1.供應鏈風險識別 1. Risk identification of supply chain 根據經合組織《來自受沖突影響和高風險地區礦石負責任供應鏈盡職調查指南》附件Ⅱ并擴展至環境和可持續性責任,我公司識別原料從產地到精煉廠的供應鏈相關風險,風險包括: Our company identified risks related to the supply chain of raw materials from the place of origin to the refinery in accordance with Annex II of OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas as well as its extension content including environmental and sustainability responsibilities. The risks include: 1)與黃金(白銀)提取、運輸或交易相關的有預謀的人權侵犯行為、強迫勞動行為、違法使用童工行為和民族歧視行為; 1) Premeditated human rights violations related to the withdrawal, transportation or trading of gold (silver), forced labor, illegal employment of child labor and ethic discrimination; 2)直接或間接支持非政府武裝組織或黑社會性質的保安部隊的行為; 2) Direct or indirect support of non-governmental armed organizations or underworld security forces; 3)對黃金(白銀)來源存在賄賂、隱瞞、欺詐行為; 3) Bribery, concealment and fraud on the source of gold (silver); 4)供應商或上游公司可能存在洗錢行為和金融恐怖等活動; 4) Possible money laundering and financial terrorism, etc. of suppliers or upstream companies; 5)為沖突提供捐助的行為。 5) Donations for conflicts. 6)礦產金或再生金利用汞生產而得; 6) Utilization of production of mercury for mineral gold or regenerated gold; 7)不遵守環境和可持續發展法律要求,礦產金或再生金源于世界遺產遺址或國內自然生態保護區。 7) Illegal source of mineral gold or regenerated gold originating from World Heritage Sites or domestic natural ecological reserves, which fails to comply with legal requirements of environmental and sustainable development. 2.供應鏈風險調查 2. Risk investigation of supply chain 我公司按照《黃金(白銀)供應鏈盡職調查政策》(QKSF/LBMA/WJ-01)和《黃金(白銀)供應鏈風險辨別及評估程序》(QKSF/LBMA/WJ-06)要求,在與供應商簽訂合同之前,填寫《黃金(白銀)供應鏈盡職調查表》。對于每個供應商,為其建立客戶檔案,收集客戶相關信息,并根據我公司的風險評估標準進行分類。充分了解供應商公司性質、注冊地址、原料產地、有效資源、相關收益方均合法經營且無犯罪記錄,并評估其財務信息、環境合規信息等。合規專員對此負責進行審查。對于礦產金銀,要求供應商提供采礦許可證或進出口許可證和證明其遵守環境保護及可持續發展相關規定等,確保符合OECD的相關規定。對于回收金,檢查供應商是否上過中華人民共和國公安部網站公布的恐怖組織名單,并通過國家企業信用信息披露系統平臺和個人征信系統查詢是否有違反盡職調查政策的記錄。通過調查,識別黃金白銀供應商是否存在強迫勞動、侵犯人權和非法使用童工及民族歧視的行為。 As specified by Gold (Silver) Supply Chain Due Diligence Policy (QKSF/LBMA/WJ-01) and Gold (Silver) Supply Chain Risk Identification and Evaluation Procedures (QKSF/LBMA/WJ-06), our company filled in the Gold (Silver) Supply Chain Due Diligence Form before signing the contract with the supplier. In addition, our company established a customer profile, collected customer-related information and made classification for each supplier according to risk assessment standards of our company. Our company comprehensively understood the nature of the supplier’s company, registered address, origin of raw materials, effective resources and related profit parties, as well as whether the relevant beneficiaries are legally operating without criminal records, and evaluated its financial information, environmental compliance information, etc., which was reviewed by the Compliance Officer. For mineral gold and silver, suppliers were required to provide mining licenses or import and export licenses as well as certificates proving that they have complied with relevant regulations of environmental protection and sustainable development, etc. so as to ensure compliance with relevant regulations from OECD. For the regenerated gold, whether the supplier has been listed on the website of the Ministry of Public Security of the People’s Republic of China as the terrorist organizations was checked, and whether there is a record of violation of due diligence policy through the platform of national enterprise credit information disclosure system as well as personal credit information system was confirmed. Moreover, our company identified whether cases including forced labor, human rights violations, legal employment of child labor and ethic discrimination concerning gold and silver suppliers occured through investigation. 3.供應商風險評估 3. Supplier risk evaluation 我公司按照《黃金(白銀)供應鏈盡職調查政策》和《黃金(白銀)供應商風險辨別及評估程序》對所有與公司簽訂合同的供應商進行評估。 Our company evaluated all suppliers that have signed contracts with us in accordance with Gold (Silver) Supply Chain Due Diligence Policy and Gold (Silver) Supply Chain Risk Identification and Evaluation Procedures. 如果存在上述風險,我公司將該供應商標注為高風險供應商,且不與之簽訂合同。如果懷疑供應商有發生上述行為的可能性,先定為暫緩合作,待補充相關材料,直到消除風險后,定位低風險供應商,方可簽訂合同,同時加強隨時的監督。 In case of above risks, our company would regard them as high-risk suppliers and would not sign a contract with them. In case of any suspicion concerning the supplier for the possibility of the above-mentioned illegality, the cooperation would be suspended and relevant materials would be added. The contract would not be signed before that the risk was eliminated and the supplier was positioned as a low-risk supplier. Meanwhile, supervision at any time would be strengthened. 2021年在遷廠期間,我公司對3家黃金供應商和1家白銀供應商,按照《黃金(白銀)供應鏈風險辨別及評估程序》進行了評估,均為低風險。均按照LBMA及上海黃金交易所相關要求進行,排除了可能存在的風險。對于每一個新增的供應商,合規小組專門組織公司高管參加會議,進行合規審核,各項資質符合合規要求。 During the refinery relocation in 2021, our company evaluated 3 gold suppliers and 1 silver supplier according to Gold (Silver) Supply Chain Risk Identification and Evaluation Procedures, all of which were rated as low-risk supplier. In addition, all matters were carried out in accordance with relevant requirements of the LBMA as well as Shanghai Gold Exchange, which eliminated possible risks. For each new supplier, the compliance team specially organized the senior executives of the Company to attend meetings and conduct compliance audits to confirm that all qualifications met the compliance requirements. 4家供應商均屬于中國境內,物料分別來源于內蒙古和深圳。 4 suppliers are all located in China, and the supply origin of materials is Inner Mongolia and Shenzhen. 在對幾家供應商評估中,對每批次的進貨記錄、化驗單、運輸憑證等均要保留,并按客戶檔案做好登記,并通過財務合規專員控制資金往來。 It is required to keep the purchase records, laboratory inspections, transportation vouchers, etc. of each batch, complete registration according to the customer file, and control the capital transaction by the Financial Compliance Officer. 合規專員在與供應商簽訂合同時,都會向合規總監和公司高管層報告相關情況,避免可能存在的風險。公司合規總監和公司高管層對供應商的最終結果具有決定權。 The Compliance Officer will report the relevant information to the Compliance Director and the Company’s senior management when signing a contract with a supplier to avoid possible risks. The Company’s Compliance Director and the Company’s senior management are entitled to decide on the supplier’s final results. 3. 向指定高級管理層報告高風險并評估 3. Report of high risks and evaluations towards designated senior management 公司建立了高風險評估和報告機制,遇到黃金白銀供應鏈存在高風險情況,立即向合規總監趙蘭芳和高級管理層匯報,并組織專門會議審核討論。 The Company has established a high-risk assessment and reporting mechanism. As a result, it is required to immediately report to the Compliance Director Zhao Lanfang as well as senior management, and organize a special conference for review and discussion in case of high-risk in the gold and silver supply chain. 在2021.1.1-2021.07.15 期間我公司沒有發現高風險供應鏈。 High-risk supply chain in our company was not found during 2021.1.1 to 2021.07.15. 結論:我公司已經充分遵守了第二步驟,對供應鏈中的風險進行識別與評估。 Conclusion: The Company has fully complied with “Step 2: Identify and evaluate risks in the supply chain” |