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Due Diligence And Risk Control Report For 2018

分类:新闻动态 作者:平台发布员 发布:2018-10-18

        

        Due Diligence And Risk Control Report For 2018 

        Guangdong Rising Rare Metals-EO Materials Ltd.

1、Company information

Guangdong Rising Rare Metals-EO Materials Ltd. is a 100% state-owned company which is one of Chinese’s leading smelters of tantalum , niobium metals.Its predecessor was Conghua Tantalum & Niobium Smeltery.It became a member of the Tantalum and Niobium International Study Center (T.I.C.) in 2002 and the formal member of ITSCI Program in 2013.

2. RMAP Assessment Summary

The company has undergone a RMAP assessment on 3th Sept 2017. The assessment is valid for one year. The assessment period was from 3th Sept 2016 to 3th Sept 2017. The assessment was conducted by Responsible Sourcing Audit Firm.

3. Company Supply Chain Policy

To avoid the use of conflict minerals, which directly or indirectly finance or benefit armed groups and/or involve other serious human right abuses in high-risk and conflict-affected regions, the company has developed a supply chain policy. The supply chain policy is fully aligned with the third edition of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). It covers all of the risks identified in Annex II of the OECD Guidance and its geographic scope is global. The company commit to deal with any Annex II risks if identified. The policy was reviewed and approved by senior management, which committed to support its implementation. The policy has been widely spread to relevant stakeholders (suppliers, customers, employees etc.) and is available on the company website at www.ctns723.com.

4. Company Management Systems

1)Management Structure

The company follows its commitments in the supply chain policy and has developed an internal procedure for due diligence with the following aspects: ?

*The company’s sale manager is responsible to oversee the due diligence program and risk management design and implementation.

Name: Chenxia Zi

Position:sale manager

Address: Taiping Town. Conghua District,Guangdong Province.China.

Tel:0086-20-87807290

*The program manager coordinate the work of the relevant departments (including Quality Department, Production Department,and Warehouse Management Department) to ensure each department follows up on their roles and responsibilities to implement the due diligence program and report any red flags and potential risks identified. ?

*The company conducts due diligence management system training once a year for key staff from all relevant departments required in due diligence program. If there is an update of the program, the company conducts additional training as necessary.

2)   Internal Systems of Control

 The company has updated its due diligence management system to be aligned with the OECD Guidance and RMAP in June 2018. The company communicated the updated supply chain policy and sourcing requirements to all identified upstream suppliers. The company has incorporated due diligence requirements into legally binding agreements with direct suppliers. The company refers to RMI’s grievance mechanism to collect information on grievances from interested parties.

3)      Record Keeping System

The company requires that all records relating to the due diligence program are maintained at least for five years and that they be properly used and safely

stored in our online company database.

5. Risk Identification

The company has a robust process to identify risks in the supply chain.

Firstly, referring to the risks in the company’s supply chain policy, the company established a procedure to identify CAHRAS. The procedure includes the resources used, the criteria to define a “conflict-affected and high-risk” area as well as the frequency with which our determination is reviewed. The company *uses the following resources to determine CAHRAS: The Heidelberg Conflict Barometer provides conflict maps, representing an annual snapshot of the presence of armed conflict. ?

*The INFORM Index for Risk

Management provides country-level risk profiles relating to humanitarian crises. Referring to its supply chain policy and external resources, the company has defined criteria and benchmark indicators to determine CAHRAs.

Secondly, the company designed a Know Your Supplier (KYS) to include information concerning supplier legal status and identity, supplier mapping and potential risks. The majority of our suppliers, representing 80 percent of our annual volume, have completed and returned a KYS form. The company’s due diligence program manager reviewed the provided information and the UN Sanction List with the Purchasing Team. Whenever inconsistencies, errors or incomplete information were identified in the KYS Responsible Minerals

the company communicated the improvement areas to suppliers and requested an updated form. If red flags were identified, the company would further engage with its suppliers to clarify and improve the documents as needed.

Thirdly, the company requested origin information for each material transaction and ensured that it was able to understand the transaction origin, transportation route, as well as direct suppliers’ names and locations.

Fourthly, all information collected was reviewed by the company against CAHRAS, sanction lists, local laws and internal sourcing requirements.

 Risk Assessment (HIGH RISK SOURCING ONLY)

For material and supply chains determined to be “high-risk”, the company conducted enhanced due diligence. This included:

 Assessing the context of CAHRAS;

Clarifying the chain of custody; ?

 Assessing the activities and relationships of upstream suppliers; ?

 Identifying locations and qualitative conditions of the extraction, trade, handling, and export of minerals; and Conducting on-the-ground assessments.

 In order to map the factual circumstances, conduct on-the ground assessments and assess risks in the high risk supply chains, we relied on the following: Participation in RMI recognized upstream assurance mechanisms:

 iTSCi: The company has been an active member of iTSC. For each high-risk sourcing transaction, iTSCi provides the following documents:

1) Incident summary reports as they become available

2) Mine Visit Recommendations including a list of mine sites with potential risks (it is advised that companies sourcing from these mine sites conduct enhanced due diligence and risk assessment)

3) Monthly country and region reports, which review the general situation on the ground

4) Data summary and other reports

The company has conducted further due diligence to review these documents from upstream program against information in the public domain and the actual transaction information to assess the level of risk.

6. Risk Mitigation (HIGH RISK SOURCING ONLY)

1iTSCi:

 The company checks with the ITSCi secretariat to obtain details of the risk mitigation process. The company seeks to: ?

 Identify the specific source of the material including the name of the producer and exporter ?

 Identify whether the reported risks have been addressed and/or are re-reported in the subsequent reporting period. ?

 Query the methodology for addressing the risks including who performed risk mitigation activities ?

 Request regular updates of the risk mitigation activities for relevant supply chains Scenario

7. Reporting on Risks beyond Annex II (OPTIONAL) We manage risks outside those identified by Annex II and use the RRA to report to our customers on how we manage those issues.

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