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

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Due diligence planning and risk assessment procedures

JIUJIANG JANNY NEW MATERIAL CO.,LTD.


DUE DILIGENCE PLAN AND RISK ASSESSMENT PROCEDURE


In accordance with our conflict mineral policy, we strictly adhere to OECD
guidelines for the procurement of ore from conflict-affected and high-risk
regions, as well as to compliance with United Nations Security Council
resolutions. In accordance with the guidance of OECD and relevant UN
Security Council resolutions, we have taken the following measures in all
business dealings in the source areas of tantalum raw materials.Review
supplier selection and purchasing decisions.The following risk-based five-step
due diligence framework for ore supply chain in conflict-affected and high-risk
regions is incorporated into the management system.
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, through
the following measures and procedures to ensure that no conflict raw materials
from conflict-affected areas are purchased and used and to prevent any
conflict raw materials and uncertainties material enters the supply chain to
prevent mineral exploitation and trade from becoming sources of conflict,
human rights violations and insecurity. In August 2018, we reviewed and
revised all internal control procedures and documents and strictly adhered to
supply commitments on chain policy and internal processes for due diligence
in the following areas have been developed:
General Manager of Janny Company is responsible for supervising the design
and implementation of due diligence plan and risk management.
The company has appointed a due diligence plan manager to coordinate with
relevant departments (including purchasing department, warehouse
management department, etc.) and production unit to ensure that all
departments perform their duties, carry out due diligence plans and report any
warnings found and potential risks.
Janny Company carries out a training of due diligence management system for
all key personnel of relevant departments every year in accordance with the

requirements of due diligence plan. If the plan is updated, the company will
carry out additional training as required.
We demand that our suppliers also adhere to all OECD-guided provisions and
UN Security Council resolutions and never buy conflict ore to sponsor conflict
directly or indirectly.
1. Internal control system
- Its due diligence management system has been updated to align it with
OECD guidelines and RMAP.
The latest supply chain policies and procurement requirements have been
communicated to all identified suppliers.
- Open and transparent procurement policy
Janny Company Raw Material Purchase Statement has been posted on the
company's public website, so that each supplier has a clear understanding of
our mining purchasing policy. The "Responsible Mineral Supply Chain
Management System Document" was issued to all departments within the
enterprise to make every employee aware of it and implement it accordingly.
- Control procedures for raw material procurement
The company formulates and implements Supplier Management Procedure,
Purchasing Contract Management Procedure and Ta Raw Material Purchasing
Acceptance. And in-and-out warehouse management process, identification
and traceability management process, procurement documents,management
Procedure and Ta Material Balance Accounting Management Procedure,total
six 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 Management
Process", the traceability and control of all tantalum raw materials in the use
process are guaranteed.
- To adopt the control system and management measures for raw material
transportation in accordance with international standards, strictly abide by the
regulations for the transport of hazardous substances including categories 7 of
substances, and at the same time, establish and implement the Regulations on

the Management of Radioactive Substances.
Conduct due diligence on suppliers and maintain continuity
In accordance with the OECD Guidelines and the audit requirements of the
Responsible Minerals Initiative, the company conducts annual due diligence
on raw material suppliers.To review and verify the validity, quality assurance
and conformity of suppliers as suppliers to adopt or cancel them.The basis of
qualification. For ITSCI labeled ores, we will visit all the supply mines of the
source mines and companies of the ores we purchased, and conduct a
comprehensive study of the mines to determine the mine's geographical
location, personnel composition and output. Every year, we check and check
whether the amount of ore produced is consistent with the original benchmark
study. Only after these mines and companies have been inspected and proved
to have no direct or indirect connection with armed groups or human rights
violations will we continue to purchase from this area or company; if we find
any non-conformity, we will ask them to rectify it, if not to meet the
requirements after rectification. We will immediately stop purchasing from the
company and return the non-conforming raw materials purchased, which can
not be included in our qualified suppliers for at least one year. In addition to
visits to local mines, we have retained at least five years of all relevant
documents on ore supplies from Africa so that problems can be verified in the
future. Janny Company never buys raw materials in cash.
We implement the OECD policy for all employees to ensure that every
employee understands and follows the policy. If employees do not do the
corresponding verification, we will immediately suspend the relevant
procurement contract. The contract will not continue until the employee verifies
and 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 chain
requirements. At the same time, we should remind and urge the upstream

suppliers of raw materials to operate legally and in compliance with the
regulations, and not to operate any "conflict raw materials" and unknown raw
materials. Special clauses on "non-conflict" are stipulated in our contracts with
all 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 international
conferences or training sponsored by international organizations such as TIC,
iTSCI, RMI, etc. to understand and learn "OECD due diligence guidelines for
mineral responsible supply chains in conflict-affected and high-risk areas", RMI
auditing standards and transparency requirements for responsible tantalum
supply chains. The company maintains regular communication with iTSCi, and
pays close attention to the study of iTSCi event report, monthly production
assessment, monthly regional status assessment report, etc. in order to timely
understand the production and operation of various mines. While maintaining
communication with downstream customers, according to RBA requirements,
the company provides CMRT to downstream visitors to ensure due diligence in
the supply chain. We also recommend that all our suppliers join the iTSCi
program and RMAP.
- Promoting to the public through the Internet that "OECD is responsible for
minerals in conflict-affected and high-risk areas guidelines for due diligence in
an appointed supply chain, the latest requirements of responsible business
alliances on the test criteria for a tantalum supply chain, and negative
requirements for transparency in responsible mineral supply chains.
Establishing complaint channels, the company has opened complaint
channels 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 and
information with upstream suppliers and downstream customers.
Establish a complaint mechanism at the company level or within the industry
as a risk warning system.
- Training staff
The company trains its employees, including senior management, to make
them fully aware of "OECD's due diligence guidelines for Responsible Supply

Chains for minerals in conflict-affected and high-risk areas" and the latest
requirements of responsible business alliances on the Tantalum supply chain
auditing standards, as well as the perspective of responsible mineral supply
chains. Lightness requirements.
- Actively fulfill social responsibility, create a corporate image of compliance
and social responsibility ,the company always closely combines the economic
development of enterprises with the fulfillment of social responsibility to ensure
legal and ethical operation.through the realization of technological innovation,
safety in production, employee rights and interests, environmental energy
conservation 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 your
dealers, including information about supplier's legal status and identity.supplier
analysis and potential risks, and collect relevant supporting documents. All our
suppliers have completed and returned the table.lattice. The company's due
diligence plan manager worked with the procurement team to review the
information provided and the United Nations sanctions list. As long as in when
inconsistencies, errors or incomplete information is found in the KYC form, the
company will ask them to improve it. If the supplier does not provide KYC, we
will stop the purchase.During the reporting period, the alarm signal related to
the submitted KYC form was found.
For each transaction, the company requires suppliers to provide information of
origin and a complete set of traceable documents, including legal
transportation routes.and the name and address of the direct supplier.
Make full use of the information provided by iTSCi tantalum ore supply chain
supervision system and on-site monitoring system to supervise tantalum in
high-risk areas mining due diligence.
The company has designed a CAHRA risk identification process to assess the
risk of negative impacts based on the supply chain policy standards in
compliance with appendix ii and the due diligence recommendations in this
guide.
3. Risk assessment and risk reduction procedures

The company has a supply chain control procedure which reports and
processes the results of the supply chain risk assessment to the designated
senior management.
Based on the above risk identification methods, enhanced due diligence has
been 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 and
quantitative 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 supply
chains, the company has always adopted the following plans to assess the
risks of each transaction from high-risk areas.
Widely participate in the recognized upstream guarantee mechanism - iTSCi
marking and bagging system.
Janny Company has been participating in the traceability verification of
high-risk tantalum raw materials. For tantalum raw materials from high-risk
areas, the company and the suppliers only purchases materials certified by
iTSCi marking and bagging system from iTSCi members. For each high-risk
purchase 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 the
ground
4) Data summary and other reports

Janny Company pays attention to learning other reports and documents of
iTSCi, such as accident report, management evaluation report, company audit
report, etc. The company conducted further due diligence to review documents
from upstream plans against public domain information and actual transaction
information. At the same time, whether it is high or low risk, Janny Company
requires all suppliers to provide the following documentary information, which
involves each transaction:
Supplier due diligence plan, including KYC questionnaire, company
registration certificate or company business license, mining certificateIf it's a
mining company.
Keep an eye on the governance information related to the operation/national
background of local companies.
Collect the supply chain regulatory documents for each transaction to ensure
that the source and route of the transaction are known.
At the same time, through on-the-spot investigation of mines, document
inspection, interviews with miners, consultation with local communities and
other stakeholders, we conduct due diligence on suppliers in high-risk areas,
and timely understand whether there are serious infringements in the process
of mining, transportation, trade and so on.
We will also make the necessary checks to ensure that vendors recommended
by iTSCi have implemented improvements and acted on them.
We will ensure that the iTSCi monthly report on the mine we purchased is
resolved.
We have three different levels of violation and response procedures.
See the example in the following table:

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微信图片_20200309104959.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


ADD.:Chengdong Industrial Base 3, Xunyang District, Jiujiang City, Jiangxi Province, China 332000
Tel: +86-792-8533981/2/7 Fax: +86-792-8533983

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