1. Company profile (all sources)
RFH Yancheng Jinye New Material Technology Co., Ltd., CID 003583, was established in 2015. Company address is located in No. 3 2nd Road Aoyang Industrial Park, Yancheng, Jiangsu Province. 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)
As a responsible company. We strictly abide by the relevant laws and regulations of our country and international norms. The RMAP audit was conducted by an independent third party UL from 11/13/2023 to11/14/2023. with an assessment starting date of 6/1/2022 and ending date of 10/31/2023, led by Roc Liao. This assessment summary report is posted on the RMI website:
https://www.responsiblemineralsinitiative.org/media/docs/Public%20Reports/RFH%20Yancheng%20Jinye%20Public%20Report.pdf
In 2023, our company complied with the OECD Guidelines on Global Responsible Supply Chain Due Diligence for Minerals in Conflict-Affected and High-risk Regions, sourcing and producing only tantalum ores assessed as low risk. The entire process was strictly controlled and firmly implemented in accordance with the requirements of the OECD five-step Framework and the Responsible Minerals Audit Process. This report is posted on the company's website：
http://www.yc-jinye.com/shehui.asp?cid=10
3. Company supply chain policy (all sources)
Our raw material procurement implementation of open, transparent procurement policy. In 2023, following the OECD Due Diligence Guidelines for Responsible Global Supply Chains for Minerals from Conflict-affected and High-risk Areas, in order to avoid the use of conflict minerals that directly or indirectly finance or benefit armed groups and/or are involved in other serious human rights violations in high-risk and conflict-affected areas, Illegal taxation or extortion, money laundering, minerals in violation of the Extractive Industries Transparency Action Plan (EITI), the development of a Supply Chain Policy and the integration of supply chain policies into contracts/agreements with suppliers. This policy is fully compliant with the requirements of the Model Global Responsible Supply Chain Policy for Minerals from Conflict-Affected and High-risk Regions (Appendix II of the OECD Guidance), which covers all the risks identified in Appendix II of the OECD Guidance and applies globally. The Company undertakes to address any Appendix II risks as soon as they are identified. This policy has been reviewed by senior managers, approved by the General Manager, and management is committed to supporting the implementation of this policy. This policy has been widely disseminated to stakeholders (suppliers, customers, employees, etc.) and published on the company's website:
http://www.yc-jinye.com/shehui_info.asp?pid=9
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, organize at least one due diligence management system training for all employees 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. On 10/26/2023, relevant management personnel and all employees were respectively trained; Two suppliers were trained in October and November respectively.
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 direct suppliers by phone, email, training, etc. The Company has incorporated its supply chain policies into specific legally binding contracts/agreements with 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 http://www.yc-jinye.com/shehui_info.asp?pid=15,
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. Compare the laboratory data with the certificate of origin of the mineral。
5.4 Further due diligence is required in the following areas of material procurement, supply, production or supplier activities:
a) The batch provided by the material is not within the compliant production period;
b) Lack of traceability documents;
c) Providing products beyond the previous production capacity;
d) Supplier's latest information is not updated and reported in time;
e) Other recognizable warning signals.
5.5 The Company reviews all information collected against CAHRA procedures, risk management procedures, local laws and internal procurement requirements. Check for reasonableness, figure out the origin, eliminate differences, and spot warning signs. According to the warning signal, compare and check the information about the supplier and the origin of the material, whether there is a red flag signal:
i) The origin of minerals or their transport routes through conflict-affected or high-risk areas;
ii) Known reserves in the country of alleged origin of the mineral, a country with limited possible resources or expected production levels (i.e. the claimed production of the mineral from that country does not correspond to its known reserves or expected production levels);
iii) The alleged country of origin of the mineral is a known transit country for minerals from conflict-affected and high-risk areas;
iv) Any other interest relationship between a supplier or other known upstream enterprise of the enterprise and a shareholder of the enterprise that supplies minerals or carries out operations in one of the above warning origin or transit places.
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.
