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Dongwu Gold Group Co., Ltd Third-Party Audit based on ISAE 3000 Management report
2021-10-25 14:42:06

Independence and competency statement
In conducting our engagement, we have complied with the applicable requirements of the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants.
In conducting our engagement, we confirm that we satisfy the criteria for assurance providers as set out in out in the Audit Guidance to carry out the assurance engagement.

The assurance scope and level of assurance:
We were engaged by Dongwu Gold Group Co., Ltd to provide reasonable assurance on its Refiner’s Compliance Report for the year ended 31 December 2020.
The assurance scope consists of the Refiner’s Compliance Report.


Summary of assurance procedures:
We planned and performed our work to obtain all the evidence, information and explanations considered necessary in relation to this assurance scope. These procedures included:

  •  Site visits to the refiner
  •  Review of refiner’s gold & silver supply chain policy and internal methodology documents
  •  Consideration of the refiner’s existing internal or external audits, and supply chain Due Diligence initiatives that could be relied upon
  •  Obtain an understanding of the refiner’s operations (including list of all supplier with risk lever and gold & silver received in the reporting period)
  •  Perform a walkthrough of the Refiner Due Diligence process to gain an understanding of implemented controls and procedures
  •  Testing a representative sample of Refiner Precious Metal supplying counterparty Due-Diligence files and transactions to confirm that documentation related to Due Diligence measures in the Precious Metal supply chain is systematically requested, collected and maintained on file in compliance with the LBMA Responsible Sourcing Guidance.
  •  Review of draft Refiner’s Compliance Report
Any significant or inherent limitations or areas not covered:
There was no significant or inherent limitations or areas not covered that were within the assurance scope.



Assurance observations, findings and recommendations for improvement:
No NC was raised during this audit.


Specific observations with respect to the Refiner’s Corrective Action Plan and implementation progress:
The Reasonable Assurance was conducted on April 13 to 14,2021 by Bureau Veritas.


Assurance conclusion
Please refer to the conclusion within the independent assurance report“3.A Independent Reasonable Assurance Report LBMA ISAE 3000_Gold_Dongwu Gold Group Co., Ltd. ”


Countries of Origin Annex for mined and recycled Precious Metal including the amounts (Kgs.) received from each origin
Please, see the attached file [8. Annex Country of Origin Mined and recycled Gold 2020_ Dongwu Gold Group Co., Ltd.]


Other relevant information
In 2020, the refiner continue to implement due diligence system (5 steps) in accordance with the requirements of LBMA RGG (Ver.8).
The following activities were carried out in accordance with updated of RGG requirement (Ver.8):
Step1:Gold policy add “content regarding ESG”.the refiner has conducted training on “ESG” in 2020,the suppliers’ contract included “ESG”.
Step2: "ESG" has been added to high risk criteria, supplier survey and assessment process.
Step3: "ESG" has been added to the risk management strategy. In general: comparison to previous years, there is no major change on the RGG policy, due diligence management system and compliance team.

Remark:
1. Via interview with purchasing manager of gold containing materials and checked procurement account, found that all the four suppliers are located in china, and their materials come from Shanghai, Inner Mongolia and Suzhou.
2. All suppliers has committed to comply with LBMA RGG requirements(including no systematic or widespread human rights violations related to gold mining, transportation or transaction).
3. Supplier survey and assessment process including “no systematic or widespread human rights violations related to gold mining, transportation or transaction.” No forced labour found in 2020.
4. China's ethnic minority policy and its practice including “against any form of ethnic discrimination and oppression” issued in September 1999, the refiner was familiar with and comply with the policy, no forced labour found during this audit.


Signature
Assurance firm: [Bureau Veritas Certification Shanghai Branch]
Date: [April 14,2021]
City, Country: [Suzhou, P.R.China]



The Auditors confirm that:

  • The information provided by the Refiner is true and accurate to the best knowledge of the Auditor(s) preparing this report.
  • The findings are based on verified Objective Evidence relevant to the time period for the assessment, traceable and unambiguous.
  • The Auditor(s) have acted in a manner deemed ethical, truthful, accurate professional, independent and objective.
  • The Auditor(s) are properly qualified to carry out the assessment at this Refiner’s facility.
Lead Auditor: Mr.Chuangen Wang
Signature:
Date: Date: April 14,2021