The 3 core companies (CCP, CCPC, DCC; hereinafter referred to as “CCPG”) of Chang Chun Group and subsidiaries recognising that risks of significant adverse impacts which may be associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and recognising that we have the responsibility to respect human rights and not contribute to conflict, we commit to adopt the OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-affected and High-Risk Areas, Edition 3 published by OECD (henceforth “OECD Guidance) to establish the minerals supply chain responsible sourcing policy and due diligence management system to identify and manage risks within minerals supply chain. The materials type covered by the Policy includes the CCPG operated copper and copper-containing materials. At the same time, CCPG commit to:
1. The Policy is applicable for the CCPG, materials covered in the Policy, the materials provides and its supply chain.
2. Communicate the Policy to covered materials suppliers, and publicly post on the CCPG's website.
3. Request suppliers comply with the Policy, and incorporate it into agreements with suppliers (e.g., Commitment Letter to Compliance with the Minerals Supply Chain Responsible Sourcing Due Diligence Management Policy)
4. We commit to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions and US sanctions resolutions or, where applicable, domestic laws implementing such resolutions.
I. 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:
a) Any forms of torture, cruel, inhuman and degrading treatment.
b) 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.
c) The worst forms of child labour.
d) Other gross human rights violations and abuses such as widespread sexual violence.
e) War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
II. Regarding child labour:
While sourcing from, or operating in high-risk areas, 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.
I. Regarding direct or indirect support to non-state armed groups
We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals. “Direct or indirect support” to non-state armed groups 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.
II. Regarding public or private security forces
1. We agree to eliminate, 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.
2. We recognize 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.
3. 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.
4. We will support efforts, or take steps, to engage with central or local authorities, international organizations and civil society organizations 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.
5. We will support efforts, or take steps, to engage with local authorities, international organizations and civil society organizations to avoid or minimize 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.
I. Regarding bribery and fraudulent misrepresentation of the origin of minerals:
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.
II. Regarding money laundering
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.
III. Regarding the payment of taxes, fees and royalties due to governments:
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 CCPG’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).
I. Regarding OHS:
While sourcing from, or operating in high-risk areas, 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.
I. 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 risks as the following:
a) Risk I: risk related to human rights
b) In risk II: risks regarding direct or indirect support to non-state armed groups.
c) Risk IV: risk related to OHS.
II. We will immediately devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk as the following, 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.
a) In risk II: risks regarding public or private security forces.
III. We commit to engage with suppliers, central or local governmental authorities, international organizations, 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 measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
a) Risk III: risk related to governance.
For any potential or actual violations set out hereof or with any doubts encouraged to promptly notify your business contact or report to us.
Miaoli Factory
E-mail：cu_diligence_ml@ccpgp.com
Tel：+886-2-2503-3371
Panjin Factory
E-mail：cu_diligence_pj@ccpgp.com
Tel：+86-427-677-5001 #835
Changshu Factory
E-mail：cu_diligence_js@ccpgp.com
Tel：+86-512-5236-8282
Chang Chun Group are dedicated to protecting the person whoever has doubt or need assistance in query or reporting about this Policy whose identity and reports will be treated confidentially strictly and prohibit retaliation for good faith reports of potential or actual misconducts as well as the involved investigators.
