[Please note that this response is from Trafigura and LAR (Lobito Atlantic Railway)]

Response from Trafigura 16.02.26

Background – BHR Enquiry on Lobito and Relocation

We invited Trafigura to respond as a commodity trader that has commercial relations with some mining companies operating in Congo, including those at the heart of the Lobito Corridor project.

According to the report, Trafigura is one of the joint venture partners, alongside others who have formed the LAR. Trafigura is also a commodity trader with supply agreements and major investments in Congolese mines, such as the Mutoshi mine currently owned by Chemaf Resources.

Kamoa-Kakula mine (a joint venture between Ivanhoe Mines, Zijin Mining Group, Crystal River Global Limited, and the Government of the Democratic Republic of Congo) is a confirmed anchor partner in the Lobito Corridor. It has a formal agreement to supply Trafigura with copper from a new smelter on the Kamoa-Kakula site.

Mutoshi was identified in Amnesty International’s 2023 report as the site of violent evictions with inadequate compensation in 2015 and 2016, a few years before Trafigura started financing the project.

Kamoa-Kakula copper mine faced controversy over displacement linked to recent expansion plans.

The report also alleges that beside any direct evictions, the Lobito Corridor is concerning for those on its frontline because it could worsen Kolwezi’s existing displacement crisis. By lowering transport costs for mining companies, the project could make it viable to mine new reserves and expand existing mines, increasing pressures on local communities' land.

Based on all these elements of the report, we are writing to inquire about the human rights due diligence measures that Trafigura will take to ensure that its commercial relations with mining companies involved in the Lobito Corridor will not exacerbate forced evictions and expropriation of most vulnerable communities in DRC.

Trafigura’s Responsible Sourcing Programme and its application to due diligence of relocation

Trafigura has committed to the UN Guiding Principles on Business and Human Rights and implements a Responsible Sourcing Programme to implement this commitment in its supply chains of minerals and metals. Trafigura has set Responsible Sourcing Expectations for its suppliers which include the expectation to respect the rights of host communities. These Expectations are embedded in supplier contracts and suppliers undergo responsible sourcing assessments, including on-site assessments and independent third-party audits to assess ESG risks and support risk mitigation. Trafigura is the first commodity trader to align its RS program with ISO 20400:2017. In 2025, we successfully completed an independent third-party alignment assessment against the Joint Due Diligence Standard – the assurance standard adopted by the RMI and The Copper Mark.

Trafigura's Responsible Sourcing team has conducted two Responsible sourcing assessments of Kamoa since 2023 in addition to a gap assessment conducted by an independent third party of Kamoa against The Copper Mark’s Joint Due Diligence Standard. Since 2020, Trafigura has undertaken responsible sourcing assessments of the Chemaf Mutoshi mining operations, conducted by Trafigura’s Responsible Sourcing team and independent third-party consultants. Periodic assessments of suppliers provide Trafigura with an up to date understanding of the environmental, social and governance performance of the company.

Regarding the Kamoa-Kakula Mine:

Kamoa Copper SA (the operating entity of Kamoa-Kakula) is not part of the Trafigura Group.

Kamoa Copper SA has publicly committed to implementing the UN Guiding Principles on Business and Human Rights and aligning with IFC Performance Standards, as documented in Ivanhoe Mines' Sustainability Report 2024.

On Community Resettlement:

Regarding the Muvunda resettlement referenced in the Amnesty International 2023 report:

• The relocation of 45 households was conducted prior to the revised Mining Regulations coming into force; however, all resettlement requirements were undertaken in compliance with applicable law.
• The company received five grievances from resettled households, all of which have been resolved and closed.
• Resettled communities have been provided with new houses, educational facilities, water infrastructure (four boreholes), a 40-bed hospital, and livelihood programmes, with approximately 58% of Muvunda affected people securing permanent employment.
• In the case of educational facilities, the distance from the Mavunda households to the nearest primary school has been reduced from 7km to 500m.
• Kamoa has also established the Kamoa Centre of Excellence, launched in September 2023, where youth from the village can gain access to a high standard of tertiary learning. 90% of affected people who have participated to the LRP have improved their living standard and been withdrawn from the program.
• The company is contracting an independent non-governmental organisation to conduct surveys documenting improvements in living standards for resettled people.

Source: Ivanhoe Mines

Regarding the Mutoshi Mine:

Chemaf SA (the operating entity of Mutoshi Mine) is not part of the Trafigura Group.

Trafigura does not hold equity in Chemaf; its relationship is through the provision of financing.

In relation to the allegations concerning Mutoshi, we note that Chemaf SA has categorically rejected claims of involvement in unlawful evictions or loss of human life.

Key facts regarding the Mutoshi project:

• The alleged events relating to the illegal removal of a settlement in 2016 pre-date Chemaf's mobilisation at Mutoshi.
• Chemaf was only permitted full access to Mutoshi by Gécamines in December 2017, with construction activities not commencing until 2018.
• Chemaf first became aware of the alleged events in 2019. These accusations were subsequently heard in the Kolwezi High Court in 2021, in which the Judge ruled that these claims were 'unfounded'.
• Chemaf has stated it was not in any way involved in the destruction of a village allegedly called Mukumbi at Mutoshi in 2016.

Source: Chemaf SA
https://chemaf.com/chemaf-amnesty-media-response/

Response to Global Witness report

Lobito Atlantic Railway (LAR) notes the report published by Global Witness on 4 December 2025 concerning the Lobito Corridor.

For clarity, the LAR consortium wishes to emphasise the following:

• Lobito Atlantic Railway (LAR) is a group founded by a private consortium. It is responsible for managing rail traffic, maintaining railway tracks and associated infrastructure, and transporting goods along the Angolan section of the railway - i.e. between the Port of Lobito on the Atlantic coast of Angola and Luau, on the border with the Democratic Republic of Congo (DRC). This is a railway of 1,300km.
• Within the DRC, Société Nationale des Chemins de Fer du Congo (SNCC) retains full responsibility for the maintenance and operation of the railway line. It provides railway access in the DRC which connects to the railway line in Angola managed by LAR.
• LAR does not expect any displacements associated with the rehabilitation of the line in Angola.
• LAR operates in line with the IFC Performance Standards and engages with local communities and stakeholders.

Source: Lobito Atlantic Railway