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home » News » ATC News

Asia Tungsten Products (Vietnam) Limited Annual Due Diligence Report 2019

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1.      Company Information

Asia Tungsten Products Co Ltd is a Hong Kong based Joint Venture company established in 2009 (CID NO. 1385233). The company owns 100% of the Vietnamese charter capital company Asia Tungsten Products Vietnam Ltd which operates a ferrotungsten refinery facility located in the Vinh Bao District, Haiphong, Vietnam (“ATC”)......

                                        Asia Tungsten Products (Vietnam) Limited

          Add.: Plot CN06, Tan Lien Industrial Group, Vinh Bao,

                 Haiphong, Vietnam

 

Asia Tungsten Products (Vietnam) Limited Annual Due Diligence Report 2019

1.      Company Information

Asia Tungsten Products Co Ltd is a Hong Kong based Joint Venture company established in 2009 (CID NO. 1385233). The company owns 100% of the Vietnamese charter capital company Asia Tungsten Products Vietnam Ltd which operates a ferrotungsten refinery facility located in the Vinh Bao District, Haiphong, Vietnam (“ATC”).

2.      RMAP Assessment Summary

ATC has undergone a RMAP assessment on 29 -30 July 2019 for the period from 1 Sep 2017 to 31 May 2019. The assessment was conducted by UL Responsible Sourcing (formerly STR Responsible Sourcing).

On 5 Dec 2019, we received an email from RMAP Program Manager stating “there are still remaining quality issues with your assessment report, notably several areas for which there is insufficient data gathered, and it has been escalated to our Independent Review Committee (IRC)……”.

On 13 Dec 2019, the RMAP Program Manager informed us that IRC has determined that the assessment conducted by the auditor did not meet the standards of the RMAP and, consequently, RMAP will need to perform a full re-assessment.  

3.      Company Supply Chain Policy

To avoid the use of conflict minerals, which directly or indirectly finance or benefit armed groups and/or involve other serious human rights abuses in high-risk and conflict-affected regions, ATC has adopted the OECD Guidance as a policy item for procurement of tungsten raw materials since 19th December 2012. It covers all of the risks identified in Annex II of the OECD Guidance and its geographic scope is global. ATC is committed to addressing any Annex II risks if identified. The policy was reviewed and approved by senior management, which committed to support its implementation. The policy has been widely disseminated to relevant stakeholders, suppliers, customers and employees and is available on ATC’s website at http://www.asiatungsten.com.vn/index.php/atc-policy--64/tungsten-minerals-procurement-policy.htm.

4.      Company Management Systems

Management structure

ATC follows through on its commitments in the supply chain policy and has developed an internal procedure for due diligence with the following aspects:

l  The Company’s General Director is responsible to oversee the due diligence program and risk management design and implementation.

l  The Company has assigned a Compliant Manager to coordinate the work of the relevant departments (including the Business Department, Quality Department, Production Department and Warehouse Management Department) to ensure each department follows up on their roles and responsibilities to implement the due diligence program and report any red flags and potential risks identified.

Internal Systems of Control

ATC has established/updated its due diligence management system to be aligned with the OECD Guidance and RMAP.

l  The management of the Company take responsibility for the informing of potential mineral suppliers of the Company's Conflict Minerals Policy Statement with mineral suppliers being asked to sign a Supplier Declaration of Agreement with ATC Conflict Minerals Policy.

l  ATC was granted full membership to iTSCi on the 25th September 2014. A comprehensive due diligence checklist is used to ensure that all purchases of tungsten minerals conform to the company policies, with the purchasing of concentrate from CAHRAs countries coming only from iTSCI full member suppliers that use the iTSCI tag system. Documents from each supply of tungsten raw materials are kept on site for supply chain audits. The Company is using the iTSCI due diligence programme to review the origin of the material and assess through the provision of iTSCI incident reports, assessment summaries and district and mine visit reports if the material meets the guidelines and conforms to the Company's Conflict Minerals Policy.

l  All senior ATC operations personnel involved in the chain of custody of tungsten minerals have also signed and committed to the policy. Operations Personnel have received trainings in regards to the Conflict Minerals Policy through routine Safety and Policy training sessions.

Record Keeping System

The Company requires that all records relating to the due diligence program are maintained at least for five years and that they be properly used and safely stored in our document control department.

5.      Risk Identification

The Company has a robust process to identify risks in the supply chain.

ATC has established a procedure to identify CAHRAs (ref no. ATC-SU-002). The procedure includes the resources used, the criteria to define a “conflict-affected and high-risk” area as well as the frequency with which our determination is reviewed. The Company uses the following resources to determine CAHRAs:

l  A. UN Sanctions List.

l  B. Worldwide Governance Indicators:

http://info.worldbank.org/governance/wgi/index.aspx#reports

ATC has designed a Know Your Supplier (KYS) to include information concerning supplier legal status and identity, supplier chain map and potential risks. The major suppliers have completed and returned a KYS form (Supplier Application Form). During the reporting period, no red flags were identified related to submitted KYS forms.

ATC requested origin information for each material transaction and ensured that it was able to understand the transaction origin, transportation route, as well as direct suppliers’ name and locations.

All information collected was reviewed by the PIC against CAHRAs, sanction lists, local laws and internal sourcing requirements.

Risk Assessment

For material and supply chains determined to be “high-risk”, ATC conducted enhanced due diligence, including:

l  Assessing the context of CAHRAs;

l  Clarifying the chain of custody;

l  Assessing the activities and relationships of upstream suppliers;

l  Identifying locations and qualitative conditions of the extraction, trade, handling, and export of minerals; and,

l  Conducting on-the ground assessments through iTSCi.

ATC has become a full member of iTSCi since 2014. For each high-risk sourcing transaction, iTSCi provides the following documents:

1)      Incident summary reports as they become available

2)      Mine Visit Recommendations including a list of mine sites with potential risks

3)      Monthly country and region reports, which review the general situation on the ground

4)      Data summary and other reports

For material determined to be “high-risk”, we only purchase from iTSCi member companies with full iTSCi tagged shipments. ATC has established standard procedures to receive material from “high-risk” area and conducted further due diligence to review relevant documents.

6.      Risk Mitigation

ATC has developed Risk Mitigation Plan to further mitigate risks of high risk sourcing (“Risk Mitigation Plan”).

l  For risk of CAHRAs, we participate in RMI recognized upstream assurance mechanisms: iTSCi, RMAP assessments.

l  For risk of tax payment due to government, we source from official mines and governmental channel with complete export certificates.

l  For risk of money laundering, we assure real transactions and request for full documentations.

Asia Tungsten Products Co Ltd (Hong Kong) and its wholly owned subsidiary Asia Tungsten Products Vietnam Ltd. continue to support EICC initiatives and actions and will continue to assess and develop due diligence procedures to ensure that all tungsten minerals purchased support the aims of a conflict free supply chain.