Daye Nonferrous Metals Co., Ltd. (hereinafter referred to as "the Company") recognizes the risks associated with adverse impacts that may arise from mining, trading, processing, and exporting mineral resources in "Conflict-Affected and High-Risk Areas" (CAHRAs). We acknowledge our obligation to respect human rights, avoid contributing to conflict, and prevent negative environmental and social impacts. We commit to adopting and widely disseminating the?Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains?(Second Edition) and the?OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas?(Third Edition), incorporating their principles into contracts and agreements with suppliers.
This policy serves as a reference for conflict-sensitive procurement activities throughout the supply chain and aims to raise risk awareness among suppliers. We pledge not to engage in any activities that may fund conflicts and commit to complying with relevant United Nations sanctions resolutions.
The Company commits to identifying and managing the following risks in its supply chain operations:
1. When conducting procurement or business activities in CAHRAs, we will neither tolerate nor profit from, assist, facilitate, or enable any party involved in:
??a. Any form of torture or cruel, inhuman, or degrading treatment;
??b. Any form of forced or compulsory labor—defined as work or service ?????extracted under threat of penalty and not voluntarily offered;
??c. The worst forms of child labor;
??d. Other serious human rights violations, such as widespread sexual violence;
??e. War crimes, serious violations of international humanitarian law, crimes against humanity, or genocide.
Risk Mitigation Measures:
2. If we have reasonable grounds to believe that an upstream supplier is sourcing from or associated with any party engaged in the above abuses, we will immediately suspend or terminate cooperation with that supplier.
3.We will not tolerate any direct or indirect support to non-state armed groups through the mining, transport, trade, processing, or export of minerals. "Direct or indirect support" to non-state armed groups through the mining, transport, trade, processing, or export of minerals includes, but is not limited to, purchasing minerals from non-state armed groups or their affiliates, making payments to them, or otherwise providing logistical support or equipment. These armed groups or affiliates:
i. Illegally control mining sites, transportation routes, trading points, or upstream actors in the supply chain; and/or
ii. Impose illegal taxes, extort money or minerals at mining sites, along transport routes, or at trading points; and/or
iii. Illegally tax or extort intermediaries, exporters, or international traders.
Risk Mitigation Measures:
4. If we have reason to believe an upstream supplier is sourcing from or linked to any party providing support to non-state armed groups, we will immediately suspend or terminate cooperation.
III. Public or Private Security Forces:
5.We prohibit providing direct or indirect support to public or private security forces that illegally control mining sites, transportation routes, or upstream supply chain actors, and that impose unauthorized taxes, extort money or minerals at mining site entrances, along transportation routes, or at mineral trading points, or levy illegal taxes or engage in extortion against intermediaries, export companies, or international traders.
6.We recognize that the role of public or private security forces at and/or around mining sites and/or along transportation routes is solely to uphold the rule of law, including safeguarding human rights, protecting miners, equipment, and facilities, and securing mining sites or transportation routes to ensure lawful extraction and trade proceed without disruption.
7.In cases where we or any entity in our supply chain enter into contracts with public or private security forces, we commit to stipulating that such security forces must be recognized by internationally accepted standards and guidelines governing public or private security forces. Specifically, we will support or implement screening policies to ensure that individuals or security units with known records of serious human rights violations are not recruited.
8.We will support or take measures to collaborate with central or local governments, international organizations, and civil society to jointly identify feasible solutions for improving the transparency, proportionality, and accountability of public security expenditure.
9.We will support or take measures to engage with local governments, international organizations, and civil society groups to avoid or minimize the negative impacts of public or private security forces stationed at mining sites on vulnerable groups, particularly on artisanal miners.
Risk Mitigation Measures:
10. Upon identifying such risks, we will develop and implement a risk management plan with suppliers and stakeholders. If the plan fails to mitigate risks within six months, we will suspend or terminate cooperation.
11.We will not offer, promise, give, or solicit any bribes, and we will resist any temptation to engage in bribery to conceal or falsify the origin of minerals, misrepresent mineral extraction, trading, processing, transportation, or export activities, or evade taxes, fees, and royalties payable to governments.
Regarding Money Laundering:
12.?If we have reasonable grounds to believe that there is a risk of money laundering arising from or linked to minerals obtained through illegal taxation or extortion at mining sites, along transportation routes, or in transactions involving upstream suppliers, we will support or take measures to contribute effectively to the elimination of money laundering.
Regarding Payments of Taxes, Fees, and Royalties to Governments:
13.We will ensure that all legally required taxes, fees, and royalties related to the extraction, trade, and export of minerals from conflict-affected and high-risk areas are paid to governments. We also commit to disclosing such payments in accordance with the transparency requirements of the countries where we operate, based on our position in the supply chain.
Risk Mitigation Measures:
14. Based on the specific position of the enterprise in the supply chain, we commit to collaborating with suppliers, central or local government agencies, international organizations, civil society, and affected third parties as appropriate. The purpose of such collaboration is to implement significant measures within a reasonable timeframe to prevent or mitigate adverse risks, improve performance, and track progress. If risk mitigation measures prove ineffective, we will temporarily suspend or terminate cooperation with upstream suppliers.For risks requiring reduction under the risk management plan, we will conduct additional risk assessments. If the risk management plan fails to achieve noticeable results within six months—such as failing to curb or reduce risks including bribery, fraudulent misrepresentation of mineral origins, money laundering, or non-payment of taxes, fees, royalties, and other payments to governments—we will suspend or discontinue cooperation with the supplier for at least three months. During this suspension, we will revise the risk management plan, outlining the performance targets that must be met before trade relations can resume.
The company will integrate this policy into its management system and the responsibilities of relevant departments in line with the principle of continuous improvement. The due diligence policy will be reviewed and updated periodically in response to changes in corporate operations, supply chains, and other business relationships. This policy applies to all suppliers of the company, and the company will take proactive measures to communicate the policy to them. The policy will take effect upon issuance and will be published on the company’s website.
Daye Nonferrous Metals Co., Ltd.
May 8, 2025
中色大冶公众号
