Dongwu Gold Group Co., Ltd.
Review Report of the Non-Existence of Forced Labor
Since its legal establishment and effective existence, Dongwu Gold Group Co., Ltd. (hereinafter referred to as “the Company” or “we”) has always attached importance to our compliance with the Labor Contract Law of the People’s Republic of China. We have built and developed a harmonious and stable labor relation by clarifying the rights and obligations of both the Company and its employees, and protecting the legitimate rights and interests of employees.
We also support the realization of the Responsible Sourcing Programme of the London Bullion Market Association (LBMA) and work closely with our customers and partners upstream and downstream of the supply chain to fulfill our corporate social responsibilities (CSR) and build a sustainable industrial chain.
I. Implementation of the Management System for the Internal Labor Relations of the Company:
1. Signing of a labor contract with each employee, and payment of social security contributions for employees in accordance with applicable laws and regulations
The labor contracts signed between the Company and its employees all include the terms and conditions concerning working time, leave and holidays, labor protection, working conditions and protection from occupational hazards, remuneration, social security and benefits, and have been submitted to the Labor and Social Security Bureau of the Suzhou Industrial Park for filing purpose.
2. Protection of employees’ legal rights and interests and coordination of labor relations between the Company and its employees by the Trade Union Committee
The Trade Union Committee of the Company, established in accordance with the Civil Code of the People’s Republic of China and the Trade Union Law of the People’s Republic of China, is responsible for participating in the democratic management of the Company, listening to employees' feedback, coordinating labor relations, safeguarding legitimate rights and interests of employees, and organizing the education and skill training of employees. Among others, the Trade Union has also set up a female employee committee to safeguard the rights and interests of female employees and supervise the implementation of the systems related to labor protection for female employees.
3. Supervision and recognition by labor and social security authorities
The Company has been supervised and inspected by the labor and social security authorities every year, and received high recognition from such authorities. In 2021, the Company was honored as an “AA Labor Security Credit Unit” and an “Enterprise with Harmonious Labor Relations” in Suzhou Industrial Park.
II. Labor Protection Requirements and Influence on Supply Chain-Related Enterprises
1. The Company has updated the Supply Chain Due Diligence Policy and the Measures for Administration of Supply Chain Due Diligence (Version E) based on the new requirements of the LBMA Responsible Gold Guidance (V9), and clarified the criteria for zero-tolerance supply chain, high-risk supply chain, medium-risk supply chain and low-risk supply chain. In case any partners are found to have violated local legislation on the environment, health, safety, labor and community and caused ESG risks, the Company will trigger a due diligence process until the partnership is terminated.
2. The Company has specified the provisions against the violations of human rights and use of child labor in the employment system under Section 6 “Evaluation Item” of the Guidelines for Partner Evaluation, and informed its customers in the Letter of Advice to Customers and required them to clarify their obligation to prevent any use of forced labor or any other violations to human rights in Article 4 of the Commitment Letter submitted.
3. In July 2022, the Compliance Director and business personnel of the Company conducted an on-site survey of Inner Mongolia Jinshan Mining Co., Ltd. (“Jinshan Mining”), to check whether it meets the requirements of quality control, environmental management, personnel training and laboratory operations, and fulfills its social responsibilities in the prohibition of child labor, freedom of association, ban of forced labor, and compliance with local regulations on labor protection. The survey results showed that the quality control and ESG performance of Jinshan Mining generally met the requirements for eligible suppliers.
4. In 2022, the Business Department of the Company conducted a compliance investigation according to the Measures for the Administration of Supply Chain Due Diligence and filled in a Supplier Evaluation Report. The Compliance Director was responsible for reviewing the authenticity, validity and completeness of the due diligence, and reporting to the senior management. No enhanced due diligence was triggered, as no zero-tolerance, high-risk or medium-risk supply chain was found in such an investigation.
The above information has been reviewed by the LBMA Coordinating Team of the Company. This report is hereby provided to certify that the social responsibilities related to labor protection within the Company and the supply chain have been fulfilled properly.
Bao Xiaoling, Compliance Director
February 10, 2023