1. Company Commitment
深圳市粤鑫贵金属有限公司（以下简称“公司”）严格遵守并执行以《中华人民共和国劳动法》为核心的法律体系来保障本企业员工的合法权益，坚决反对并禁止一切形式的强迫劳动。按照《LBMA 负责任黄金指南第 9 版》和《LBMA 负责任白银指南第 2 版》的要求，禁止采购有强迫劳动行为在内的所有矿产以及任何使用强迫劳工开采和加工的黄金白银，确保供应链符合 OECD 指南的要求。特别承诺不涉及以下情况:
Shenzhen Yuxin Precious Metals Co., Ltd. (hereinafter referred to as "the Company") strictly adheres to and enforces a legal framework centered around the Labor Law of the People's Republic of China to protect the legitimate rights and interests of its employees. The Company firmly opposes and prohibits all forms of forced labor. In accordance with the LBMA Responsible Gold Guidance 9th Edition and the LBMA Responsible Silver Guidance 2nd Edition, the Company prohibits the procurement of any minerals, as well as gold and silver mined and processed using forced labor. We ensure that the supply chain complies with the OECD Guidelines. Specifically, we commit to avoiding the following practices:
Forced Labor: Work or service extracted under the threat of punishment, conducted involuntarily.
Violence: Direct physical coercion by the employer to force the worker to serve the employer.
Threats: Threats made by the employer to inflict violence or other forms of harm upon the worker as a means of forcing them into labor.
Illegal Restriction of Personal Freedom: The use of detention, confinement, or other coercive methods to unlawfully deprive or restrict the freedom of movement of others to control their bodily activities.
2. Policy Scope
本政策适用于公司全体员工、供应商、承包商及业务合作伙伴，涵盖贵金属采购、精炼、加工、销售等全供应链环节。我们要求所有合作伙伴共同遵守本政策，并承担与公司一致的责任。
This policy applies to all employees, suppliers, contractors, and business partners of the Company, covering the entire supply chain from precious metal procurement, refining, processing, to sales. We require all partners to comply with this policy and bear responsibilities consistent with those of the Company.
3. Specific Measures to Prohibit Forced Labor
Voluntary Labor Principle
所有员工的工作必须基于自愿，禁止通过暴力、威胁、债务束缚、扣押身份证件或其他形式强迫劳动。员工有权自由终止劳动关系或提出申诉。
All work performed by employees must be voluntary. Forced labor through violence, threats, debt bondage, confiscation of identity documents, or other means is prohibited. Employees have the right to freely terminate their employment relationship or file a grievance.
Fair Recruitment and Employment
确保招聘过程合法透明，禁止收取员工招聘费用或押金，杜绝人口贩卖或剥削性用工行为。
Ensure that recruitment processes are legal and transparent. Charging employees recruitment fees or deposits is prohibited, as well as any practices related to human trafficking or exploitative labor.
Supply Chain Due Diligence
对供应商提供确信的强制人权风险评估，优先选择同等标准认证的合作伙伴。
Conduct due diligence on suppliers to assess forced labor risks. We prioritize selecting partners who hold equivalent certifications and meet compliance standards.
Employee Rights Protection
确保员工享有法定工资、合理工时、安全的工作环境及自由结社权利。
设立匿名举报渠道，保护举报人免受报复。
Ensure that employees receive statutory wages, reasonable working hours, a safe working environment, and the right to freely associate.
Establish anonymous reporting channels to protect whistleblowers from retaliation.
Training and Awareness
定期对员工及供应商开展反强迫劳动培训，强化人权保护意识及合规操作能力。
Regularly provide anti-forced labor training to employees and suppliers, strengthening human rights protection awareness and compliance capabilities.
Special Clauses for High-Risk Areas
不采购直接或间接涉及强迫劳动的矿产，包括刚果（金）及其周边国家冲突矿产（如未通过合规认证）。
The Company strictly complies with LBMA’s control requirements for conflict-affected and high-risk areas:
We do not procure minerals directly or indirectly involved in forced labor, including conflict minerals from the Democratic Republic of Congo (DRC) and its surrounding countries (if not certified compliant).
Suspension of Cooperation: If any supplier is found to engage in forced labor practices, cooperation will be immediately terminated, and the relevant regulatory authorities will be notified.
5. Supervision and Improvement
每年委托第三方机构对供应链进行社会责任审计，结果向LBMA及相关利益方披露。
The Company will commission a third-party organization to conduct social responsibility audits of the supply chain annually, with the results disclosed to LBMA and relevant stakeholders.
管理层定期审查政策执行情况，持续改进人权风险管理体系。
Management will review the policy's implementation regularly, ensuring continuous improvement in the human rights risk management system.
合规总监：王子杰
申诉电话：18923490683
申诉邮箱：874278232@qq.com
Compliance Director: Wang Zijie
Complaints Phone: 18923490683
Complaints Email: 3949890619@qq.com