Responsible mineral sourcing due Diligence Report(2021)

I. Company Information (all sources)

 FIR.METALS&RESOURCE.,LTD (FIR for short) was established in 2006 with a registered capital of 3,076,923 yuan and CID number CID002505. Add: Jiulong Industrial Zone, Yanling County, Hunan Province, Zip code: 412500, Tel :0086-731-26291313. The company is committed to the production of tantalum niobium metal and its products, the main products: tantalum powder, tantalum bar and tantalum parts. FIR is fully committed to avoiding the use of conflict materials. We strive for excellence, while providing customers with satisfactory products, we have developed our own responsible sourcing supply chain policy, we are committed to shoulder the corresponding social responsibility, and strictly abide by the OECD guidelines and relevant laws and regulations.

Processing materials: potassium fluotantalate and tantalum waste 

Period covered by this report: October 1, 2020 to October 1, 2021

The Responsible Supply Chain Policy has been reviewed and approved by senior management, who are committed to supporting the implementation of this policy while widely disseminating it to relevant stakeholders (suppliers, customers, employees, etc.) and publishing it on the company's website:

Ii. RMAP Evaluation Summary (all sources)

As a responsible company, FIR has been actively  supporting and participating in the annual review of RMAP. From 2014 to 2022, FIR has gone through seven audits, the last audit date was August 15, 2022, based on the most recent passed audit, RMI Audit Committee (ARC) determined that Zhuzhou Gaoli New Materials Co., Ltd. is in compliance with the (2017) Tantalum Audit Manual. Valid from October 15, 2020 to October 15, 2021; The new audit cycle has not passed the complete review, and the company is in a state of active rectification. FIR for compliance smelter in RMI system  state,  due diligence report on the company website,

Iii. Company Supply Chain Policy (all sources)

In order to avoid the use of conflict minerals that directly or indirectly finance or benefit armed groups and/or are involved in other serious human rights violations in high-risk and conflict-affected areas, the Company has developed its own supply chain policy, This supply chain policy is in full compliance with the third edition of the OECD Guidelines for Responsible Supply Chain Due Diligence on ores from conflict-affected and high-risk Areas (OECD Guidelines). It covers all the risks identified in Appendix II of the OECD Guidance and applies on a global scale. The public can undertake to address any Appendix II risks as soon as they are identified. This policy has been reviewed and approved by senior management, which is committed to supporting its implementation. This  policy has been to relevant stakeholders (suppliers, customers, employees, etc.), can be found in the company's web site

Iv. Company Management System (all sources)

FIR has established a strict responsible mineral supply chain management system and developed a series of integrated supply chain management systems to prevent any conflict between unknown materials and raw materials from entering the supply chain through the following measures and procedures for purchasing and never using conflict-affected areas, so as to prevent mineral exploration and trade from becoming a source of conflict, human rights violations and insecurity. Zhuzhou Colliers strictly abides by its commitment in terms of supply chain policy and has developed internal due diligence processes in the following areas: -- FIR issued the Supplier Management Policy and appointed the General Manager to oversee the design and implementation of the due diligence plan and risk management, and coordinate the work of relevant departments (including Operation management, Quality Assurance, finance, production units and warehouses) to ensure that all departments are committed to their duties. To perform responsible mineral supply chain management and report any warning signs and potential risks identified.

-- The FIR has promulgated the "Mineral Procurement Complaint Handling Measures", in which specialized personnel are responsible for the complaints of all participants in the circulation process, and will track the processing results and timely feedback to the complainants, and will conduct risk assessment and follow-up treatment of the designed materials according to the investigation results.

-- FIR conducts due diligence management system training for key personnel of all relevant departments once a year  in accordance with the requirements of responsible mineral supply chain management. If the plan is updated, the company will conduct additional training as required.

A. Internal control system

-- FIR has updated its due diligence management system to align it with OECD guidelines and RMAP.

-- FIR has communicated the latest supply chain policies and procurement requirements to all identified upstream suppliers.

-- Open and transparent procurement policies

1) The raw material purchasing statement has been posted on the FIR company website, so that every supplier has a clear understanding of our purchasing policy.

2) The Responsible Mineral Supply Chain Management System and Supplier Management Policy have been issued to all departments within the company, so that every employee is aware of and follows the requirements.

-- Control procedures for raw material procurement

The Supplier management Policy has formulated the Supplier Management Policy, the Provisions on the Management of Origin Traceability of tantalum-containing Raw Materials and Products, the Provisions on the Management of batch number of tantalum-niobium Raw materials, the Provisions  on  the  Management  of  tantalum-niobium  Raw  Materials Transportation, the Provisions on the inspection and acceptance of tantalum-niobium mines, the Provisions on the Management of Raw material Supply chain Risk Assessment, the List of Applicable Laws and Regulations, and the Supplier's commitment to anti-corruption and anti-bribery The "Book" and the "KYC Understanding of Supplier Management Regulations" and other control procedures to restrict and prevent any "conflict raw materials" and unknown raw materials from entering the FIR supply chain. -- FIR conducts due diligence on suppliers on an ongoing basis, in accordance with the OECD Guidelines and the audit requirements of the Responsible Minerals Initiative, conducts due diligence on raw material suppliers annually, and verifies the legitimacy, quality assurance and compositeness of suppliers as a basis for acceptance or disqualification. While maintaining communication with downstream customers, FIR provides CMRT forms to downstream customers in accordance with the requirements of the RBA to ensure supply chain due diligence.

-- FIR has set up a risk assessment committee under the leading group of  RMI System Operation Management, and has appointed General Manager, Buyer and RMI responsible officer to evaluate all the information related to  suppliers and raw materials, and determine the rationality of raw material  sources (such as origin, production capacity, type characteristics, etc.). The origin of the investigation, the transportation process, the supplier according to the warning signal assessment, find the warning signal, the warning signal to investigate and issue the handling opinion

-- Since 2009, FIR has officially become a member of the International  Tantalum Niobium Research Center (T.I.C.), focusing on T.I.C. in real time. The new joint report, learn about the new policy; At the same time, we have contacted the ITSCI organization in December 2020 to apply for joining the upstream mechanism to ensure the legal compliance of the supply chain, and are currently going through the procedures.

-- Actively fulfill social responsibilities and establish a compliant corporate image The operation and social responsibility company has always closely combined with the economic development of the enterprise and the fulfillment of social responsibilities, to ensure that under the premise of law and law, through technological innovation, production safety, employees' rights and interests, environmental protection, energy saving, emission reduction and other activities to achieve ethical management, and fully fulfill social responsibilities.

-- We will strictly abide by the international transportation standards of 7 types of substances, and we will ensure that the disposal, storage and transportation of hazardous substances meet the requirements of relevant laws and regulations. We guarantee that there will be no leakage in the transportation and production process, so as to prevent adverse effects on the environment and human body

-- FIR has established RMI's appeal mechanism, set up contact channels, collected appeal information from relevant parties, including appeal email address, telephone number and responsible person, and accepted supervision from all sectors of society. During the period covered by this report, the company has not received any appeal from relevant parties (affected persons or whistleblowers).

-- Training staff in various ways, THXC through centralized training, OA publicity, conference publicity, display board publicity, RMI official website training academy video (wechat publicity) training, including the general manager of all employees, in order to fully understand the OECD guidelines and RMAP inspection requirements.

B. Record Retention System: The Company requires that all records related to responsible mineral supply chain management be kept for at least five years, properly used and securely stored in the company database.

V. Risk identification (all sources)

First, the company has a CAHRAS identification and control procedure, including the resources used, applicable standards and frequency of review. The raw material procurement Risk Assessment committee of the company has carried out risk identification for all the procurement of tantalum-containing raw materials in accordance with the provisions of the high-risk identification procedure, and recorded the identification results. CAHRA has established a List of Qualified Suppliers. A review of the relevant sanctions list was conducted for all supplier individuals and companies and no sanctions information was found for supplier individuals and companies during this reporting period.

Second, to understand the supplier process, the company has conducted basic due diligence on all counterparties. The company has established a Know your counterparty (KYC) process to collect and update the information of counterparties  (suppliers), including at least the business license of suppliers, the identity information of shareholders, the legal status of suppliers, the scope of goods and the origin of goods, etc. Strict collection of relevant supporting documents; While requiring all suppliers to complete and return KYC related forms, the company has established a discrepancy review process. If inconsistent, incorrect or incomplete information is found, the company will ask the other party to provide correct, consistent and complete supporting documents again, and will not be included in the list of qualified suppliers. During the period of this report, it was found that the KYC questionnaire of one supplier was incomplete. Our company has implemented the difference review in time, and has since obtained relevant KYC supporting documents. All our suppliers have filled in and returned the form, and the differences have been resolved in time.
Third, to identify and assess supply chain risks, the company has established the "Supply Chain Risk Identification and Assessment Procedure" to analyze the potential risks of all suppliers and their raw materials to ensure that the warning signals mentioned in the OECD Guidelines on tin, tantalum and tungsten will not be triggered; Established a variance review procedure to conduct a variance review of suppliers and their raw materials, and no relevant variance related to raw materials was identified during the reporting period. After the risk identification and assessment of all suppliers, the company issued the corresponding risk assessment report. After all the above actions are completed, our company will proceed to the next step of the procurement process.

6. Risk Management (High-risk areas)

Based on the above risk identification methodology, the Company will conduct an enhanced due diligence program for raw materials and supply chains identified as "high risk". This program includes: 1 assessment of upstream supplier activities and relationships; 2. Identify the location and quantitative conditions under which the ore is mined, traded, handled and exported; And 3 Conduct an on-site risk assessment if necessary. During this year's procurement process, our company did not have high-risk raw materials.

In short, our company will conduct due diligence in strict accordance with the requirements of the OECD in the future work to ensure that the company's due diligence system can fully identify and adequately manage the risks related to the model supply chain policy in Appendix II of the Minamata Guidelines, and adhere to responsible sourcing.


August 30, 2022