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发表时间：2022-03-03 17:52:21 浏览：251
Shenzhen Point Gold Refining Co., Ltd.
2021Due Diligence Management Compliance Report of Supply Chain
Company name: Shenzhen Point Gold Refining Co., Ltd.
Address: Factory Building 1, No.3 Tanmian Road, Xikeng Village, Xikeng Community, Henggang Street, Longgang District, Shenzhen City
Year-end report: 2021 LBMA Due Diligence Management Compliance Report of Supply Chain
Report date: January 12, 2022
Person in charge of the Report: Shi Wei
Title of Reporter: Compliance Risk Control Director firstname.lastname@example.org
I. Company profile
Shenzhen Point Gold Refining Co., Ltd. (hereinafter referred to as Point Gold) was established in 2015 with a registered capital of RMB 150 million. Relying on the deep processing and trade of precious metals, Point Gold engages in all aspects of precious metal refining, such as innovation, regeneration, safety and environmental protection, green development and smart society, forming a “double-high” enterprise advantage with high economic efficiency and high R & D capability. Meanwhile, Point Gold is provided with a number of national policy access licenses and qualifications, which lays a solid foundation for the future development of the enterprise!
The registered trademark of the product is the “Gold Bull” brand. In 2019, Point Gold became a full member of Shanghai Gold Exchange and began to provide standard gold ingots (gold bars) for Shanghai Gold Exchange. The main products include 1000g gold bars of AU99.99, 100g and 50g small gold bars of AU99.99 for Shanghai Gold Exchange. In 2020, it independently designed and developed the “Gold Bull” brand series of investment gold products for sale in the gold market. Since the launch of the products into the market, the product qualification rate, the customer complaint and the customer satisfaction rate are 100%, 0 and 100% respectively.
The Refinery of Point Gold is located in Factory Building 1, No.3 Tanmian Road, Xikeng Village, Xikeng Community, Henggang Street, Longgang District, Shenzhen City. The refinery has hundreds of professionals. The whole production process can be 70% automated and is targeted to solve the three technical problems involved in the production process: environmental protection, comprehensive recovery of gold resources and zero discharge of production wastewater, forming a circular economy development model of the gold industry. The product production line covers precious metals such as gold, silver, palladium and platinum with dozens of forms and qualities and hundreds of specifications. The refinery of Point Gold is equipped with advanced equipment and leading technique. The annual gold refining quantity and the annual silver refining quantity of Point Gold can reach more than 80 tons and more than 60 tons respectively.
II. Overview of suppliers
The gold and silver materials of the Company are the crude gold and silver recycled from the society, mainly the used jewelry.
III. Overview of compliance
The Company conducted the due diligence supply chain investigation on all suppliers and required that the sources of the raw materials provided by all suppliers shall be legal and compliant.
Step 1: Establish strong company management systems
Compliance Statement with Requirement:
We have fully complied with Step 1: Establish strong company management systems.
The Company strictly abided by the requirements of “establishing strong company management systems” in Step 1 of LBMA Responsible Gold and Silver Guidance and has established strong management systems to ensure the full implementation of the supply chain due diligence.
1. Policy aspect
The Supply Chain Due Diligence Policy has been approved and issued by the Company, which complies with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and extends to environmental and sustainability responsibilities. The Policy is publicly published on company website with link: http://www.kmfgold.com/news/jituanyaowen/106.html.
The Policy requires the Company and its suppliers to strictly abide by the national laws and regulations on employee rights, environmental protection, fair trade and other laws and regulations and vigorously engage in the supply chain due diligence to ensure that the sources of minerals of gold and silver and recycled gold and silver meet the LBMA’s due diligence management requirements. Besides, The Policy requires the Company and its suppliers to make a commitment to refuse gold and silver from areas involving human rights violations, conflicts, bribery, money laundering, terrorist financing, illegal mining and world heritage sites and other high-risk areas of mercury mining.
2. Management structure
The Company has established an internal management system to define the management, roles and responsibilities, internal audit and communication according to the issued policy while carrying out the management review of due diligence system.
The Company conducted a management review on November 10, 2021, with the management review results reported to the Compliance Director.
2.1 Rules and regulations
The Company has formulated the Due Diligence Management Measures of Supply Chain and Due Diligence Management Policy of Supply Chain according to the LBMA Responsible Gold (Silver) Guidance, which mainly clarifies the organizational structure, responsibilities and definition of high-risk areas of supply chain due diligence and formulates high-risk supply chain evaluation standards, investigation and handling procedures, transaction monitoring, document preservation, etc. The above systems have been issued in the form of official documents after being approved by the Compliance Risk Control Director, Chairman and Board of Directors as document control.
2.2 Responsibility and authority
The Company sets Compliance Risk Control Director, Compliance Risk Control Officer and Compliance Officer.
The Compliance Risk Control Director is in charge of the Company’s supply chain due diligence by the Company’s Deputy General Manager. Specifically, the Compliance Director is responsible for the establishment and improvement of the due diligence management system of supply chain, the supervision of the supply chain due diligence process, the coordination and handling of abnormalities in the supply chain due diligence and the approval of the Compliance Report.
The Compliance Risk Control Officer is the person in charge of the Finance Department of the operation sector to be responsible for all matters related to the due diligence management of supply chain. Specifically, the Compliance Risk Officer takes charge of the formulation and updating of the supply chain due diligence policies and systems, the formulation of the high-risk supply chain evaluation standards and the implementation of the supply chain due diligence measures, the guidance, coordination and reporting of the Company’s risk assessment, response and implementation, the supervision and check of the implementation and assessment of all departments and the reporting of abnormalities in supply chain due diligence. At the same time, the Compliance Risk Officer is responsible for the review of the supply chain due diligence, the assessment on whether the due diligence is sufficient, the collection of additional documents or information if necessary, the organization of employee training on the responsible supply chain, the preparation and updating of supply chain policies and the supply of appropriate information for the senior managers to perform their duties.
The Compliance Officer is appointed by the Business Department, Logistics Department, Finance Department and the Factory and is responsible for the strict implementation of the supply chain due diligence measures and high-risk supply chain evaluation standards, the collection and retention of sufficient supply chain supporting documents, the establishment of supplier due diligence files and the regular on-site investigation on important suppliers.
The Company has established an accountability mechanism for the Compliance Risk Control Officer and the Compliance Officer to ensure the effective implementation of supply chain due diligence and avoid high-risk supply chain transactions through supervision and inspection. Officers concerned are required to regularly report the supply chain due diligence to senior managers and convene internal meetings in time.
3. Strong internal traceability systems
The Company has established a set of supply chain traceability systems for realizing the collection and maintenance of the supply chain information of each batch of products, and the distribution of a unique number to each batch of products out of the warehouse.
3.1 Supply chain traceability systems
The credit investigation has been implemented on all suppliers. After the credit investigation of collecting and reviewing the supplier qualification, business operation, shareholder information, material source through the due diligence questionnaire is passed, the contract then be signed to stipulate that the raw materials are legal and in line with LBMA Due Diligence Policy. For each batch of incoming materials sent by the suppliers, have been provided with the corresponding ex-warehouse sheet, indicating the product type, weight, acceptance personnel and the supplier’s signature for confirmation. After smelting, sampling and testing for the incoming materials, the incoming materials finally form standard bullion with a unique number and are traded through Shanghai Gold Exchange.
The Company has supervised all transactions to ensure the consistency between the transactions and the supply chain investigation.
The Company has inspected the due diligence of the supply chain. Each batch of incoming materials was provided with unique number and traceable production information. Complete documents and data have been kept for all raw materials warehousing, and the gold materials received were provided with warehouse-in sheet, inspection sheet, financial vouchers, etc.; while the silver materials received were provided with incoming material warehouse-in sheet, inspection sheet, financial vouchers, etc. Besides, it is necessary to clarify the data that each department has collected and saved in daily work. The Business Department, Testing Department and Finance Department have saved the relevant documents, and regularly send the relevant data to the archives room for filing, with a retention period of over 5 years.
3.2 Maintenance of data
In the process of the business operation, relevant records such as ID card of customers, identity verification data, business license, qualification verification data, the supplier due diligence questionnaire form, the in-warehouse sheet, ex-warehouse sheet and test sheet of each batch of materials have been kept for more than 5 years.
The Company incorporates the due diligence management training of supply chain into the Company’s annual training plan every year. The Company works on implementing the due diligence management of supply chain through organizing the Company’s key posts and Compliance Officer to accept training regarding the requirements and contents of the due diligence management of supply chain and LBMA Responsible Gold and Silver Guidance. Two times of training on LBMA-related knowledge were organized for the personnel of relevant departments of the Company and management personnel and production personnel of the Factory on March 16 and November 22, 2021.
3.4 Payment through official bank channels
When the Company pays for goods, the Marketing Department initiates the countersignature procedure for capital matters, makes online payment through the bank where the Company’s basic account is located, and prints the bank receipt as a voucher attachment.
4. Strengthen cooperation and assist the trading parties of the gold and silver supply chain to establish due diligence capability
The Company encourages long-term relationships based on trust and mutual recognition with suppliers, especially those suppliers comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and extend to environmental and sustainability responsibilities.
The Company has forwarded the policies and requirements of the gold and silver supply chain to the relevant transaction participants by e-mail, so as to enhance the ability of supply chain participants to conduct due diligence and support the EITI principle. The Company and suppliers strictly abide by the provisions of the contract and the law, with assistance to be provided for suppliers to establish due diligence capability to a greater extent.
All suppliers of the Company have signed the Supplier’s Social Responsibility Commitment to promise that the sources of gold and silver are legal and compliant in line with LBMA’s regulations. Major customers trading with the Company all have the invoices of their downstream customers filed to avoid the risk of tax evasion.
5. Establish a confidential complaint mechanism
The Company uses the official website link: http://www.kmfgold.com/news/jituanyaowen/106.html to publish the telephone number and email and allow employees and external stakeholders to express their doubts about the responsible supply chain, mining, trade, processing and export, as well as concerns about the supply chain or any newly identified risks. Meanwhile, the Company has established excellent complaint handling procedures to protect employees’ privacy throughout the appeal process and keep the informant’s information confidential to further eliminate retaliation for any behavior.
In 2021, the Company received no complaints from employees and external stakeholders.
Step 2: Identify and assess risk in the supply chain
Compliance Statement with Requirement:
We have fully complied with Step 2: Identify and assess risk in the supply chain.
The Company strictly abided by the requirements of “identifying and assessing risk in the supply chain” in Step 2 of LBMA Responsible Gold and Silver Guidance and has formulated the identification procedures (including standards, referenced resources and processes) for conflict-affected and high-risk areas, and the judgment standard of the high-risk supply chain as well as the treatment procedures for the identified risks, so as to fully identify, evaluate and mitigate the risks in the supply chain. In 2021, the incoming materials of the Company were all from domestic recycled gold and Silver, and China was determined as a low-risk area according to the identification procedures for the Company’s conflict-affected and high-risk areas, no high-risk supply chain found.
1. Identify supply chain risks
According to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the extension to environmental and sustainability responsibilities, gold and silver smelting companies identify relevant risks and pay close attention to gold and silver from places involving human rights violations, armed conflict, illegal mining, mining and utilization of mercury and world heritage sites, as well as gold and silver used for bribery, money laundering, terrorist financing and other acts. The Company established supplier files for each supplier and conducted the investigation according to the Company’s risk status. The Company completed the establishment of supplier files before signing contracts with the suppliers.
2. Assess supply chain risks
2.1 Supply chain investigation
The Company conducts due diligence on the supply chain through the following measures with the completed due diligence questionnaire:
(1) Qualification verification. For all suppliers, the due diligence management investigation of the supply chain have been conducted. Before cooperation, the partners are required to provide corresponding qualification certificates and the legal customers are required to provide business licenses. Individual customers are required to provide copies of ID cards. Mine customers are required to provide mining licenses and environmental impact assessment certification and the miners are required to wear labor protection appliances, health and safety transactions and physical examination of occupational diseases.
(2) Establish supplier files. A detailed investigation is required to be carried out for the Supplier’s basic information, shareholder information, actual controller, supplier management structure, type and origin of raw materials provided, type of precious metals planned to be refined, settlement method with suppliers, supplier profile and other information. The Company extends the supply chain investigation to the upstream of the supplier as far as possible to finally determine its risk level and terminates cooperation with suppliers involving high-risk standards.
(3) Establish the incoming material register. Due diligence is required to be carried out for the date, weight, raw material source and main upstream suppliers of the current batch of incoming materials of the supplier to further judge the risk level of incoming materials.
(4) Establish the workflow of special research reports about customers. When visiting customers, the Company traces the source of raw materials and conveys the due diligence management policy of gold and silver smelting companies to suppliers. Besides, the customers are required to sign the policy.
2.2 Determination of conflict-affected and high-risk areas. The Company has developed an identification process for conflict-affected and high-risk areas. The Company identifies the countries/regions included in the list of conflict-affected and high-risk areas of the European Union, the countries specified in the Dodd-Frank Act and the included in the FATF gray list as the high-risk countries/regions.
2.3 High-risk supply chain
According to the relevant regulations of LBMA and OECD and in combination with the actual situation of the Company, the following judgment criteria for a high-risk supply chain are specially specified:
(1) Mined gold and silver or recycled gold and silver come from or are transferred or transported through conflict-affected and high-risk areas;
(2) Mined gold and silver are claimed to come from a country with limited known reserves, limited resources or limited expected production;
(3) Recycled gold and silver come from known conflict-affected and high-risk areas, or are transferred through such areas with some reason to suspect;
(4) The companies in the supply chain or other known upstream companies are located in a country with a high risk of money laundering, crime and corruption;
(5) The beneficial owners of the companies in the supply chain or other known upstream companies are politically sensitive persons;
(6) Companies in the supply chain or other known upstream companies actively participate in high-risk business activities (such as weapons, gambling, casinos, antiques and works of art, diamonds), or act as the religions and religious leaders;
(7) Mined gold and silver come from small mines with incomplete domestic procedures and illegal mining and the mining of gold and silver comes from manual mining;
(8) Mined gold and silver or recycled gold and silver are produced by using mercury;
(9) The environmental and sustainable development laws are not obeyed and the mined gold and silver or recycled gold and silver come from world heritage sites or domestic natural ecological reserves;
(10) Other high-risk situations.
When any of the above judgment criteria exists objectively, the supply chain is judged as a high-risk supply chain. The Department Compliance Officer immediately prepares materials and reports them to the Compliance Risk Control Officer who reports them to the Compliance Director for approval. Then, the Compliance Director takes countermeasures, stop trading and eliminate risks.
2.4 The Company establishes a risk assessment process to assess the risks of the Company’s gold and silver suppliers:
The Financial Department and Human Resources Department are in charge of the quantitative assessment of the losses resulted from risk events, and are responsible for holding relevant responsible persons accountable, tracking and investigating risk events, so as to eliminate hazard sources and reduce losses
Through the due diligence on upstream suppliers of raw material, the Company publicizes the “OECD Guidelines on Due Diligence on Qualified Supply Chains in Conflict-Affected and High-Risk Areas” to suppliers, as well as reminds and urges upstream suppliers of raw material to conduct business in a legal and compliant manner, avoiding to sell the following raw materials with high risk to demanders:
(1) Involving systematic and widespread human rights violations related to gold/silver mining, transportation and trading, forced labor, child labor, as well as cruel, inhuman and humiliating abuse;
(2) Involving war crimes, violations of international human rights law, human rights crimes or genocide;
(3) Directly or indirectly supporting non-governmental armed groups, public or private security forces, purchasing precious metals or providing assistance (Refer to the definition in the appendix of gold and silver in the OECD Guidance on Due Diligence on Mineral Supply Chain in Conflict-Affected Areas and High-Risk Areas);
(4) Obtaining from bribe or hiding the true source of gold and silver;
(5) Involving money laundering or purchasing precious metals from high-risk and conflict-hit areas;
(6) Involving terrorist financing;
(7) Involving aggravation of conflicts;
(8) Possibility of mining and producing gold with the use of mercury;
(9) Possibility of not compliance with legal requirements regarding environmental protection and sustainable development, mining gold from world heritage sites or domestic natural ecological reserves;
(10) Involving soil erosion, water & soil loss and land desertification caused by the development of mineral resources, land subsidence, collapse, mountain collapse, landslide, debris flow and other geological disasters;
(11) Involving pollution of waste residue, wastewater and waste gas to water, soil and air, destruction of wildlife resources and natural geomorphological landforms, risk to public health and property damage.
3. Report risk assessment to the senior management
The Company establishes the risk assessment report system. When the supply chain investigation indicates that it comes from a high-risk area and is assessed as a high-risk supply chain, the transaction shall be stopped and reported to the Compliance Director. In 2021, all gold and silver suppliers were assessed as low-risk suppliers.
Step 3: Design and implement a management strategy to respond to identified risks
Compliance Statement with Requirement:
We have fully complied with Step 3: Design and implement a management system to respond to identified risks.
The Company strictly abided by the requirements of “designing and implementing a management strategy to respond to identified risks” in Step 3 of LBMA Responsible Gold and Silver Guidance. No high-risk supply chains were found in 2021, so risk mitigation is not required.
The Company has formulated the Management Measures for Supply Chain Risk Mitigation and put forward the risk mitigation strategies, including (i) reducing risks while continuing transactions; (ii) mitigating risks while suspending transactions; or (iii) terminating the transaction as document control, which stipulates the treatment methods for violations found in the supplier assessment and daily business development. Besides, the processing steps of high-risk behaviors of suppliers are regulated and the responsibilities of organizations and personnel at all levels for due diligence management are clarified for the implementation of progress follow-up by senior managers.
After the suspected high-risk incoming materials are found, they shall be registered separately and notified to the refining workshop. The corresponding raw materials shall be melted separately and shall not be mixed with the raw materials from other customers in the whole process flow. The finished gold and silver produced by such raw materials shall be numbered separately and stored separately with other finished gold and silver in the vault.
When the supply chain investigation indicates that it comes from a high-risk area, it is necessary to conduct enhanced due diligence, including on-site assessment of the risks in the policy. When the due diligence of the supply chain indicates that it may come from high-risk areas, it is necessary to immediately suspend the smelting of the mined gold and silver and recycled gold and silver until the supplier provides additional data or information that can prove its impossible existence within 6 months. If relevant evidence is not provided within 6 months, the transaction shall be stopped immediately and reported to relevant personnel.
The information provided includes:
(1) Provide government documents proving that there are no systematic or widespread human rights violations related to the extraction, transportation or trade of the mined gold and silver and recycled gold and silver, such as the legitimacy certificate issued by the relevant public security organs or commercial organs in the place where the supplier is located;
(2) Provide documentary evidence that no direct or indirect support has been provided to illegal armed groups;
(3) Provide certificates of origin that do not cover the mined gold and silver and recycled gold and silver through fraud, such as certificates of origin issued by relevant government sectors;
(4) Provide documentary evidence that there is no money laundering or terrorist financing;
(5) Provide qualification certificates of domestic small mines;
(6) Provide information that can prove that the mining of gold and silver is not produced by using mercury;
(7) Provide the guidelines, policies and system documents related to environment and sustainable development and the obtained environmental impact assessment report of relevant organizations;
Step 4: Arrange for an independent third-party audit of the refiner due diligence
Compliance Statement with Requirement:
We have fully complied with Step 4: Arrange for an independent third-party audit.
公司严格遵守LBMA黄金、白银责任指南第四步“对精炼商的尽职调查实践开展独立的第三方审计”的要求，于2022年聘请RCS对公司2021年度供应链尽职体系进行审计。 The Company strictly abided by the requirements of “arranging for an independent third-party audit of the refiner due diligence” in Step 4 of LBMA Responsible Gold and Silver Guidance and hired RCS to audit the Company’s 2021 supply chain due diligence system in 2022.
Since 2015, the Company has hired an independent third-party audit institution (Shenzhen Yongming Accountant Firm) to audit its financial affairs and issue audit reports every year.
Step 5: Annual report on supply chain due diligence
Compliance Statement with Requirement:
We have fully complied with Step 5: Report on supply chain due diligence.
The Company strictly abided by the requirements of “annual report on supply chain due diligence” in Step 5 of LBMA Responsible Gold and Silver Guidance.
The Company has published the supply chain due diligence policy of Shenzhen Point Gold Refining Co., Ltd. every year.
According to the due diligence results in 2021, no supplier was required to carry out the risk mitigation management strategy. At the end of 2021, there were no suppliers whose assessment results of gold and silver were “suspension of cooperation” or “termination of cooperation”. The Due Diligence Management Compliance Report of Supply Chain will be published on the Company’s official website.
IV. Management conclusion:
In conclusion, in the financial year ending December 31, 2021, Shenzhen Point Gold Refining Co., Ltd. implemented effective management systems, procedures, processes and practices in accordance with the requirements of the London Bullion Market Association (LBMA) Responsible Gold and Silver Guidance. Shenzhen Point Gold Refining Co., Ltd. is committed to continuous improvement and all corrective measures will be regularly monitored internally. The corrective action plan is communicated separately to implementing agencies of LBMA and the management personnel of the London Bullion Market Association (LBMA) Responsible Gold and Silver Guidance.
V. Other report comments
If users of this report wish to provide any feedback to Shenzhen Point Gold Refining Co., Ltd. with respect to this report, please contact relevant department of the Enterprise by E-mail email@example.com.