Sustainability, Environment and Local Community


Safety and occupational health as well as care for the environment are central to Griffin’s values. Griffin endeavours to achieve economic, social and environmental benefits to its stakeholders while establishing environmentally friendly (‘green”) operations and developing a circular and low-carbon economy and striving to realise high-quality sustainable development.



Griffin believes that establishing a strong and trustworthy relationship with its stakeholders is essential to the Group’s sustainable development. Actively understanding and responding to the needs of stakeholders is the cornerstone of Griffin’s sustainable development management. The Company and its subsidiaries regularly communicate with its stakeholders to understand their concerns and act accordingly.



Key Issues


Government and regulatory agencies
  • Compliance with laws, regulations and policies
  • Corporate governance
  • Safety and environmental protection


  • Carry out community projects and cooperation with government agencies (See separate corporate governance report)
  • Daily communication and reporting
Shareholders and investors
  • Sustainable development governance
  • Human rights policy disclosure
  • Anti-corruption


  • Regular reporting
  • Anti-slavery policy, equal opportunities employer
  • Bribery and corruption policy
Employees and their families
  • Salary and benefits
  • Training and development
  • Health and safety
  • Employee performance interviews
  • Staff representative conference
  • Regular safety reporting, safety meetings and safety inductions.


  • Customer service
  • Supply chain management
  • Product quality
  • Dedicated procurement department
  • Independent assay and moisture checks of concentrate sold.



  • Community investment
  • Community benefits
  • Environmental protection and ecology


  • Involvement in local community
  • Local community support, including infrastructure, poverty alleviation, schooling.
  • Care and protection of local environment with minimal discharges.



As a responsible corporate citizen, Griffin not only abides by local regulatory requirements but seeks to apply best worldwide practices regarding the protection of the environment. Hebei Hua Ao strictly abides by the “Environmental Protection Law of the People’s Republic of China, the Environmental Impact Assessment Law of the People’s Republic of China, and the Cleaner Production Promotion Law of the People’s Republic of China” and other relevant laws and regulations. In doing so, Griffin is committed to conserving resources and protecting the environment by reducing the impact on the environment and natural resources. Griffin conducts its operational activities in strict accordance with the requirements of laws and regulations with the establishment of internal environmental monitoring plans, the use of professional testing agencies to strictly monitor air emissions, wastewater, solid waste discharge to enable the timely resolution of any issues that might be encountered.

Griffin continues to improve related management systems and technical standards for energy management, improve resource utilisation rates and maximise the efficiency of resources and energy consumption. Such practices include:

  • Controls to prevent the discharge of waste into the environment;
  • Sewage treatment plants at the mine and camp sites to deal with all effluent produced;
  • All water from the Caijiaying Mine and accommodation site being recycled;
  • Boiler flue gases being treated by a dust and sulphur extraction system to prevent the emission of pollutants into the atmosphere being enhanced with a new 40 tonner low emission boiler being installed;
  • Waste rock and mill tailings being used for backfilling underground stope voids. This minimises the mine footprint by reducing the need for larger tailings and waste storage facilities;
  • Noise, dust and blasting vibration from operations being strictly controlled;
  • Decommissioning and rehabilitation work on Tailings Dams 1 & 2. This work includes battering the waste dump slope, backfilling, topsoil sheeting and planting of vegetation to international standards and in compliance with PRC environmental regulations;
  • Funding the state endorsed China “greening” project including the planting of trees by local villagers in the Caijiaying Mine area;
  • Awarding of state endorsed China “green mine” certification;
  • Approval from the relevant authorities to increase the capacity of the dry tailing’s storage facility without an increase in the footprint of the facility via modern design practices and with a new tailings facility being constructed in 2021. Crucially, these facilities are “dry” compared to those that are “wet” and have failed internationally;
  • Recycling of dry tailings by transportation to a local brickwork for use as base material in brick manufacturing;
  • A dedicated waste collection building to accumulate Caijiaying Mine waste prior to sorting, collection and recycling;
  • The planting of 60 landscape trees outside the main gate and 30,000 elm trees and 3,000m² of grass planting around the Caijiaying Mine as part of local Chinese Environmental Protection Agency greening project;
  • Planting of Mongolian scotch pine trees over an area of 3,869m² to suppress dust and prevent surface degradation. In addition, paving stones have been laid with grass seed to cover an area of 575m² and 743 m² of paving stones without grass seeding;
  • The construction of a new hazardous waste storage facility;
  • Installation of drainage trenches around the ROM pad, waste dump and main access gate area to ensure effective water run-off and protection against soil erosion;
  • Timely renewal of environmental permits including water usage permits, radioactive source safety permits and waste discharge permits;
  • Installation of a Total Suspended Particles online monitoring systems continually monitored by the Municipal Environmental Protection Authority Information Centre;
  • Heavy Metal on-line monitoring equipment replaced by more modern systems and monitored on-line by the Municipal Environmental Protection Authority Information Centre;
  • Installation of additional fencing and dust cannons on the ROM pad to further control dust and any heavy metal emissions;
  • Upgraded dust collection system in the screening house with new dust collectors effectively reducing fine ore loss and dust discharge;
  • The completion and acceptance of 2020 clean production targets with the targeted reduction in heavy metals confirmed;
  • Mist cannon and vacuum trucks for dust suppression;
  • The blending of semi-coke coal with common coal for use in boilers to reduce the discharge of smoke, sulphur dioxide and nitric oxide;
  • Greening of site and camp accommodation areas including vegetable gardens and flower beds; and
  • Ground hardening of main passageways around the Caijiaying surface facilities.



Griffin strictly abides by China’s air emissions standards, and strictly controls air pollutants such as sulphur dioxide and nitrogen oxides generated during mining and processing by installing waste gas treatment devices to ensure that air pollutants emissions meet relevant standards. The smoke and dust generated by heating boilers and hot blast stoves are efficiently treated by a series of desulphurisation and dust removal equipment such as bag filters to ensure that the pollutant emission concentration in the exhausted gas meets the requirements of China’s “Boiler Air Pollutant Emission Standard” (GB13271-2014). The main dust generating areas such as crushing and screening at the mill are equipped with a sealed cover and bag filters with a dust removal efficiency of 98.65%. The resulting emissions meets the requirements of China’s national standard “Pollutant Emission Standard of Lead and Zinc Industry “ (GB25466-2010 ).

In addition, dust removal devices are set up in Hebei Hua Ao’s workshops. Areas affected by uncontained dust emissions are controlled by setting up dust nets, spraying water and regular cleaning. Multiple total suspended particulate matter online monitors have been installed in the mining area to ensure that the total suspended particulate matter and the concentration of unorganised particulate emissions meet the requirements of China’s national standard “Comprehensive Discharge Standard of Air Pollutants” (GB162967-1996).



Waste water is mainly domestic sewage, production waste water and drain water from the mine. After treatment, domestic sewage and plant wastewater can all be reused for production, with the drain water treated on site and then used for mineral separation. In 2020, all production waste water was recycled achieving waste water “zero discharge”.



Non-hazardous waste produced mainly includes waste rock and tailings. All waste rock produced is backfilled to the underground open stopes resulting 100% utilisation of mined waste rock. Part of the tailings generated is used for underground paste fill while the remainder is used for making bricks or stored in the tailings facility. This results in total utilization and safe disposal of all wastes.


Griffin strictly abides by China’s national standard “Hazardous Waste Storage Pollution Control Standard (GB18579-2001)” and has formulated internal documents such as “Hazardous Waste Temporary Storage Management”, “Hazardous Waste Ledger Management” and “Hazardous Waste Incident Report”. All hazardous waste generated is disposed of by a qualified third party. In accordance with the PRC government’s environmental protection requirements, Hebei Hua Ao has installed an online monitoring system for hazardous waste transfer and connected it directly to the National Environmental Protection System to prevent illegal disposal of hazardous waste.



In 2020, Griffin established a taskforce to address complex technological challenges. Led by the Caijiaying General Manager, it is mainly responsible for the coordination of scientific and technological research and innovation. It continues to optimise mining methods to maximise the mineral resource utilisation. Griffin actively promotes digital, modern and intelligent mining by formulating a scientific and technological innovation management reward system and annual incentive plan.

Griffin attaches great importance to energy conservation and emission reduction with a series of positive actions implemented in 2020.

  • Formulated a “Water Conservation Management System” which is strictly implemented and records water consumption in real time. Further employees’ awareness of water conservation is cultivated in daily work and life.
  • Strict adherence to the “Cleaner Production Promotion Law of the People’s Republic of China” and other relevant
  • laws and regulations, actively carrying out cleaner production and setting up a clean production review team. In 2020, Hebei Hua Ao replaced the metal halide lamps in the workshop with LED lamps. After the replacement, the annual power consumption was reduced by 51,480 kWh.
  • An “Energy Conservation and Emission Reduction Work Leading Team” was established to make relevant assessments and promote energy conservation. Griffin established a resource utilisation assessment system, set up energy consumption targets for each workshop and team and incorporated the related KPIs into the annual assessment while encouraging employees to build up a sense of responsibility for energy conservation and environmental protection. All of these measures ensure the success of Griffin’s energy conservation and emission reduction work.



In order to actively respond to environmental emergencies, a “One Plant, One Policy” Implementation Plan for Emergency Response to Heavy Pollution Weather has been formulated and strictly implemented during these events. Environmental risk assessments are regularly undertaken in accordance with relevant Chinese regulations, “Action Plans for Environmental Emergencies”, which are filed with the local Environmental Protection Agency.



Griffin complies with the “Regulations on the Safety Management of Hazardous Chemicals”, “Regulations on the Management of Precursor Chemicals”, “Measures for the Public Security Management of Precursor Explosive Hazardous Chemicals” and other relevant laws and regulations and realises professional management of hazardous chemicals through dedicated storage facilities for hazardous chemicals.



In 2020, Griffin actively enhanced its green mine operation and compiled the “Green Mine Self-Assessment Report” and “Green Mine Building Implementation Plan”. In doing so it successfully passed the national green mine review in China and was listed in the PRC national green mines list.

For the green mine implementation programme, Griffin established a green mine construction team headed by the Caijiaying General Manager. This team ensured that all the tasks were properly and timely completed for green mine certification. Further, Griffin formulated the “Mining Geological Environmental Protection” and assigned specialists to evaluate each key process and point to enhance ecological and environmental governance, train employees to improve the awareness of sustainable utilisation of the mineral resources and apply an effective system to ensure a green mine development.



Hebei Hua Ao commenced the closure and rehabilitation of the Tailings Facilities 1 and 2 in July 2020 and successfully completed this in November, 2020. Both tailing facilities’ closures and rehabilitation included a number of complex works such as a reservoir area treatment, slope greening, and a safety facilities set-up, with a total investment of more than $14.2 million.



Griffin’s environmental best practices have been recognised in the past by Chinese Government authorities with Hebei Hua Ao being presented with the National Environmental Award and the Mine Development Outstanding Achievement Award at successive China Mining Conferences.

In January 2021 the central Chinese MNR published its formal list of mines operating in China which have passed the national level green mine assessment, with the Caijiaying Mine heading the list.


Key Environmental Indicators


Environmental Performance Indicators 2020

  • Nitrogen oxides (tons) 11.00*1
  • Sulphur dioxide (tons) 6.89
  • Smoke and dust (tons) 1.80
  • Wastewater discharge (tons) 0
  • Wastewater discharge intensity (tons/RMB million) 0 *2
  • Hazardous waste safely disposed of (tons) 36.11
  • General solid waste generation (tons) 646,431 *3

*1     Nitrogen oxides, Sulphur dioxide, and smoke mainly emanates from heating boilers.

*2     Hazardous waste is mainly from waste mineral oil, and waste oil drums.

*3     General solid waste is mainly from tailings.


Energy and Resources Consumption

Environmental Performance Indicators 2020

  • Diesel consumption (tons) 293.87
  • Coal consumption (tons of standard coal) 2,818.26
  • Purchased electricity (MWh) 51,658.40
  • Total water consumption (10,000 tons) 40.25



Hebei Hua Ao values its employees by adhering to “Talents are the First Resource” policy. This insists on a people oriented principle and protection of employees’ basic rights and interests as well as mutual development between employees and the Company. This is an important part of Griffin’s overall sustainable development by continuing to optimise employee talents, improve the overall quality of employees and committing to building a professional and ethical team with a high sense of responsibility.



Griffin is an equal opportunities employer and Hebei Hua Ao strictly complies with the Labour Law of the PRC, the Labour Contract Law of the PRC, the Law of the PRC on the Protection of Women’s and Children’s Rights and other relevant laws and regulations. Griffin has established a number of employee management systems and procedures to protect the legitimate rights and interests of employees, including recruitment and dismissal, compensation and promotion, working hours, holidays, equal opportunities, diversification and other employee benefits. Griffin has contracts with employees in accordance with all laws and regulations to ensure that all employees are given equal opportunities for career development and to build a harmonious labour relationship.

Hebei Hua Ao implements an 8-hour working day system in accordance with PRC law and stipulates that the average working hours of employees should not exceed 40 hours per week. Due to the nature of some activities, a special working hours system may be implemented after obtaining approval from the relevant departments.

Griffin offers competitive salary and welfare benefits to its employees according to the nature of the job. An employee whose work exceeds regular working hours will be offered additional compensation or compensatory leave. Hebei Hua Ao implements a system of 20 days of continuous work and 10 days of continuous leave. Hebei Hua Ao reimburses travel expenses between the Caijiaying Mine and the employees home.

Griffin advocates a diverse workforce and does not discriminate on the grounds of gender, age, nationality, race, religious beliefs, and physical condition in either recruitment, training, selection, salary and promotion.

Griffin is against any forms of slavery, forced labour or child labour and will not deal with any party which it believes engages in such practices.



The health and safety of the Group’s employees is of paramount importance. All Group companies abide by the relevant laws and regulations of their country of incorporation and operation, including the Law on the Prevention and Control of Occupational Diseases of the PRC and the Measures for Supervision and Administration of Employer’s Occupational Health Surveillance. In particular, Hebei Hua Ao has established a sound and safe production management system and improved the emergency plans for production safety accidents to reduce the risks of occupational hazards.



Mining is inherently dangerous and without proper safety management and procedures there is a degree of risk of injury, potentially fatal, to anyone in the mine or processing facilities. Griffin is focused on the occupational health and safety awareness of its employees, contractors and all those visiting the Caijiaying Mine and surface facilities. A safe working environment is the top priority. Referring to industry practices and regulatory requirements, Griffin has formulated a comprehensive instruction on health and safety and is committed to building a “dual control” safety management system that is being continually enhanced.

In order to implement the safety management policies and ensure the occupational safety of employees, contractors and those visiting, safety management operational practices include the following:

  • Emergency rescue plan and organised emergency drills and exercises on a regular basis;
  • Regular production safety meetings;
  • Training on safe production to employees, contractors and visitors;
  • Occupational hazards health checks before, during and after work;
  • Regular safety meetings with all contractors;
  • Implementation of and regular upgrading of “Six Systems” including emergency sheltering, monitoring and control, underground personnel positioning, communication, wind pressure self-rescue, and water supply and rescue; and
  • Regular underground drainage system checks to prevent the danger of underground surges.


In 2020, Hebei Hua Ao conducted 3 major safety inspections. A total of 395 hidden risks were identified and 395 were rectified. Relying on a meticulous safety management system, the incident rate of all types of accidents decreased significantly this year. The total frequency of recordable injury accidents per million working hours was 4.5, which was 8.8 lower than the result in 2019.



Griffin strongly values the prevention and control of occupational diseases while constantly upgrading the occupational health protection equipment and facilities to improve the production and working environment of employees. Hebei Hua Ao provides annual occupational health check-ups for employees who are exposed to occupational hazards to ensure their health and safety.



In 2020 Hebei Hua Ao incorporated three contractors into its safety management system and unified management structure. A “Safety Production Management Agreement” and “Safety Liability Letter” was signed with all contractors stipulating that everyone entering the mine site must wear protective equipment while cautiously fulfilling their responsibilities of safe production. In addition, mine safety education and training was provided for new employees of contractors with safety education and training for all contractors once or twice a month to continuously improve contractors’ safety awareness.


Employee Structure of Hebei Hua Ao Mining in 2020

At 31st December 2020, Hebei Hua Ao employed the following personnel:

Category Employee basic information Number of employees Proportion

  • Total number of employees: 438 (100%)
  • New employees joined in 2020: 49 (11.2%)
  • Male: 377 (86.1%)
  • Female: 61 (13.9%)
  • Management Personnel: 23 (5.3%)
  • General Personnel: 415 (94.7%)
  • 30 years of age or under 33 (7.5%)
  • 31 to 50 years of age: 262 (59.8%)
  • Above 50 years of age: 143 (32.7%)



In order to carry out better prevention and control of Covid-19 during the pandemic, Hebei Hua Ao established an epidemic prevention and control group headed by the Caijiaying General Manager and formulated the “Covid-19 Prevention and Control Plan”. This clarified work responsibilities and set out a series of procedures such as personnel screening, site disinfection and other controls. Hebei Hua Ao guaranteed sufficient stocks of hazard prevention materials which enabled operations to continue with minimal disruption. In addition to employee health and safety protections, a special shuttle bus was sent to Wenzhou City in Zhejiang to return employees after the Spring Festival. Hebei Hua Ao maintains active and continual communication with local governments and provides free nucleic acid testing for all employees returning to work.

Wherever possible, Griffin Group employees were encouraged to work from home in compliance with local regulatory requirements.



Griffin values the training and development of all employees. It has formulated scientific promotion channels and flexible employee training systems to support employees’ career development and improve employees’ capabilities. In 2020, Hebei Hua Ao invested RMB 350,000 ($52,000) in employee training. The training coverage rate reached 100%. Training conducted in 2020 included:

  • Management personnel training: 6 management personnel received PRC safety officer training and
  • Certificates;
  • Technician training: 45 technicians received PRC skill training and relevant certificates: and
  • Safety training: Internal safety training was provided to 438 employees.



Suppliers are one of the important cornerstones of our sustainable development. To ensure that supplier activities comply with the requirements of local regulatory authorities and our selection criteria, a mature supplier management system has been established that strictly controls the entire process of supplier access, evaluation and subsequent management.

When establishing procurement contracts for equipment, building materials, steel, chemicals and other products, Griffin sets clear environmental and safety management requirements for suppliers, stipulating that they must strictly comply with national and local environmental and safety laws and regulations in production and operating activities. Product packaging must be solid and clearly marked. The supplied goods must be safe and neatly package and delivered to the designated place safely. In addition, a commitment letter on “Illegal Employment of Employees” from the suppliers is requested, requiring them to strictly comply with the “Constitution of the People’s Republic of China, the Employment Contract Law of the People’s Republic of China, the Law of the People’s Republic of China on the Protection of Minors and the Provisions on Prohibition of Using Child Labour.”

Griffin strictly prohibits the employment of child labour and late salary payment to their employees so as to prevent social and environmental risks within the supply chain.



Quality Control

With strict production management and quality control, every effort is made to ensure the production of high quality zinc and lead concentrates that satisfy customers’ needs. The extraction of all lead from the Zinc concentrate produces a separate lead concentrate containing precious metals and ensures that a highly desirable lead free zinc concentrate is produced.

The following measures are undertaken in the efficient production of good quality concentrate:

  • Strict maintenance plans to ensure that equipment is always in good and reliable condition;
  • Ongoing improvements to the flotation process, including optimisation of system controls, enhancement of process stability resulting in better recovery of lead, zinc, gold and silver;
  • PLC control systems to further ensure the stability of processing operations;
  • Ongoing technical training to employees to improve their capabilities and their ability to deal promptly and safely with all emergencies;
  • Samples taken every two hours during processing to correct variances and ensure the stability of processing; and
  • A combination of internal and external inspections for assay analysis to ensure the accuracy of all assay data.


Protection of Rights and Interests of Customers

Griffin takes a responsible and proactive approach to building long-term, harmonious and stable customer Sustainability, Environment and Local Community relationships and endeavours to resolve all customer claims promptly. In 2020, Hebei Hua Ao did not receive any complaints or have any returns regarding concentrate quality nor did it recall any concentrate sold due to safety or health issues.



Griffin through Hebei Hua Ao has invested heavily in the local community. This includes working with the local community towards eliminating poverty and improving people’s livelihood. Griffin believes that the enterprise and community development are closely related, combining corporate strengths with community needs. Griffin actively carries out community improvements, supports local institutions and provides charitable support where needed. By establishing a “Community Development Plan” and other support, Griffin has formulated community development plans in areas such as poverty alleviation, education, medical care, industrial support, infrastructure construction, disaster relief and traditional culture support. These are considered and implemented as a way to promote harmonious economic and social development and to be an excellent corporate citizen of the PRC.


Poverty Alleviation

In order to assist and implement the decisions and directives of the Chinese government to reduce poverty, and in accordance with the requirements of the Leading Group of Poverty Alleviation in Hebei Province, Griffin has implemented a poverty alleviation plan in conjunction with the local community. This includes pensions and other financial support as well as non-financial donations to local people.



Since the commencement of operations at the Caijiaying Mine, Hebei Hua Ao has been providing financial support to the only elementary school in No.3 Township, Zhangbei County, Zhangjiakou City, Hebei Province. This includes the establishment of the “Hebei Hua Ao Hope Scholarship” to encourage local high school graduates to enter university. The “Huaao Hope Scholarship” was established with an annual investment of Rmb 100,000, and is specifically implemented and managed by the Zhangbei County Hope

Project Leading Group. In 2020, a total of 28 college students were granted this special scholarship, with a total amount of Rmb 73,000.


Community Investment

Community communication is seen as an effective way to build trust with local community people and achieve harmony and co-prosperity between the Company and the community. As well as poverty alleviation and support for local cultural events this has included:

  • The construction and maintenance of a new water bore and water supply;
  • The construction and maintenance of a sealed road from San Hao township to the Caijiaying Mine area;
  • 500 head of cattle to Caijiaying Village to successfully create a dairy and cattle farm.

In 2020, Hebei Hua Ao provided Rmb55,800 for the maintenance of the water pipeline system in Caijiaying Village, No. 3 Township in Zhangbei County, Zhangjiakou City, Hebei Province. Hebei Hua Ao assisted local people in repairing their houses and address any potential impact of blasting vibrations and other disturbances on their properties, with a total investment of more than Rmb12 million. In addition, Hebei Hua Ao provided pension subsidies to 386 elderly people in Xiaobazi Administrative Village in Zhangbei County. The total fund was more than Rmb550,000. 500 head of cattle were paid for and provided to Caijiaying village to successfully create a dairy and cattle farm to ensure a more sustainable annual income less reliant on the seasonality of crops grown in the short summer months.

In 2020, Hebei Hua Ao donated money and Covid-19 relief materials for local epidemic prevention and control. During the outbreak, masks, food, and other epidemic prevention materials were donated to No. 3 Township in Zhangbei County, at a cost of Rmb 33,400. A further Rmb 100,000 was donated to support the recovery from Covid-19.

These actions have won unanimous praise from the local government and residents.

It is estimated that the Caijiaying Mine currently provides direct and indirect employment to over 1,000 Chinese nationals.

During 2020, Hebei Hua Ao paid Rmb 95 million ($14.5 million) (2019: Rmb 116 million) in taxes, royalties, social security fees and other duties to Chinese Governmental authorities and agencies. It is recognised as the largest tax payer in the local Zhangbei County and one of the largest in Zhangjiakou City prefecture.