The company recognizes that mining, trading, processing, and exporting minerals in high-risk areas may have risks that may cause significant negative impacts, and recognizes that we have the obligation to respect human rights and not have a negative impact on society. The company promises to adopt and widely disseminate the ” United Nations Guiding Principles on Business and Human Rights, Guidelines for Social Responsibility of China’s Outbound Mining Investment Industry, and Due Diligence Guidelines for Responsible Mineral Supply Chains in China, and refer to the Organization for Economic Cooperation and Development on minerals from conflict-affected and high-risk areas Responsible Supply Chain Due Diligence Guidelines and other relevant guidance documents, and incorporate them into contracts and agreements with suppliers. This policy provides a reference for the conflict-sensitive procurement activities involved in the whole process of the mineral resource supply chain and the risk awareness of suppliers. The company promises to abide by the relevant United Nations sanctions resolutions, abide by the applicable domestic laws for the implementation of such resolutions, and will not participate in any behavior that will help or facilitate conflicts.
To this end, the company promises to identify and avoid the following risks in business activities:
- gross violations of human rights. The Company will neither tolerate nor in any way benefit, aid, assist or facilitate any party to perform: 1) the worst forms of child labor; 2) any form of torture, cruel, inhuman and degrading treatment; 3) Forced or compulsory labor of any kind, i.e. forced to perform all labor or services under the threat of punishment, without the consent of others; 4) Other serious violations and abuses of human rights, such as generalized sexual violence; 5) war crimes, crimes against humanity, genocide or other serious violations of IHL.
Risk management for serious human rights abuses: If the company has reasonable grounds to believe that an upstream supplier is sourcing from or associated with any party that has committed serious human rights abuses, we will immediately suspend or discontinue cooperation with that supplier.
2. Direct or indirect support to illegal organized armed groups and public or private security forces. The Company will not tolerate any direct or indirect support for non-state armed groups through mineral extraction, transportation, trading, processing or export. Provide “direct or indirect support” to non-State armed groups through the extraction, transportation, trade, processing or export of minerals, including but not limited to purchasing minerals from non-State armed groups or their affiliates, paying fees, or otherwise Provide logistical support or equipment, etc. 1) Illegal control of mining areas, or other means of controlling transportation routes, mineral resource trading locations, and upstream actors in the supply chain; 2) Illegal taxation or extortion of money at the entrance to the mining area, along the route leading to the mining area, or where mineral resources are traded or natural resources; 3) illegal taxation or extortion of middlemen, exporters or international traders.
Risk management for direct or indirect support to non-state armed groups: If the Company has reasonable grounds to believe that an upstream supplier is sourcing from or has a relationship with any party providing direct or indirect support to Where a business is in the supply chain, immediately develop, adopt and implement a risk management plan with suppliers and other stakeholders to prevent or reduce the risk of providing direct or indirect support to public or private security forces. If the risk management plan has not been implemented for six months, we will suspend or discontinue the cooperation with the supplier.
3. Corruption, money laundering and payments to the government. The company does not offer, promise, give or ask for any bribes, and resist bribes, and will not falsely report the taxes and fees that should be paid to the government for mining, trading, processing, transportation, export and other activities of mineral resources in order to conceal or falsify the origin of mineral resources. bribes and royalties.
Risk management of bribery, money laundering and payments to governments: Depending on where the company is in the supply chain, we commit to working with suppliers, central or local government agencies, international organizations, civil society and affected Third parties cooperate, as appropriate, to improve or track performance for the purpose of taking significant steps to prevent or reduce the risk of a negative impact within a reasonable time span. If the risk reduction measures have not been effective for six months, the company will suspend or discontinue cooperation with upstream suppliers.
4. Land rights, emissions and small workshops. The Company does not engage in, tolerate, or benefit from the exploitation of resources on lands without the free, prior, informed consent of key dignitaries and Aboriginal people, including mining under statutory title, lease, concession or license business. We do not participate in, tolerate or benefit from mining operations where the culture and heritage of local and indigenous peoples are not respected and protected, or that damage the traditional culture of local people.
The Company does not participate in, tolerate, nor benefit from the procurement of resources on land that is illegally obtained by legal title, lease, concession or license, or in violation of national laws and regulations. The company ensures that it avoids major adverse effects on the surrounding soil, air and water conditions, and serious violations of relevant local laws and regulations, including manufacturing, trading, and use that are subject to international exposure due to high toxicity to organisms, environmental persistence, or potential irreversible ecological effects Banned chemicals and hazardous substances, or emissions of arsenic and mercury.
The company agrees to ensure compliance with applicable laws and regulations on the management of hazardous chemicals and toxic and hazardous substances, and avoid manufacturing, trading, and using chemicals and hazardous substances that are subject to international bans due to their high toxicity to living organisms, environmental persistence, or potential irreversible ecological effects, among which Including strict control of arsenic and mercury emissions in accordance with the highest international standards, management of cyanide, ensuring that the disposal, storage and transportation of hazardous substances are in compliance with relevant laws and regulations, ensuring that there are no leaks, spills or other forms of release into the environment during the process . We prohibit the exploitation of resources in World Heritage Sites or legally protected areas, and the resulting threat to the Outstanding Universal Value of those properties.
Concerned about the risks of forced labor, child labor, unsafe working conditions, uncontrolled use of hazardous chemicals and other significant environmental impacts associated with small workshops or small-scale miners, the company seeks to establish relationships with small-scale workshops or small-scale miners in mining areas Relations of production.
Risk management for land rights, emissions and small workshops: If the company has reasonable grounds to believe that there is such a risk, we will immediately formulate and adopt with suppliers and other stakeholders based on the specific position of the company in the supply chain and implement risk management plans to prevent or reduce specific risks associated with land rights violations, significant adverse environmental impacts or associated with small workshops or small-scale miners. If the risk management plan has not been implemented for six months, we will suspend or discontinue the cooperation with the supplier.
5. Child labor is prohibited.
1) Principles for the protection of children’s rights: The company supports Article 3 of the Convention on the Rights of the Child promulgated by the United Nations in 1989: All actions concerning children shall take the best interests of children as the primary consideration. Article 32.1: Children have the right to be protected from economic exploitation and work that may interfere with or affect a child’s education or be harmful to a child’s health or physical, mental, spiritual, moral or social development.
2) Age of children in employment: The minimum age for employment specified in this Code is based on the Minimum Age at Work Convention of the International Labour Organization (Convention No. 138, 1973). According to the Convention, a “child” is any person under the age of 15. If the legal minimum age for employment or completion of compulsory education under the law of the supplier’s location is higher, the higher legal age shall prevail. However, for some individual developing countries, where the legal minimum age for employment in the supplier’s location is 14, the lower legal age shall prevail. The company also requires all upstream and downstream suppliers to abide by and implement the terms of this section, never employ children in the process of producing goods or providing services, and we solemnly promise to never employ children in the process of producing goods or providing services.
3) Employment management methods: The company should always have written employment management methods and clearly stipulate the minimum age of workers in the policy. Management methods must comply with applicable laws and regulations.
Risk management for child labor: For suppliers: If the company has reasonable grounds to believe that such a risk exists, immediately develop, adopt and implement with suppliers and other stakeholders based on the company’s specific position in the supply chain Risk management plan to prevent violations of children’s rights and employment of child labor. Once verified, it is required to make corrections within a time limit and suspend cooperation until the correction is completed. If the risk management plan has not been implemented for six months, we will suspend or discontinue the cooperation with the supplier.
For the company: The company requires the personnel department to strictly review the identity information of applicants during the recruitment process, and requires the personnel department to log in to the government website to verify the age of the applicant. If it does not meet the Chinese regulations on the minimum age of workers, it should not be recruited into the company. .
- Occupational Health and Safety. The Company is required to comply with all applicable laws related to workplace health and safety and to provide employees with training on safe workplace practices. We must provide a safe and healthy work environment, properly manage the handling of hazardous materials and equipment, and provide systems and training that help prevent accidents and injuries.
The Company shall establish procedures and systems to manage, track and report occupational injuries and diseases in the workplace. These procedures and systems should encourage workers to report accidents, classify and record work-related injuries and occupational diseases, investigate the cause of accidents and implement corrective programs to root out the underlying problem, provide necessary treatment, and assist workers in their recovery and return to work.
Risk management for occupational health and safety: If the company has reasonable grounds to believe that such risks exist, the company will immediately formulate, adopt and Implement a risk management plan to prevent violations of occupational health and safety. Once verified, it is required to make corrections within a time limit and suspend cooperation until the correction is completed. Otherwise, if the risk reduction measures taken by the company do not work, the company will suspend or interrupt cooperation with suppliers. The company’s specialized departments and responsible teams will follow the relevant policy documents and procedures (including risk reduction measures) formulated by the company in accordance with the “Occupational Health and Safety”.
- If a supplier violates the provisions of this code and fails to implement corrective actions within the agreed time limit, the company has the right to unilaterally suspend purchasing from the supplier without being liable for breach of contract until the supplier implements corrective measures and achieves significant improvement Results; have the right to unilaterally terminate the cooperative relationship with the supplier without bearing the responsibility for breach of contract, the loss and impact caused, and even the legal consequences shall be fully borne by the supplier.
Cobalt Supply Chain Due Diligence Policy and Commitment Download
