Guangzhou Tinci Materials Technology Co., Ltd., as a responsible enterprise, recognising that risks of significant adverse impacts which may be associated with extracting, trading, handling and exporting minerals from high-risk areas, and recognising that we have the responsibility to respect human rights and not contribute to adverse impacts to society.
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 of extraction 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.To this end, We has developed its "Responsible Mineral Management Policy" (hereinafter referred to as the "Policy") based on the OECD's "Guidelines for Responsible Supply Chain Responsibility Management of Minerals from Conflict Affected and High Risk Areas" and with reference to the EU Battery Regulation (EU 2023/1542).
The scope of responsible minerals of Guangzhou Tinci Materials Technology Co., Ltd. includes lithium.
Applicable to the responsible mineral management of the supply chain of Guangzhou Tinci Materials Technology Co., Ltd. and all its subsidiary companies.
We commit to identify and manage the following risks in supply chain operations management:
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 service which 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.
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, or linked to, any party committing serious abuses as defined in paragraph 1.
Regarding direct or indirect support to non-state armed groups or illegal armed controlled areas:
3. We will not tolerate any direct or indirect support to non-state armed groups or illegal armed controlled areas through the extraction, transport, trade, handling or export of minerals. “Direct or indirect support” to non-state armed groups or illegal armed controlled areas 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 illegal armed controlled areas 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;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 traders.
Regarding risk management of direct or indirect support to non-state armed groups or illegal armed controlled areas:
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 groupsor illegal armed controlled areas 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 mine sites,transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation 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 miners where minerals 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.
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 suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan.Where we identify a reasonable risk of activities inconsistent with paragraphs 8 and 9, we will respond in the same vein.
Regarding bribery and fraudulent misrepresentation of the origin of minerals:
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.
Regarding occupational health and safety:
15.We will not profit from, assist with, or facilitate or source from, or be linked to, any party providing life threatening occupational health and safety conditions to direct and / or indirect employees and / or any person present on the party's operations.
Regarding risk management of occupational health and safety:
16.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 as defined in paragraph 15.
Regarding child labor:
17.We will not employ, profit from, assist with, or facilitate, or source from, or be linked to, any party employing, profiting from, assisting with, or facilitating the employment of children under the minimum working age which is legally prescribed by the host country laws and regulations. If there is no relevant host country law or regulation, the minimum working age shall be 16 years.
Regarding risk management of child labor:
18.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 employing children as defined in paragraph 17.
Regarding Environmental Protection:
19.We will not profit from, assist with, or facilitate significant adverse impacts regarding ambient soil, air ,water, climate, biodiversity or community life, including the manufacture, trade, use of chemicals and hazardous substances which are subject to an international ban due to their high toxicity, environmental persistence, or potential irreversible ecological effects, or source from or be linked to any party with gross violation of local laws and regulations.
Regarding Exploitation of Resources:
20.We do not participate in, tolerate, or profit from the exploitation of resources from land where the free, prior and informed consent of local and indigenous peoples has not been obtained, a legal title, lease, concession, or license has been obtained illegally , or national laws have been violated, or significant health and safety risks to surrounding communities in the mining process.
Regarding Culture, Heritage Protection and Legally Protected Area:
21.We do not participate in, tolerate, or profit from extracting or sourcing resources from mining operations where the culture and heritage of local and indigenous peoples have not been respected and protected, or where traditional cultures and heritage of local peoples have been harmed.
Regarding Artisanal or Small-Scale Mining:
22.We particularly concern about forced labor, child labor, unsafe working conditions, uncontrolled use of hazardous chemicals and other significant environmental impact risks related with artisanal or small-scale miners, seeking to establish production relationship with artisanal or small-scale miners in mining areas.
Regarding Risk Management of Environmental Protection, Exploitation of Resources，Culture, Heritage Protection and Legally Protected Areas:
23.If we have proper reasons to believe that such a risk exists, we will immediately work with suppliers and other stakeholders to develop, adopt and implement risk management plans based on where the enterprise’s specific position in the supply chain is. In order to prevent or mitigate the specific risks related to infringement of land rights, leading to significant adverse environmental impact or local cultural heritage damage. If the risk mitigation measures do not work, we will suspend or terminate our cooperation with upstream suppliers.
Governance Mechanism.
24.We are committed to continuous improvement, periodic review and updating of its policies and related processes. Under the leadership of senior managers, the responsible mineral due diligence committee, composed of multi-sector representatives, is implemented specifically. The team comprises key members from System, Procurement, SQE, Supply Chain, Quality and Legal Department, ensuring comprehensive monitoring of responsible mineral risks throughout the supply chains. The management team is responsible for developing and implementing management specifications to guarantee their applicability, transparency and effectiveness. Conduct due diligence of supply chain in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the EU Battery Regulation (EU 2023/1542), identify and assess risks, design and implement response strategies for identified risks, implement risk management programs, monitor and track the effectiveness of risk mitigation measures, and provide feedback to company management.
Policy Dissemination:
25.We establish a long-term partnership with suppliers, conducts relevant training and due diligence investigation activities, and ensures that suppliers are aware of and comply with the company's policies and requirements on responsible minerals through cooperation agreements or commitments, and also requires suppliers to communicate this policy to their upstream to ensure that conflicts and human rights violations do not occur in the supply chain of the company.
Claims Mechanism
26.We have established a claims mechanism to send an e-mail (fzrkcss@tinci.com) for advice or reporting any doubts or findings of violations of this policy.
