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2023 Due Diligence Report

Time:2025-3-30

1. Company Profile (all sources)

RFH Yancheng Jinmei New Materials Co., LTD., CID 004062. On June 29, 2017, the company acquired 15 mu of land at No. 16, Weifang Second Road, Funing High-tech Industrial Development Zone, for the construction of tantalum oxide and niobium oxide calendering processing project, with a total investment of 30 million yuan.

 

2.RMAP Evaluation Summary (all sources)

As a responsible company, we are committed to helping the Upstream Supply Chain share social responsibility. Strictly abide by the relevant laws and regulations of our country and international rules. On April 7, 2023, we conducted a DAP audit by UL, an independent third-party audit firm, with an evaluation starting from 01/01/2022 and ending from 03/31/2023, with Roc Liao, the lead auditor. This assessment summary report is posted on the RMI website, https://www.responsiblemineralsinitiative.org/media/docs/downstream/Downstream_Audit_Summary_Report_RFH_Yancheng.pdf.

 

In 2023, our company complied with the OECD Due Diligence Guidelines for Responsible Global Supply Chains for Minerals from Conflict-affected and High-risk Regions” and only purchased  RMI-approved company raw materials. The entire process was strictly controlled and firmly implemented in accordance with the OECD five-step framework and the requirements of the Supplement on Tin, Tantalum and Tungsten and the Responsible Minerals Inspection Process. This report is posted on the company's website:http://cz918.com.cn/beta/20250407-jinzhui/en/zeren_info.asp?pid=14

 

3. Corporate Supply Chain Policy (all sources)

Our company implements an open and transparent purchasing policy for raw materials. In compliance with the OECD Guidelines on Responsible Global Supply Chain Due Diligence on Minerals from Conflict-affected and high-risk Areas, in order to avoid the use of  minerals that directly or indirectly finance or benefit armed groups and/or are involved in other serious human rights violations in high-risk and conflict-affected areas, Illegal taxation or extortion, money laundering, conflict minerals in violation of the Extractive Industries Transparency Action Plan (EITI), the development of a Supply Chain Policy and the integration of supply chain policy into contracts/agreements with suppliers. This policy is in full compliance with the Model Policy on Global Responsible Supply Chains for Minerals from Conflict-Affected and High-risk Regions (Appendix II of the OECD Guidance), which covers all the risks identified in Appendix II of the OECD Guidance and applies globally. The Company undertakes to address any Appendix II risks as soon as they are identified. This policy has been reviewed by senior managers and approved by General Manager. Management is committed to supporting the implementation of this policy. This policy has been to the stakeholders (suppliers, customers, employees, etc.), in the company's web site http://cz918.com.cn/beta/20250407-jinzhui/en/zeren_info.asp?pid=13

4. Corporate Management System (all sources)

4.1 Our company strictly abides by its commitment in terms of supply chain policy and has developed internal due diligence procedures in the following aspects:

● The General Manager is responsible for overseeing the design and implementation of the due diligence system and risk management.

●Li Yang be appointed as Senior Manager to implement the due diligence system and coordinate the work of relevant departments (including Social Responsibility, Supply and Marketing, Production and Technology, General Affairs and Quality) to ensure that all departments perform their duties, conduct due diligence and report any warning signs and potential risks they find.

●Company  only purchases tantalum raw materials from suppliers approved by RMI, confirmation of inclusion in the approved list can be found in the smelter list or in the downstream assessment program participants.

Tantalum Smelters List:

http://www.responsiblemineralsinitiative.org/tantalum-smelters-list/

Downstream Assessment Program Participants:

http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/downstream-program/

 

●According to the requirements of the due diligence system, our company has conducted due diligence management system training for the main personnel of all relevant departments, and included it in the induction training for new employees. If the system is updated, the company will carry out additional training as required. On March 22, 2023, all staff were trained according to the training plan.

●The senior manager shall organize management review at least once a year. Analyze changes in internal and external factors, stakeholders' needs and expectations, fulfillment of company policies and commitments, performance of management processes, status of improvement actions, results of internal and external audits, resource adequacy, etc. Report audit results and continuous improvement plans to the General Manager.

4.2 Internal control system

●Company has established a due diligence management system and formulated the Due Diligence Management Manual. The process of supplier selection, approval and material flow is controlled through implementation, Supplier Management Procedures, Internal Raw Materials Control Procedures, Identification and Traceability Procedures, etc. Quality balance assessment is carried out throughout the process to ensure consistency with OECD guidelines and RMAP.

●Company has communicated the latest supply chain policy and purchasing requirements to its direct suppliers by phone, email, training, etc. The Company has incorporated its supply chain policy into specific legally binding contracts/agreements with its direct suppliers. The company inspects 100% direct suppliers once a year, accounting for 100% of the annual sales, and communicates the risk assessment report to the suppliers. Spare no effort to improve supplier performance, and organize relevant personnel to train and build capacity for suppliers when necessary.

●Company established a "complaint management procedure", and on site (http://cz918.com.cn/beta/20250407-jinzhui/en/zeren_info.asp?pid=15), senior manager's contact information as the complaint channel, accept the supervision of the society from all walks of life.

4.3 Record Retention System

The company requires that all records related to the due diligence system be maintained for at least five years. Execute the Documentation Control Procedure. Paper documents must be stored in filing cabinets and protected against moisture, mildew and moth. Electronic documents and records using computer processing backup, anti-virus on schedule, to ensure the safety of documents and records.

5. Risk identification

5.1 The Company implements Risk Management Procedure to identify risks in the supply chain. Review all information collected against internal procurement requirements such as the UN Sanctions List, the US Sanctions List, the EU Sanctions List, local laws and Supplier Management Procedure. All direct suppliers conduct risk assessments at least once a year.

5.2 The Company has designed the Supplier Management Procedure to understand the supplier process and incorporate the information about the supplier's legal status and identity, supplier analysis and potential risks. All of our suppliers have completed and returned KYC forms. Senior managers of the company reviewed the information provided with the procurement team. Whenever inconsistencies, errors or incomplete information are found in the KYC forms, the Company will work further with the supplier to clarify and improve the documentation where necessary. During the reporting period, there were no warning signs associated with the KYC forms submitted.

5.3 The Company only procured tantalum raw materials from suppliers approved by RMI, conducted basic due diligence on suppliers in accordance with the Risk Management Procedure, and verified their identities by accessing the RMI website and reviewing the list of Conforming smelters and List of Downstream Assessment Participants; Visit the suppliers' website to review the Supply Chain Policies and Due Diligence Reports; View full Supplier Evaluation Reports and more. Assess and mitigate risks in the supply chain and verify the presence of the warning signals mentioned in OECD Appendix II to check compliance with our supply chain policy.

5.4 For each transaction, the company requires suppliers to provide production date analysis certificates for each shipment and a complete set of traceability documents for comparison. Conduct further due diligence if inconsistencies or discrepancies are found.

5.5 In the context of raw material procurement or supplier activities, there are a range of circumstances that require further due diligence:

a) The batches provided by the material are not within the compliant production period;

b) Lack of traceability documents;

c) Providing products beyond the previous production capacity;

d) Supplier's latest information is not updated and reported in time;

e) Other recognizable warning signals.

5.6 Use the network or field visits and other channels to spot check from time to time, if found inconsistent and the situation will affect the risk assessment results, suspend the cooperation with the supplier. Suspend or continue to work with the supplier based on the results of the re-risk assessment.

6. Risk assessment and risk mitigation

6.1 The Company implements Risk Management Procedures to assess and mitigate risks in the supply chain.

6.2 In accordance with the above risk identification methods, conduct enhanced due diligence on raw materials and supply chains identified as "high risk", where necessary, on-the-ground assessments are carried out to develop feasible risk mitigation plans in consultation with suppliers, local and central authorities and affected stakeholders.

6.3 Risk reduction strategies include:

a) Continuing trade throughout measurable risk management.

b) Suspend trade while continuing to reduce risk.

c) Terminate the cooperation with the supplier if risk mitigation measures are not feasible or acceptable.

6.4 This risk management plan shall be reported to the general manager and transmitted to the supplier, and relevant departments shall supervise the implementation regularly.

6.5 During this evaluation period, the Company has no "high risk" procurement and no risk mitigation plan in execution for the time being.


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