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发表时间：2023-02-03 10:22:42 浏览：517
Shenzhen Point Gold Refining Co., Ltd.
Responsible Platinum and Palladium Procurement Complaint Procedure
The Company has established a review system for materials containing platinum and palladium and sales in accordance with the requirements of LPPM Responsible Platinum and Palladium Guidance to strengthen the compliance management of platinum and palladium supply chain of Shenzhen Point Gold Refining Co., Ltd. and ensure that supply chain of the Company is free from human rights violations, money laundering and terrorist financing. All suppliers of the Company shall cooperate with the Due Diligence Team of the Company for review. All suppliers shall abide by relevant national laws and regulations and ensure the compliance of the source and destination of platinum and palladium supplied. Stakeholders (affected persons or whistleblowers) in the platinum and/or palladium supply chain of the Company shall be allowed to complain about the existing/potential risks in the process of mining, trade, processing and export and it shall be ensured that such complaints are handled properly.
LPPM Responsible Platinum and Palladium Guidance, LPPM Responsible Platinum and Palladium Supply Chain Due Diligence Management System, and Supply Chain Policy of Shenzhen Point Gold Refining Co., Ltd.
3. Scope of application
The Procedure is applicable to any internal and external stakeholders involved in the responsible platinum and/or palladium procurement supply chain of the Company, including any organization, government organization, non-governmental organization, individual, etc.
4 Management organization and duties
The Company has established a Complaint Handling Team composed of Compliance Control Director, Compliance Risk Control Officer and Compliance Officer, and the team is responsible for handling complaints.
5 Working procedure
5.1 Collection of complaint information
The Company has established contact/complaint channels:
合规总监 施巍 0755-28718483 firstname.lastname@example.org
Compliance Director: Shi Wei 0755-28718483 email@example.com
合规风控官 黄静 0755-28718483 firstname.lastname@example.org
Compliance Risk Control Officer Huang Jing 0755-28718483 email@example.com
It is published on the official website of Shenzhen Kin Ming Feng Precious Metals Co., Ltd. (http://www.kmfgold.com/news/gongsixinwen/151.html) with telephone and e-mail addresses provided to receive relevant inquiries and complaints. The Compliance Officer of the Company will regularly check them.
Information will be received at work from interested parties on concerns about responsible supply chain in connection with mining, trade, processing and export.
5.2 Complaint contents
When interested parties lodge a complaint against supply chain management of the Company, the complaint shall include the following contents:
Specify the decision against which the complaint is lodged and the reasons;
Attach relevant written evidence;
Specify the steps taken to solve the problem before lodging a complaint;
5.3 Classification of complaint information
The Company shall classify and identify the received inquiry and complaint information, and the complaint information is divided into general information, special/important complaint information and inadmissible information.
5.3.1 General information: related parties’ consultation on the Company’s responsible mineral supply chain management, suppliers’ questionnaires, etc.
5.3.2 Special or important complaint information:
Information for management not conforming to LPPM requirements;
Information of mineral procurement from suppliers involving high-risk areas identified by the Company;
Information of mineral procurement from suppliers not conforming to supply chain policy of the Company.
5.3.3 Inadmissible information:
Petty, malicious, unreasonable or complaint seemingly for the purpose of gaining a competitive advantage.
Complaints not supported by convincing objective evidence.
5.4 Handling of complaint
5.4.1 About anonymous complaint
Anonymous complaint is supported. The Complaint Handling Team shall not disclose the complainant’s information to anyone outside the team and keep confidential the contents of the complaint that may involve information of the complainant. If the contents of the complaint have interest with members of the team, the team shall immediately require the members to withdraw. If any retaliation against the complainant is found, the Company will seriously handle relevant employees in accordance with the Company’s Articles of Association. If they are suspected of violating laws and committing crimes, the case will be reported and referred to the judiciary authorities for handling.
5.4.2 Complaint handling procedure
申诉处理小组工作组应在收到申诉后 10 个工作日内确认收到申诉，在基于申诉是否符合5.3的基础上确认接受或拒绝申诉。
The Complaint Handling Team shall confirm the receipt of the complaint within 10 business days upon receipt of the complaint, and confirm the acceptance or rejection of the complaint based on whether the complaint meets 5.3.
If the complaint is rejected, a written explanation shall be provided for the complainant and recorded. No further action shall be taken.
With regard to particularly important complaint information, the Complaint Handling Team shall investigate, review and decide the grievance or complaint within 45 business days after deciding to accept it. The team shall make best endeavors to finish the work before the deadline. Extra time may be needed in a very few cases. The Complaint Handling Team shall take reasonable measures, including convening one or more meetings, to make a reasonable decision. Examples of such measures include:
Request the complainant or others to provide more information
If the complainant refuses to cooperate, it can be deemed as a reason for suspending the procedure. The Complaint Handling Team shall decide whether to suspend the complaint procedure through consensus.
The complaint decision shall be conveyed to the complainant in written form and the complaint decision shall include:
How and when was the complaint decision made?
Any new suggestions
The Compliance Officer shall regularly summarize risk handling results, and publicize the complaint contents, handling methods and handling results in the official website of the Company. The Compliance Risk Control Officer is responsible for supervising the implementation of risk mitigation measures throughout the process and reporting the progress to the Compliance Director daily. After implementation of the risk mitigation measures is completed, the Compliance Director shall regularly evaluate the effectiveness of the measures and makes summary and evaluation.
5.5 Record of complaint
The Complaint Handling Team shall record the complaints received, including the following contents:
Who submitted the complaint and time;
Type, problem or theme of the complaint and the information submitted with the complaint;
Accept or reject the decision.