The Requesters state that Gécamines, “in agreement with the World Bank”, dismissed 10,655 employees and workers under the Voluntary Departures Operation (VDO), adding that the VDO would not have taken place if the World Bank was not a contracting party “to finance the restructuring of Gécamines.” They further add that the Bank imposed “the requirement to dismiss and pay a portion of the work force [that it] deemed excessive in its view.” The Requesters state that employees accepted to be part of the VDO because they hadn’t received their wages for 36 months. They also state that “it was only to escape certain death, or at least immediate impoverishment, that employees instinctively signed on to this operation.” They add that their signatures came “under material, moral, and psychological duress.” The Requesters refer to the application Article 78 of the Congolese Labor Code in matters arising between employers and workers, including en masse dismissal. They state that the Congolese labor laws and regulations pertaining to en masse dismissal were not followed. They add that “Gécamines and the World Bank granted former employees a miniscule amount, equivalent to one-fifth of what they were due, even though the campaign that was carried out to sign up these former employees had offered much more attractive payoffs.” They also add that the amounts granted “sufficed only to pay debts contracted to ensure their survival.” The Requesters further add that Gécamines and the World Bank did not even comply with the recommendations laid out as law in Presidential Decree 035/2003 of March 18, 2003. The Requesters enumerate the impacts of the VDO, stating that they include, among other: “impoverishment, dismantling and destruction of households, prostitution of girls who are still minors, juvenile delinquency among boys, lack of school enrollment for children, famine and malnutrition (one meal per day, or even one meal every other day), a spike in the morbidity rate (due to a lack of medical care) and the mortality rate among former employees (an average of 2.5 deaths per week at the present time).” The Requesters add that the former Gécamines employees, who worked in Gécamines for more than 25 years, are hopeless and “find themselves sentenced to a collective suicide.” They also add that former Gécamines employees’ hope resides in payment of their due. The Requesters state that based on the Universal Declaration of Human Rights, the DRC Constitution, and the Congolese Labor Law, they have undertaken steps to reestablish their rights “in all institutions of the Republic.” They add that “all institutions of the Republic have been unanimous in recognizing that [their] rights have been trampled upon and that there is a need to correct the harmful effects of the ill-conceived Voluntary Departures Operation by paying the final breakdown in full, in accordance with the spirit of Article 103 of the Congolese Labor Code, and as stipulated in Recommendation VII of the Permanent Framework for Social Dialogue.” The Requesters conclude that the VDO caused “the utter destitution” of 10,655 direct victims and roughly 350,000 “collateral victims,” asking for speed in the implementation of Recommendation VII of the Permanent Framework for Social Dialogue. In a separate communication, the Requesters state that they wrote to the World Bank on February 27, 2009, but “received no reply.” They also state that the Bank failed to take into account the “social management of the restructuring that it imposed on Gécamines.” They add that their “rights were violated, causing [them] intangible and tangible damages with multiple and serious consequences.” They ask the Panel to “open an inquiry aimed at resolving this social conflict.” In this regard, the Requesters ask for: “payment of 36 months’ of arrears in compensation, pension principal, payment of legally paid leave, all social benefits associated with the contract.” The Requesters authorize the Panel to publish the Request. (Second Registration Request, pgs 2-3, https://www.inspectionpanel.org/sites/default/files/ip/PanelCases/55-Second%20Notice%20of%20Registration%20%28English%29.pdf)