The Requesters claim that the “World Bank financed the design, evaluation, and implementation of the operation known as ‘Voluntary Departures,’ which resulted in the dismissal of 10,655 Gécamines workers from August 11, 2003 to February 6, 2004 in exchange for severance payments ranging from US$1,900 to US$30,000.” They state that the reintegration effort, in the form of social assistance and training, for employees who voluntarily left their work at Gécamines, should mean that the employees receive their severance allowance and be engaged in individual or collective activities enabling them to earn the necessary income for their own survival and that of their dependents. The Requesters state that the Bank adopted “special rules and procedures for adopting the loan of US$43,483,422 intended ‘to facilitate the departure of employees freely seeking to end their careers in the enterprise.’” According to the Requesters the conditions determined by the Bank, including the payment of a lump-sum amount, are in contravention of the provisions of Articles 67, 78, 100, 144, and 152 of the Congolese Labor Code. They add that each employee was presented with a standard transaction instrument entitled “Agreement to terminate the labor contract by mutual agreement” which each had to sign in exchange for a letter of credit drawn up by the Katanga Reintegration Coordination Unit in order to collect the severance payment at the a bank in Likasi. They state that “under pressure from the World Bank,” Gécamines dismissed an initial tranche of 10,655 employees in contravention of the Congolese Labor Code. In addition, they claim that the supervisory authority of Gécamines, with approval from the World Bank, ignored the legal standards and the conventions that the government had agreed to for the settlement of wage arrears and the payment of final reckonings to the Gécamines employees. They add that their “rights and interests were directly and negatively affected by the criminal participation of the World Bank in violating the contractual obligations between our former employer Gécamines and each of us.” They further add that this has deprived them of wage arrears and the final reckoning to which each of them is entitled, and which they should have collected if their contracts had not been terminated in this manner. They also add that they are “deprived of all other social advantages (…) and have lost all acquired benefits of any kind.” They state that this sudden adaptation to “a life of poverty” has caused great harm to the victims of the Voluntary Departures Operation such as themselves. The Requesters also claim that the assistance programs for former Gécamines employees were limited. They state that the Katanga Reintegration Coordination Unit, in the small project support program and the “KUJENGA UHURU” program, supported only activities involving selfpromotion and “automatically covered only a portion of the former Gécamines employees, selected as being those most motivated and with the greatest potential, so as to permit them to achieve the objectives of their economic reintegration.” According to the Request, one of the Requesters has been placed on retirement by Gécamines and the other is unemployed and not receiving adequate support. Also, the Request makes references to a civil lawsuit between one of the Requesters and another employee of Gécamines. The Requesters state their different “rights and interests,” according to DRC laws and to an agreement signed between Gécamines and labor unions. They also state that “the World Bank failed to observe its rules and procedures in the context of the programs agreed with the Congolese government on the restructuring of Gécamines with a view to finding an honorable solution to reducing the labor costs of our former employer Gécamines and properly indemnifying the [Gécamines employees].” (First Notice of Registration, 'The Request', pgs 2-3, https://www.inspectionpanel.org/sites/default/files/ip/PanelCases/54-First%20Notice%20of%20Registration%20%28English%29.pdf)