MINSHAN ENVIRONMENT ENERGY HIGH TECH CO., LTD.
2022 Refiner’s Compliance Report
(Published in January 2023)
In order to comply with the requirements of the "London Bullion Market Association Responsible Silver Guidelines", our company has established a strong management system, adopted the supply chain due diligence method to identify and assess risks for all suppliers, and formulated the management of high-risk supply chains. strategies to ensure that supply chain risks are within an acceptable range, and through independent third-party audits to ensure that the company's silver supply chain fully complies with the LBMA Responsible Silver Guidance.
This report summarizes the compliance of MINSHAN ENVIRONMENT ENERGY HIGH TECH CO., LTD. in the fiscal year 2022 (January 1, 2022-December 31, 2022) with the requirements of the < LBMA Responsible Silver Guidance>.
MINSHAN ENVIRONMENT ENERGY HIGH TECH CO., LTD.
Long’an District Industrial Park, Anyang City, Henan Province, China
December 31th, 2022
Date of Report
January 20th, 2023
Senior management responsible for this report
Mr. Chen Yanwei/Compliance Director
Founded in the 1990s, Minshan is a circular economy ecological enterprise integrating urban mine development, comprehensive recovery and recycling of hazardous waste and solid waste resources, clean production of non-ferrous and precious metals, high-tech materials and smart energy. Minshan takes the "bottom blowing smelting-smelting reduction-oxygen-rich volatilization" technology with independent intellectual property rights as the core, and is equipped with waste lead-acid battery resource recycling, flue gas recovery acid production and non-ferrous rare metal purification production lines. High-purity lead, electronic grade sulfuric acid, zinc alloy, gold, silver, copper, antimony, bismuth and other non-ferrous rare and precious metals in high-end equipment manufacturing, intelligent manufacturing, electronic information industry, military aerospace nuclear power and other fields.
After more than 20 years of development, Minshan has become an environmental protection enterprise with mature technology in the industry. Its "bottom blowing smelting-smelting reduction-oxygen-rich volatilization" technology is a low-carbon technology innovation and industrialization demonstration project of the National Development and Reform Commission.
1. Silver Smelting and Refining Processes
The main raw material of silver smelting is lead anode slime from the lead system of the company. The company’s main raw material for lead ingots is lead concentrate，about 18% of the company's lead concentrate are imported, and the remaining 82% are sourced domestically.
The silver smelting and refining process include anode slime reduction smelting in reducing furnace→ oxidation smelting in silver separator furnace → silver electrolysis refining → bar casting”.
2. Silver product specifications
The silver ingots produced by our company have two specifications: 15kg±1kg and 30kg±2kg. The silver content is not less than 99.99%, and the quality standard conforms to the provisions of the national standard GB/T 4135-2016 on IC-Ag99.99. In 2022, our company's silver ingot production is 128955 kilograms.
Step 1: Establish strong company supplier management systems
Compliance Statement with Requirement:
We have fully with Step 1: Establish strong Supplier management systems.
公司于2019年12月15日发布了《LBMA负责任白银供应链尽职调查管理体系》，该政策符合经合组织《来自受冲突影响和高风险地区的矿石负责任供应链尽职调查指南》附件 II 中规定。体系中规定了白银供应链尽职调查政策、内部的组织构架及责任、尽职调查流程、白银供应链的风险识别方法、评判标准以及管理策略，此外还规定了白银供应链尽职调查培训、供应链追溯系统、记录的保存期限、交易监控等事宜。
The company has established the "LBMA Responsible Silver Supply Chain Due Diligence Management System" on December 15th, 2019, which is consistent with the model set out in Annex II of OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The system included the silver supply chain due diligence policy, internal organizational structure and responsibilities, due diligence process, and silver supply chain risks Identification methods, evaluation criteria, and management strategies. In addition, it also stipulates the silver supply chain due diligence training, supply chain traceability system, record retention period, transaction monitoring and other matters.
According to the system requirements, documents were generated such as "Risk Assessment Method and Evaluation Form" and "Action Strategy".
In 2022, our company completed the due diligence of all silver suppliers in strict accordance with the requirements of the system, and conducted risk identification and evaluation to effectively control the risks of the silver supply chain.
Our silver supply chain due diligence policy strictly prohibits silver suppliers from doing the following:
All Silver-bearing minerals provided to your company are legitimate (the silver bars purchased from your company are used for legal purposes), which does not involve the following situations:
1. Systematic or widespread human rights abuses associated with the extraction, transport or trade of silver, including worst forms of child labor, any forms of torture, inhuman and degrading treatments, widespread sexual violence or other gross human rights violation forced or compulsory labor, war crimes, crimes against humanity or genocide;
2. Direct or indirect support to illegitimate non-state armed groups, public or private security forces which illegally control mines sites, traders, others intermediaries, transport routes through the supply chains or illegally tax or extort money or minerals through the supply chains;
3. Bribery and fraudulent misrepresentation of the origin of silver;
4. Non-compliance with taxes, fees and royalties due to Governments related to mineral extraction, trade and export from conflict affected and high-risk areas;
5. Money laundering or terrorism financing;
6. Contribution to conflict;
7. Higher-risk business activity such as arms, gaming and casino industry, antiques and art, sects and their leaders;
8. Upstream companies or their beneficial owners with significant influence are PEPs;
9.Not comfort to the legal requirement for environmental protection and sustainable development.
The official website is published: https://www.aymsys.com/news/16_516
管理架构Internal management structure
According to the system requirements, we have set up a special management team, including a compliance director, a compliance manager and 6 compliance team members, and clarified the responsibilities of all. The appointment notice of compliance-related personnel is available on the company's official website https://www.aymsys.com/news/16_515.
Compliance Director: A senior manager authorized by the company, who is responsible for approving the signing of cooperation contracts with suppliers (including whether to cooperate with high-risk suppliers) according to the company's raw material procurement policy and the company's production, financial and sales conditions. Contract signing), and is responsible for matters related to compliance review of suppliers. Internal senior managers train relevant employees in accordance with the LBMA Responsible Silver Guidelines document, so that the relevant persons in charge clearly understand the purpose and significance of the system and their responsibilities in the implementation of the due diligence policy.
Compliance Manager: Assist senior management to take overall responsibility for due diligence of the silver supply chain and identify whether the origin of raw materials of suppliers involves related matters in high-risk areas, be responsible for all matters in the silver supply chain, and ensure that they can avoid conflict with others in an informed way. Appropriate measures have been taken during cooperation or transactions in high-risk supply chains, and risk assessment reports have been submitted; customers who are judged to be low-risk will continue to cooperate, and high-risk customers will suspend cooperation until the other party provides corresponding supporting documents or rectifies the relationship. Compliance managers are obliged to train on responsible supply chains, draft and update silver supply chain policies, and provide accurate information for senior managers to fulfill their responsibilities.
The raw material procurement center (domestic and foreign) ensures the long-term, stable and safe supply of mineral powder and raw materials, and refuses to cooperate with relevant enterprises, organizations or countries in high-risk areas.
The quality inspection center weighs and tests the purchased silver-containing raw materials; the production department is responsible for the incoming and outgoing records of raw materials and saves them in the ERP system.
The Precious Metals Division is responsible for the weighing and marking records of the output silver ingots. The workshop organizes the production of materials and makes records of the material input and the output of silver ingots. The closed process and ERP system are used in the production process to ensure the safety of silver production and processing. and traceability.
The production department is responsible for combining with the raw material procurement center to ensure the accuracy of receiving silver-containing raw materials, and the precious metal business department is responsible for the statistics of the quantity of silver before sales to ensure the safety of the physical silver.
The marketing center needs to confirm the identity information of the delivery person according to the risk report of the corresponding customer (non-high-risk customer) given by the compliance manager, and use a supervision mechanism to ensure the security of the transaction during the transaction process.
In 2022, the management team conducted due diligence on all silver suppliers in strict accordance with the requirements of the system documents, and the compliance manager supervised and reviewed all the findings to ensure that all suppliers of silver-containing materials met the LBMA requirements and obtained compliance before cooperation. approval of the Director of Regulations.
可追溯系统和其他供应链参与者的识别Traceability and identification of other supply chain actors
According to the requirements of the management system, the company has determined the supply chain traceability system. During the business process, the ERP system is used to collect and save the information provided by all suppliers, including the contract review form, contract text, settlement method, transportation process, weight and inspection report, Production date, storage time, etc.
According to the customs import declaration or bill of lading, overseas ore fines can know the country of origin and turnover country of ore fines; part of the source of domestic ore fines comes from mines and is reflected in the KYC and transaction contracts, and the other part of domestic ore fines is sourced from For the sake of commercial confidentiality, these traders make an export commitment that the source of mineral powder comes from domestic mines; through due diligence and the cooperation of the subsequent ERP system chain, we can trace the finished product to the raw material, and trace the raw material to the raw material. The finished product can be traced back to each supplier’s purchase contract for each batch of products. According to the contract content, information including precious metal type, purchase weight, analysis report and related due diligence documents can be traced.
The company regularly organizes training for all departments related to silver, and a total of two trainings were conducted in 2022.
1. July 7, 2022, LBMA Responsible Silver Supply Chain Due Diligence Management System;
2. On November 20, 2022, LBMA Responsible Silver Supply Chain Due Diligence Management System. The effect evaluation was carried out after the training.
According to the management system requirements, all supplier-related documents, including due diligence documents, risk assessment forms, compliance documents, contract texts, inspection records, and warehouse records are kept for at least five years.
交易付款和交易监控Transaction Payment & Monitoring
All business of the company is collected and paid through official bank channels without any cash transactions. The settlement of foreign imported products is paid by T/T, and the domestic payment is by bank transfer.
According to the requirements of the management system, we conduct transaction supervision on each batch of silver products and keep relevant payment vouchers. The compliance officer is responsible for transaction monitoring, checking the background of transactions that are inconsistent or suspected to be inconsistent in any form, confirm the findings in writing, and report to the compliance director.
In 2022, no discrepancies or any form of discrepancies were found.