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         Jiujiang Janny New Material Co., Ltd

        首页 >> 新闻动态 >>行业新闻 >> Due diligence planning and risk assessment procedures

        Due diligence planning and risk assessment procedures



        In accordance with our conflict mineral policy, we strictly adhere to OECD
        guidelines for the procurement of ore from conflict-affected and high-risk
        regions, as well as to compliance with United Nations Security Council
        resolutions. In accordance with the guidance of OECD and relevant UN
        Security Council resolutions, we have taken the following measures in all
        business dealings in the source areas of tantalum raw materials.Review
        supplier selection and purchasing decisions.The following risk-based five-step
        due diligence framework for ore supply chain in conflict-affected and high-risk
        regions is incorporated into the management system.
        Due diligence plan
        Establishing a Strong Enterprise Management System
        The company has a very strict management system for the supply chain,
        formulating a series of complete supply chain management system, through
        the following measures and procedures to ensure that no conflict raw materials
        from conflict-affected areas are purchased and used and to prevent any
        conflict raw materials and uncertainties material enters the supply chain to
        prevent mineral exploitation and trade from becoming sources of conflict,
        human rights violations and insecurity. In August 2018, we reviewed and
        revised all internal control procedures and documents and strictly adhered to
        supply commitments on chain policy and internal processes for due diligence
        in the following areas have been developed:
        General Manager of Janny Company is responsible for supervising the design
        and implementation of due diligence plan and risk management.
        The company has appointed a due diligence plan manager to coordinate with
        relevant departments (including purchasing department, warehouse
        management department, etc.) and production unit to ensure that all
        departments perform their duties, carry out due diligence plans and report any
        warnings found and potential risks.
        Janny Company carries out a training of due diligence management system for
        all key personnel of relevant departments every year in accordance with the

        requirements of due diligence plan. If the plan is updated, the company will
        carry out additional training as required.
        We demand that our suppliers also adhere to all OECD-guided provisions and
        UN Security Council resolutions and never buy conflict ore to sponsor conflict
        directly or indirectly.
        1. Internal control system
        - Its due diligence management system has been updated to align it with
        OECD guidelines and RMAP.
        The latest supply chain policies and procurement requirements have been
        communicated to all identified suppliers.
        - Open and transparent procurement policy
        Janny Company Raw Material Purchase Statement has been posted on the
        company's public website, so that each supplier has a clear understanding of
        our mining purchasing policy. The "Responsible Mineral Supply Chain
        Management System Document" was issued to all departments within the
        enterprise to make every employee aware of it and implement it accordingly.
        - Control procedures for raw material procurement
        The company formulates and implements Supplier Management Procedure,
        Purchasing Contract Management Procedure and Ta Raw Material Purchasing
        Acceptance. And in-and-out warehouse management process, identification
        and traceability management process, procurement documents,management
        Procedure and Ta Material Balance Accounting Management Procedure,total
        six process control procedures, limit and prevent any "conflict origin"
        material"and unknown raw materials enter the supply chain.
        Traceable material tracking process
        Through the implementation of the "Marking and Traceability Management
        Process", the traceability and control of all tantalum raw materials in the use
        process are guaranteed.
        - To adopt the control system and management measures for raw material
        transportation in accordance with international standards, strictly abide by the
        regulations for the transport of hazardous substances including categories 7 of
        substances, and at the same time, establish and implement the Regulations on

        the Management of Radioactive Substances.
        Conduct due diligence on suppliers and maintain continuity
        In accordance with the OECD Guidelines and the audit requirements of the
        Responsible Minerals Initiative, the company conducts annual due diligence
        on raw material suppliers.To review and verify the validity, quality assurance
        and conformity of suppliers as suppliers to adopt or cancel them.The basis of
        qualification. For ITSCI labeled ores, we will visit all the supply mines of the
        source mines and companies of the ores we purchased, and conduct a
        comprehensive study of the mines to determine the mine's geographical
        location, personnel composition and output. Every year, we check and check
        whether the amount of ore produced is consistent with the original benchmark
        study. Only after these mines and companies have been inspected and proved
        to have no direct or indirect connection with armed groups or human rights
        violations will we continue to purchase from this area or company; if we find
        any non-conformity, we will ask them to rectify it, if not to meet the
        requirements after rectification. We will immediately stop purchasing from the
        company and return the non-conforming raw materials purchased, which can
        not be included in our qualified suppliers for at least one year. In addition to
        visits to local mines, we have retained at least five years of all relevant
        documents on ore supplies from Africa so that problems can be verified in the
        future. Janny Company never buys raw materials in cash.
        We implement the OECD policy for all employees to ensure that every
        employee understands and follows the policy. If employees do not do the
        corresponding verification, we will immediately suspend the relevant
        procurement contract. The contract will not continue until the employee verifies
        and proves that the ore will not support the conflict directly or indirectly.
        Otherwise, we will cancel the contract and stop buying from the supplier.
        Janny does not support cash purchase. If any supplier has such requirement,
        we will refuse to purchase.
        - Broad channels of mass communication
        Through due diligence of raw material suppliers, the company publicizes
        "OECD's impact on conflict areas" to all suppliers.Guidelines for due diligence
        of responsible supply chains for minerals in regions and high-risk areas",
        RMAP assessment criteria, transparency and accountability supply chain
        requirements. At the same time, we should remind and urge the upstream

        suppliers of raw materials to operate legally and in compliance with the
        regulations, and not to operate any "conflict raw materials" and unknown raw
        materials. Special clauses on "non-conflict" are stipulated in our contracts with
        all suppliers.The suppliers have promised that the raw materials supplied are
        "non-conflict raw materials".
        The company itself and also the suppliers actively participate in international
        conferences or training sponsored by international organizations such as TIC,
        iTSCI, RMI, etc. to understand and learn "OECD due diligence guidelines for
        mineral responsible supply chains in conflict-affected and high-risk areas", RMI
        auditing standards and transparency requirements for responsible tantalum
        supply chains. The company maintains regular communication with iTSCi, and
        pays close attention to the study of iTSCi event report, monthly production
        assessment, monthly regional status assessment report, etc. in order to timely
        understand the production and operation of various mines. While maintaining
        communication with downstream customers, according to RBA requirements,
        the company provides CMRT to downstream visitors to ensure due diligence in
        the supply chain. We also recommend that all our suppliers join the iTSCi
        program and RMAP.
        - Promoting to the public through the Internet that "OECD is responsible for
        minerals in conflict-affected and high-risk areas guidelines for due diligence in
        an appointed supply chain, the latest requirements of responsible business
        alliances on the test criteria for a tantalum supply chain, and negative
        requirements for transparency in responsible mineral supply chains.
        Establishing complaint channels, the company has opened complaint
        channels to the community, including telephone numbers, responsible persons,
        in order to be willing to accept. supervision from all circles of life.
        When necessary, the company is willing to share supply chain data and
        information with upstream suppliers and downstream customers.
        Establish a complaint mechanism at the company level or within the industry
        as a risk warning system.
        - Training staff
        The company trains its employees, including senior management, to make
        them fully aware of "OECD's due diligence guidelines for Responsible Supply

        Chains for minerals in conflict-affected and high-risk areas" and the latest
        requirements of responsible business alliances on the Tantalum supply chain
        auditing standards, as well as the perspective of responsible mineral supply
        chains. Lightness requirements.
        - Actively fulfill social responsibility, create a corporate image of compliance
        and social responsibility ,the company always closely combines the economic
        development of enterprises with the fulfillment of social responsibility to ensure
        legal and ethical operation.through the realization of technological innovation,
        safety in production, employee rights and interests, environmental energy
        conservation and emission reduction activities, we will fully fulfill our social
        2. Supply Chain Risk Identification Procedure
         The company has designed a set of KYC forms to understand your
        dealers, including information about supplier's legal status and identity.supplier
        analysis and potential risks, and collect relevant supporting documents. All our
        suppliers have completed and returned the table.lattice. The company's due
        diligence plan manager worked with the procurement team to review the
        information provided and the United Nations sanctions list. As long as in when
        inconsistencies, errors or incomplete information is found in the KYC form, the
        company will ask them to improve it. If the supplier does not provide KYC, we
        will stop the purchase.During the reporting period, the alarm signal related to
        the submitted KYC form was found.
        For each transaction, the company requires suppliers to provide information of
        origin and a complete set of traceable documents, including legal
        transportation routes.and the name and address of the direct supplier.
        Make full use of the information provided by iTSCi tantalum ore supply chain
        supervision system and on-site monitoring system to supervise tantalum in
        high-risk areas mining due diligence.
        The company has designed a CAHRA risk identification process to assess the
        risk of negative impacts based on the supply chain policy standards in
        compliance with appendix ii and the due diligence recommendations in this
        3. Risk assessment and risk reduction procedures

        The company has a supply chain control procedure which reports and
        processes the results of the supply chain risk assessment to the designated
        senior management.
        Based on the above risk identification methods, enhanced due diligence has
        been carried out for materials and supply chains identified as "high risk"
        investigation. This includes:
        Evaluate the activities and relationships of upstream suppliers;
        Identification of mining, trading, processing and export locations and
        quantitative conditions of ores;
        Field risk assessment.
        Since the establishment of iTSCi, in order to analyze the actual situation,
        conduct on-the-spot assessment and evaluate the risks in high-risk supply
        chains, the company has always adopted the following plans to assess the
        risks of each transaction from high-risk areas.
        Widely participate in the recognized upstream guarantee mechanism - iTSCi
        marking and bagging system.
        Janny Company has been participating in the traceability verification of
        high-risk tantalum raw materials. For tantalum raw materials from high-risk
        areas, the company and the suppliers only purchases materials certified by
        iTSCi marking and bagging system from iTSCi members. For each high-risk
        purchase transaction, iTSCi provides the following documents:
        1) Event summary report
        2) Suggestions for site visits, including lists of potentially risky sites
        (recommended for companies purchasing from these mines)
        Enhanced due diligence and risk assessment)
        3) Monthly national and regional reports to review the general situation on the
        4) Data summary and other reports

        Janny Company pays attention to learning other reports and documents of
        iTSCi, such as accident report, management evaluation report, company audit
        report, etc. The company conducted further due diligence to review documents
        from upstream plans against public domain information and actual transaction
        information. At the same time, whether it is high or low risk, Janny Company
        requires all suppliers to provide the following documentary information, which
        involves each transaction:
        Supplier due diligence plan, including KYC questionnaire, company
        registration certificate or company business license, mining certificateIf it's a
        mining company.
        Keep an eye on the governance information related to the operation/national
        background of local companies.
        Collect the supply chain regulatory documents for each transaction to ensure
        that the source and route of the transaction are known.
        At the same time, through on-the-spot investigation of mines, document
        inspection, interviews with miners, consultation with local communities and
        other stakeholders, we conduct due diligence on suppliers in high-risk areas,
        and timely understand whether there are serious infringements in the process
        of mining, transportation, trade and so on.
        We will also make the necessary checks to ensure that vendors recommended
        by iTSCi have implemented improvements and acted on them.
        We will ensure that the iTSCi monthly report on the mine we purchased is
        We have three different levels of violation and response procedures.
        See the example in the following table:



        We also have a private EMAIL address where everyone can provide us with
        information about emergencies that may be exposed.
        Jiujiang Janny New Material Co., Ltd.
        August 20, 2018

        ADD.:Chengdong Industrial Base 3, Xunyang District, Jiujiang City, Jiangxi Province, China 332000
        Tel: +86-792-8533981/2/7 Fax: +86-792-8533983

        技术支持: 九江大幸网络传媒 & 九江网 | 管理登录

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