Yunnan Tin Co., Ltd.
Supply Chain Due Diligence Management Policy
Yunnan Tin Industry Co., Ltd. (hereinafter referred to as“the Company”) recognizesthe potential adverse impacts associated with mining, trading, processing, and exporting mineral resources in "Conflict-Affected and High-Risk Areas" and acknowledges our obligation to respect human rights and not contribute to conflict. We commit to adopting and widely disseminating the "Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains" (Second Edition), the "OECD Due Diligence Guidance for Supply Chain Due Diligence Management of Minerals from Conflict-Affected and High-Risk Areas" (Third Edition), and the content related to the "Responsible Minerals Assurance Process Standard for Tin and Tantalum."
This policy representing acommon reference for conflict-sensitive sourcing practices and suppliers’riskawareness from the point of extraction until end user. We commit to refraining from any action which contributes to the financing of conflict, to comply with relevant United Nations sanctions resolutions, and to committing our company to the due diligence steps described in the Tin and Tantalum Supplement of the OECD Guidance.
The Company commits to identifying and managingthe following risks in the supply chain operations:
I.Regarding serious abuses associated with the extraction, transport or trade of minerals:
While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to , assist with or facilitate the commission by any party of:
(i) Any form of torture, cruel, inhuman or degrading treatment;
(ii)Any forms of forced or compulsory labour, which means work or servicewhich is exacted from any person under the menace of penalty and forwhich said person has not offered himself voluntarily;;
(iii) The worst forms of child labour;
(iv)Other gross human rights violations and abuses such as widespreadsexual violence;
(v) War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
Regarding risk management of serious abuses:
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as definedabove.
II. Regarding direct or indirect support for non-State armed groups1;
We will not tolerate any direct or indirect support to non-State armed groups through mining, transportation, trade,handling or export of minerals.“Direct or indirect support”to non-State armed groups throughthe extraction, transport, trade, handling or export of minerals includes, but is not limited to, procuringminerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates2who:
i.illegally control mine sites or otherwise control3transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or
ii.illegally tax or extort4money or minerals at points of access to mine sites,along transportation routes or at points where minerals are traded;and/or
iii.illegally tax or extort intermediaries, export companies or internal traders.
Risk Mitigation Measures:
We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups.
III.Regarding public or private security forces:
We disagree to provide direct or indirect5support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.
We recognise that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
Where we or any company in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the international widely recognized standards6. In particular, we will support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired.
We will support efforts, or take steps, to engage with central or local authorities, international organisations and civil society organisations to contribute to workable solutions on how transparency, proportionality and accountability in payments made to public security forces for the provision of security could be improved.
We will support efforts, or take steps, to engage with local authorities, international organisations and civil society organisations to avoid or minimise the exposure of vulnerable groups, in particular, artisanal miners where minerals in the supply chain are extracted through artisanal or small-scale mining, to adverse impacts associated with the presence of security forces, public or private, on mine sites.
Risk Mitigation Measures:
In accordance with the specific position of the company in the supply chain, we will immediately devise, adopt and implement a risk management plan7with upstream suppliers and other stakeholders to prevent or mitigate the risk of director indirect support to public or private security forces, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan8.
IV.Regarding bribery and fraudulent misrepresentation of the origin of minerals
We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.9
Regarding money laundering
We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals derived from the illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.
Regarding the payment of taxes, fees and royalties due to governments10:
We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the company's position in the supply chain, we commit todisclose such payments in accordance with the requirements of host country onthe disclosure of tax information paid to government departments.
Risk Mitigation Measures:
In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organisations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measureable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation. Companies should conduct an additional risk assessment. on those risks requiring mitigation after the adoption of the risk management plan. If within six months from the adoption of the risk management plan there is no significant measurable improvement to prevent or mitigate the risks of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees and royalties to governments, companies should suspend or discontinue engagement with the supplier for a minimum of three months. Suspension may be accompanied by a revised risk management plan, stating the performance objectives for progressive improvement that should be met before resuming the trade relationship.
The Company will integrate this policy into the company management system and the responsibilities of related departments based on the principle of continuous improvement. This policy also applies to all the Company's suppliers, and we will take active measures to disseminate the policy to our suppliers. The policy will take effect from the date of publication and will be posted on the Company's website.
1 Enterprises should identify non-state armed groups in accordance with UN Security Council resolutions.
2 "Affiliates" includes traders, consolidators, intermediaries, and others in the supply chain that work directly with armed groups to facilitate the extraction, trade or handling of minerals.
3 "Control" of mines, transportation routes, points where minerals are traded and upstream actors in the supply chain means i) overseeing extraction, including by granting access to mine sites and/or coordinating downstream sales to intermediaries, export companies or international traders; ii) making recourse to any forms of forced or compulsory labour to mine, transport, trade or sell minerals: or iii) acting as a director or officer of, or holding beneficial or other ownership interests in, upstream companies or mines.
4 "Extort" from mines, transportation routes, points where minerals are traded or upstream companies means the demanding, under the threat of violence or any other penalty, and for which the person has not voluntarily offered, sums of money or minerals, often in return for granting access to exploit the mine site, access transportation routes, or to transport, purchase, or sell minerals.
5 "Direct or indirect support" does not refer to legal form of support, including legal taxes, fees, and/or royalties that companies pay to the government of a country in which they operate.
6 Such as Voluntary Principles on Security and Human Rights.
7 If force majeure factors such as tsunamis, earthquakes, fires, epidemics, wars, etc, are encountered during the implementation of the risk management plan, the timeline can be adjusted accordingly, but a written explanation should be provided.
8 Companies should conduct an additional risk assessment on those risks requiring mitigation after adopting risk management plan. Within six months from adopting risk management plan, if there is no significant measurable improvement to prevent or mitigate the risk of direct or indirect support to public or private security forces, companies should suspend or discontinue engagement with the supplier for a minimum of three months. Suspension may be accompanied by a revised risk management plan, stating the performance objectives for progressive improvement that should be met before resuming the trade relationship.
9 See OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions(1997); and the United Nations Convention Against Corruption (2004).
10 The company advises suppliers to comply with transparency requirements of their countries, such as suppliers in EITI member countries adhering to the principles and standards proposed by the Extractive Industries Transparency Initiative.
