We are committed to conducting business in compliance with all applicable laws and regulations and the highest ethical standards. We promise to conduct our business with professionalism, honesty, and integrity in all business transactions and relationships and prohibit any activities that adversely affect the integrity and reputation of the Company.
Creating a fair, transparent, and honest work and business environment is our goal. We have zero tolerance for bribery, extortion, and corruption. We require every project we operate, as well as every director, employee, supplier, and contractor we work with, to comply with it.
At the headquarters level, we have formed a “5-in-1” business ethics management system made up of the Company’s Supervisory Committee, Disciplinary Inspection Committee, supervision body, audit body, and internal control body. The Supervision and Audit Office at the headquarters is set up as a dedicated department for the business ethics management system, vertically managing the supervision and audit departments of our subsidiaries to maintain the independence of the internal supervision system.
The Corporate Code of Conduct sets out Zijin Mining’s stand on business ethics, including promoting free and fair competition, anti-corruption, avoiding conflicts of interest, and paying taxes in compliance with the laws.
We have formulated a series of policies such as the Rules on Internal Supervision, Administrative Disciplinary Measures, Implementation Measures for Inspection Work, and Regulations on Internal Audit Management to investigate and deal with corruption and fraud. The hiring, employment and remuneration of persons with special relationship are regulated, as well as the business dealings them. Employees are required to declare their persons with special relationship on a regular basis, effectively reducing the risk of corruption of personnel and creating an honest work environment.
We require all directors, supervisors, employees, suppliers and contractors to abide by our policies and standards. We are committed to creating a healthy and transparent supply chain, and integrity clauses are included in all contracts between our subsidiaries and suppliers or contractor. To ensure that the relevant policies and standards are implemented:
We conduct a variety of activities such as integrity pledge signatures, surveys, warning films, and integrity talks to strengthen anti-corruption education and promote the development of the Company’s integrity system.
We organise collaborative “Anti-bribery” talks for suppliers and contractors to learn about anti-corruption policies and regulatory documents such as the Policy Statement on Whistleblowing Management and the Policy Statement on Business Ethics Management.
We strictly comply with domestic and international laws and regulations and international standards, such as the Anti-Unfair Competition Law of the People’s Republic of China, the Contract Law of the People’s Republic of China, and the Model Provisions on Protection Against Unfair Competition. In order to establish an honest and fair competition mechanism and avoid the occurrence of unfair competition, we conduct special investigations into leads related to unfair competition that we discover and receive in whistleblowing reports. We also conduct regular reviews of the projects of our subsidiaries, with different frequencies set according to the project level. In the past three years, we did not involve in any unfair competition related lawsuits against the Company.
The Company’s supervision body receives and verifies strictly all whistleblowing reports strictly as prescribed by laws and regulations, and submits the findings to the management. After receiving approval from the relevant management body, we take actions against violations by means of conversation, disciplinary actions, or even referral to judicial authorities.
On an annual basis, we conduct business ethics and anti-corruption inspections, audits, internal controls, and special inspections on our subsidiaries. Based on the findings of these reviews, we summarise the problems and improve accordingly. We develop anti-corruption review plans for new projects and key projects every year and for other projects every two years, and we will adjust these plans based on risk levels and industry trends.
We will further improve supervision efficiency and effectiveness using information technology and big data, recruiting supervision experts，continuously track and monitor the issues reflected in whistleblowing reports and the issues identified through internal checks, and take appropriate measures to improve our management. Meanwhile, we integrate business ethics and Corporate Code of Conduct into employee performance appraisal standards.
We encourage all stakeholders to report truthfully any possible violations of business ethics management. To ensure that stakeholders’ petitions are promptly and effectively dealt with, the Company set up a grievance and whistleblowing mechanism for stakeholders since the early days of its establishment. We have issued the Policy Statement on Whistleblowing Management and formulated the Written and In-person Whistleblowing Management Measures to regulate whistleblowing work.
The whistleblowing system is maintained and managed by the Company’s Supervision and Audit Office, with dedicated personnel responsible for receiving grievance information. The mechanism is applicable to all stakeholder groups and covers all business activities of the Company. The whistleblowing methods are published on the Company’s official website, as well as included in the clauses of all external contracts. This can effectively help the Company identify and solve problems, protect the rights and interests of complainants, standardise the handling of grievances, and improve the Company’s business management.
Whistleblowers may report violations under their real names or anonymously using the following methods:
Our tax strategy is based on the compliance with the tax laws, regulations and rules in the countries in which we operate. We continue to enhance our tax management which covers the entire process of accounting, tax declaration, monitoring, evaluation, forecasting and reporting in respect of tax-related business. We aim to improve the organizational system for taxation management, guard against and control taxation risks, so as to ensure that taxes are paid in accordance with laws and regulations in business decision-making and daily operations, and to make use of the current preferential taxation policies reasonably.
In light of our tax strategy, we do not take an aggressive tax planning and do not conduct transactions without economic and commercial substance. Instead, we hire the professional and international tax agents presenting tax advice on significant and uncertain matters externally and independently to avoid triggering tax risk in various tax jurisdiction. Additionally, tax agents not only assist us to solve tax affairs in business and economic activities, but also guide us to process tax issues compliantly for tax risk-control.
We established an Information Committee, with the Chairman of the Board as the director, the CEO as the executive deputy director, and the vice president in charge of information security as the deputy director. The Information Committee is the decision-making body for major information security matters such as the Company's information security management guidelines and policies responsible for guiding the construction of information security systems. The general manager of the Information department (Information Security Officer) will report on the Company's network security every month.
We have formulated a sound information security system and technical standards, and implemented corresponding management measures to protect the confidentiality, integrity and availability of information systems, automation equipment and data. Our group-wide information security management scope includes:
We have formulated the "Information Security Incident Emergency Response Plan", which stipulates the importance level of information security incidents such as network interruption and equipment failure, as well as emergency reporting, disposal, and information disclosure procedures. We organize disaster backup and recovery drills every six months and keep drill records. Meanwhile, we clarified the reporting procedures and time limits for information security emergencies: the relevant on-site personnel immediately report to the department head → the department head informs the relevant personnel for on-site disposal, and immediately press procedure. Report directly to the leader and, if necessary, to the main responsible personnel. After receiving the information security incident report, the responsible personnel or direct management leader should quickly organize a response, report to the emergency response office, and report to the local government/public security department if necessary.
We organize various information security awareness training covering all employees, such as information security and privacy protection related activities, lectures, and disseminations on work platform. Employees who violate information security management regulations or fail to fulfill their information security responsibilities will receive penalties depending the circumstances. At the same time, information security work is also a part of the assessment of the informatization work of subsidiaries, accounting for 10%.