CONFLICT MINERAL POLICY STATEMENT OF YUNNAN CHENGFENG NON-FERROUS METALS CO., LTD.
Yunnan Chengfeng Non-ferrous Metals Co., Ltd is a large tin producer in China that has the ability of smelting and processing. Our cassiterite is generally sourced from Chinese mines and some imported from Myanmar.
根据2010 年7 月21 日生效的《多德—弗兰克华尔街改革和消费者保护法案》第1502 节规定：“冲突矿物”包括锡石及其衍生物，同时还有其它两种矿物和黄金。公司支持这项法案所要达成的目标，也从未与刚果民主共和国东部省份有关冲突采矿行业联系，并将认可此项法律对于在美国证券交易所的上市公司所做的相关披露要求。
Section 1502 of the US Dodd-Frank Wall Street Reform and Consumer Protection Act effective on July 21st 2010 defines ‘Conflict Minerals’ as including ‘cassiterite and its derivatives’ along with two other minerals and gold. Yunnan Chengfeng Non-ferrous Metals Co., Ltd generally supports the objectives of this law and has no link between mining and conflict in the eastern Provinces of the Democratic Republic of Congo (DRC), and recognizes the disclosure requirements that this law imposes on SEC reporting companies in the US.
Our tin business partly involves the purchase and treatment of secondary materials that we obtain from end-of-life materials, by-products or intermediate products from Chinese suppliers. We also consider our tin recycling business to be an important and positive contribution to the sustainable management of natural resources and an activity that should be promoted. In the process of sourcing, we require commitment by our suppliers that their materials should originate in conflict-free minerals. Otherwise, we will terminate sourcing immediately.
Both the Organization for Economic Co-operation and Development (OECD) and the United Nations (UN) have released broadly similar guidelines for company due diligence on minerals from conflict affected and high risk areas, and in the case of the UN, specifically for the DRC. The OECD guidance encourages companies to draw upon it when establishing their due diligence practices, and the guidance aims to promote responsible sourcing by incorporating the flexibility to allow trade to continue.
We have assessed our sources and suppliers of minerals according to the ‘red flag’ criteria contained in the OECD guidance and consider that the need for further due diligence is not required. Our company does not source cassiterite from the DRC or adjoining countries.
We are engaged in the Conflict Free Smelter Program and participate in auditing processes to provide assurance for our customers that our tin ingot and products are from sources not linked to conflict.
Although not sourcing cassiterite from the DRC or adjoining countries, we have made relevant personnel within our company such as smelter managers and mineral purchasers aware of the ‘conflict minerals’ law of the US, as well as the ‘red flag’ criteria of the OECD guidance. We have also made our suppliers aware of these criteria and have included relevant text in our supply contracts.
RELEVANT COMPANY AND ASSOCIATION ACTIONS
Our company has not, and is not purchasing cassiterite from the DRC and/or adjoining countries, since that is not part of our business model. However, we fully support the aims of the iTSCi program to differentiate between minerals trade that may be funding conflict, and the trade that is not, in order to allow artisanal mining to continue when possible, and to avoid a complete embargo on the region. We consider that ‘conflict minerals’ can most effectively be controlled at source, rather than at the point of smelting.
The intention of the supply chain should be to facilitate and promote improved governance, peace and stability, respect for human rights, economic development, and improved livelihoods in the DRC and adjoining countries.
Despite having no direct involvement in purchasing from the DRC, but as a leading member of the tin production industry, our company therefore aims to contribute to the achievement of two goals:
Minimizing the trade in cassiterite that directly or indirectly finances or benefits armed groups in the DRC and/or adjoining countries, and;
Promoting ways for legitimate minerals from the region to enter the global supply chain, thereby supporting the economy of the region and the local communities that depend on this trade.
We also communicate this policy to our customers and publicly through other channels such as our company website.
This statement is effective from January 1, 2016
YUNNAN CHENGFENG NON-FERROUS METALS CO., LTD.