Due Diligence Report of Responsible Minerals Supply Chain in 2021
1.Company Profile:
Jiujiang Tanbre Co.,Ltd(Short name as JJTC) is established in 2005,it belongs to Jiangxi Tungsten Holdings Group Company.The CID No.is CID 000917.JJTC is the only smelter, it located at No.62 Jiuhu Road Jiujiang City,Jiangxi Province,China, and the Post Code is 332014.JJTC is the official member of Tantalum -Niobium International Study Center( TIC), and also gotten approved by iTSCI in September 2012, to be one of the full members. JJTC mainly produce tantalum oxides,niobium oxides,tantalum niobium carbides , the relative process materials and other rare earth phosphors, we strive to serve the end users, to provide satisfactory products and best services.
2. RMAP Assessment Summary:
JJTC has been actively support and participate in the annual audit of RMAP (Responsible Mineral Assurance Process).JJTC had passed the EICC assessment in September 2013 for the first time, and up to 2018 year, JJTC had accepted the independent third party RMAP assessment committed by RMI for 8 years. Now JJTC is in the cap period of (2019-2020 year) re-audit , the assessment is valid for one year, the assessment period was from December 19th,2019 to December 18th,2020 ,the assessment was conducted by Responsible Sourcing Audit Firm. The re-audit assessment date of 2020-2021 year (From December 19th ,2020 to December 18th,2021) will be fixed in the second half of 2022 year , and the assessment summary report will be public and available at:www.jjtanbre.com.cn
3. Company Supply Chain Policy:(For All resources)
To avoid the use of conflict minerals, which directly or indirectly finance or benefit armed groups and/or involve other serious human right abuses in high-risk and conflict-affected regions, JJTC has developed a supply chain policy. The supply chain policy is fully aligned with the third edition of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). It covers all of the risks identified in Annex II of the OECD Guidance and its geographic scope is global. The company is committed to addressing any Annex II risks if identified. The policy was reviewed and approved by senior management, which committed to support its implementation. The policy has been widely disseminated to relevant stakeholders (suppliers, customers, employees etc.) and is available on the company website at www.jjtanbre.com.cn.
4. Company Management System(FOR ALL SOURCES)
Management Structure
JJTC has strictly management system on the supply chain, follows through on its commitments in the supply chain policy and has developed an internal procedure for due diligence with the following aspects to prevent any conflict-area material and unknown material from entering into the the JJTC produce technology, to prevent the mining and trading being the sources of the conflict,human rights violation and insecure:
● JJTC’s CEO is responsible to oversee the due diligence program and risk management design and implementation.
● JJTC has assigned a due diligence program manager to coordinate the work of the relevant departments (including the Sales and Procurement Department, Technology & Quality Management Department, Production Department, Healthy &Safety &Environment Protection Department, and All Produce workshops) to ensure each department follows up on their roles and responsibilities to implement the due diligence program and report any red flags and potential risks identified.
● JJTC conducts due diligence management system training once a year for key staff from all relevant departments required in due diligence program. If there is an update of the program, the company conducts additional training as necessary.
5. Internal Systems of Control
5.1 The company has established/updated its due diligence management system to be aligned with the OECD Guidance and RMAP in January 2018.
5.2 JJTC communicated the updated supply chain policy and sourcing requirements to all identified upstream suppliers .
5.3 Public and Pellucid Purchase Policy
5.3.1 JJTC Responsible Mineral Purchase policy has been public on the website of JJTC, has incorporated due diligence requirements into legally binding agreements with direct suppliers.
5.3.2 JJTC has issued the “Responsible Mineral purchase chain management system” and “Relative regulation on the purchase of Tantalum raw material”,so that each employee can learn and implement comply with them.
5.4 Control procedure for Procurement of Raw material
JJTC has developed and executed “The management regulations of suppliers ”,“The Risk identification management regulations of Raw material supply chain”,“The Transport management regulations of Tantalum-niobium materials”and etc control procedure program,prevent any “conflict material”and unknown material from entering into the supply chain of JJTC.
5.5 Adopt the control system and test method for the transportation of raw material based on the coincident international standards
JJTC has obeyed and adopts the international transportation regulations on hazardous substances including level-7 substances. Meanwhile, also has established and implemented “ The determination of U in Tantalum-Niobium material” ,”The determination of Th in Tantalum-Niobium material” and “The measurement of the Radioactive substance”.
5.6 Conduct due diligence on suppliers and maintain persistence
In accordance with the requirements of OECD guidelines and the Responsibility Mineral Initiative, JJTC conducts annual due diligence on the raw material suppliers, and through the reviewing the legitimacy,quality assurance and complexity of all suppliers to check to adopt or disqualification.
5.7 While maintaining communication with downstream clients, as per the requirements of RBA, JJTC has provided the CMRT to them to ensure due diligence in the supply chain.
5.8 When establishing business relationships with upstream suppliers, JJTC will require them to commit to support and obey the implementation of EITI, and also willing to accept our supervision, and send back the stamped and signed one for records.
5.9 JJTC has established the compliant mechanism of RMI, the contact/Compliant channels had been posted on the JJTC’s website to collect complaint information from relevant parties.
5.10 Variety ways in training employees
JJTC adopting the methods of focusing training,internal panel propaganda to training all the employees including the senior management, to make them fully understand the “Recommendation of the Council on Due Diligence for Responsible Supply Chains of Mineral from Conflict-Affected and High-Risk Areas”, and the newest requirement of tantalum standard on the Responsible mineral assurance process issued by RBA and the transparency of Responsible mineral supply chain.
6. Risk identification (For all sources)
JJTC has established a wholesome procedure to identify the risk of supply chain.
6.1 At first,referring to the risks of supply chain policy,JJTC has developed the procedure to identify CAHRA. It has including the resources used, the criteria for identifying “Conflict area and high-risk” area and the frequency with we decide for review. JJTC has used below resources to determine the CAHRA :
▲ Dodd-Frank Act
▲ Latest edition of EU CAHRAS list
▲ Heidelberg barometer of 2020 year
▲ The human freedom index of 2020 year
▲ Corruption Perceptions Index of 2020 year
6.2 JJTC has designed a set of knowing your supplier (KYC) form,including the information on the legal status and identify of the suppliers,judge the supplier and potential risks, and has collected relevant supporting documents.Our supplier has completed and returned the filled KYC form this year.The due diligence program manager has reviewed the collected summary information with the procurement team, has conducted a risk assessment in accordance with RMI management requirements, and has issued the “low risk procurement area list”and “high risk procurement area list”. If any inconsistency,error or incomplete information is found in the KYC form, JJTC will ask them to improve and request the updated form.Once the warning signal is identified, JJTC will communicate with the suppliers to clarify and improve the documents when needed. During the reporting period, there were no warning signals associated with the KYC forms.
6.3 For each transaction,JJTC required the supplier to provide the origin information and a whole set of traceablity documents, to ensure to learn about the source of the transaction,transportation route and the name and address of the directly suppliers.
6.4 JJTC has reviewed all information collected as per CAHRA, sanctions list, local laws and international procurement.
6.5 No complaints has been received from relevant parties (including the affected person or whistle-blowers) during the period covered by this report.
7. Risk assessment (High-risk Procurement only)
7.1 Based on above risk identification methods,JJTC has conducted enhanced due diligence on the raw material and supply chain which are identified as “High-risk”.It includes as followings:
▲ Assess the background of the CAHRA.
▲ Clarify regulatory chains.
▲ Assess the activities and relationships of upstream suppliers.
▲Identify location and quantitative conditions for mining,trading,processing and exporting of ores.
▲ Conduct a field risk assessment.
7.2 In order to analyze the actual situation,carry out field assessment and evaluate the risks in the High-risk supply chain,JJTC has been an effective member of iTSCI since 2012 year,for each transcation from high-risk areas, JJTC always has adopted the following mechanism to assess the risks.
▲ The iTSCI tag system is an approved upstream inspection mechanism.
JJTC has announced that will only purchase tantalum material origin from High-risk areas through the iTSCI tag identified system. For each High-risk transaction, iTSCI provides the documents as followings:
1) Accident summary report (After obtaining).
2) Mine investigation recommendations,including a list of mines with potential risks(it is recommended that companies conduct enhanced due diligence and risk assessment which has purchased from these mines ).
3) Monthly countries and regional reports ,review the general situation on the ground.
4) Data summary and other reports.
▲ JJTC always pay attention to other iTSCI reports and documents, such as accident reports,management assessment reports,company audit reports etc.
▲ JJTC has conducted further due diligence,reviewing documents from upstream schemes against information in the public domain and actual transaction information.
7.3 In addition, all suppliers are required to provide the following documents/information regarding each transaction,whether high-risk or low-risk:
1) Supplier’s due diligence plan,including KYC table,company registration certification or company business license,mining license( If it is mining company),tax registration certificate.
2) Pay highly attention to the governance information related to the operation/national background of the local company.
3) Collect the monitoring documents of the supply chain of each transaction to ensure that the source of the transaction and the transportation route are known.
8. Risk reduction (High-risk Procurement only)
In view of the assessment results of high-risk supply chain, JJTC requires the procurement department of tantalum raw material to control the risk as following risk mitigation measures:
▲ Report the survey and evaluation results of the high-risk supply chain to the senior management of JJTC, indicating the relevant information,actual and potential risks .
▲ Develop and Implement the risk management plan according to the company’s supply chain policy risk management strategy. Implement effective mitigation measures for exiting risks and conclude the agreements with suppliers and affected stakeholders .Risk mitigation strategies include continuing to trade throughout the measurable risk management process,suspending trade while reducing risk,and suspending cooperation with suppliers if risk reduction measures are not feasible or acceptable.
▲ Participate in RMI approved upstream audit mechanism:iTSCI
JJTC inquired the iTSCI secretariat for detailed information on the risk reduction process.For the publicly labeled incident report batches,check whether the risk has been resolved and/or reported in the monthly origin update incident summary reports. Require periodic updates of related supply chain risk reduction activities.
▲ Continuously monitor the risk, and evaluate again after the risk situation changes.
JIUJIANG TANBRE CO.,LTD
March 15th,2022
