Document name: Responsible Sourcing Policy
Document No.: ZHL/H-003-2021
Prepared by: Wei Shengkun
Reviewed by: Chen Junyu
Approved by: Liu Jingxu
Effective date: June 1, 2021
Our company clearly recognizes the possible adverse effects of mining, processing, importing and exporting metal products from conflict-affected areas and high-risk areas and our responsibility to respect human rights and resist conflicts. The Company will strictly follow the national laws and regulations on employee rights, environmental protection, fair trade and other laws and regulations to ensure the legal sources of mineral gold and secondary gold. To this end, we make the following commitments:
I. Perform a zero-tolerance policy for large-scale abuse of human rights caused by the mining, transportation or transactions in metals:
1. Any form of torture and other cruel, inhuman or degrading treatments;
2. Any form of forced labor, that is, forcing anyone to work or provide services by threat rather than an individual wish;
3. The worst forms of child labor;
4. Crimes of violation and abuse of human rights such as sexual violence;
5. War crimes or other serious violations of international humanitarian law, crimes against humanity and genocide.
If we determine that the upstream supplier violates any of the above, we will interrupt or suspend our cooperation with the supplier promptly.
II Fraudulent misrepresentations on bribery, money laundering and mineral origin
1. Bribery offering and acceptance, fraudulent misrepresentation: offering, promising, carrying out or demanding any bribe, covering up or forging the mineral origin, falsely reporting the taxes, expenses and royalties payable to the government for mineral mining, trade, processing, transportation, export and other activities for bribery
2 Money Laundering: there is a money laundering risk arising from or related to the minerals obtained by mining, trade, processing, transportation or export of illegal taxation or extortion at the entrance of the mine site, along the transportation route, or at the place where the upstream supplier’s minerals are traded
If we determine that the upstream supplier involves bribery offering, bribery acceptance, money laundering, or fraudulent misrepresentation, or that the upstream supplier violates any of the above, we will suspend or interrupt our cooperation with the supplier promptly.
III. Non-compliance payment of taxes, royalties and management expenses payable to the government in the mining, trade and export of minerals in conflict-affected and high-risk areas
1. The upstream supplier or the mining area has not paid all legal taxes, expenses and royalties related to ore mining, trade and export in conflict-affected and high-risk areas to the government and has not effectively disclosed such payments according to the position of the upstream supplier in the supply chain and the principles of the Extractive Industry Transparency Initiative (EITI).
If we determine that the upstream supplier has not paid legal taxes, expenses and royalties in conflict-affected and high-risk areas and has not disclosed such payments in accordance with the principles of the Extractive Industry Transparency Initiative (EITI), we will suspend or interrupt our cooperation with the upstream supplier promptly (The Company will regularly (quarterly) update the list of EITI-related countries to ensure that the list of relevant countries is correct).
II. Perform a zero-tolerance policy for acts directly or indirectly supported by non-governmental armed groups (e.g. financing and conflict fuelling of terrorist organizations):
(Including but not limited to non-governmental armed groups, public or private security forces or their affiliates that commit the following acts:
1. Illegal control of mining sites or upstream suppliers of transportation routes, metal trading points and supply chains;
2. Illegal blackmail and extortion at the mine entrance, along the transportation line or at the metal trading point;
3. Illegal blackmail for middlemen, export companies or international traders, financing for terrorist organizations and conflict fuelling.
If we determine that the upstream supplier purchases minerals from or has a relationship with any party that provides direct or indirect support to non-state armed groups, or the upstream supplier violates any of the above, we will suspend or interrupt our cooperation with the supplier promptly.
III. Perform a zero-tolerance policy for illegal mining that does not comply with environmental and sustainable development laws:
1. Mined gold coming from small mines with incomplete domestic procedures;
2. Mined gold coming from world heritage sites or domestic natural ecological reserves.
If we determine that the upstream supplier violates any of the above, we will suspend or suspend the transaction and contact this supplier promptly.
IV. Prohibit offering, promising, giving or demanding bribes or kickbacks in any way to individuals, including government officials, customers, suppliers or any other organization.
V. Require our employees, suppliers and business partners to comply with the above policies and take necessary measures to ensure the implementation of the above policies.
We are willing to accept the supervision of customers and relevant organizations and favorably receive suggestions from suppliers and stakeholders on the above policies.