Special Report
By Ethical Business Team
The Democratic Republic of Congo produces more than 70 per cent of the world’s cobalt, a mineral essential to the batteries powering electric vehicles and consumer electronics. Yet systematic exploitation remains embedded in supply networks feeding global manufacturers. An estimated 40,000 children work in the country’s artisanal cobalt mines, some as young as six years, according to data compiled by Save the Children in 2024.
“One day I found a large block of cobalt in one of the holes and removed it. From that day on my body has hurt a lot,” Muntosh, a 12-year-old from Lualaba province, told Save the Children researchers in 2024. He had witnessed his brother’s death in a mine collapse at age six but continued working there for six years.
This gap between corporate commitments and operational reality reflects a broader challenge confronting multinational corporations and African governments: achieving genuine supply chain transparency in regions where informal economies dominate, regulatory enforcement remains weak, and economic incentives favour opacity over disclosure.
The scale of exploitation
Modern slavery affects an estimated 50 million people worldwide, with 28 million trapped in forced labour, according to 2025 data from the International Labour Organisation. Africa accounts for 7 million victims. The continent represents 17 per cent of the world’s population but bears a disproportionate burden of exploitation.
Yet Africa’s supply chain abuses extend far beyond headline cases. They permeate sectors critical to global commerce: cobalt mines in the DRC supplying battery manufacturers; gold fields in Tanzania linked to Swiss refineries; cotton farms in West Africa feeding European textile mills; fishing fleets off Ghana processing seafood for international markets.
The financial implications are mounting. European Union member states must transpose the Corporate Sustainability Due Diligence Directive into national law by 26 July 2026. The directive, which entered force on 25 July 2024, imposes penalties reaching 5 per cent of global turnover for non-compliance with supply chain monitoring requirements.
“Large companies must take their responsibilities in the transition towards a greener economy and more social justice,” the EU Council stated in May 2024 when giving final approval to the directive. “The Corporate Sustainability Due Diligence directive will give us the possibility to sanction those actors that violate their obligations.”
Companies face mounting litigation exposure. Technology firms including Apple, Alphabet, Dell, Microsoft and Tesla have been named in lawsuits over deaths and injuries sustained by child labourers in DRC cobalt mines. A U.S. Court of Appeals ruled in 2024 that buying cobalt in the global supply chain does not constitute participation in a forced labour venture under federal trafficking laws, though plaintiffs’ lawyers expect further litigation.
Mapping invisible networks
Traditional supply chain management focused on cost reduction and logistics efficiency. Modern frameworks demand something more complex: visibility into networks stretching across multiple tiers of suppliers operating in jurisdictions with limited oversight.
Consider the cobalt supply chain. Ore from artisanal mines in Kolwezi passes through local traders, enters Chinese processing facilities, becomes cathode material for Korean battery cell manufacturers, and reaches assembly plants in Vietnam. Labour practices vary at each stage. Accountability diminishes.
Of the 255,000 Congolese mining for cobalt, 40,000 are children, some as young as six years, according to Wilson Center research. Workers earn less than USD 2 (KES 260) per day whilst using their own tools, primarily their hands.
“We’re seeing a huge need for green energy solutions globally, which heavily relies on cobalt, but it is imperative that what fuels our smartphones, computers, and electric cars doesn’t also fuel child rights violations,” Greg Ramm, Save the Children’s DRC country director, said in June 2024.
Tanzania’s gold extraction challenge
Tanzania produces approximately 50 tonnes of gold annually, worth KES 490 billion (USD 3.8 billion) at current prices. Roughly 10 per cent originates from artisanal and small-scale mining operations where labour abuses are documented.
Research published in 2023 examined conditions at mines in three Tanzanian districts. Investigators found abject household poverty drove children into mining because families could not provide basic needs. The study, appearing in the journal Heliyon, documented children working both on surface and underground operations.
“Children work both on the surface and underground, risking death caused by explosions, rock falls, and tunnel collapses,” the researchers wrote. Workers breathe dust-filled air and toxic gases, ferry large sacks of ore, and face mercury intoxication during gold amalgamation.
Tanzanian law prohibits mines from employing children under 18. The government has done little to enforce this prohibition, rarely inspecting small-scale mines or sanctioning those who hire children, according to Human Rights Watch documentation from multiple investigations.
Gold from these sites enters supply chains serving Swiss refineries, which supply manufacturers in India, Italy and the United States. The United Arab Emirates is Tanzania’s top buyer, with the country also exporting to Switzerland, South Africa, China and the United Kingdom.
“I buy from anyone and I sell to anyone,” one Tanzanian gold trader told Human Rights Watch investigators, speaking about transactions involving children.
Technology’s limited reach
Blockchain-based tracking systems have emerged as proposed solutions. IBM Food Trust, SAP’s Supply Chain Transparency platform, and specialist providers claim to offer immutable records of product movement from origin to end-user.
The diamond industry adopted blockchain tracking in 2018 through De Beers Group’s Tracr platform, which now processes 40 per cent of De Beers production. Each stone receives a digital certificate recording its journey from mine to retailer.
A 2023 audit by Levin Sources found that whilst Tracr successfully tracked stones through formal channels, it had minimal impact on artisanal mining, which accounts for 20 per cent of global diamond production. Stones mined outside certified operations bypass the system, entering through grey-market channels in Dubai, Antwerp and Mumbai.
The fundamental limitation is technological: blockchain records data inputs but cannot verify their accuracy. If a Congolese cobalt trader records ore as coming from a certified mine when it actually originates from an artisanal site employing child labour, the blockchain dutifully records the false information.
Regulatory experiments and enforcement gaps
Ghana, Côte d’Ivoire, and more recently the DRC are the only countries in the region that have identified high-risk sectors and have taken action to eradicate modern slavery within supply chains, according to the Walk Free Foundation’s assessment of 51 African countries.
Kenya has attempted mandatory disclosure through public procurement reforms. The Public Procurement and Asset Disposal Act establishes the Public Procurement Regulatory Authority as a watchdog for procurement in Kenya. The Constitution requires that public procurement be carried out in a system that is fair, equitable, transparent, competitive and cost-effective.
However, enforcement capacity remains constrained. A 2024 report on Kenya’s governance found that corruption at ports and border points represents the most problematic factor for international trade. Border compliance procedures take significantly longer than regional averages. Rampant corruption undermines transparency efforts.
“We can compel disclosure, but we cannot compel change,” said one regulatory official familiar with Kenya’s procurement oversight, speaking to Business Daily Africa in 2024 about the limitations of transparency requirements.
The economics of compliance
Cost considerations shape corporate decision-making. Implementing comprehensive supply chain monitoring systems requires significant investment. A 2023 survey by Deloitte found companies spend an average of USD 2.4 million (KES 312 million) annually on supply chain auditing and compliance for operations spanning multiple African countries.
For multinationals with revenues in the billions, this represents a manageable expense. For mid-sized firms, particularly those in lower-margin sectors such as agriculture or textiles, the burden creates acute pressure.
Ethiopian coffee exporters operate on profit margins averaging 3 to 5 per cent. Full traceability to smallholder farmers can add USD 0.15 to USD 0.30 per kilogram in administrative costs. Given that Ethiopia exported 280,000 tonnes of coffee in 2023, the aggregate cost to the sector could reach USD 84 million (KES 10.9 billion) annually.
Some exporters have responded by consolidating suppliers, working with fewer, larger cooperatives that can absorb compliance costs. This improves traceability but reduces market access for smallholder farmers lacking cooperative membership. In Sidamo, one of Ethiopia’s premium coffee regions, the number of farmers selling directly to exporters fell by 37 per cent between 2019 and 2023.
Policy gaps and misaligned incentives
Current regulatory frameworks reflect a patchwork of national legislation and voluntary industry standards, creating opportunities for arbitrage. Companies facing strict requirements in Europe or North America can route products through jurisdictions with laxer oversight.
The African Continental Free Trade Area, which came into effect in 2021, facilitates intra-African trade but includes no harmonised labour standards. Goods can move freely between member states regardless of production conditions.
“The agreement prioritises tariff reduction and customs harmonisation but remains silent on labour standards,” Judith Oloo, a University of Nairobi specialist in international trade law, wrote in a 2024 paper. “Without common baseline requirements, countries compete by offering investors weaker regulatory environments.”
Some African governments view stringent labour regulations as a competitive disadvantage. Officials in Rwanda and Ethiopia have explicitly marketed low labour costs and flexible employment regulations as incentives for foreign manufacturers seeking alternatives to Asian production bases.
Procurement practices and pressure
Purchasing decisions by multinational corporations directly influence labour conditions at supplier level. Short lead times, price pressure and volatile order volumes create conditions that incentivise cost-cutting at workers’ expense.
A 2024 study by the University of Sussex examined procurement practices in the East African textile sector. Researchers found European fashion retailers typically demand production turnarounds of four to six weeks, with penalties for late delivery but no compensation for rush orders.
To meet these deadlines, Kenyan and Ugandan factories frequently impose mandatory overtime reaching 30 hours per week, often without proper payment. The study identified a direct correlation between buyer payment terms and labour violations. Factories receiving payment within 30 days of delivery reported 60 per cent fewer wage disputes and health and safety violations compared with those subject to 90-day payment terms.
“Factory owners tell us they cannot afford to pay proper wages or maintain safe conditions because buyers demand lower prices every season,” Sarah Omondi, general secretary of the Kenya Textile Workers Union, said during an October 2024 panel discussion. “The brands claim they want ethical supply chains, but their purchasing behaviour says otherwise.”
Risk assessment frameworks
Practical supply chain management requires systematic risk assessment. The Organisation for Economic Co-operation and Development provides guidance through its Due Diligence Guidance for Responsible Business Conduct, but implementation varies widely.
Effective frameworks typically incorporate several components. Companies must identify all entities in their supply chain, including subcontractors and labour brokers. This requires moving beyond tier-one visibility to understand where raw materials originate and how production is organised.
Resources such as the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor flag high-risk sectors and jurisdictions. As of 2024, the list includes 30 African countries across 45 product categories. The Democratic Republic of Congo appears for cobalt, with children mining the mineral. Tanzania features for gold mined by children. Zimbabwe is listed for lithium extracted by child labour.
Copper and cobalt dug up by children in the DRC, and lithium unearthed by kids in Zimbabwe, are all used in electric vehicles and their batteries, according to analysis of the 2024 Labor Department list published by New Security Beat.
Direct engagement with workers provides information that audits often miss. Several companies have established confidential hotlines and smartphone applications allowing workers to report violations anonymously. However, uptake remains low in regions with limited digital access or where workers fear retaliation.
Third-party audits offer more credible assessments than internal reviews, though quality varies amongst auditing firms. A 2023 investigation by the Financial Times found some social compliance auditors spent as little as four hours on site and conducted interviews only with management-selected workers.
Practical steps and evidence
Organisations seeking to address supply chain labour risks can adopt several evidence-based approaches.
Extended payment terms to suppliers reduce financial pressure. Research from the University of Cambridge Judge Business School demonstrates that improved payment terms correlate with better labour conditions. Companies such as Unilever have moved to 14-day payment cycles for certain African suppliers, reporting measurable improvements in audit scores.
Investment in supplier capacity building offers an alternative to simply dropping problematic suppliers, which often shifts problems elsewhere without resolving them. Some firms fund training, equipment upgrades and management systems. The Better Work programme, a partnership between the International Labour Organisation and the International Finance Corporation, operates in Ethiopia, Lesotho and Madagascar, providing technical assistance to improve factory conditions whilst maintaining commercial relationships.
Support for regulatory development enables companies to engage constructively with African governments to strengthen labour inspection systems and enforcement capacity. The corporate-funded Ethical Trading Initiative works with governments in Kenya, Malawi and Zambia to improve inspector training and increase audit frequency.
Staged sourcing requirements acknowledge that immediate demands for full compliance can prompt suppliers to hide abuses or subcontract to unvetted operations. Phased approaches that set clear timelines for improvement, coupled with technical support, yield better long-term outcomes.
The limits of voluntary measures
Voluntary certification schemes proliferate in African agriculture. Fair Trade, Rainforest Alliance, UTZ and numerous others operate across the continent. Yet systematic evidence of impact remains limited.
A 2024 meta-analysis published in World Development reviewed 87 studies assessing certification programmes across African agricultural supply chains. The analysis found modest improvements in working conditions at certified farms but no significant spillover effects to non-certified operations in the same regions.
The fundamental challenge is market structure. In sectors where buyers possess substantial bargaining power relative to suppliers, costs of compliance fall disproportionately on producers. Unless end consumers pay premium prices sufficient to offset these costs, or unless regulation mandates universal standards, individual suppliers face incentives to minimise expenditure on labour conditions.
“We cannot expect African suppliers to shoulder the entire burden of due diligence whilst absorbing downward price pressure from buyers,” Ngozi Okonjo-Iweala, Director-General of the World Trade Organisation, stated during a 2024 speech in Geneva. “The costs of ethical supply chains must be shared equitably across the value chain.”
Evidence of progress and persistent gaps
The International Labour Organisation launched the GALAB Project in November 2024 to combat child labour in the DRC’s artisanal cobalt mining sector. The initiative builds on the earlier COTECCO Project, which registered over 6,200 children engaged in mining in Haut-Katanga and Lualaba provinces as of March 2024.
“The GALAB project is a crucial step forward in our collective efforts to combat child labour in the DRC’s cobalt supply chain,” Nteba Soumano, ILO Country Director for Central Africa, said at the November 2024 launch. “By strengthening remediation services and engaging the private sector, we can make a real difference in the lives of children and their families.”
The project coordinates through a Child Labour Monitoring and Remediation System, referring identified children to educational support, income-generating activities for families and vocational training for older children. It collaborates with UNICEF, IMPACT Transform and the PABEA-Cobalt initiative.
Yet big brands in Europe and elsewhere are rarely held responsible for abuses in their supply chains, according to Professor Tomoya Obokata, UN Special Rapporteur on contemporary forms of slavery, in an October 2025 interview. “Enforcement requires resources and trained officials. Prosecution and punishment are also difficult, while accountability and impunity are significant issues.”
The European directive’s reach
The EU’s Corporate Sustainability Due Diligence Directive represents the most comprehensive regulatory framework enacted to date. Member states must transpose the directive into national law by July 2026. Companies will face compliance deadlines staggered by size: firms with more than 5,000 employees and EUR 1.5 billion (KES 234 billion) turnover must comply by 2028; those with more than 3,000 employees and EUR 900 million (KES 140 billion) turnover by 2029.
However, in February 2025, the European Commission adopted an Omnibus package proposing amendments to simplify due diligence requirements. The Office of the High Commissioner for Human Rights expressed concern that simplification could result in standards not aligned with international obligations.
The EU Omnibus Package proposed substantive amendments to CSDDD, now under legislative debate. These proposed changes aim to simplify how companies approach human rights due diligence without reducing accountability, according to analysis published by compliance specialists in early 2025.
Chief amongst the proposed changes is possible restriction of due diligence to direct suppliers, which would considerably limit responsibility along entire supply chains. Civil liability provisions are under debate. Reporting obligations might shift from annual to every five years, reducing administrative overhead.
“It is pretty important because it is more than likely to hurt the ongoing efforts to eradicate contemporary forms of slavery, such as child labour and forced labour, further down in the supply chains,” Professor Obokata said regarding the simplification proposals in October 2025.
G20 responsibilities and purchasing power
Modern slavery affects more than half of the people living in G20 countries. Seven G20 members, including India, China, Saudi Arabia, Russia, Indonesia, Turkey and the United States, are amongst the ten countries with the largest absolute numbers of people in modern slavery, according to the Walk Free Foundation’s 2025 assessment.
G20 purchasing practices fuel exploitation in lower-income countries at the frontlines of global supply chains. Electronics, garments, and solar panels are among the high-risk imports linked to forced labour, the foundation stated in an October 2025 analysis.
The G20 accounts for 85 per cent of global GDP and sits at the centre of the world’s trading system. Yet modern slavery has never been explicitly addressed in the annual Leaders’ Declaration, leaving a major gap in global action.
“Modern slavery, including forced labour, forced marriage, debt bondage, and human trafficking, is a profound economic injustice that continues to disproportionately impact women and girls,” said Jacque Brittain, Gender Equality Executive Director at Walk Free, during the October 2025 W20 Social Summit in South Africa. This marked the first time the W20 considered modern slavery.
The foundation recommends G20 countries strengthen existing mandatory reporting legislation by implementing penalties and managing publicly accessible repositories. Additional legal measures should include import controls on products linked to forced labour, Magnitsky-style sanctions and public lists of companies found to tolerate forced labour in their supply chains.
Companies and their leverage
Companies responding to the challenges vary in approach. Some technology firms have pledged to keep cobalt mined by children out of their batteries, typically hiring third-party auditors to monitor conditions. Critics charge these inspections are often ineffectual.
Other companies have stopped buying from the DRC altogether. The problem is that complete boycotts would put thousands of desperately poor people out of work without addressing underlying conditions. A World Bank analysis noted that perceived reputational risks associated with sourcing artisanal cobalt from the DRC could negatively impact the country’s comparative advantage in supplying cobalt from 2025 onwards.
BMW secured an agreement with Moroccan producer Managem, the world’s only primary cobalt mine, to cover 20 per cent of its requirements for the 2020-2025 period. The company sources the remaining 80 per cent from Australia, avoiding DRC involvement.
Several automotive and technology companies launched Cobalt for Development in 2019 to support ethical practices in the DRC’s cobalt mining industry. BMW Group, BASF, Samsung SDI, Samsung Electronics and later Volkswagen participated. The initiative has run for an initial three-year period analysing how workers’ lives, work environment and communities can be improved.
Tesla joined the Fair Cobalt Alliance in 2020, which aims to support artisanal miners. The company announced in 2021 a pilot blockchain programme to trace cobalt from mine to product. However, blockchain limitations mean the technology cannot verify the accuracy of inputs at source.
Root causes and structural factors
Poverty, inequality and intersecting forms of discrimination affecting vulnerable groups drive forced and child labour. Beyond legal measures, attention to root causes is essential.
“First and foremost, member states of the United Nations must do a great deal more. They must have clear legislative frameworks and enforce national laws against child and forced labour,” Professor Obokata said in the October 2025 interview. “Almost all countries already have laws or regulations prohibiting these practices, but enforcement is key.”
That requires effective labour inspectorates going into the field to identify violations. This is not happening in many regions. Enforcement requires resources and trained officials.
“Wealthy nations also share equal responsibility to support these countries in addressing these root causes,” Obokata added. “Ultimately, consumers in Europe, Japan, North America, and certain parts of Asia are driving the demand for affordable goods and services. Major corporations respond to this demand, which leads to cheaper labour further down the supply chain.”
In Tanzania, research published in 2024 found that migratory nature of artisanal mining led some parents to not prioritise children’s education. Peer pressure and parental influence promoted entry into mining or reinforced its continuation. Early socialisation of children as future miners and lack of perspective contributed to persistent child labour within mining communities.
Poor reinforcement of mining regulations was cited as another factor legitimising child labour. Since factors promoting exploitation are multifaceted, efforts for elimination require multi-layered approaches aimed at addressing root causes at household, community and government levels.
Measuring effectiveness
Evidence from sectors that have achieved measurable progress suggests effective intervention requires several elements working in concert. Mandatory disclosure requirements must be backed by credible enforcement. Harmonised standards across jurisdictions prevent regulatory arbitrage. Buyer purchasing practices need to provide suppliers with stable demand and fair payment terms. Independent verification mechanisms require genuine worker participation. Sustained investment in regulatory capacity within African states is essential.
No single intervention suffices. Technology provides tools for data collection but cannot substitute for regulatory oversight. Corporate social responsibility programmes generate positive examples but lack the scale to address systemic issues. National legislation creates incentives but requires cross-border cooperation.
The Walk Free Foundation’s assessment of 51 African countries found governments scored an average of 36 per cent on responses to modern slavery, the weakest average response of all regions. Whilst governments improved identification measures and legal frameworks, gaps in services available to survivors remained. Only limited action has been taken to address systemic risk factors.
“If you have children working in remote areas, you need a budget to visit,” Masasila, a village secretary in Tanzania’s mining region, told Thomson Reuters Foundation, noting he could not recall ever seeing inspectors at the mining site near his village.
For government workers tasked with inspecting mines for health, safety and labour violations, enforcing the law at far-flung informal mines is an onerous task. Two labour inspectors cannot cover hundreds of artisanal mining sites spread across vast regions.
Outstanding questions
Whether current regulatory momentum translates to meaningful change will depend on implementation. History provides ample examples of well-intentioned legislation foundering on weak enforcement, corruption or insufficient resources.
For corporations, legal risks mount as courts prove more willing to hold parent companies accountable for subsidiary actions. Reputational damage from labour scandals can erode brand value built over decades. A new generation of investors applying environmental, social and governance criteria scrutinises supply chain practices with rigour.
The question is how quickly companies and governments can build the systems needed to make transparency meaningful. The next scandal may not allow for gradual adjustment.
About this special report
This investigation draws on research published between 2023 and 2025 by international organisations including the International Labour Organisation, Walk Free Foundation, Human Rights Watch, Save the Children, the World Bank and academic institutions. Documentary evidence includes the EU’s Corporate Sustainability Due Diligence Directive (2024/1760), UN Special Rapporteur reports, peer-reviewed studies in journals including Heliyon and World Development, and compliance assessments by organisations including Deloitte and Levin Sources.
Field research cited includes investigations in the Democratic Republic of Congo’s Lualaba and Haut-Katanga provinces, Tanzania’s gold mining regions, and East African textile manufacturing zones. Data on child labour in artisanal mining comes from the ILO’s Child Labour Monitoring and Remediation System, U.S. Department of Labor assessments, and documentation by civil society organisations operating in affected regions.
Legal and regulatory analysis incorporates the EU directive’s text and implementation timeline, African Continental Free Trade Area provisions, and national legislation in Kenya, Tanzania, Ethiopia and other jurisdictions. Economic data on compliance costs, profit margins and trade flows derives from industry surveys, government statistics and multilateral institution reports.
