Nanjing Hanrui Cobalt Co.,Ltd Cobalt Supply Chain Due Diligence Policy and Commitment (Edition 3)
- 分类：供应链管理
- 作者：
- 来源：
- 发布时间：2019-01-20 14:51
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【概要描述】
Nanjing Hanrui Cobalt Co.,Ltd Cobalt Supply Chain Due Diligence Policy and Commitment (Edition 3)
【概要描述】
- 分类：供应链管理
- 作者：
- 来源：
- 发布时间：2019-01-20 14:51
- 访问量：
详情
Nanjing Hanrui Cobalt Co.,Ltd (hereinafter referred to as the "the company")
has long been committed to creating a win-win cooperation to all the partners,
and the company considers that the exploitation and usage of cobalt resources
shall contribute to both economic growth and sustainable development.The
company has recognized the great challenges to achieve the goal and the
risks of significant adverse impacts which may be associated with exploiting,
trading, processing and exporting minerals from high-risk areas, to which we
consider that we have the responsibility to respect human rights or retard the
adverse impacts to the society.
Therefore,the company commits to adopt the Chinese Due Diligence
Guidelines for Responsible Mineral Supply Chains (Chinese Guidance),
published by the China Chamber of Commerce of Metals, Minerals &
Chemicals Importers & Exporters (CCCMC) and the OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected
and High-Risk Areas, Edition 3 published by the OECD (OECD Guidance) as
well as other internationally acknowledged standards. In line with the principle
of constant improving, we will incorporate the following policies into the
management of supply chain through a series of steps including clear policy
formulating; proper organization structure building; multilateral communication
and reports, etc.
In order to achieve the goal, the company takes solemn commitment and will
take following measures:
I. Practice of responsible procurement
The company has recognized the long-term and complexity of a sustainable
supply chain management, to which we have invested sufficient human,
material and financial resources and have also established the supply chain
governance committee and supply chain management department.A
Regulation of Supply Chain Governance Committee has been drawn in order
to standardize the responsible cobalt supply chain.
At meantime,the company has recognized that a sustainable management
shall not be realized without the joint actions by parties of both upstream and
downstream. For that reason ,the company will actively participate in industry
governance and joint actions, to improve the transparency and traceability of
the cobalt supply chain by formulating the supplier regulation, seeking
communication and cooperation with suppliers and downstream enterprises as
well as promoting information transferring.
II. Control of supply chain risks
The company commits to adopt the Chinese Due Diligence Guidelines for
Responsible Mineral Supply Chains (Chinese Guidance), published by the
China Chamber of Commerce of Metals, Minerals & Chemicals Importers &
Exporters (CCCMC) and the OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Edition
3 published by the OECD (OECD Guidance) and carry out the evaluation and
management of the risks in the supply chain. The risks include but not limit to：
1. Serious abuses associated with the extraction, transport or
trade of minerals
While extracting from, transporting, trading or operating in high-risk areas, we
will neither tolerate nor by any means assist with or facilitate the commission
by any party of：
（1）any forms of torture, cruel, inhuman and degrading treatment；
（2）any forms of forced or compulsory labour, which means work or service
which is exacted from any person under the menace of penalty and for which
said person has not offered himself voluntarily；
（3）the worst forms of child labour；
（4）other gross human rights violations and abuses such as widespread
sexual violence;
（5）war crimes or other serious violations of international humanitarian law,
crimes against humanity or genocide.
Risk management against serious abuses：
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 committing serious abuses.
For the condition of employing child labour because of mis-verification, we
shall discontinue the employment immediately and assist the child to continute
the education(ie, assist the child to access into school, share the tuition and
living expenses).In case the livelihood is affected due to the end of
employment, we shall employ other adult family member as alternative until
the child reaches the working age.
2. Risks regarding direct or indirect support to non-state
armed groups
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 nonstate 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:
Illegally control mine sites or otherwise control transportation routes,
points where minerals are traded and upstream actors in the supply chain;
and/or Illegally tax or extort money or minerals resources at points of access to
mine sites, along transportation routes or at points where minerals are traded;
and/or Illegally tax or extort intermediaries, export companies or international
traders.
Risk management against of direct or indirect support to
non-state armed groups:
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
3. Risks regarding public or private security forces
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.
Therefore, we commit 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.We will support efforts, or take steps, to
engage with local authorities, international organisations and civil society
organisations to avoid adverse impacts that associated with the presence of
security forces, public or private, to the local communities and vulnerable
groups.
Risk management against public or private security forces:
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.In such cases, we
will suspend or discontinue engagement with upstream suppliers after failed
attempts at mitigation within six months from the adoption of the risk
management plan.
4. Risks regarding Corruption, Money Laundering and
Payments to Governments
We will not offer, promise, give or demand any bribes, and will resist the
solicitation of bribes to conceal or disguise the origin of mineral resources, to
misrepresent taxes, fees and royalties paid to governments for the purposes of
mineral resources extraction, trade, processing, transport and export.
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, processing, transport or
export of mineral resources derived from the illegal taxation or extortion of
mineral resources at points of access to extraction sites, along transportation
routes or at points where mineral resources are traded by upstream suppliers.
We will ensure that all taxes, fees, and royalties related to mineral resources
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 international
standards.
Risk management against Corruption, Money Laundering and
Payments to Governments
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 organizations, 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.
5. Risks regarding land rights, emissions and artisanal
operators
We will not engage in or tolerate extracting resources or otherwise
benefiting from land where the free, prior and informed consent of local
communities and indigenous peoples has not been obtained, including those
for which the extractor holds a legal title, lease, concession, or license. We will
not engage in or tolerate extracting resources or otherwise benefiting from
mining operations where the culture and heritage of local communities and
indigenous peoples have not been respected and protected, or where
traditional cultures of local peoples have been harmed.
We will not engage in or tolerate extracting resources or otherwise
benefiting where a legal title, lease, concession, or license has been illegally
obtained or violates national law. We will ensure avoiding major adverse
impacts and gross violation of local laws and regulations regarding ambient
soil, air, and water conditions, including manufacturing, trading, and using
chemicals and hazardous substances subject to international bans due to their
high toxicity to living organisms, environmental persistence, or potential for
irreversible ecological impacts, and/or releasing arsenic and mercury
emissions.
We commit to regularly assess and mitigate the adverse impacts on soil, air,
and water by the mining operation, consider ambient soil, air, and water
conditions, and apply technically and financially feasible pollution prevention
principles and techniques that are best suited to avoid, minimize, and control
pollution, monitor emissions and discharges of all possible pollutants
according to the relevant laws and regulations of host countries, follow up and
remedy pollution issues in a timely manner, and clearly record and make public
the results, as well as employ emissions control and reduction strategies.
We agree to ensure and surpass applicable legal requirements with regard to
chemicals and toxic substances, avoid manufacturing, trading, and using
chemicals and hazardous substances subject to international bans due to their
high toxicity to living organisms, environmental persistence, or potential for
irreversible ecological impacts, including rigorously suppressing arsenic and
mercury emissions and managing cyanide according to the highest
international standards and ensure that hazardous wastes are handled, stored,
transported, treated, and disposed according to laws and regulations and in a
way that eliminates leaks, spills, or other releases to the environment.
We will prohibit extracting resources from World Heritage properties or legally
protected areas, thereby providing a threat to the outstanding universal value
for which these properties are protected.
We will pay specific attention to risks of forced labour, child labour, unsafe
working conditions, uncontrolled use of hazardous substances and other
significant environmental impacts with regard to sourcing from artisanal and
small-scale producers and work together and seek a productive relationship
with artisanal and small-scale operators in the extraction area.
Risks management against land rights, emissions and
artisanal operators
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
suppliers and other stakeholders to prevent or mitigate the risk of infringing
land rights, causing major adverse environmental impacts, or specific risks
regarding artisanal and small-scale operators, where we identify that such a
reasonable risk exists.
6. Risks regarding personal safety and occupational health
While exploiting, transporting, trading, processing and exporting minerals from
high-risk areas, the company commits will not directly or indirectly
support,participate in or associate with any behavior which may seriously
against personal safety or occupational health, includes but not limits to:
(1) The violation of laws
(2) The insecure building or workplace.
(3) The contact of dangerous machines,equipments or substances under
insecure circumstance.
Risks management against personal safety and
occupational health：
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 life threatening occupational health and safety
conditions.
Other committments:
The company has recognized that the risks of child labour could be identified
among the artisanal or small-scale mining. The risks are showing strong
connection with the local economy level, public management ability and
community sources of livelihood,etc, which are systematic, actual and complex.
Neither shall we support any form of child labour in the artisanal mining nor
shall we simply reject any procurement of artisanal mining resources which
might cause adverse impacts to the livelihood of local community.
On account of the above identified risks ,the company herein commits to
enhance the system establishment of cobalt supply chain due diligence
management,cooperate with both upstream and downstream as well as
other interested parties, in order to work for the solution of child labour problem
existing in supply chain. At meantime, for the risks identified in the supply
chain are dynamic and complex, the company herein commits to gradually
expand the scope of risk identification,to perfect the measures of risk control in
order to achieve the common development for the whole supply chain.
Improvement of supply chain transparency
The company herein commits to participate actively in the communication with
interested parties, build the mechanism of appeal, respond actively to
interested parties’ expectation and regularly disclose the performance of
supply chain management. Under the leadership of the supply chain
governance committee, the company will evaluate the performance of
suppliers periodically. To the major and/or common problems in supply chain,
the company will organize both domestic and outside experts to work out the
solution in order to ensure the responsibility and improvement of the
responsible supply chain management.
Nanjing Hanrui Cobalt Co.,Ltd
2019 January
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