1. Company profile (all sources)
Yancheng Jin Ye New Material Technology Co., Ltd. (Jin Ye Company for
short), CID 003583, was established in 2015. Company address is located
in Yancheng, Jiangsu Province, Aoyang Industrial Park, No. 3 2nd Road.
The main production of niobium oxide, tantalum oxide, sold to the
domestic market, the company is to high purity niobium oxide, tantalum
oxide products development, production of higher value-added products,
strive to enter the international market.
2. Summary of RMAP Evaluation (all sources)
Be a responsible company. The RMAP audit was conducted by an
independent third party commissioned by RMI in March 2021. We strictly
abide by the relevant laws and regulations of our country and
international norms. In 2021, our company complied with the OECD
Guidelines on Global Responsible Supply Chain Due Diligence for Minerals
in Conflict-Affected and High Risk Areas by sourcing and producing only
tantalum ores assessed as low risk. The whole process is strictly
controlled and implemented in accordance with the requirements of the
OECD Five Step Framework and the Responsible Mineral Examination
Process. The report on the company website (/news/6/).
3. Company supply chain policy (all sources)
Our raw material procurement implementation of open, transparent
procurement policy. In 2021, following the OECD ore affected by conflict
and high-risk regions responsible for global supply chain guide due
diligence, to avoid the use of direct or indirect funding armed groups
or make them benefit conflict minerals, and/or involved in and affected
by the conflict areas at high risk of other serious human rights
violations, illegal tax or blackmail, money laundering, in violation of
the extractive industries transparency action plan (EITI) conflict
minerals, established the policy of supply chain, and the supply chain
policy included in the contract/agreement with suppliers. This policy is
fully consistent with the Model Policy for a Global Responsible Supply
Chain for Minerals in Conflict-Affected and High Risk Areas (Annex II of
the OECD Guide), which covers all the risks identified in Annex II of
the OECD Guide and applies globally. The Company undertakes to deal with
any Appendix II risk as soon as it is discovered. This policy is
reviewed by senior managers and approved by the general manager. The
management is committed to supporting the implementation of this policy.
This policy has been to the stakeholders (suppliers, customers,
employees, etc.), in the company's web site /news/5/.
4. Company management system (all sources)
4.1 Our company strictly abides by its commitment in supply chain
policies and has developed due diligence plans in the following aspects:
1) The General Manager is responsible for overseeing the design and
implementation of the due diligence system and risk management.
2) Li Rongfeng has been appointed Senior Manager to implement the due
diligence system, coordinate the work of relevant departments (including
Social Responsibility Department, Supply and Marketing Department,
Production and Technology Department, General Affairs Department and
Quality Department), ensure that all departments are responsible for
their duties, conduct due diligence, and report any warning signs and
potential risks that are found.
3) According to the requirements of the due diligence system, Company
has carried out due diligence management system training for key
personnel of all relevant departments every year, and included it in the
induction training for new employees. If the system is updated, the
company will carry out additional training according to the need.
4) Senior managers organize a management review at least once a year.
Analyze changes in internal and external factors, needs and expectations
of stakeholders, implementation degree of company policies and
commitments, management process performance, status of improvement
actions, results of internal and external audit, resource adequacy,
etc., report audit results and continuous improvement plan to general
manager.
4.2 Internal control system
1) Company has set up a due diligence management system and formulated
the Due Diligence Management Manual. Control the process of supplier
selection, approval and material flow through enforcement, Supplier
Management Procedures, Internal Raw Material Control Procedures,
Labelling and Traceability Procedures, etc. Implement a quality balance
assessment throughout the process to be consistent with OECD guidelines
and RMAP.
2) Company has communicated updated supply chain policies and
procurement requirements to all its direct suppliers. The Company has
incorporated its supply chain policies into specific legally binding
contracts/agreements with its direct suppliers. The company inspects
100% of the direct suppliers once a year, accounting for 100% of the
annual sales volume, and conveys the risk assessment report to the
suppliers. Spare no effort to improve supplier performance, if
necessary, organize relevant personnel for supplier training and
capacity building.
3) Company established a "complaint management procedure", and on site
(/news/8/), senior manager's contact information as the complaint
channel, accept the supervision of the society from all walks of life.
RMI's appeal mechanism is also available.
4.3 Record Retention System
The company requires that all records relating to the due diligence
system be kept for at least five years. Implement Document Record
Control Procedure. Paper documents must be stored separately in filing
cabinets and protected against moisture, mildew and moths. Electronic
documents and records using computer processing backup, timely
anti-virus, to ensure the safety of documents and records.
5. Risk identification
5.1 The Company shall implement the Procedures for Identifying
Conflict-Affected and High Risk Areas to identify high risk areas. This
includes the resources used, the identification of thresholds for
"conflict-affected and high-risk" areas, and the frequency. The company
uses the following resources to determine CAHRA:
1) The Dodd-Frank Act, the EU List, and the Heidelberg Conflict Barometer, which reveal areas of armed conflict;
2) The Global Corruption Perceptions Index reflects the risk profile of national governance;
3) The Human Freedom Index looks at the scope and extent of human rights.
5.2 The Company has designed a set of Supplier Management Process to
understand suppliers, including information about the legal status and
identity of suppliers, analysis of suppliers and potential risks. All
our suppliers have completed and returned the KYC form. The company's
senior managers, together with the procurement team, reviewed the
information provided and the United Nations sanctions list. Where
inconsistencies, errors or incomplete information are found in the KYC
forms, the Company will work further with the Supplier to clarify and
improve the documentation as needed. During the reporting period, no
warning signals were detected in relation to the KYC forms submitted.
5.3 For each transaction, the Company requires the Supplier to provide
origin information and, if necessary, legal transportation routes and
upstream supply chain information.
5.4 The Company reviews all information collected against CAHRA
procedures, risk management procedures, local laws and internal
procurement requirements.
6. Risk assessment and risk mitigation
6.1 The Company shall implement the Risk Management Procedures to assess and mitigate risks in the supply chain.
6.2 For each transaction from a high risk region, the risk is assessed.
The evaluation report is reported to the general manager and
communicated to the supplier.
6.3 Conduct enhanced due diligence on materials and supply chains
identified as "high risk" in accordance with the risk identification
method. This includes:
A) Assess the background of CAHRA;
B) Clarify the chain of custody;
C) Assessing the activities and relationships of upstream suppliers;
D) Identification of locations and quantitative conditions for the extraction, trade, treatment and export of ores;
E) Conduct on-site risk assessment.
6.4 In order to analyze the actual situation, carry out field assessment
and assess the risks in the high-risk supply chain, we have developed
field assessment plans and procedures.
6.5 Develop a feasible risk mitigation plan in consultation with
suppliers, local and central authorities and affected stakeholders.
Risk mitigation strategies include:
A) Continue to trade throughout the measurable risk management process.
B) Temporary suspension of trade while risk reduction continues.
C) Termination of cooperation with suppliers in the event that risk mitigation measures are not feasible or acceptable.
6.6 The risk management plan shall be reported to the general manager
and conveyed to the supplier, and the relevant departments shall
supervise the implementation of the plan regularly.
6.7 During this evaluation period, the Company has no "high risk"
purchases and no risk mitigation plan is currently in operation.
