Shenzhen Cuilu Gold Refinery Co., Ltd. strictly adheres to the "LPPM Responsible Platinum/Palladium Guidance" and establishes a platinum/palladium supply chain due diligence management system in accordance with its requirements. We actively implement platinum/palladium supply chain due diligence to ensure compliance with the requirements of the "LPPM Responsible Platinum/Palladium Guidance." We strictly prohibit the following behaviors in the supply chain:
1.Violations of human rights, including the use of child labor, torture, inhumane or degrading treatment, widespread use of violence, or other serious human rights abuses such as forced labor, war crimes, crimes against humanity, or genocide.
2.Providing direct or indirect support to illegal armed groups or public or private security forces that control mining areas, traders, other intermediaries, or transportation routes through the supply chain, or engaging in illegal taxation, extortion of money or minerals throughout the supply chain ("Illegal armed groups, public or private security forces").
3.Covering up the origin of platinum/palladium through bribery or fraud.
4.Failure to comply with government requirements regarding extraction, trade, and export taxes on minerals from conflict and high-risk areas.
5.Money laundering or financing of terrorism.
6.Funding conflicts.
7.Engaging in high-risk business activities, such as weapons, gambling, antiques and art, sects, and their leaders.
8.Beneficiaries being politically sensitive individuals or wanted persons.
If any of the above behaviors are identified in the supply chain, we will take measures to isolate the purchased products and immediately suspend or terminate any transactions with the supplier.
We will establish a due diligence management system in accordance with the requirements of the "OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" (Third Edition). This includes establishing supplier due diligence management files, establishing a material traceability system, collecting supply chain information, providing training to employees, define high-risk criteria, conducting regular risk assessments of the platinum/palladium supply chain, establishing an complaint channel for responsible sourcing, and ensuring the retention of all relevant documents to ensure the continuous compliance of the supply chain with the "LPPM Responsible Platinum/Palladium Guidance" and the responsible procurement of platinum and palladium by the company.
This policy is effective from the date of issuance.
Effective Date: April 1, 2023