Responsible Mineral Procurement Due Diligence Report


1.Company Information

Company name: Dragon Silver Holding Limited. The company was founded in 2014, the company's CID number is CID003579, the company is a tin ingot processing factory, and the company address is:7/F,Yale Industrial Centre,61-63 Au Pui Wan Street,Sha Tin,NT,HK.

Time period covered by this report: October 1, 2020 to September 30, 2021

2. RMAP Audit summary

According to the RMI downstream audit standards, the company has formulated a responsible mineral sourcing policy and established a responsible mineral supply chain due diligence management system. The company received an RMI downstream audit in 2019 and conformant, the audit is valid for 2 years. At present, the company is fully preparing for the re-audit, and the re-audit time has been scheduled in November 2021.

3. Responsible Minerals Sourcing Policy

In order to ensure that the company does not purchase or use tin raw materials from conflict-affected and high-risk areas that involve serious human rights violations, the company has formulated a responsible sourcing policy. This responsible sourcing policy is in fully aligned with the third edition of the OECD Guidance for Responsible Supply Chain Due Diligence (OECD Guidance) for minerals from conflict-affected and high-risk areas. It covers all the risks contained in Annex II of the OECD Guidance and applies globally.

The company promises to deal with any risks in Annex II as soon as it is discovered. This policy has been reviewed and approved by the senior management, and is committed to the full implementation of the policy. This policy has been widely disseminated to related parties (suppliers, employees, etc.) and published on the company website:

4.  Company Due Diligence Management System

4.1 Management Structure

a          The company abides by its commitment to responsible procurement policies, establishes a responsible procurement due diligence management system, and formulates internal due diligence procedures.

b          The company appoints the general manager as the top management to be responsible for the decision-making, supervision and effectiveness of the due diligence management system.

c           The company has appointed a procurement manager as the project manager to coordinate the work of relevant departments (including procurement, production and warehouse) to ensure that all departments perform their due diligence, implement the due diligence process, and report any red flags and potential risks found.

d         The company conducts due diligence management system training for key personnel of all relevant departments every year in accordance with the requirements of the due diligence procedures. If policies or procedures are updated, the company will carry out additional training as needed.

e          The company evaluates the information related to the identified suppliers and raw materials every year. If a red flag is found, we will investigate and deal with it.

4.2  Internal control system

The company communicated the latest responsible sourcing policy and sourcing requirements to all suppliers in October 2021. The company has incorporated the requirements of responsible sourcing into legally binding agreement with direct suppliers. The company will review the relevant information when receiving each tin raw material, and check whether the information is complete and whether the information is consistent.

The company has established a grievance mechanism with reference to the requirements of the OECD Guidance. Collect complaints from related parties for the company's supply chain responsible sourcing issues through e-mail. The company has established a grievance process and protects the identity information of the complainant who is not subject to retaliation. The grievance email address

4.3  Due Diligence Records

The company requires all records related to responsible sourcing and due diligence management to be kept for at least five years.

5. Risk identification and assessment

The responsible sourcing project manager conducts a risk assessment of each supplier every year. According to the type of business of our company and the characteristics of sourcing, the risk sources are mainly the following four types of risks: whether the material comes from a conformant smelter (such as RMAP) that has been verified by a third party; whether the material documents are complete; Whether the supplier information is consistent; any negative allegation from NGO and media (for risks under Annex II of the OECD Guidance).

At present, all our suppliers are RMAP conformant. According to the company's 2021 risk assessment, no risk identified from all our suppliers.

6. Risk Management

Risk management and control will be formulated according to the three strategies of OECD Guidance: 1. Take control measures and continue trading; 2 Take control measures and suspend trade until the risk has been mitigated; 3. If its major risk or risk control are not feasible, terminate trading with suppliers. After the risk assessment of each supplier, refer to the different control measures corresponding to different risks for risk mitigation. The specific risk control measures will be discussed with the supplier and other stakeholders, and the stakeholders’ feedback will be adopted. The project manager is responsible for regularly monitoring and the implementation of risk control and mitigation effects. Report to the general manager regularly. If risk mitigation is not feasible or effective, will terminate busines with suppliers.

7. Summary

The company will continue to improve the due diligence management system to ensure the effective implementation of the management system, so that the company's due diligence and sourcing practices is aligned with RMAP audit standards, and comply with EU conflict minerals regulations and customer requirements.