Human Rights Action Group and Hidmonna Eritrean-Canadian Human Rights Group vs. Alpha Exploration Ltd.

Allegations

On 30 March 2026, Human Rights Action Group and Hidmonna Eritrean-Canadian Human Rights Group filed a complaint against Alpha Exploration Ltd. at the Canadian NCP. The complaint concerns Alpha’s mineral exploration activities at the Kerkasha Project in Eritrea and its business relationship with the state-owned Eritrean National Mining Corporation (ENAMCO).

The complaint alleges that Alpha’s wholly owned Eritrean subsidiary Alpha Exploration Eritrea Limited holds the rights to the Kerkasha Project, a mineral exploration project in Eritrea. According to the complaint, Alpha has agreed to give the Eritrean government the right to a 10% free-carried interest in any mining project developed within the Kerkasha Project area and the right to another 30% participating interest. Although the Project is still in the exploration phase and that ENAMCO’s participation rights have not yet been exercised, the complaint claims that based on documented evidence around forced labour in relation to Eritrea’s national service system and its use in state-owned enterprises in the mining sector, there is a risk that forced labour could arise in connection with the Kerkasha Project. The complaint further alleges that revenues from mining activities flowing to the Eritrean state risk contributing to broader human rights abuses by the Eritrean government. The complaint further points to the lack of evidence that Alpha has adopted a human rights policy or undertaken human rights due diligence to address these risks.

Relevant OECD Guidelines

• Chapter IV
• Chapter IV Paragraph 1
• Chapter IV Paragraph 2
• Chapter IV Paragraph 3
• Chapter IV Paragraph 4
• Chapter IV Paragraph 5
• Chapter IV Paragraph 6

Outcome

In September 2026, the Canadian NCP published its initial assessment. It found that the complaint satisfied the six admissibility criteria. Although Alpha is headquartered in the British Virgin Islands and the issues take place in Eritrea, the NCP considers that the company has a sufficient connection to Canada as its shares are listed on the TSX Venture Exchange. The NCP further stated that after the filing of the complaint, Alpha had provided the NCP information around its approach to human rights and published its Human Rights Policy in early September 2026. The NCP noted that the information provided did not address the due diligence undertaken in relation to the Kerkasha Project in detail, and that the implementation of the Policy remains relevant to the dialogue between the parties. In relation to the risk of contributing to broader human rights abuses by the Eritrean government through mining revenues, the NCP further found that as the project remained at the exploration stage, the issue related primarily to potential future financial benefits. The NCP therefore did not accept this issue for further consideration.

The NCP offered its good offices to the parties on Alpha’s human rights due diligence for the Kerkasha Project, including the implementation of its Human Rights Policy, its approach to identifying, assessing, preventing and mitigating potential adverse impacts, and how it addresses human rights risks associated with its relationship with ENAMCO.

More details

Documents

• Partially accepted

  7 October 2026

  Initial assessment

  NCP