RFH Yancheng Jinye New Material Technology Co., Ltd. recognizes that mining, trading, processing, and exporting minerals in conflict-affected and high-risk areas may have major negative impacts, and recognizes that we have the obligation to respect human rights and not contribute to conflicts. We are obligated not to have a negative impact on the environment and society. We promise to adopt and widely promote the following responsible mineral procurement policies for conflict-affected and high-risk areas, and incorporate them into contracts and/or agreements signed with suppliers. This policy provides a basic reference for the whole process of our company's mineral resources supply chain, conflict-sensitive procurement activities, and suppliers' risk awareness. We are committed to complying with the "OECD Due Diligence Investigation on the Global Responsible Supply Chain of Minerals in Conflict-affected and High-risk Areas" Comply with applicable domestic laws to implement such resolutions. We promise that our company will conduct due diligence on mineral origin and chain of custody in accordance with the OECD Due Diligence Guidelines, and incorporate into our due diligence management system the risk-based five-step Framework principles for mineral supply chain due diligence in conflict-affected and high-risk areas, as well as the Additional Content on Tin, Tantalum and Tungsten. We promise that the company will not directly or indirectly benefit armed groups that seriously violate human rights in the Democratic Republic of Congo or neighboring countries by purchasing tin, tantalum, and tungsten gold.
To this end, we are committed to identifying and avoiding the following risks in our business activities:
1. Serious violations of human rights
●We neither tolerate nor in any way benefit, facilitate, assist or facilitate the implementation of any party:
● Any form of torture, cruel, inhuman and degrading treatment;
●Any form of forced or compulsory labor. Forced or compulsory labor refers to any labor or service that is squeezed out of any individual under the threat of punishment and not provided voluntarily by that person;
●The worst forms of child labor;
●Other serious violations and violations of human rights, such as widespread sexual violence;
●War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
reduce risk:
If we have reasonable grounds to believe that the upstream supplier has purchased or is associated with any of the above-mentioned serious human rights violations, we will immediately suspend or interrupt the cooperation with that supplier.
2. Direct or indirect support for non-state armed groups and public or private security forces
We will not tolerate any direct or indirect support for non-state armed groups through mining, transportation, trading, processing or export of minerals. Providing "direct or indirect support" to non-state armed groups through mining, transportation, trading, processing or export of mineral resources includes, but is not limited to, purchasing minerals from non-state armed groups or their affiliates, making payments to them, or in other ways Provide logistical support or equipment for it. These armed groups or related parties:
●Illegal control of mine sites, or other means to control transportation routes, mineral trading points, and upstream actors in the supply chain;
●Illegal taxation or extortion of money or minerals at the entrance of the mine site, along the transportation route or at the mineral transaction point;
●Illegal taxation or extortion of middlemen, export companies, or international traders.
We will stop illegally controlling mine sites, transportation routes, and upstream participants in the supply chain, illegally levying taxes or asking for money or minerals at the entrance of the mine site, along the transportation route or at the mineral transaction point, or from middlemen, export companies or international traders Public or private security forces that illegally levy taxes or conduct blackmail provide direct or indirect support.
We recognize that the role of public or private security forces along the mine site and/or its surrounding areas and/or transportation roads is only to maintain the rule of law, including the protection of human rights, the protection of miners, the safety of equipment and facilities, and the protection of mine sites or transportation routes. Legal mining and trade are not disturbed. We will support or take measures to cooperate with local governments, international organizations and civil society organizations. The mineral resources in the supply chain are mined through small workshops or small-scale mining methods to avoid or minimize the presence of public or private security forces. The negative impact of mining sites on disadvantaged groups, especially the negative impact on small workshop miners.
reduce risk:
If we have reasonable grounds to believe that the upstream supplier purchases from or is associated with any party that provides direct or indirect support to non-state armed groups, we will immediately suspend or discontinue cooperation with that supplier.
When we identify the existence of such risks, we will immediately formulate, adopt and implement risk management plans with upstream suppliers and other stakeholders based on the company’s specific position in the supply chain, so as to prevent or reduce public or The risk of private security forces providing direct or indirect support.
In this case, if the risk management plan is not effective for six months, we will suspend or discontinue cooperation with upstream suppliers.
3. Regarding bribery and fraudulent misrepresentation of the origin of minerals, money laundering and various fees paid to the government
We will not offer, promise, conduct or demand any bribes, and resist the temptation. We will not falsely report the taxes, fees and concessions paid to the government for activities such as mining, trading, processing, transportation, and export of minerals in order to conceal or falsify the origin of minerals. Bribery for mining fees.
If we have reason to believe that there are mining, trading, processing, transportation or export of mineral resources caused by illegal taxation or blackmail at the entrance of the mine site, along the transportation route, or the upstream supplier's mineral resource transaction place. For related money laundering risks, we will support or take measures to contribute to the effective elimination of money laundering.
We will ensure that all legal taxes, fees and royalties related to the mining, trading, and export of mineral resources in conflict-affected and high-risk areas are paid to the government, and we are committed to comply with the Extractive Industry Transparency Action Plan based on the company’s position in the supply chain. 》(EITI) principles in the disclosure of such payments.
reduce risk:
If we have reasonable grounds to believe that such risks exist, we promise to cooperate with suppliers, central or local government agencies, international organizations, civil society, and affected parties as appropriate, based on the company’s position in the supply chain. With the aim of taking significant measures within a reasonable time span to prevent or reduce risks with negative impacts, to improve or track performance. If the risk reduction measures do not work, we will suspend or discontinue cooperation with upstream suppliers.
The personnel responsible for due diligence of the supply chain of Yancheng Jinye New Material Technology Co., Ltd. are:
Li Rongfeng
Phone: 18862073836
Mail: lyfyuxin@foxmail.com
Approver:
Date:
This policy is effective from October 16, 2019
Revised on May 13, 2024
