Business Ethics
Business Ethics
Business Ethics

A high-standard business ethics management system is an important pillar of ours 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 in accordance with 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.

Targets and Progress
Progress in 2022
  • 100%
    Business ethics training coverage 100% among directors, supervisors and senior management
  • 75.5%
    Business ethics training coverage 75.5% among employees
  • 70.9%
    Business ethics training coverage 70.9% 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, anticorruption, avoiding conflicts of interest, paying taxes under the law, and whistleblower protection. We require every subsidiary, director and employee, as well as 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 of the Supervisory Committee, a Disciplinary Inspection Committee supervision body, audit body and 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. They are vertically managed by the Supervision and Audit Office at the headquarters to implement total supervision.

  • Prevention
    We prevent unfair competition and corruption through risk management, business ethics awareness promotion, education and training, as well as smooth whistleblowing channels.
  • Audit
    We review and identify issues through internal audit, handling of whistleblowing anti-fraud investigation 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 Companvs Audit and Internal Control Committee.
  • Supervision
    We continuously monitor and supervise improvements until all negative impacts are fully eliminated or minimised.
Risk Management

When operating 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 risk or result in fines and damage to 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 minimise corruption, bribery, unfair competition and other risks related to business ethics through 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, is involved in a major environmental or safety accident, or has a significant negative impact on the company's reputation, business ethics, human rights protection, community relations, responsible supply chain and other ESG performance, and clearly 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 carry out verification. 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 in accordance with the law. 


Zijin Mining formulates anti-corruption review plans at least once a year for new subsidiaries and key subsidiaries and at least once every two years for other subsidiaries and 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 in our business ethics and anticorruption 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 prior to 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 on the Company's anti-corruption policy and provide feedback channels

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


To build an open and transparent supply chain, integrity clauses are included in the contracts signed between the Group and its subsidiaries and suppliers and contractors. We regularly organise collaborative anti-bribery exchange seminars with suppliers and contractors to jointly learn our anti-corruption policy and regulatory documents such as the "Policy Statement on Whistleblowing Management" and "Policy Statement on Business Ethics Management".

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 and 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. We have different review frequencies based on the level of the projects. In the past three years, we did not have any litigation cases against the Company in relation 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 effectiveness of the mechanism.

The whistleblowing system is maintained and managed by the Company’s Supervision and Audit Office. 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 by means of conversations or disciplinary actions, or even transferring the case to judicial authorities for handling.

Whistleblower Protection

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

  • We encourage whistleblowers to make report. We receive and accept grievance and whistleblowing reports through dedicated personnel at dedicated locations and 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 the information, implementing strict control on the number of people with access to the information and concealing the personal information of the whistleblower.
  • We have a stakeholder recusal mechanism where persons with a conflict of interest with the whistleblower or who has a stake in the information reported must take the initiative to recuse themselves. Upon request of the whistleblower 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 actual 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:

Tax Strategy

We respect and comply with the tax laws, regulations and rules in the countries in which we operate, and fulfil all tax obligations on time. We carry out related party transactions in accordance with the guidelines of the Organization for Economic Cooperation and Development (OECD). We will prepare and submit corresponding documents (including country reports, subject documents and local documents) to the tax authorities.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 in accordance with 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 tax management system that are 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 units, subsidiaries) and management (from the CFO of headquarters to the tax officers of subsidiaries). Our tax risk assessment mechanism effectively ensures the implementation of tax policies in a manner consistent with business ethics. We do not use aggressive tax structures or conduct transactions without commercial substance. In order to avoid tax risks in different jurisdictions, we will consult international agency and seek independent external tax advice on major matters and uncertainty. It 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 by tax manuals and trainings, so as to consolidate tax management. These measures can strengthen tax-related risk management, prevent tax 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 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:

  • 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

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%.