Engage to improve – why inclusion is the most responsible choice for artisanal gold

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Kevin Telmer for Gold Network

From the rapids of the Brazilian Amazon to boardrooms shaping global gold policy, Dr. Kevin Telmer has spent decades working alongside artisanal miners to unlock the sector’s potential for poverty alleviation, environmental stewardship, and economic inclusion. In this wide-ranging conversation, he reflects on the origins of his mission, the systemic barriers keeping artisanal gold out of formal markets, and why the future of responsible sourcing hinges on genuine engagement, not exclusion.

Dr. Telmer, you’ve dedicated over two decades to the artisanal and small-scale gold mining (ASGM) sector. What first drew you to this field and what has kept you in it all these years?

I’ve been lucky to have had such an adventurous career! My journey into the ASGM sector began in 1995 in the Brazilian Amazon. I was a geologist and doctoral student in geochemistry at the time and working at the Geological Survey of Canada on the side. The opportunity to go the Amazon and work with artisanal miners popped up with Yvonne Maurice, a senior GSC researcher running a resource development assistance program. We randomly met at a jammed photocopier and that is where it all started! My job was to look at the mercury use and contamination, quantify everything about it, and think about ways to reduce it. I was remarkably qualified as I had been looking at mercury in the Ottawa River as part of my PhD work. I jumped at the chance and once I got a taste of ASM and its universe, I have never looked back.

What quickly drew me in was the people factor. This was the perfect mix of science and people’s lives, very directly and rather urgently – something I yearned for in life but that I felt was missing in my other work. Through field work with miners, I quickly came to understand that my skills and aptitude gave me a profound opportunity to improve the sector, particularly in how it could alleviate poverty and foster good, upwardly mobilising, wealth generation that would break through subsistence level incomes and send kids to school. And 30 years later, it’s clear that my instinct was right. The sector has been pumping out millions of better-paying jobs all around the world since then.

It was clear to me even then that this sector was overlooked and very misunderstood and therefore misrepresented. You could just see the injustices so clearly. But on a few sides. On one, whole communities of thousands of people, really good salt-of-the-earth hardworking people, were cast as criminals. And yet there I was, pushing “voadeiras” (long motor boats) up the rapids of the Tapajós River with them to collect samples. And having a laugh together doing it. On another side, there were horrible ecosystem sterilizing practices going on. On a third side, it was clear that the sector held immense potential for positive social and economic impact, and some important science to boot. And on a fourth, being a good Canadian and a geologist, it was a time warp back into the 1850s to 1930s, a Canadian Nation-building period largely funded by exactly the same industry. All of the best bars in the city I live in today, Victoria, British Columbia, are housed in beautiful red brick buildings built by the Canadian gold rushes, although I would hardly call 80 years a rush – another misrepresentation.

What has kept me deeply invested for over two decades is the sheer scope and complexity of the work, all the incredible people I’ve partnered with along the way, the joy of field work, and the adventure and nature. Sometimes that stuff, the good stuff, got out of reach, which is one reason for my most recent shift in approaches to bringing improvements to ASM.

My career has spanned field operations, technical innovations, scientific research, policy development, finance, and economics. I was a professor of geochemistry, an NGO founder and leader, and am now a business developer, owner and operator. Without intentionally doing it, I’ve built a vast professional network while working in over 30 countries across three continents. I am fond of saying “You learn through doing”. In this sense, the work I have done together with artisanal miners and my various colleagues, along with the knowledge, science, and skills that we have shared and brought into the ASM universe has been the bedrock of my career.

I have always been able to quickly establish authenticity with miners and them with me. I am interested in their work and have found my capability to help them improve it a motivational force for both them and I. As it turns out, a smart scientist is very welcome in the ASM community. I often explain this to others as a car mechanic talking to a car mechanic – it is quickly a natural and easy conversation. And that opens the door to talking and learning about anything else in ASM or sharing anything from my world.

On a mission level (the mission to improve ASM), this trust and collaboration are essential for delivering the technical and systemic improvements needed – livelihoods, environmental, social, and governance. At this point, with decades of experience (you learn through doing!), and some smart career moves, I think I am more capable than ever to help bring a good portion of the roughly 700 tonnes of annual gold production from ASM into the formal economy (75 Billion US$). That is the single most important outcome and the clearest key performance indicator for the improvement of the sector – how much of the 700 tonnes flows into the formal gold bullion industry. Bringing a big part of it in has massive social and environmental dividends, globally.

What was your founding vision for the Artisanal Gold Council, and how has it evolved since its inception?

When I founded the Artisanal Gold Council (AGC) in 2007, it was part of my academic research program at the School of Earth and Ocean Sciences, University of Victoria. At that point in my career after getting tenure and becoming an established academic researcher, I came to realize that a professor and his grad students are not a particularly robust approach to help the ASM sector. It was always a temporary engagement and with motives that had to be crafted for the criteria of research grant programs or academic achievement. So I created a more dedicated vehicle, the Artisanal Gold Council, with a clear mission to help artisanal mining. The idea was that it would genuinely resonate with ASM miners and their governments, and be able to develop the long-term relationships needed to underpin the collaboration necessary to deliver improvements. The goal was to build a multidisciplinary team of experts – a think tank – that would equal the levels of expertise deployed by the formal mining sector (smaller but same quality), and deliver technical and governance improvements to ASM.

Since then, the AGC has evolved into a globally recognized improvement agency. It became one of the few organizations worldwide with the sustainable development of the ASM sector as its core mission and exclusive focus. I raised 50M USD over 15 years in project funding and we had up to 80 staff at one point, but I never managed to wean it off “project funding” and into the think tank modality where its core operations were funded by an endowment. That was my operational goal since its inception, knowing from academia the intensive effort required to acquire and administer grants as well as navigate the whim of funding agencies.

The international development industry gave AGC a great start and I am very grateful for that, but it is a tough slog and far from perfect in terms of achieving results. Lots of politics that have nothing to do with ASM. Calling it a meritocracy would be generous.

As I became aware that the international development industry was going to be a slow pathway to ASM improvement, I began to see business development as a better method of engagement and improvement. So I transitioned from Executive Director in May 2023 to Advisor and remain such until today. I handed the reins over to wonderful and hard-working Roger Tissot who is doing his very best to craft a future for the AGC and is exploring new avenues to do so while its mission remains steadfast. The AGC continues to undertake projects across numerous countries. Its continuation and evolution speaks to the enduring relevance and critical need for the work it is focussed on.

I remain of the opinion that the ASM sector needs mining experts and scientists. At some level, gold mining is irreducibly complex. Exploration, land rights, permits, mining, metallurgy, waste management, occupational health, etc. These are part of every mining operation no matter how small. Mining simply can’t be managed casually without experience and expertise – certainly not in the manner that something like small-scale agriculture can.

How has your thinking evolved over the years around the ethics of gold sourcing and the true meaning of ‘responsible gold’?

That is a giant and provocative question. My answer really just scrapes the surface. What is meant by responsible gold depends on who you ask. If it is the downstream European luxury goods market, it is every cliché under the sun – all the ESG criteria and all 17 of the UN’s sustainable development goals (which shockingly never utter the word “mining” once, by the way) packaged into an incredible product that is doing enormous good. But the reality is that only the tiniest little dribble of a few tonnes of ASM’s 700 tonnes per year can enter this so-called “responsible gold” market, and it has been that way for 20 years. It is embarrassing how seriously blocked out of the market ASM gold and its millions of people have been for decades.

The banks, the giant miners, and the regulators have created a hegemonic market in which one needs enormous resources and expertise to enter. All ASM gold is effectively classified as “high risk” by the LBMA and its associated banks. LBMA-accredited refiners “de-risk” their supply chains simply by avoiding ASM gold altogether mainly due to the potential reputational risk (headline risk) and the high cost and complexity of performing due diligence (induced by the regulations). It is more expensive for a small supply of ASM gold to be certified as legitimate than it is for a huge supply from the giant corporations. It’s hard for me to see this as responsible.

Just 1% of millions of people’s very hard work is deemed acceptable to this downstream market. The rest, the other 99%, are more or less cast as criminals with endless headline-catching drama stories about “blood gold” and slavery that are absolutely not representative, but have become the dominant narrative. Since 1980 – a good starting date for the modern gold rush – demonization has been the name of the game for ASM. It’s the easy story. All you need is one photograph.

If you are speaking to basic artisanal miners who have been cast aside by the global markets because the fruits of their labour are not good enough (inexplicably to them), then responsible gold is a cruel joke. The awful part about this is that blocking the flow of artisanal gold to the international markets opened the door to workarounds and has rendered 99% of the ASM workforce and its operations vulnerable to predation by bad actors. It made it easy for smugglers and mafias to enter and profit at the expense of the small miners. The longer this blockage persists, the more entrenched the bad actors become.

Of course, there do need to be standards, but those in existence today are more like sanctions than standards. Of course, there are some terrible ASM operations and bad actors that should be eliminated. But it is not 99%! And who gets to decide that 10 million of the rural poor in 80 countries can only sell their goods to pirates? There is some serious paternalism going on, and there is some serious lack of appreciation of the west’s own roots – where artisanal and small-scale mineral production played a huge role in establishing its financial and industrial foundations. For example, the Toronto Stock Exchange and Newmont Gold were born on the backs of artisanal gold. And Donald Trump’s family wealth began from his grandfather’s participation in Canada’s gold rushes.

But of course, there is hope and a pathway to success and a role for any that want to participate. The OECD has a guidance system for sourcing ASM gold which I boil down to AGE’s company slogan “engage to improve”. The ASM sector needs help. It needs professionalization. But it can’t be helped if it is illegal or non-economical to engage with it. That is like saying, “ok, let me know when everything is perfect and then I’ll come back and buy your gold”. Recognizing that the enemy of the good is the perfect, the OECD’s guidance says that one can engage provided that two conditions are met: (1) There are no red flags present – red flags are worst forms of child labour, and involvement of terrorists. It’s easy to find many ASM operations that don’t have red flags – the majority; and (2) An improvement program needs to be developed to manage any yellow flags like poor environmental performance. The nature and timing of improvement programs is currently under discussion by the LBMA’s ASM task force with respect to its responsible gold guidance program.

In my opinion, 30% of global ASM gold should be able to enter the international market immediately through an “engage to improve” mechanism. And any new or reformed regulations and standards should be adapted to ensure that this key performance indicator is front and centre. 30% is a huge amount of gold (210 tonnes) and a huge number of deserving people.

So my thinking on the ethics of gold sourcing and the true meaning of ‘responsible gold’ has certainly deepened and expanded over the years. My early fixation on environmental performance, for example when authoring the global estimate for mercury use in ASM for negotiating the Minamata Convention on Mercury, has broadened after decades of direct engagement with miners in the field. To achieve the aspirational outcomes that many want for the ASM sector, the single most ethical and responsible action is inclusion. And not timidly. Policy needs to be re-shaped to this end.

In a nutshell: “buy their gold and help them improve”.

What are the biggest challenges ahead for the artisanal gold sector and what gives you hope?

My guess is that regulatory complexity and headline risk will continue to be a barrier and leave ASM largely orphaned. It is mostly the banks calling shots because the refiners and businesses can’t operate without intact banking relationships, and the banks really aren’t even at the table. Most people designing and promoting the regulations do not have any real “skin in the game” and so are unaware of the scale of the burden that the regulations create. Most are salaried employees of institutions or governments or NGOs or banks and do not directly bear the consequences of the policies they develop. And getting fingerprints on the policies (“authorship”) is part of the reward currency of this constituency which leads to bloat and virtue signalling. Because ASM is so poorly understood, largely avoided, and has very little voice, the administrative and financial burden being created by virtuous policies just isn’t calibrated to reality.

For example, AGE has opened a subsidiary in Dubai to import gold. It took 1.5 years, tens of thousands of dollars, a perfect pedigree, and many highly educated and experienced professionals to establish the company, get a bank account for trading gold, and get onboarded with a good delivery refinery. Then to onboard a new ASM supply chain required another giant effort with a local veteran ASM partner that took another six months, tens of thousands and highly experienced experts and professionals. Think about that. If AGE with its PhD’s and MSc’s and Engineers and Chartered Accountants and Lawyers and its decades of experience struggles, how can the gold industry or development industry expect progress on ASM to occur, let alone rapidly or at scale. I believe it is easier to open a junior mining company and list it on the Toronto Stock Exchange. That in itself is not easy but it is a familiar, well serviced, and well understood program. It is certainly easier to get the junior miner financed.

But again, it is important to point out the current realities, but there is hope. People and organisations are listening. Word of the importance of professionalising the ASM sector is spreading. The giant actors in the gold sector and the international development sector and the governments of ASM countries really do want improvements to happen. There is strong recognition that ASM is here to stay, that it is an absolutely fundamental part of the gold industry (especially in terms of employment and livelihoods), and that alternative approaches are required. I think that these actors have come to understand that the ASM sector will continue to grow and evolve with them or without them and they are therefore striving to find ways to participate. So despite the formidable obstacles, I remain hopeful for the future of the ASM Gold sector.

I think the path forward, and one in which there can be lots of opportunities for participation, is developing professional ASM businesses. These can act as examples of expertise and professionalism that can deliver improvements and education at scale. That is exactly what AGE is doing. We call these “Pro-Hubs”. These businesses can touch and improve even the distant corners of the supply chain. ASM is many things, but two of the clearest are that it is a business, and it is innovative. Business innovation is therefore the engagement strategy that will work. That is what I am doing now. Full-time business development and innovation in the artisanal and small-scale gold mining sector.

If you could send one message to the global gold industry about the value and potential of artisanal miners, what would it be?

Go into business with ASM, buy their gold, and install an improvement program. It is the real engagement mechanism. It is a Herculean task, but it is worth it. It will pay off. Engage to improve.

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