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

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DUE DILIGENCE PLAN AND RISK ASSESSMENT PROCEDURE

In accordance with our conflict mineral policy, we strictly adhere to OECDguidelines for the procurement of ore from conflict-affected and high-riskregions, as well as to compliance with United Nations Security Councilresolutions. In accordance with the guidance of OECD and relevant UNSecurity Council resolutions, we have taken the following measures in allbusiness dealings in the source areas of tantalum raw materials.

Due diligence plan 

Establishing a Strong Enterprise Management System

The company has a very strict management system for the supply chain,formulating a series of complete supply chain management system, throughthe following measures and procedures toensure that no conflict raw materialsfrom conflict-affected areas are purchased and used and to prevent anyconflict raw materials and uncertainties material enters the supply chain toprevent mineral exploitation and trade from becoming sources of conflict,human rights violations and insecurity. In August 2018, we reviewed andrevised all internal control procedures and documents and strictly adhered tosupply commitments on chain policy and internal processes for due diligencein the following areas have been developed:

General Manager of Janny Company is responsible for supervising the designand implementation of due diligence plan and risk management.

The company has appointed a due diligence plan manager to coordinate withrelevant departments (including purchasing department, warehousemanagement department, etc.) and production unit to ensure that alldepartments perform their duties, carry out due diligence plans and report anywarnings found and potential risks.   

Janny Company carries out a training of due diligence management system forall key personnel of relevant departments every year in accordance with therequirements of due diligence plan. If the plan is updated, the company willcarry out additional training as required.

We demand that our suppliers also adhere to all OECD-guided provisions andUN Security Council resolutions and never buy conflict ore to sponsor conflictdirectly or indirectly.


1. Internal control system

-Its due diligence management system has been updated to align it withOECD guidelines and RMAP.

The latest supply chain policies and procurement requirements have beencommunicated to all identified suppliers.

-Open and transparent procurement policy

Janny Company Raw Material Purchase Statement has been posted on thecompany's public website, so that each supplier has a clear understanding ofour mining purchasing policy. The"Responsible Mineral Supply ChainManagement System Document"was issued to all departments within theenterprise to make every employee aware of it and implement it accordingly.


-Control procedures for raw material procurementThe company formulates and implements Supplier Management Procedure,Purchasing Contract Management Procedure and Ta Raw Material PurchasingAcceptance. And in-and-out warehouse management process, identificationand traceability management process, procurement documents,managementProcedure and Ta Material Balance Accounting Management Procedure,totalsix process control procedures, limit and prevent any"conflict origin"material"and unknown raw materials enter the supply chain.

Traceable material tracking process

Through the implementation of the"Marking and Traceability ManagementProcess", the traceability and control of all tantalum raw materials in the useprocess are guaranteed.

-To adopt the control system and management measures for raw materialtransportation in accordance with international standards, strictly abide by theregulations for the transport of hazardous substances including categories 7 ofsubstances, and at the same time, establish and implement the Regulations onthe Management of Radioactive Substances.

Conduct due diligence on suppliers and maintain continuity


In accordance with the OECD Guidelines and the audit requirements of theResponsible Minerals Initiative, the company conducts annual due diligenceon raw material suppliers.To review and verify the validity, quality assuranceand conformity of suppliers as suppliers to adopt or cancel them.The basis ofqualification. For ITSCI labeled ores, we will visit all the supply mines of the
source mines and companies of the ores we purchased, and conduct acomprehensive study of the mines to determine the mine's geographical
location, personnel composition and output. Every year, we check and checkwhether the amount of ore produced is consistent with the original benchmark
study. Only after these mines and companies have been inspected and provedto have no direct or indirect connection with armed groups or human rightsviolations will we continue to purchase from this area or company; if we findany non-conformity, we will ask them to rectify it, if not to meet therequirements after rectification. We will immediately stop purchasing from the
company and return the non-conforming raw materials purchased, which cannot be included in our qualified suppliers for at least one year. In addition tovisits to local mines, we have retainedat least five years of all relevantdocuments on ore supplies from Africa so that problems can be verified in thefuture. Janny Company never buys raw materials in cash.

We implement the OECD policy for all employees to ensure that everyemployee understands and follows the policy. If employees do not do thecorresponding verification, we will immediately suspend the relevantprocurement contract. The contract will not continue until the employee verifiesand proves that the ore will not support the conflict directly or indirectly.Otherwise, we will cancel the contract and stop buying from the supplier.

Janny does not support cash purchase. If any supplier has such requirement,we will refuse to purchase.

-Broad channels of mass communication

Through due diligence of raw material suppliers, the company publicizes"OECD's impact on conflict areas"to all suppliers.Guidelines for due diligence

of responsible supply chains for minerals in regions and high-risk areas",RMAP assessment criteria, transparency and accountability supply chainrequirements. At the same time, we should remind and urge the upstreamsuppliers of raw materials to operate legally and in compliance with theregulations, and not to operate any"conflict raw materials"and unknown rawmaterials. Special clauses on"non-conflict"are stipulated in our contracts withall suppliers.The suppliers have promised that the raw materials supplied are"non-conflict raw materials".


The company itself and also the suppliers actively participate in internationalconferences or training sponsored by international organizations such as TIC,iTSCI, RMI, etc. to understand and learn"OECD due diligence guidelines formineral responsible supply chains in conflict-affected and high-risk areas", RMIauditing standards and transparency requirements for responsible tantalumsupply chains. The company maintains regular communication with iTSCi, andpays close attention to the study of iTSCi event report, monthly productionassessment, monthly regional status assessment report, etc. in order to timelyunderstand the production and operation of various mines. While maintainingcommunication with downstream customers, according to RBA requirements,the company provides CMRT to downstream visitors to ensure due diligence inthe supply chain. We also recommend that all our suppliers join the iTSCiprogram and RMAP. 

-Promoting to the public through the Internet that"OECD is responsible forminerals in conflict-affected and high-risk areas guidelines for due diligence inan appointed supply chain, the latest requirements of responsible businessalliances on the test criteria for a tantalum supply chain, and negativerequirements for transparency in responsible mineral supply chains.

Establishing complaint channels, the company has opened complaintchannels to the community, including telephone numbers, responsible persons,in order to be willing to accept. supervision from all circles of life.

When necessary, the company is willing to share supply chain data andinformation with upstream suppliers and downstream customers.

-Training staff

The company trains its employees, including senior management, to makethem fully aware of"OECD's due diligence guidelines for Responsible SupplyChains for minerals in conflict

-affected and high-risk areas"and the latestrequirements of responsible business alliances on the Tantalum supply chainauditing standards, as well as the perspective of responsible mineral supplychains. Lightness requirements.

-Actively fulfill social responsibility, create a corporate image of compliance

and social responsibility ,the company always closely combines the economicdevelopment of enterprises with the fulfillment of social responsibility to ensurelegal and ethical operation.through the realization of technological innovation,safety in production, employee rights and interests, environmental energyconservation and emission reduction activities, we will fully fulfill our social

responsibility.

2. Supply Chain Risk Identification Procedure

The company has designed a set of KYC forms to understand yourdealers, including information about supplier's legal status and identity.supplieranalysis and potential risks, and collect relevant supporting documents. All oursuppliers have completed and returned the table.lattice. The company's duediligence plan manager worked with the procurement team to review theinformation provided and the United Nations sanctions list. As long as in wheninconsistencies, errors or incomplete information is found in the KYC form, thecompany will ask them to improve it. If the supplier does not provide KYC, wewill stop the purchase.During the reporting period, the alarm signal related tothe submitted KYC form was found.

For each transaction, the company requires suppliers to provide information oforigin and a complete set of traceable documents, including legaltransportation routes.and the name and address of the direct supplier.

Make full use of the information provided by iTSCi tantalum ore supply chainsupervision system and on-site monitoring system to supervise tantalum inhigh-risk areas mining due diligence.

3. Risk assessment and risk reduction procedures 

Based on the above risk identification methods, enhanced due diligence hasbeen carried out for materials and supply chains identified as"high risk"investigation. This includes: 

Evaluate the activities and relationships of upstream suppliers;

Identification of mining, trading, processing and export locations andquantitative conditions of ores;

Field risk assessment.

Since the establishment of iTSCi, in order to analyze the actual situation,conduct on-the-spot assessment and evaluate the risks in high-risk supplychains, the company has always adopted the following plans to assess therisks of each transaction from high-risk areas.

Widely participate in the recognized upstream guarantee mechanism-iTSCimarking and bagging system.

Janny Company has been participating in the traceability verification ofhigh-risk tantalum raw materials. For tantalum raw materials from high-riskareas, the company and the suppliers only purchases materials certified byiTSCi marking and bagging system from iTSCi members. For each high-riskpurchase transaction, iTSCi provides the following documents:

1) Event summary report

2) Suggestions for site visits, including lists of potentially risky sites(recommended for companies purchasing from these mines)

Enhanced due diligence and risk assessment)

3) Monthly national and regional reports to review the general situation on theground

4) Data summary and other reports

Janny Company pays attention to learning other reports and documents ofiTSCi, such as accident report, management evaluation report, company auditreport, etc. The company conducted further due diligence to review documentsfrom upstream plans against public domain information and actual transactioninformation. At the same time, whether it is high or low risk, Janny Companyrequires all suppliers to provide the following documentary information, whichinvolves each transaction:

Supplier due diligence plan, including KYC questionnaire, companyregistration certificate or company business license, mining certificateIf it's amining company.

Keep an eye on the governance information related to the operation/nationalbackground of local companies.

Collect the supply chain regulatory documents for each transaction to ensurethat the source and route of the transaction are known.

At the same time, through on-the-spot investigation of mines, documentinspection, interviews with miners, consultation with local communities andother stakeholders, we conduct due diligence on suppliers in high-risk areas,and timely understand whether there are serious infringements in the processof mining, transportation, trade and so on.

We will also make the necessary checks to ensure that vendors recommendedby iTSCi have implemented improvements and acted on them.

We will ensure that the iTSCi monthly report on the mine we purchased isresolved.

We have three different levels of violation and response procedures.

See the example in the following table:

QQ圖片20191219152728.png

We also have a private EMAIL address where everyone can provide us with information about emergencies that may be exposed. 361466917@qq.com


Jiujiang Janny New Material Co., Ltd.
August 20, 2018

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