紫金矿业

Business Ethics
Business Ethics
Business Ethics

A high-standard business ethics management system is important to ensure we operate with integrity. Zijin Mining is committed to upholding professionalism, honesty, and integrity in all business dealings and relationships and conducting business following all applicable laws and regulations and the highest levels of business ethics. We always aim to create a fair, transparent, and honest working and operating environment and prohibit all activities that could tarnish the integrity and reputation of the Company. We value and continuously foster a culture of integrity, take a firm stance against any form of corruption, and are committed to creating a healthy business environment that is clean and friendly.

UN Sustainable Development Goals
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UN Global Compact
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Targets and Progress
Progress in 2023
  • 100%
    Business ethics training coverage 100% among directors, supervisors and senior management
  • 87.97%
    Business ethics training coverage 87.97% among employees
  • 73.77%
    Business ethics training coverage 73.77% among suppliers and contractors
Our Approach

Our Corporate Code of Conduct, Policy Statement on Business Ethics Management, and Policy Statement on Whistleblowing Management set out the Company’s position related to business ethics, such as promoting free and fair competition, anti-corruption, avoiding conflicts of interest, paying taxes under the law, and whistleblower protection. We require every subsidiary, director, employee, supplier, and contractor we work with to adhere to our business ethics policies.

 

We have established a “5-in-1” business ethics management system comprising the Supervisory Committee, a disciplinary inspection body, an audit body, and an internal control body. The Supervision and Audit Office is established at the Company’s headquarters as a dedicated department for the business ethics management system. It is directly under the Supervisory Committee to maintain the independence of the internal supervision system. We have also set up internal supervisory and audit departments in subsidiaries, with dedicated personnel responsible for compliance management and supervision. The Supervision and Audit Office vertically manages them at the headquarters to implement total supervision.

  • Prevention
    We prevent unfair competition and corruption through risk management, promoting business ethics awareness, education and training, and smooth whistleblowing channels.
  • Audit
    We review and identify issues through internal audits, handling of whistleblowing anti-fraud investigations, and third-party review and report the findings and outcomes to the Company’s Audit and Internal Control Committee.
  • Improvement
    We improve and mitigate negative impacts by formulating improvement measures based on reviewing reports and implementing such measures with the approval of the Company’s Audit and Internal Control Committee.
  • Supervision
    We continuously monitor and supervise improvements until all negative impacts are eliminated or minimized.
Risk Management

When we operate internationally, laws of different places of jurisdiction may impose different compliance requirements on our business. Suspected ethical, compliance or legal breaches may also put our business at significant risks or result in fines and damage to our reputation. Following the United Nations Convention against Corruption and the Company’s Risk Management Rules, during the reporting period, we issued the Operational Guidelines for Risk Management to include anti-corruption as one of the core elements in identifying risks. We minimize corruption, bribery, unfair competition, and other risks related to business ethics by improving the relevant management system, tightening process controls, carrying out training and education, and providing more protection for complainants and whistleblowers. We conduct regular anti-corruption assessments and propose improvement measures to continuously cultivate our risk management culture.

Oversight and accountability

We have established an accountability mechanism for violations of the Code of Conduct. If employees violate the ESG principles in our Corporate Code of Conduct, are involved in a major environmental or safety accident, or have a significant negative impact on the company’s reputation, business ethics, human rights protection, community relations, responsible supply chain, and other ESG performance, and bears the main responsibility for the incident, the Company can veto their incentive pay and refuse to pay option bonuses.


If such behavior is found, we will organize relevant departments to verify. After it is confirmed that there is indeed an act violating the Corporate Code of Conduct, we will form a formal investigation report. After deliberation by the management meeting, we will hold relevant responsible persons accountable and record and file. Those suspected of committing crimes will be handed over to judicial organs by the law. 

Anti-corruption

Zijin Mining formulates anti-corruption review plans at least once a year for new and key subsidiaries and at least once every two years for other subsidiaries. It regularly revises them based on risk levels and industry trends. We carry out inspections, audits, internal controls, and special inspections on our subsidiaries every year according to various elements of our business ethics and anti-corruption policies and continuously improve the issues identified in the review results.

  • Zero tolerance
    Maintain zero tolerance for corruption, conduct all businesses in strict compliance with domestic and international anti-corruption laws
  • Due diligence
    Screen all business counterparties, third parties, and job applicants carefully before entering into relationships
  • Risk identification and response
    Regularly identify and update corruption risks associated with the business processes and effectively respond to identified risks
  • Communication and training
    Provide information, recommendations, and training for senior management, employees, suppliers, and contractors to be fully aware of the Company’s anti-corruption requirements
  • Supervision and improvement
    Perform regular external and internal audits on the effectiveness of the anti-corruption procedures and improve the procedures accordingly
  • Accountability and penalties
    Thoroughly investigate all suspected acts of corruption and hold the persons who commit corruption accountable
  • Reporting
    Regularly inform stakeholders of the Company’s anti-corruption policy and provide feedback channels

We assess job positions with high corruption risk regularly and provide focused training for directors, supervisors, senior management, new hires, newly promoted employees, and those in key sensitive positions with high risks. We organized an array of activities for our employees, including signing the oath of integrity on International Anti-Corruption Day, anti-corruption questionnaire surveys, putting forward rational suggestions, integrity talks, and integrity “better half” to strengthen the anti-corruption and integrity education.

 

Integrity clauses are included in the contracts signed between the Group and its subsidiaries, suppliers, and contractors to build an open and transparent supply chain. We regularly organize collaborative anti-bribery exchange seminars with suppliers and contractors to jointly study our anti-corruption policy and regulatory documents.

Anti-monopoly and Anti-unfair Competition

Zijin Mining advocates free and fair competition while opposing all forms of monopoly and profiteering:

  • We strictly abide by “the Law of the People’s Republic of China Against Unfair Competition,” “the Civil Code of the People’s Republic of China,” and other relevant anti-monopoly and anti-unfair competition laws, regulations, and international standards.
  • We have a mechanism for honest and fair competition. To prevent unfair competition, we conduct special investigations into the unfair competition clues that are identified or reported.
  • We also regularly review the projects of our subsidiaries, with different review frequencies based on the project’s level. In the past three years, we have not had any litigation cases against the Company related to unfair competition.
Grievance and Whistleblowing Mechanism

Zijin Mining encourages all stakeholders to candidly report any potential violations against business ethics management. To ensure all stakeholders have easy access to grievance channels and their concerns are promptly addressed, the Company provides a complete grievance and whistleblowing mechanism for stakeholders, continuously develops grievance and whistleblowing channels, and regularly checks and evaluates the mechanism’s effectiveness.

The Company’s Supervision and Audit Office maintains and manages the whistleblowing system. Dedicated personnel members are responsible for receiving grievance information, following which they handle and verify the information of all parties strictly according to policy and legal requirements and report the verification and investigation findings to the management. After approval by the appropriate management bodies, violations are addressed using conversations, disciplinary actions, or even transferring the case to judicial authorities for handling.

Whistleblower Protection

Zijin Mining does not tolerate harmful conduct or retaliation against whistleblowers. We encourage all stakeholders to report anything suspicious or improper. Information provided by whistleblowers helps us identify and address issues and improve how we do business. To gain the trust of whistleblowers and encourage them to report, we take the following measures:

  • We encourage whistleblowers to report. We receive and accept grievance and whistleblowing reports through dedicated personnel at dedicated locations, on dedicated telephone lines and mailboxes, or through third parties.
  • We record every report individually and take strict measures to keep the information confidential, such as encrypting and storing it, implementing strict control over the number of people with access to it, and concealing the whistleblower’s personal information.
  • We have a stakeholder recusal mechanism where persons with a conflict of interest with the whistleblower or who have a stake in the information reported must take the initiative to recuse themselves. Upon the whistleblower’s request and when deemed necessary by the head of supervision, persons who may have a potential conflict of interest are also required to recuse themselves after it is confirmed by the Supervision and Audit Office.
  • We do not allow any form of punishment, disciplinary action, or retaliatory action against whistleblowers. We take strict action against anyone who threatens or takes retaliatory action. Depending on the situation, we may take disciplinary action, dismiss the person, or even transfer the case to judicial authorities to pursue civil and criminal responsibilities.

Whistleblowers may report to the Company (headquarters) using their real names or anonymously in the following ways:

Telephone
+86-0597-3833182
Online platform: Ziin Mining integrity reporting platform
https://rac.zjky.cn/honest/static/index.html
Email
jcsjs@zjky.cn
WeChat
Zijin Mining Supervision Platform
In-person or by mail
Supervision and Audit Office, Zijin Mining, 1 Zijin Road, Shanghang County, Fujian Province 364200
Tax Strategy

We respect and comply with the tax laws, regulations, and rules in the countries in which we operate and fulfill all tax obligations on time. We carry out related party transactions following the Organization for Economic Cooperation and Development (OECD) guidelines. We prepare and submit corresponding documents for the required reporting periods (including country reports, subject documents, and local documents) to the tax authorities within the required timeframe. We have established a tax strategy covering the process of tax accounting, declaration, monitoring, assessment, forecast, and report so as to prevent and control tax risks. We pay taxes following the law in our business decisions and activities and actively create economic contributions to the countries in which we operate. In addition, we have developed a tax management system compatible with our tax strategies and set our tax objectives to optimize the tax structure and control tax risks.

Tax governance
We have established a sound tax governance covering all levels of institutions (headquarters, business departments, and subsidiaries) and management (from the CFO of headquarters to the tax managers of subsidiaries). Our tax risk assessment mechanism effectively ensures the implementation of tax policies consistent with business ethics. We do not use aggressive tax structures or conduct transactions without commercial substance. We consult international agencies to avoid tax risks in different jurisdictions and seek independent external tax advice on major matters and uncertainty. This helps us better understand potential tax issues that our business activities may lead to and guide our tax compliance in different jurisdictions. In addition, due to the complexity and variability of tax legislation, we will improve the professional quality of finance and tax personnel through tax manuals and training to consolidate tax management. These measures can strengthen tax-related risk management, prevent risks, and ensure tax compliance.
Prohibit tax evasion
We will not tolerate any tax evasion. At the same time, we encourage employees and related parties to report any illegal behaviour to improve our business management. We will protect the confidentiality of information and whistleblower to prevent any retaliation. Refer to " Grievance and Whistleblowing Mechanism" and "Whistleblower Protection" for reporting channels and protection mechanisms.
Tax transparency
We have been transparent and positive in our interactions with the tax authorities. We (including our subsidiaries) will maintain a professional relationship with the local tax authorities based on the principles of transparency and trust. For new businesses in which tax obligations is not clearly stated by laws and regulations, there may be differences in legal interpretation between the tax authorities and us. We will actively communicate with the tax authorities to solve the problems.
Information Security and Privacy Protection

We have established an Information Committee, with the Chairman of the Board as the director, the President 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 management guidelines and policies. It is 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:

  • Personnel safety management
  • Data center security management
  • Information asset security management
  • Network security management
  • Software system security management
  • Client security management
  • Security management of documents, data, and storage media
  • Third-party access control
  • Outsourcing management
  • Information security emergency management
  • Cloud computing security management
  • Mobile Internet Security Management
  • IoT Security Management
  • Safety management of industrial control systems

To address information security and privacy breaches, we have developed the “Information Security Incident Emergency Response Plan.” This plan categorizes various information security incidents, such as network interruptions and equipment failures, by their levels of severity and outlines procedures for emergency reporting, response, and disclosure. We conduct disaster recovery and backup exercises biannually. Additionally, we have established clear protocols and timelines for reporting information security emergencies: relevant on-site personnel must immediately report incidents to the department head, who then instructs relevant staff to manage the situation on-site according to established procedures. Direct reporting to leadership is required, and in urgent cases, reporting may escalate to the company’s principal executive. Upon receiving a report of an information security incident, the principal executive or direct managing leader must quickly mobilize a response, inform the company’s emergency response office, and, if necessary, notify local government or public security authorities. 

 

We organize various information security awareness training sessions for all employees, such as activities related to information security and privacy protection, lectures, and disseminations on the work platform. Depending on the circumstances, employees who violate information security management regulations or fail to fulfill their information security responsibilities will receive penalties. Furthermore, information security work has become part of the appraisal of the digital transformation work of subsidiaries, accounting for 10%.