. Many subcontracted workers we interviewed reported working up to 30 consecutive days, including night shifts, without proper rest, and being subjected to punishing shift rotations. One worker, who reported earning a monthly salary of $550, described six months of such difficult conditions. Shift lengths often exceed 12 hours, with workers stating that they work from 5am to 7pm (14 hours) in two of the investigated mines. This is a sharp increase from the maximum limit of 8 working hours per day set out in Article 119 of the Congolese Labour Code.

Workers said that breaks are either not respected or left to informal arrangements among workers. One interviewee explained that he only manages to eat by alternating with another worker at his post: “There is no rest, not even for lunch. We work according to the machine because we’re in production.” Long commutes reduce resting hours, resulting in 16-hour days for a number of workers. Some workers have to wait an hour after each shift to catch the company-provided transport back to their homes. The waiting time is not paid.

The physical toll of these demanding schedules leads to fatigue and increases the risk of accidents, especially in high-risk areas of the mining site involving heavy machinery: “In cobalt production, the bosses tell us that we have to produce 100 tonnes, so even if the shift is over, you have to carry on, and if you refuse, you’re in trouble. I am tired, but I can’t quit.” Another interviewee shared his despair : “I am ill, but my superior refuses to allow me to get treatment. The unions are ignoring me. What are we waiting for? Are we waiting for death? And if I die, who will pay for my children and insure them?” Despite promises of reform in the collective agreements, many workers still feel that real changes to shift patterns and rest periods are not being implemented.

Workers also complained about not having paid leave. One interviewee reported: “You’re entitled to four days off and [the mine] deducts it from your salary. It costs about $150.”  Similar experiences were reported to us across the investigated mines.

Some signs of progress

While labour rights challenges in the Congolese mining sector remain significant, the team did identify several encouraging signs of progress for workers. Notably, unions have now been established at two major Chinese-operated mines, SOMIDEZ and Sicomines, following a combination of legal intervention and sustained collective worker action. These developments have led to the signing of two collective bargaining agreements between mine operators and directly employed workers.

These advances were partially a result of legal petitions filed by CAJJ lawyers, which prompted the local court to instruct the labour inspectorate to investigate alleged violations of the labour code in two mines. When the inspectorate confirmed in April 2022 and May 2023 that union elections had not taken place at either site, in breach of Congolese law, the court directed the companies to take corrective action. This opened the door for workers to organise.

It was ultimately worker-led action fuelled by frustration and an enduring demand for change, that proved decisive. At Sicomines, important improvements were made after a week-long strike in November 2023. Directly employed workers secured a collective agreement in January 2025 which included an additional salary payment that functions like a bonus (known as the 13th-month), increased wages, financial assistance for funerals, and other rights. At SOMIDEZ, there was action by workers in mid-March 2025 demanding the payment of their wages and a collective agreement. The negotiations are still ongoing at the time of the report and were set to conclude at the end of the month of June 2025.

At other industrial mines, some directly employed workers also reported modest salary increases and improved benefits, such as expanded education allowances for dependents.

Following our first report, at least two large-scale mines conducted audits of their subcontractors – sometimes in response to requests from downstream customers such as refiners and EV companies concerned about worker exploitation – which led to the termination of some contracts where violations of Congolese labour laws were found.

Workers also reported small but meaningful changes to daily operations. For example, signage on machinery at some of the mines – previously only in Mandarin – have now been translated into French at several sites, improving worker safety and equipment handling. While it is surprising that this was not the case earlier, the change marks a welcome step forward.

The Congolese government has also taken some action. Since our first report, the Labour inspectorate has increased its staff and capacities. While there were previously only two inspectors in the Kolwezi mining area in 2021, there are now 40 labour inspectors and 8 controllers.

Yet, despite these gains, workers noted that conditions for subcontracted workers in particular have remained extremely challenging.

Uses of cobalt in 2021

US adds industrial cobalt to forced labour list

Since the publication of RAID and CAJJ’s 2021 Road to Ruin report, a significant policy shift in the United States has brought increased scrutiny to labour conditions in Congo’s industrial cobalt mines, especially on subcontracted labour. In September 2024, the United States Department of Labor added cobalt from Congolese industrial mines to its ‘List of Goods Produced by Child or Forced Labour’. This expanded an earlier designation that applied only to cobalt from artisanal mining sources. The updated listing confirms that forced labour risks are also present in large-scale industrial mining – particularly in relation to the widespread use of subcontracted labour.

US officials cited mounting evidence, including the RAID and CAJJ report and other investigations, which have highlighted how subcontracting practices in industrial mines contribute to exploitative working conditions. The US government move reinforces growing international recognition that labour and other human rights abuses are not only confined to artisanal mining, but are embedded in the formal industrial-scale cobalt and copper supply chains that feed the global green energy transition.

This designation carries serious implications for cobalt entering the US, including in electric vehicles, rechargeable battery and all goods that use the ore. It places an onus on US companies to demonstrate that the cobalt used in their products is responsibly sourced – and free from labour rights violations. The decision to add industrial cobalt to the list is a welcome and necessary step towards greater accountability and scrutiny of exploitative practices in the industrial mining sector.

Conclusion

Urgent and far-reaching reforms are needed to ensure that all Congolese workers, regardless of employment status, can enjoy safe, fair and dignified work. The Congolese government and international companies should be working together to ensure that the green energy transition does not replicate the exploitation and inequality of the fossil fuel era. As the world shifts away from carbon-intensive energy, the drive for critical minerals, such as copper and cobalt for electric vehicles, artificial intelligence data centres, and other technological components, should not come at the expense of thousands of Congolese workers.

Recommendations

For mining companies:

• Hire the majority of your Congolese workforce directly and limit subcontracting to urgent and short-term arrangements.
• Pay a living wage in light of the 2025 calculation and publicly commit to paying at or above the living wage for all workers at your Congolese operations, whether direct or indirect hires.
• Ensure equal, non-discriminatory treatment for all workers, including temporary and daily staff, with equal access to services, facilities and opportunities. Amend company policies as needed. Address discrimination issues as part of your broader commitment to responsible business conduct in DRC.
• Investigate human rights and environmental risks. Include all workers in every stage of human rights due diligence. Ensure their awareness and involvement in risk assessments, monitoring and grievance processes. Do not substitute your own due diligence with third party social audits.
• Review mine site health and safety standards, guaranteeing all workers (including subcontractors) have proper PPE, and provide regular thorough training.
• Support the right of all workers, including subcontracted and temporary staff, to form and join independent trade unions. Refrain from any interference, intimidation or retaliation, and ensure that union representatives have the freedom and resources to operate effectively within the workplace.

For companies down the supply chain:

• Use your full leverage to push suppliers and mining operators in DRC to stop worker exploitation, as well as to provide a living wage and benefits. Include a business contract termination clause in cases of human rights or environmental violations.
• Map your supply chain all the way to the cobalt mine and make it publicly available. Detail the due diligence measures you have in place to ensure these suppliers do not contribute to the exploitation of workers.
• Immediately review due diligence processes to address the full scope of workers’ rights issues, including those in this report, across supplier operations in line with international and local standards. If gaps exist in your due diligence documents, urgently revise the process and add these issues to your risk list.
• Apply responsible sourcing standards that fully address human rights and workers’ rights – not only child and forced labour in artisanal cobalt mining. Urge industrial standard-setting bodies to include labour rights in assurance and audit schemes.
• For industry certification bodies, certification schemes must expand their focus to include the full range of labour rights issues raised in this and other reports. These issues should be treated as core indicators in audits and assurance processes, not peripheral concerns.

For the Congolese government:

• Enforce strong regulation and penalty systems for companies that fail to comply.
• Encourage the allocation of sufficient funding and resources for labour inspections, thereby strengthening oversight of mining companies and their subcontractors within the region.
• Develop and implement training sessions or workshops for companies operating in the mining sector to raise awareness of local cultural norms, anti-discrimination principles, and respectful workplace practices. These initiatives should aim to prevent racial and gender-based discrimination and promote more equitable treatment of Congolese workers by foreign firms. Monitor this training and its effectiveness through regular government oversight and labour inspections.