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 2024
  • 100%
    Business ethics training coverage 100% among directors, supervisors and senior management
  • 75.25%
    Business ethics training coverage 75.25% among employees
  • 76.81%
    Business ethics training coverage 76.81% among suppliers and contractors
Our Approach

Our "Corporate Code of Conduct", "Policy Statement on Business Ethics Management", and "Policy Statement on Whistle blowing Management" collectively articulate the company's stance on business ethics. We require the company's employees, suppliers, and contractors to adhere to our business ethics policies. Additionally, documents such as the "Rules on Internal Supervision", "Several Provisions on Integrity in Practice", "Measures for the Management of Whistle blowing", and "Regulations on Internal Audit Management" are crucial institutional supports for our business ethics management. During the reporting period, we revised the “Measures for Administrative Disciplinary” to strengthen penalties for violations of business ethics, and introduced the "Rules on Employee Credit Management" as an internal policy, promoting the principle of "honor for the trustworthy, shame for the untrustworthy, and abandonment for those without credibility". Our business ethics management follows a decision-making and execution process of prevention, ongoing review, and post-event improvement to minimize business ethics risks.

  • 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

In our international operations, laws across different jurisdictions impose varying compliance requirements on our business. Actions suspected of violating ethics or law could pose significant risks to our business, leading to penalties or reputational damage.

Risk ldentification

Within the Company's operations, violations such as commercial bribery, misappropriation of company assets, infating engineering quanties, procurementfraud, and falsifying travel reimbursements occasionaly occur. These fraudulent acts increase operational management costs, erode the Company's integrityculture, and cause disorder and chaos in management activities. We adhere to the "United Nations Convention against Corruption" and the Companys "RiskManagement System", identifying anti-corruption as one ofthe core risk categories.Weregularyupdate our riskinventoryto preventidentified integrity risks suchas inflated engineering quantities, procurement fraud, misappropriation of company assets, and fals;lfed trave! reimbursements. During the reporting periodsignificant faudulent cases occurred in procurement and trade sectors severely impacted the Companys reputation and brand image. These cases highlght theexisting risk management gaps in our procureent and trade sectors and have prompted us to continuously improve our business ethics risk management practices.

Risk Monitoring and Assessment

We conduct anti-corruption reviews at least annualy for new and key proiects and at least everytwo years for other proiects, adiusing plans according to the risklevel and operalional siluaion, Each vear, based on the contents of our business ethics and anti-coruption polices, we conduct inspections. audits internacontrols, and speial checks at subsidiaries and continuously optimise based on the isues found in these reviews. uring the reporing period, we launched aspecial anti-corupion campaign in the procurement and trade sector. We focused on strengthening governance from the ground up by enhaning twelwe keyareas; organisational structure, business processes,performance evaluations, job rotation poicies,big data monitoring, and specialised oversight. This effort wasaimed at elevating the level of standardised management across the entire procurement and trade system.

Risk Response

We reduce risks such as coruption, unfair competition, and other ethical breaches by enhancing management systems, strengthening process controlsproviding training and education, and improving whistleblower protection. For misapprapriation of company assets, we enforce strict procedures for inventoryin-and-out management and conduct regular or random stock checks. For procurement fraud, we have set stringent supplier entny requirements and restricsuppliers listed on the exclusion list. Additionaly, we conduct regular ant-coruption assessments and propose improvement measures to continuousiy nurturea 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

In terms of data security, we face risks of external attacks or internal misuse, as well as the possibility of data tampering during transmission and processing, which may severely affect data accuracy and reliability. To address this, we employ Continuous Data Protection (CDP) technology to effectively safeguard data security. With increasing reliance on information systems for business operations, availability risks have become more prominent. To control such risks, we have formulated a Business Continuity Plan (BCP), established a "two locations, three centers" disaster recovery system, and provided hot standby support for critical business information systems to ensure business continuity and stability.

  • 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

For information security and privacy breach emergencies, we have developed the Incident Response Plan for Information Security Emergencies, which specifies the severity levels of various information security incidents (such as network outages and equipment failures), as well as emergency reporting, disposal, and information disclosure procedures. We organize disaster emergency and backup recovery drills every six months. Meanwhile, we have clarified the reporting procedures and time limits for information security emergencies: on-site personnel shall immediately report to the department head → the department head shall notify relevant personnel for on-site disposal and proceed with the procedures immediately. Reports shall be directly submitted to leadership, and in necessary cases, directly to the enterprise's principal responsible person. Upon receiving reports of information security incidents, the enterprise's principal responsible person or direct management leader shall promptly organize a response and report to the company's emergency duty office, and report to local government/public security authorities when necessary.

 

We also conduct information security awareness training covering all employees through various means, including annual special events on information security and privacy protection, and irregularly releasing updates on information security and privacy protection on work platforms. For employees who violate information security management regulations or fail to fulfill information security responsibilities, disciplinary measures shall be taken in accordance with the Administrative Disciplinary Measures, depending on the circumstances. Additionally, information security and privacy protection are incorporated into the performance evaluation of subsidiaries, accounting for 10% of the total assessment.