九江市杰尼新材料有限公司
 Jiujiang Janny New Material Co., Ltd

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Responsible Supply Chain Due Diligence Report 2019

1. Company profile (information)

Jiujiang Janny New Material Co., LTD. (Hereinafter as Janny Company) was founded in 2008. Its CID number is CID003191.It is located at No.3 Industry Area, Binjiang East Road, zip code 332000.Through continuous accumulation and development, Janny Company has been providing high quality tantalum and niobium Metal products for tantalum and niobium industry.Janny Company has taken the initiative to assume social responsibilities from the beginning to the end and strictly abides by Chinese relevant laws and regulations and International rules.

2. RMAP Evaluation Summary (all sources)

As a responsible company, Janny Company has been actively supporting and participating in RMAP annually.From 2017 to 2018, Jinxin has received two consecutive independent third party RMAP audits commissioned by RMI, and successfully passed the annual audits in 2017-2018.The assessment will be valid for one year and will be conducted by an independent third party from August 1, 2018 to July 31, 2019.The company's 2018-2019 RMAP review and evaluation is scheduled for August 2019.

The assessment summary report is available at www.zmdfgj.com.

3. Responsible Mineral Supply Chain Policy (all sources)

Janny Company has always strictly adhered to and fully complied with OECD responsibilities for minerals from conflict-affected and high-risk areas. Janny Company has developed its own responsible minerals supply chain policy to avoid direct or indirect funding the armed groups which may benefit from conflict minerals and/or are involved in other serious violations of human rights in high-risk and conflict-affected areas.The policy is available on the company's website www.zmdfgj.com.

According to OECD guidelines, we use different risk levels for different materials from different countries and regions. We have developed management methods to ensure that we comply with  the requirements of the OECD guidelines Five-step framework.For this reason, we founded a special management team, led by the general manager, including all the company's senior executives, purchasing department, warehouse management department and other relevant functional departments and production directors.

4. Management System

The company has a very strict management system for the supply chain, developed a series of complete supply chain management system, through the following measures and procedures to ensure that conflict raw materials from conflict-affected areas are never procured and used , preventing any conflict raw materials and unidentified sources of materials entering the supply chain.Prevent mining and trade of minerals from becoming a source of conflict, human rights violations and insecurity.

In August 2018, we reviewed and revised all internal control procedures and documents, strictly adhering to the supply chain policy commitments, and has developed internal due diligence processes as below:The company has appointed the due diligence plan Manager to coordinate relevant departments,including purchasing department, warehouse management department and

other relevant functional departments and production department. All the departments must follow through  on  their  duties,  carry  out  due  diligence  plans  and  report  any  potential  warning   risk .According to the due diligence plan , Janny Company conducts due diligence management system training for all key personnel of relevant departments once a year. If the plan is updated, the company will carry out additional training as needed.

5. Internal Control System

-- Due diligence management system has been updated to bring it into line with the OECD guidelines and RMAP.

-- Updated supply chain policies and purchasing requirements have been communicated to all identified suppliers.

-- -Open and transparent procurement policy

Janny Company’s raw material purchase statement has been published on the company's public website, so that each supplier clearly understand our purchase policy.Responsible minerals supply chain management system document is issued to all departments within the enterprise, so that every employee knows and implements it.

-- -Control procedures for raw material purchase

The company has formulated and implemented six processes of《supplier management process》,

《procurement contract management process 》and 《tantalum raw material procurement and acceptance》,《Identification and traceability management process》,《Procurement documents management process》and《Tantalum material balance accounting management process》to limit and prevent any conflict materials and unknown raw materials entering the supply chain.

-- -Traceable material tracking process

Ensure the traceability and control of all tantalum raw materials in the use process by implementing the《Identification and traceability management process》.

-- -Adopting the raw material transportation control system and management methods in line with international standards, strictly observing the provisions on the transportation of hazardous substances including class 7 material, and measures for the administration for the《Regulations of radioactive substances》have been established and implemented.

-- -Conduct due diligence on suppliers and maintain continuity

In accordance with the OECD guidelines and audit requirements of the responsible minerals initiative, the company conducts annual due diligence on raw material suppliers to review and verify the supplier's legitimacy, quality assurance and conformity, and to adopt or cancel the supplier based on qualification.If we find any non-conforming items, we will ask them to make rectification, and if they cannot meet the requirements after the rectification ,We will immediately stop purchasing from the company and return the purchased non-conforming raw materials which cannot be included in our list for at least one year.

We will go to the mine for on-site audit and due diligence.

-- -Extensive channels of mass communication

Through due diligence on raw material suppliers, the company promotes to all suppliers "OECD's impact on conflict affected areas"."Due diligence guidelines for responsible supply chains for minerals in districts and high-risk areas", RMAP assessment criteria, transparency and

accountability,Supply chain requirements.At the same time, remind and urge upstream raw material suppliers to operate legally and in compliance, and not to operate any conflict raw materials or unknown material.The special terms of "non-conflict" are stipulated in our contracts with all suppliers, all suppliers promises that the raw materials supplied are "non-conflict raw materials".

--- The company requests our suppliers to actively participate in international conferences or trainings sponsored by international organizations, such as TIC, iTSCI, RMI, etc., to understand and learn about "OECD due diligence guide for responsible supply chain of minerals in conflict-affected and high-risk areas", RMI audit standards and transparency requirements of responsible tantalum supply chain.The company pays close attention to the study of iTSCi  incident report, monthly production evaluation, monthly regional status evaluation report, etc., so as to timely understand the production and operation of each mine.While maintaining communication with downstream customers, the suppliers provide CMRT to our company as required by RBA to ensure the supply chain due diligence.

-- -The OECD is responsible for minerals in conflict-affected and high-risk areas,responsible business alliance's latest requirements for the tantalum supply chain inspection standards and negative requirements for transparency in the supply chain of responsible minerals.

-- -Establish a channel for complaints.

The company opens a channel for complaints to the society, including the telephone number and the person in charge, aiming to be willing to accept supervision from all sectors of society.

-- -Where necessary, the company is willing to share supply chain data and information with upstream suppliers and downstream customers.

-- -Train the staff

Janny Company trains the employees, including senior management, and make them fully understand the "OECD and high-risk areas affected by the conflict area mineral responsible supply chain guide" due diligence and responsible business alliances on tantalum supply chain of the latest requirements of inspection standards and responsible mineral transparency of supply chain requirements.

-- -Actively fulfill social responsibility, build a company image of compliance and social responsibility

The company always combines the economic development of the enterprise with the fulfillment of social responsibility, and ensures the legal and moral operation.

We will fully fulfill our social responsibilities through activities such as technological innovation, production safety, employee rights and interests, and environmental energy conservation and emission reduction.

6. Risk identification

The company has designed a set of KYC forms to understand your counterparty, including information about the legal status and identity of the supplier, analyzes potential risks and collects relevant supporting documents.All our suppliers completed and returned the KYC.The company's due diligence program manager reviewed the information provided and the UN sanctions list with the procurement team.As long as the inconsistencies, errors, or incomplete information found in

the KYC form will be required by the company to improve.During the reporting period, no warning signal associated with the submitted KYC form was found.

-- -For each transaction, the company requires the supplier to provide the origin information and a complete set of traceability documents, including the legal shipping route and direct supplier name and address.

-- -Make full use of the information provided by the iTSCi tantalum ore supply chain supervision system and the on-site supervision system to supervise tantalum due diligence in high-risk areas mining.

7. Risk assessment and risk reduction

-- -According to the above risk identification method, enhanced due diligence has been carried out for raw materials and supply chain identified as "high-risk"

The investigation.This includes:

Assess upstream supplier activities and relationships;

Identify the location and quantitative conditions of ore extraction,trade,processing and export;

Conduct field risk assessment.

-- -In order to analyze the actual situation, carry out field assessment and evaluate the risks in high-risk supply chain, since iTSCi has been established ,the company has always used the following plan to assess the risk of every transaction coming from a high-risk area.

Extensive participation in the approved upstream assurance mechanism-iTSCi tagging and bagging system .

Our company requests our suppliers to be full member of iTSCi, has been actively supporting the work of iTSCi and participating in the traceability verification of high risk tantalum raw materials.For tantalum raw materials originating in high-risk areas, our suppliers only purchase raw materials certified by the iTSCi tagging and bagging system from iTSCi members.For each high-risk purchase transaction, iTSCi provides the following documents:

1) Event summary report

2) Mine Site visit recommendations, including a list of potentially risky sites (Due diligence and risk assessment recommended to companies sourcing from these sites)

3) National and regional monthly reports to review the general situation on the ground

4) Data summary and other reports

Janny Company focuses on learning other iTSCi reports and documents,such as incident reports,management evalution reports,company audits etc..The company conducted further due diligence to review relevant documents from upstream initiatives against public domain and actual transaction information.

At the same time, Janny Company requires all suppliers to provide the following document information for both high and low risk areas to each transaction:Supplier’s due diligence plan, including KYC,Company registration license or business license,mining license if it is a mining company.

Pay close attention to govermant information related to local company’s operation/country background. Collect the supply chain regulatory documentation for eachtransaction to ensure

that the source of the transaction and the shipping path are known.

Meanwhile, we will also conduct due diligence on suppliers in high-risk areas through field visits to mines,document checks,interviews ,consultation with local people and other stakeholders,and know wether serious infringement occurs in the process of mining ,transportaion and trade of minerials.

JiuJiang Janny New Material Co. LTD August 20, 2018


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