供应链政策（Supply Chain Policy）
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Policy For Responsible Global Supply Chain of Minerals
Recognising that risks of significant adverse impacts which may be associated withextracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and recognising that we have the responsibility to respect human rights and not contribute to conflict, we commit to adopt, widely disseminate and incorporate in contracts and/or agreements with suppliers the following policy on responsible sourcing of minerals from conflict-affected and high-risk areas, as representing a common reference for conflict-sensitive sourcing practices and suppliers’ risk awareness from the point ofextraction until end user. We commit to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.
Regarding serious abuses associated with the extraction, transport or trade of minerals:
1. 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 forms of torture, cruel, inhuman and 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 for which said person has not offered himself voluntarily;
iii) the worst forms of child labour;
iv) other gross human rights violations and abuses such as widespread sexual violence;
v) war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
2. 如果我们有合理理由认为该风险存在，即上游供应商正从实施第 1 条所规定的严重侵权行为的任何一方进行采购或与该方有关联，我们将立即中止或中断与该供应商的合作。
Regarding risk management of serious abuses:
2. We will immediately suspend or discontinue engagement with upstream
suppliers where we identify a reasonable risk that they are sourcing from, orlinked to, any party committing serious abuses as defined in paragraph 1.
3. 我们不会容忍任何通过矿产开采、运输、贸易、处理或出口为非国家武装团体提供直接或间接的支持。通过矿产开采、运输、贸易、处理或出口为非国家武装团体提供 “直接或间的支持”包括且不限于从非国家武装团体或其关联方购买矿产，向其进行付款，或以其他方式为其提供后勤支援或设备等。这些武装团体或关联方：
ii) 在矿址入口、运输路线沿线或矿产交易点非法征税或者勒索钱财或 矿产；并/或
Regarding direct or indirect support to non-state armed groups:
3. We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals. “Direct or indirect support” to non-state armed groups through the extraction,transport, trade, handling or export of minerals includes, but is not limited to,
procuring minerals from, making payments to or otherwise providing logistical
assistance or equipment to, non-state armed groups or their affiliates who:
i) illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain;5 and/or
ii) illegally tax or extort6 money 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 international
Regarding risk management of direct or indirect support to non-state armed groups:
4. 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 as defined in paragraph 3.
Regarding public or private security forces:
5. We agree to eliminate, in accordance with paragraph 10, direct or indirect support to public or private security forces who illegally control minesites, transportation routes and upstream actors in the supply chain; illegally tax
or extort money or minerals at point of access to mine sites, alongtransportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.
6. 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.
7. 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 Voluntary Principles on Security and Human Rights. 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.
8. 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.
9. 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 minerswhereminerals 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.
10. 如果我们发现在一定程度上存在此类风险，将根据企业在供应链上所处的具体位置，立即制定、采用和实施上游供应商及其他利益相关方风险管理计划，从而使第五段中所述的为公共或私人安全武装提供直接或间接支持的风险得到遏制或降低。如果风险管理计划实施六个月未起作用，我们将暂时停止或中断与上游供应商的合作。我们发现在一定程度上有可能存在有违第 8 段和第 9 段内容的行为的情况下，将采取同样的应对措施。
Regarding risk management of public or private security forces:
10. In accordance with the specific position of the company in the supply
chain, we will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces, as identified in paragraph 5, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliersafter failed attempts at mitigation within six months from the adoption of the risk management plan.8 Where we identify a reasonable risk of activitiesinconsistent with paragraphs 8 and 9, we will respond in the same vein.
Regarding bribery and fraudulent misrepresentation of the origin ofminerals:
11. 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.
Regarding money laundering:
12. 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 governments:
13. 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 to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI).
Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees and royalties to governments:
14. 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.
Guangdong Xianglu Tungsten Co., Ltd.
Policy established: [AUG. 23TH, 2019]