Sustainability
SUSTAINABILITY Policy
The directors and management are focused on ensuring the long-term sustainability of the Group and its business to benefit its shareholders and other stakeholders. Sustainability is supported by the Group’s values; operating in an environmentally responsible manner by continually improving circular and low-carbon operations including engagement in green partnerships, targeting zero waste, prioritising the health and safety and development of employees, conducting business with integrity throughout the Group and supply chain as well as actively engaging and contributing to the local community.
The report is prepared with reference to the Sustainability Reporting Guidelines of the Global Reporting Initiative (GRI Standards), the Guidelines on Corporate Social Responsibility Reporting for Chinese Enterprises (CASS-CSR 4.0), the Guidelines on Corporate Social Responsibility Reporting for Chinese Enterprises – Mining Industry (CASS-CSR 4.0) of the Chinese Academy of Social Sciences, and the Guide for Business Action on SDGs by the UN Global Compact.
Unless otherwise stated, the report covers the period from 1 January 2024 to 31 December 2024. To enhance data comparability, part of the content is outside of the above period.
Since its establishment and commencement of operations in 1994, the Company has pursued a policy of green, ecological, and efficient operations. Whilst maintaining green operations, it continuously refines the management of Caijiaying, explores sustainable development paths, and contributes to green, low-carbon, and circular economic development. The Company places great emphasis on corporate culture and employee care, with safety as a core value. It upholds values such as mutual respect, teamwork, dedication, pursuit of excellence, innovation, and integrity. By prioritising technological innovation and management advancement, the Company actively fulfills its corporate social responsibilities, striving to maximise both economic and social benefits from mining development and to establish itself as a top-tier mining enterprise.
SLAVERY Policy
Whilst section 54 of the UK Modern Slavery Act 2015 does not apply Griffin Mining Ltd, as it is incorporated in Bermuda and does not do business in the United Kingdom, the Griffin Mining Ltd Group of Companies seeks to comply with international best practice as well as local legislation with regard, inter alia, human rights and the environment. Griffin strives to create a safe and harmonious work environment, strictly prohibiting the employment or use of unpaid labour or child labour, opposes any form of forced labour and requires suppliers and vendors to implement the same employment standards.
Griffin strictly enforces the national minimum working age regulations and verifies the identity and age of candidates at the time of recruitment. Hebei Hua Ao regularly evaluates and assesses suppliers to ensure they are fulfilling their environmental and social responsibilities. This includes ensuring Griffin does not deal with any supplier involved in any way with slavery.
UN Sustainable Development Goals
The directors and management are focused on ensuring the long-term sustainability of the Company and its business to benefit its shareholders and other stakeholders. Sustainability is supported by the Group’s values; operating in an environmentally responsible manner by continually improving circular and low-carbon operations, prioritising the health and safety and development of employees, conducting business with integrity throughout the Group and supply chain as well as actively engaging and contributing to the local community around the Caijiaying Mine
Enhancing Governance Compliance
Sustainable Development Governance (“SDG”)
Sustainable Development Governance Concept
Griffin recognizes that a strong governance framework for sustainable development is essential for a Company’s long-term success. The Company upholds principles of environmental sustainability, social responsibility, and efficient governance. Griffin integrates safety and green mining concepts into its corporate strategy while refining compliance governance. Through continuous improvement of its environmental management system, Griffin strives to reduce waste and pollutant emissions, enhance energy and resource efficiency, and undertake land reclamation and ecological restoration to minimise any environmental impact. Additionally, Griffin maintains positive relationships with local communities, contributing to their economic development and infrastructure improvement. Furthermore, Griffin has established a robust ESG governance framework, adheres to the highest ethical standards, and enhanced risk management systems. Griffin believes that compliance is the cornerstone of stable corporate development and a key factor in earning stakeholder trust.
Sustainable Development Governance Structure
The Company integrates sustainable development governance into its strategic and operational activities, continuously optimising the governance framework to ensure effective ESG management. Griffin has established a three-tier governance structure comprising the Board of Directors, Management, and relevant functional departments, each with clear roles and responsibilities:
• Board of Directors: As the highest governing body, it is responsible for formulating and refining sustainable development strategies, overseeing their implementation, assessing risks and opportunities related to sustainability, and monitoring performance and targets.
• Management: It is responsible for coordinating and guiding sustainability initiatives, reporting regularly to the Board on ESG progress, and overseeing the preparation and disclosure of sustainability reports.
• Functional Departments: It is responsible for advancing and implementing sustainability strategies and executing specific ESG initiatives.
Stakeholder Communication
The Company values stakeholder engagement and has established diverse and regular communication channels to understand and address stakeholder concerns and expectations.
| MAJOR STAKEHOLDERS | MAIN CONCERNS | COMMUNICATION AND FEEDBACK CHANNELS |
| Government and regulatory agencies | Legal compliance | Complying with the requirements of laws and regulations |
| Safety and environmental protection | Daily communication and reporting | |
| Creating job opportunities | Government meetings and visits | |
| Boosting economic development. | Strategic cooperation | |
| Shareholders and investors | Compliance operation | Shareholders meeting |
| Risk management | Performance conference | |
| Sustainable development governance | Disclosure of information such as periodic reports and policies | |
| Information transparency | Investor communication platform | |
| Employees | Human rights protection | Employee representative meetings |
| Compensation and benefits | Employee performance interview | |
| Employee care | Regular safety inspection and reporting | |
| Training and development | Employee activities | |
| Occupational health and safety | Employee activities | |
| Suppliers and business partners | Customer service | Customer satisfaction surveys |
| Supply chain management | Responsible procurement | |
| Product quality | Strict and independent assay and moisture checks of concentrate sold | |
| Promoting the development of industrial chain | Experience exchange and technical cooperation | |
| Community | Community investment. | Involvement in local community communication |
| Social | Supporting community development | |
| Environmental protection and ecology. | Insisting on low-carbon operations | |
| Climate change. | Mining area project meeting |
Materiality Analysis
In 2024, to better identify and evaluate the importance of ESG key issues, Griffin conducted a materiality analysis, selecting the topics most relevant to stakeholders and forming a materiality matrix to guide the sustainable development work and practice of the Company.
Identification and Selection
According to domestic and foreign regulatory policies, the Company’s own business characteristics and development and industry dynamics and other standards, 22 ESG key issues closely related to the Company’s business development are selected to form a list of ESG key issues.
Assessment and Analysis
Conducting a questionnaire survey for internal and external stakeholder groups, including government and regulatory agencies, shareholders and investors, employees, suppliers and partners, and the community, and carrying out an assessment and analysis of the importance of the issue based on the questionnaire results.
Confirmation and Report
Through the questionnaire results, the issues were prioritised in two dimensions of “Relative Significance to the Company” and “Relative Significance to the stakeholders” to form the Company’s 2024 analysis matrix of substantive issues, which was disclosed in this report.
Analysis matrix of substantive issues
Business Ethics
Honesty and integrity are core principles and guide Griffins business operations. Griffin continuously strengthens its business ethics management system, proactively identifies and assesses potential risks, and formulates targeted management strategies to enhance its ability to prevent and control ethical risks. Employees at all levels must strictly comply with relevant laws and regulations, adhere to the highest ethical standards, and oversees best business ethics practices. Griffin encourage all employees and business partners to participate in ethical supervision, fostering a business environment rooted in integrity.
Anti-corruption Management
Griffin identifies anti-corruption-related regulations, and strictly abides by the Anti-Unfair Competition Law of the People’s Republic of China, the Anti-Money Laundering Law of the People’s Republic of China, the Anti-Monopoly Law of the People’s Republic of China and other relevant laws and regulations. Through the formulation and implementation of a series of measures, Griffin clarifies the requirements of business ethics, regulates the behaviour of employees, and updates the construction of compliance management systems. In this regard, Griffin:
• Develops a code of conduct for employees and detailed anti-corruption policies, clarifies the behavioural standards and requirements of business ethics for employees at all levels, monitors the Company’s business operations and the commercial behaviour of stakeholders, and strictly prohibits any director or employee from engaging in illegal or unethical economic activities. • Calls upon all departments to adhere to the principles of anti-corruption and clean governance. Clearly states the prohibition of all forms of bribery and corruption during the onboarding of new employees. Requires all employees to promptly report any gift exchanges. • The Human Resources Department and the relevant management of the Operations Department are responsible for regularly reviewing, assessing, and updating the code of conduct for employees. Griffin identifies and strives to avoid potential risks to its business and operational processes.
• Strengthens daily supervision and regular reviews. Optimises the reporting process for anti-corruption and anti-fraud activities. Standardises the procedures for employee reporting and investigations to ensure compliance requirements are met.
• Promotes a culture of integrity by regularly organising various trainings and publicity activities. Ensures employees understand and embrace the Company’s culture of integrity. Integrates anti-corruption concepts into employees’ daily work.
• Conveys a zero-tolerance attitude towards bribery and corruption to suppliers and partners. Includes anti-corruption clauses in supplier agreements and contracts for goods and services to create a harmonious and clean business environment.
Whistleblowing Mechanisms
To ensure the effective implementation of the Company’s business ethics standards, Griffin places great emphasis on and continuously optimises the construction of reporting mechanisms. The Company advocates that employees at all levels and partners actively participate in the supervision of integrity and honesty. Griffin has established a variety of reporting channels to facilitate employees and stakeholders in reporting any behaviour that violates business ethics, is illegal, or is inappropriate.
Griffin strictly enforces a whistleblower confidentiality policy, providing whistleblowers with the option to report anonymously or under their real name. Griffin strictly keeps the identity of the whistleblower and the information of the report confidential. Griffin explicitly prohibits any form of retaliation and protects the legitimate rights and interests of whistleblowers. For reported matters, Griffin standardizes the investigation and handling procedures to ensure the objectivity and fairness of the investigation. Griffin promptly corrects any non-compliant behaviour that is confirmed to be true. Through the above measures, the Company is committed to creating a corporate culture that is clean, transparent, and fair.
Risk Management & Control
Any non-compliance or unexpected incidents may pose significant risks to the Company, including financial losses and reputational damage. To effectively prevent and respond to potential risks related to production and operations, Griffin has established a systematic risk management framework and response mechanisms. By conducting in-depth identification and comprehensive assessment of various risk sources in our operations, Griffin continuously optimises risk management strategies, improves internal control processes, and promotes a strong risk awareness and sense of responsibility among all employees.
Griffin integrates ESG risk management into its comprehensive risk management system and has developed corresponding control and improvement measures to ensure the efficient implementation of all mechanisms. In identifying major risks, Griffin conducts regular audits to track and supervise the execution of response measures. Issues discovered during audits are continuously revised to effectively prevent the spread and accumulation of major risks.
