CASE STUDIES
Demonstrating due diligence maturity in Bolivia
The context
Kumi’s client was a major commodities trader which had extensive business with mineral supply chains in Bolivia.
Bolivia’s zinc and lead supply chains are dominated by thousands of small-scale mining cooperatives operating under weak regulatory oversight, exposing buyers to risks of child and forced labour, unsafe working conditions, environmental harm, and limited traceability
Kumi had been conducting an on-the-ground due diligence and capacity building programme with them for over 2 years.
What we did
On-the-ground assessment approach
Built on existing programme: We designed the visits as a joint exercise with the downstream customer, leveraging years of prior assessments and engagement to test whether commitments were holding up in practice.
Mixed-method evidence gathering: Combined direct observation of mine and plant operations, documentation review, and stakeholder interviews with management, workers, and ASM representatives.
Validated paper against practice: Where documentation looked complete, we pressed for operational evidence to confirm whether systems were genuinely embedded rather than nominal.
Risk-led prioritisation: We focused first on child and forced labour risks at the cooperative tier, prioritising by severity, reversibility, and where buyer leverage is structurally weakest.
Aligned with the customer’s verification process: We cross-checked findings against the downstream customer’s evidence expectations, producing a single consistent picture rather than parallel assessments.
What this allowed us to uncover
Gaps between policy and practice: Documentation often looked stronger than operational reality, with labour controls inconsistently applied across the workforce in ways that only surfaced through interviews and on-site checks.
Weak visibility into the supplier-of-supplier tier: Formal traceability policies existed, but practical oversight of the cooperative layer, where most zinc and lead actually originate, was limited.
Context-specific labour risks: Watchmen and workers living on-site with their families, including children, in operator-provided housing, a structural risk specific to remote Bolivian mining areas that would not appear in any policy review.
Systemic sector dynamics: Spot-trading dominance, the absence of a national definition of “responsible small-scale mining,” and minimal government enforcement mean buyer-led due diligence is effectively the only meaningful guardrail.
Variability in counterparty maturity: Clear divergence between sites that had progressed under the Capacity Building Programme and others that remained misaligned with client expectations, despite similar formal commitments.
The difference it made
Enabled a defensible sourcing decision: The visits gave the downstream customer the independent, on-the-ground evidence needed, which directly unlocked the purchase of Bolivian-sourced minerals from our client.
Extended visibility to the cooperative tier: Closed a blind spot that desk-based screening cannot reach, giving both Kumi’s client and its customer line-of-sight into the supplier layer where most zinc and lead originate and where risk concentrates.
Surfaced context-specific risks for active management: Identified issues such as on-site family housing arrangements and inconsistencies between documented and applied labour controls, allowing them to be addressed rather than escalating into reputational or commercial exposure.
Positioned our client as the most credible responsible buyer in Bolivia: Demonstrated, with evidence, the maturity of a multi-year due diligence and capacity-building programme, turning a compliance investment into a clear commercial differentiator with downstream customers.
Reinforced alignment with international standards and anticipated regulation: The approach is grounded in OECD, LME, LBMA and RMI expectations, positioning the client ahead of tightening downstream scrutiny from customers and emerging EU due diligence requirements.
