Shenzhen Germanside Nanotechnology Co., LTD. (hereinafter referred to as "Germanside Nanotechnology" or "we") recognizes that there is a risk of significant negative impact on the mining, trading, processing and export of mineral resources in conflict-affected and high-risk areas; And recognizing that we have an obligation to respect human rights, not to contribute to conflict and not to have a negative impact on the environment and society, to achieve respect for human rights and to avoid human rights violations or sources of human rights violations and insecurity as a result of mineral resource procurement.

 

We promise to implement and widely spread China minmetals chemical import reference (CCCMC) issued by chamber of commerce in China responsible mineral responsible supply chain management guidelines and the organization for economic cooperation and development released by the organization for economic cooperation and development of ore affected by conflict and high-risk areas responsible for a responsible supply chain management guidelines, we are committed to comply with the relevant UN resolutions, abide by the applicable to perform such resolution of domestic law, will not engage in any conflict to help facilitate behavior. To this end, we undertake to identify and avoid the following risks in our business activities:

 

I. Gross violations of human rights

 

We will neither tolerate nor in any way profit from, facilitate, assist or facilitate the operation of any party in the mining, procurement, smelting or operation of any mineral:

 

1. Torture, cruel, inhuman or degrading treatment in any form;

 

2. Any form of forced or forced labor. Forced or forced Labour means Labour or services which are not voluntarily provided by any individual extracted under the threat of punishment;

 

3. The worst forms of child labor;

 

4. Other forms of child labor;

 

5. Other serious violations and violations of human rights, such as ordinary ACTS of sexual violence;

 

6. War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

 

Risk mitigation measures:

 

If we have reasonable grounds to believe that an upstream supplier is purchasing or associated with any party that commits a serious human rights violation, we will immediately suspend or discontinue our cooperation with that supplier.

 

2. Direct or indirect support for illegal organized armed groups and public or private security forces

 

We do not tolerate any direct or indirect support for non-state organized armed groups through the exploitation, transport, trading, processing or export of mineral resources. Providing "direct or indirect support" to non-state organized armed groups through the exploitation, transportation, trading, processing or export of mineral resources, including but not limited to the purchase of resources from, payment to, or other means of logistical support or equipment to illegal organized armed groups or their affiliates. These armed groups or affiliates:

 

1. Illegal control of mine sites or other means of control of transportation routes, trading points of mineral resources and upstream actors in the supply chain;

 

2. Illegally taxing or extorting money or mineral resources at the entrance of the mine site, along the transportation route or at the trading point of mineral resources;

 

3. Illegal taxation or extortion on middlemen, export enterprises or international traders.

 

We will put an end to the illegal control mine site, transport routes and upstream supply chain participants, the entrance of the mine site, transportation routes or mineral resources trading posts along the tax illegal or extort money or mineral resources, or to middlemen, export enterprises or international traders illegal tax or extortion of public or private security forces to provide direct or indirect support.

 

Risk mitigation measures:

 

If we have reasonable grounds to believe that an upstream supplier procured or is associated with any party providing direct or indirect support to a non-state organized armed group, we shall immediately suspend or discontinue our cooperation with that supplier.

 

Corruption, money laundering and various expenses paid to the Government

 

We will not offer, promise, give or ask for any kind of bribe, and will not demand for bribe. We will not offer bribe to the government for the purpose of concealing or forging the origin of mineral resources, falsely reporting the activities such as mining, trading, processing, transportation and export of mineral resources, and paying taxes, fees and royalties.

 

We prohibit all bribery in business activities and transactions, including bribery by agents and other third parties, and set standards and approval procedures for giving and receiving gifts. To do our best to promote responsible business practices with all business partners.

 

We will ensure that all lawful taxes, fees and royalties related to the exploitation, trading and export of mineral resources in conflict-affected and high-risk areas are paid to the Government and undertake to disclose such payments based on the location of the business in the supply chain.

 

Risk mitigation measures:

 

According to enterprise's location in the supply chain, we are committed with the supplier, the central or local governments, international organizations, civil society and affected by a third party, as appropriate, in line with measurable measures within a reasonable time span, the purpose of prevent or reduce the risk of adverse effects, to improve or tracking performance. If risk mitigation measures do not work, we will suspend or discontinue our cooperation with upstream suppliers.

 

4. Land rights, emissions and small workshops

 

We do not participate, tolerate or benefit from the exploitation of resources on land without the free, prior and informed consent of local and indigenous people, including those who hold legal title, leases, concessions or licences. We do not participate in, tolerate or benefit from mining operations in which the culture and heritage of the local people and indigenous peoples are not respected and protected or at the expense of their traditional culture.

 

We do not participate in, tolerate or benefit from the exploitation of resources on land where legal title, leasehold, concession or license are unlawfully obtained, or where domestic law is violated. We ensure that we avoid significant adverse effects on the conditions of the surrounding soil, air and water, as well as serious violations of relevant local laws and regulations, including the manufacture, trading and use of chemicals and dangerous substances that are subject to international bans due to their high toxicity to living organisms, environmental durability or potential irreversible ecological effects.

 

We agree to ensure compliance with applicable legal requirements for the management of chemicals and toxic substances and to avoid the manufacture, trading and use of chemicals and hazardous substances that are subject to international bans due to their high toxicity to living organisms, environmental durability or potential irreversible ecological effects.

 

We are specifically concerned about the risks associated with forced Labour, child Labour, unsafe working conditions, the use of uncontrolled hazardous chemicals and other significant environmental impacts associated with small mills or small-scale miners, and seek to establish production relationships with small mills or small-scale miners in mining areas.

 

Risk mitigation measures:

 

If we have a reasonable reason to think that there is such a risk, we will according to the enterprise in the supply chain of the location, immediately together with suppliers and other stakeholders, adopt and implement the risk management plan, so as to prevent or reduce the abuse of land rights, cause significant adverse environmental impact or specific risks associated with small workshops or small-scale mining.

 

V. Life-threatening health and safety situations

 

We do not tolerate or benefit from any work done before employees are trained in safety techniques, and we ensure compliance with relevant local laws and regulations to prevent employees from operating in a life-threatening health and safety environment. We are committed to regularly assessing and reducing the adverse impact of the work environment on the lives and health of our employees. Adopt preventive methods and technologies with technical and financial feasibility and applicability, and try to avoid, reduce and control the occurrence of safety accidents.

 

Risk mitigation measures:

 

If we have reasonable grounds to believe that such risks exist, we will immediately work with suppliers and other stakeholders to develop, adopt and implement risk management plans based on the specific location of the enterprise in the supply chain, so as to prevent or reduce specific risks that endanger life, health and safety.

 

 

If you have any questions about this policy, please email us at sdc@dynanonic.com