
Appeal and Communication Mechanism
1、 Purpose
In order to strengthen communication and writing with affected areas, upstream and downstream enterprises in the supply chain, government departments, non-governmental organizations, media, and other relevant parties, respond to their concerns in a timely and effective manner, continuously improve the company's supply chain governance capabilities and information transparency, and adhere to the principles of "honesty, trustworthiness, and responsibility", a dedicated "Kaipeng Mining Co., Ltd. Supply Chain Appeal and Communication Mechanism" has been established. Ensure that raw material procurement complies with the requirements of the "Supply Chain Responsibility Management System", conscientiously fulfill corporate social responsibility, establish a standardized, scientific, and effective appeal mechanism, allow relevant parties of the company (affected personnel or whistleblowers) to express doubts related to mining, trade, processing, and export situations and receive proper handling.
2、 Reference
Supply Chain Due Diligence Management System and Kaipeng's Due Diligence Management Policy for Responsible in Global Supply Chain
3、 Scope of application
This system applies to the relevant parties of our company and the departments, units, and personnel involved in responsible mineral procurement related work of our company.
4、 Management organization and responsibilities
The company has established an appeal handling team, consisting of members from the quality department and the comprehensive department. The team is responsible for handling appeals.
5、 Work Procedure
5.1 Appeal Methods
Mailing address: 87th Floor, Building A, Ping An International Finance Centre(PAFC), Futian District, Shenzhen, Guangdong
Acceptor: Minister of Audit and Supervision
Report Hotline: +86 191 2930 4407
Report E-mail: report@yitegroup.cn
Wechat: Yite Holdings
b) Industry level appeal:
Our company followed China Minmetals and Chemical Industry Import and Export Chamber of Commerce’s "Mediation and Consultation Mechanism for Mining Industry and Mineral Value Chain". The content of the mechanism can be found in:
https://www.cccmc.org.cn/kcxfzzx/zyzx/al/ff80808187f9e83501881d10823206e4.html
5.2 Content of Appeal
When relevant parties file an appeal against the company's supply chain management, the appeal must include the following content:
5.2.1 Provide a specific explanation of the content and reasons for appealing to the appellant;
5.2.2 Attach relevant supporting evidence;
If allowed, please include:
a. The name (which can be anonymous) and contact information of the appellant;
b. The appellant suggests feasible solutions.
5.3 Classification of Appeal Information
The company needs to classify and identify the inquiries and appeals received, with appeals classified into special/important appeal information and non acceptance information.
Special or important appeal information
a. Manage information that does not meet the responsible supply chain requirements of Kaipeng Mining Co., Ltd;
b. Information on high-risk areas identified by the company for mineral procurement;
c. Information that the company's mineral procurement does not comply with the company's supply chain policy.
Information not accepted
a. Complaints unrelated to the responsible management of the company's mineral supply chain;
b. Complaints that are trivial, malicious, unreasonable, or seemingly aimed at gaining a competitive advantage;
c. Complaints without convincing objective evidence to support them.
5.4 Handling of appeals
This appeal mechanism operates through the following six steps:
Step 1: Receive appeals or communications
The staff responsible for handling appeals and communication are responsible for recording the content of appeals and communication, and ensuring that the relevant content is recorded in the appeal file;
Step 2: Preliminary evaluation
Preliminary assessment of whether the content of the appeal and communication complies with the scope of this appeal and communication mechanism, and communication of relevant information to the relevant leaders and departments of the company.
Step 3: Appeal Confirmation
Within seven working days after receiving the appeal and communication matters, provide written feedback to the appellant to confirm receipt of the appeal and provide steps and time for resolving the appeal.
Step 4: Appeal Response
The appeal investigation will be launched immediately upon receipt of the appeal, and the investigation report or action report related to the appeal will be completed within one month from the date of the appeal, and a response conclusion will be formed. There will be three ways to respond:
a. Not within the scope of appeal, appeal not established, rejected;
b. Accept the appeal, but our company does not have any appeal issues and does not need to take corrective or improvement measures;
c. Accept the appeal and confirm the need for corrective or remedial measures.
Step 5: Improvement Action
If the appellant is not satisfied with the investigation report or action measures, the company will conduct further investigation and research to determine the action plan that needs to be further developed and implemented. If the appellant still cannot reach an agreement with the company on improvement actions, the appeal can be referred to a third party for mediation or external experts can be hired to participate in review and negotiation.
Step 6: Monitoring and Evaluation
The company's quality department will report to the committee every quarter on the appeals, resolutions, and pending situations received; Analyze the status and timeline of appeal resolution annually, and evaluate the effectiveness of appeal and communication mechanisms.
5.5 Record of appeal
The appeal handling team should record the received appeals in the appeal register, including the following contents:
Who submitted the appeal and when;
The type, issue, or topic of the appeal, as well as the information submitted with the appeal;
Archive the materials related to the appeal handling process and keep them for at least 5 years.
6、 Management of complainants who are falsely accused or subjected to retaliation
a. After receiving the appeal information, the Quality Department is responsible for the storage of the information, the transmission of information review, the processing and feedback of the information. Without the consent of the relevant leaders of the company, it is prohibited to disclose to anyone other than the relevant personnel. Any violation shall be punished in accordance with the company's rules and regulations.
b. Those who retaliate or instruct others to retaliate will be dealt with seriously by the company according to the severity of the circumstances, and those suspected of illegal or criminal activities will be transferred to judicial authorities for handling.
7、 The complainant's safeguard measures
7.1 The company shall provide protection measures such as maintaining cooperation privileges and additional rewards for partners or related personnel who file complaints or communicate about non compliant incidents related to reporting supply chain responsibility management. The company provides immunity and maintains the right to cooperate with partners who actively declare and communicate, and provide valuable clues.
7.1.1 Regardless of whether the relevant units actively or passively provide improper benefits to company employees and their affiliated personnel, if the relevant units actively explain the situation to Kaipeng Mining Co., Ltd., the company will continue to maintain business cooperation and will not pursue the responsibility for the violations explained, and will be exempt from punishment.
7.1.2 If Kaipeng Mining Co., Ltd. actively cooperates with the investigation and voluntarily explains the existence of problems during the investigation process, the company will reduce its liability for violations. If Kaipeng Mining Co., Ltd. voluntarily provides non compliant information on supply chain due diligence management that Kaipeng Mining Co., Ltd. has not mastered during the investigation process, it may be exempted from punishment within the scope of the company's rights.
7.2 Kaipeng Mining Co., Ltd. strictly keeps confidential the appeal information. The appeal materials should be strictly managed as confidential information, and no one is allowed to access them without the approval of relevant company leaders. It is strictly prohibited to transfer the appeal materials to the respondent, to retaliate against the informant, to protect the legitimate rights and interests of the informant, and to transfer to judicial authorities for handling serious leaks that cause damage to the legitimate rights and interests of the informant.

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