Shenzhen Point Gold Refining Co., Ltd. is a certificated application member of the London Bullion Market Association (LBMA) and has implemented the LBMA RGG and RSG due diligence management system to fully implement the OECD due diligence guidelines for supply chains from conflict-affected and high-risk areas.

To cooperate with the smooth implementation of our LBMA RGG and RSG system, all suppliers shall comply with the requirements of the LBMA RGG and RSG management system and promise that the acquisition of all types of gold and silver products provided to our company is legal without involving the following circumstances:

1. Systematic or widespread abuses of human rights related to gold/silver mining, transport and transaction, forced labor, child labor, torture, inhuman and degrading treatment;

2. War crimes, violations of international human rights laws, crimes related to human rights or ethnic cleansing;

3. Purchasing precious metals or assistance for direct or indirect support for non-governmental armed groups, public or private security forces (refer to definitions in the Gold and Silver Appendix to OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas);

4. Acquisition of gold or silver through bribery or concealing the origin of gold or silver;

5. Purchasing precious metals from areas with money laundering or inherent high risks or areas of conflict;

6. Existence of terrorist financing;

7. Existence of intensified conflicts;

8. Utilization of mercury production for mining gold;

9. Possibility of violating legal requirements concerning environmental protection and sustainable development, gold mining from world heritage sites or domestic ecological natural reserves;

10. Existence of soil erosion, water and soil loss, land desertification, land subsidence, collapse, mountain collapse, landslide, debris flow and other geological disasters arising from the development of mineral resources;

11. Existence of water, soil and air pollution due to waste residues, wastewater and water gas, destruction of wild animal and plant resources and natural geomorphological landforms, citizens’ health endangered and property loss.

Gold and silver products provided by qualified suppliers recognized by us must comply with various requirements in the LBMA RGG and RSG management system. The relevant responsible departments of the Company must carefully check the suppliers’ information, establish the supplier information management files and irregularly investigate and evaluate the risks of suppliers.

All gold and silver suppliers and relevant silver partners related to Shenzhen Point Gold Refining Co., Ltd. concerning gold and silver trading and processing must receive the following risk level scores according to LBMA Responsible Gold Guidance and LBMA Responsible Silver Guidance (see Annex I).

According to the risk scores, the Company will take different risk termination approaches once all gold and silver suppliers and relevant silver partners related to Shenzhen Point Gold Refining Co., Ltd. concerning gold and silver trading and processing reach the following scores (see Annex II).

All suppliers are expected to observe the above system and sign the Suppliers’ Social Responsibility Commitment Letter (see Annex III).

The Management Policy shall be implemented upon the date of issuance.

Shenzhen Point Gold Refined Co, Ltd.

    January 5, 2020 

Annex I: Risk Level Scores

Annex II: Risk Ranking

Annex III:

Suppliers’ Social Responsibility Commitment Letter

Supplier’s name:                  Responsible person:           

Address:                              Tel.:                      

Shenzhen Point Gold Refining Co., Ltd.:

We have acknowledged the procurement policy meeting the LBMA RGG and RSG responsible management system requirements sent by your company. To ensure the smooth implementation of the policy, we are willing to observe all requirements under the management system and cooperate with your company in daily operation. In the name of the Company, I _________ make the following commitments:

The Company is willing to actively assume social responsibilities, make contributions to society and be dedicated to ensuring the health and safety of the employees of the enterprise. All types of gold and silver products provided for your company are acquired legally and do not involve the following circumstances:

1. Systematic or widespread abuses of human rights related to gold/silver mining, transport and transaction, forced labor, child labor, torture, inhuman and degrading treatment;

2. War crimes, violations of international human rights laws, crimes related to human rights or ethnic cleansing;

3. Purchasing precious metals or assistance for direct or indirect support for non-governmental armed groups, public or private security forces (refer to definitions in the Gold and Silver Appendix to OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas);

4. Acquisition of gold or silver through bribery or concealing the origin of gold or silver;

5. Purchasing precious metals from areas with money laundering or inherent high risks or areas of conflict;

6. Existence of terrorist financing;

7. Existence of intensified conflicts;

8. Utilization of mercury production for mining gold;

9. Possibility of violating legal requirements concerning environmental protection and sustainable development, gold mining from world heritage sites or domestic ecological natural reserves;

10. Existence of soil erosion, water and soil loss, land desertification, land subsidence, collapse, mountain collapse, landslide, debris flow and other geological disasters arising from the development of mineral resources;

11. Existence of water, soil and air pollution due to waste residues, wastewater and water gas, destruction of wild animal and plant resources and natural geomorphological landforms, citizens’ health endangered and property loss.

Note:

1. The Commitment Letter is public to all employees and stakeholders and is implemented upon the date of issuance.

2. We accept your inspections without prior notice, including the production premise, office areas, account books, documents, recruitment matters and records to ensure the effective implementation of the commitment.

General Manager:

Seal of the Company:

Time: