Risk Register

风险矩阵

Sub-process 子流 Risk Ref. No.

Policies of Lack
风险 of proper policies CT.C&E.01
控制编号
Construction may lead to disordered
and management.
Engineering

Block for Unplanned increase in CT.C&E.02

registering project's costs,
Duplicate compromising the
projects in the company's Budget
SAP System

Construction Lack of feasibility analysis CT.C&E.03

Planning might lead to poor
decision making
Construction Construction projects CT.C&E.04
Planning without proper approvals
would lead to over-budget

Project's Errors in project decision- CT.C&E.05

approval making, resulting in asset
loss or waste of resources.

Contracts' Projects executed out of CT.C&E.06

technical the specified conditions,
proposals or with quality
review and commitments
approval by
the technical
area

Contracts' Occurrence of urgent CT.C&E.07

measuring investments, not
document budgeted, and executed in
approval FRS unfavourable commercial
conditions
Rolling Losses in company's CT.C&E.08
Forecast production due to loss of
Monitoring eficiency or unplanned
(Special stops of plants and
Engineering machinery
Projects)

Projects' Unplanned increase in CT.C&E.09

Financial project's costs,
Control compromising the
company's Budget

Projects' Purchase orders without CT.C&E.10

Material proper approval would
Purchases lead to over-budget.

Projects' Lack of quality control CT.C&E.11

Quality would lead to engineering
Control quality defect.
Project Lack of security CT.C&E.12
Security supervition would lead to
Control security accident.

Projects' Projects executed not CT.C&E.13

monitoring aligned with planning
effectively and project
quality could not be
guaranteed.

Project Inadequate or lack of CT.C&E.14

completion formal and account
check register of concluded
projects
 Control Regi
控制矩阵

Control Objective
控制目标 the construction
Ensure and
engineering work is under proper
guidence.

Certifique-se de que o trabalho de

construção e engenharia esteja sob
orientação adequada.

Ensure that there will not be duplicate

register of projects in the SAP System

Garantir que não haverá cadastro

duplicado de projetos no Sistema SAP

Ensure that sufficient and appropriate

feasibility analysis is conducted before
project begining

Garantir que uma análise de

viabilidade suficiente e apropriada
seja realizada antes do início do
projeto
Constrction projects should be
approved properly.

Ensure all projects are in accordance

to the approval flow in Governance
book.

Ensure that all the technical suppliers

are technically able to perform the
service or deliver the item

Ensure the correct measurement and

invoicing of the hired services
Ensure that all the projects are in
accordance to the approved budget

Ensure that all the projects are in

accordance to the approved budget

The purchase orders and the quality

of materials are under proper
monitor.

The quality of the construction

materials is under proper and
constant monitor.
The security of the project is
guaranteed by proper controls.

Ensure that the ongoing SIB projects

are in accordance to the initial project
planning

Ensure all projects are appropriately

checked, accepted and activated after
project completion.
 Control Register
控制矩阵

Description of Controls ICFR Control

There
控制描述 are policies in place to regulate the procedures of the construction and engineering N
work, including,
- CMOC Construction&Engineering Audit Management 洛阳钼业工程建设审计管理办法
；
- CMOC Construction Project Management 洛钼集团建设项目管理办法；
- CMOC Construction Project Completion Acceptance 洛钼集团建设工程项目竣工验收
管理办法；
- CMOC Construction Project Design Alteration 洛钼集团建设工程项目设计变更管理办
法；
- CMOC Construction Project Visa Management洛钼集团建设工程项目现场签证管理办
法等。

Existem políticas em vigor para regular os procedimentos das obras de construção e

engenharia, incluindo,
The SAP System isde
- Gerenciamento parameterized to block thee duplicate
auditoria de construção engenhariaregister
CMOCofMedidas
a Projects,
de by not N
allowing the register
gerenciamento of morede
de auditoria than one project
construção with the same
de engenharia identification
de molibdênio code.
Luoyang;
- CMOC Construction Project Management Management Measures for Construction
It is important
Projects to mention
of China Molybdenumthat each
Group;one of the projects has a single identification code,
created
- Medidas based on its PDI.
de Gestão de Aceitação de Conclusão de Projeto de Construção CMOC para
Aceitação de Conclusão de Projetos de Construção do China Molybdenum Group;
O Sistema
- CMOC SAP está
Medidas deparametrizado para bloquear
Gestão de Alteração o cadastro
de Projeto duplicado
de Construção paradeAlteração
um Projeto,
de não
permitindo o cadastrodedeProjeto
Projeto de Alteração mais de
deum projeto com
Construção o mesmo
do Grupo código
China de identificação.
Molybdenum;
- CMOC Construction Project Visa Management, China Molybdenum Group Construction
ÉSite
importante mencionar
Visa Management que cadaetc.
Measures, um dos empreendimentos possui um código de
identificação único, criado com base em seu PDI.
CMOC needs to develop feasibility criteria. All the projects must be assessed according to N
criteria. The engineering department carrys out a full feasibility analysis and publish a
report. The main contents of the report include but are not limited to: project overview,
project background, construction conditions, market forecast, total investment and
funding sources, budgets, economic and social benefit analysis, conclusions and
recommendations, etc.

The feasibility report is prepared by the engineering department and reviewed by the
finance department and the company's management.

A CMOC precisa desenvolver critérios de viabilidade. Todos os projetos devem ser

avaliados de acordo com critérios. O departamento de engenharia realiza uma análise de
viabilidade completa e publica um relatório. Os principais conteúdos do relatório incluem,
mas não estão limitados a: visão geral do projeto, histórico do projeto, condições de
construção, previsão de mercado, investimento total e fontes de financiamento,
orçamentos, análise de benefícios econômicos e sociais, conclusões e recomendações,
etc.

O relatório de viabilidade é elaborado pelo departamento de engenharia e revisado pelo

departamento financeiro e pela administração da empresa.
Proposal review and approval N

After the completion of the project design, the engineering department initiates the
project review process and prepare related supporting documents. The review is
conducted by multi departments, including the engineering department, the request
department, the financial director and othe company's management, etc..

The engineering department initiates the approval process in the OA system, where
clarifies the project name, project dates, stages, the opinion of the project leaders, and
attaches supporting documents, which are reviewed by management (engineering,
finance, request department,GMO, etc.). The project will be proposed to government
after approval.

The project leader fills out the PDI form with all the detailed information from the project. N
The PDI form will be appropriately approved according to the approval matrix in Docu
Sign system. After approval, the project analyst sends the approved PDI form to
accounting analyst requiring the active number of this project. Accounting analyst checks
the information and registers the project in SAP system, creating the active number of this
PDI. Then the active number will be returned to project analyst.

For all technical acquisitions to be made (Material / Services), as part of the quotation N
process, the purchasing team sends all the received technical proposals (without the
commercial info) to the technical departments for evaluation. The technical department
reviews the technical proposals and indicates which of the involved suppliers are able to
perform the service or deliver the item.

The hired services are measured by the respective company, that sends a preview of the N
measuring document to the CMOC's contract user before invoicing. The contract user
analyses the document and creates a FRS in SAP system. The approval of the FRS follows
the approval matrix in the company's policy. After approval, vendor could issue the
invoice.
Monthly the Administrative Engineering team performs a monitoring of the financial N
performance of the ongoing projects, by comparing the approved budget for each one of
the projects to its financial events. In the monitoring, the engineering team considers the
sponsorship changes (budget reallocation between approved projects).

Preparation and approval of project budget Y

The project budget is prepared based on the approved project design proposal. The
budget is sent to investment department for review and then submit it to the engineering
department, finance department, request department for approval.

A laboratory is based on site. It is responsible for testing the quality of materials supplied Y
and its operation is strictly based on ISO standard. Purchase order related controls please
refer to CT.P2P.06.

The engineering department, construction and supervision units jointly carry out quality N
acceptance check for purchased construction materials, and sign on the "Acceptance
Form". If a third-party test is required, the third-party agency will conduct the quality test
and issue the quality report. If the acceptance is unqualified, it will not be accepted.
Safety production inspection N

The engineering department clarifies the management objectives and requirements of

each stage of the project from the safety perspective. The engineering department has
set up a project safety management, who conducts daily inspections of the construction
site and regularly prepares an inspection report.

If hidden dangers of safety accidents are found during the inspection process, the safety
management will report to the project leader in time, and requiring the construction unit
to carry out remediation plan within a time limit. Follow-up remediation shall be reflected
in the inspection report.

N
Every two weeks, the engineering department holds meetings with the project
supervision and construction units and other relevant request departments to discuss the
project progress and main issues , including but not limited to: quality management,
progress management and safety management.

At the same time, the supervision unit prepares and submits a monthly project report to
the engineering department to summarize the project progress and issues identified in
the month, and the follow-up matters.

After the project is completed, in order to proceed with the activation of the project in Y
SAP System, the project manager fills and sends “Activation Dossier” to Accounting
analyst,the dossier contains at least 1) Activation Letter, which is signed by Project
Specialist; 2) Project Charter;3) Composition of Expense; 4) Invoice; 5) Closing terms and
acceptance report, which is signed by Project responsible and Project client/sponsor.
After Accounting analyst receives the checks the Activation Dossier, she activates the
project in the SAP system.
Control Level Control Owner Control Type Control Document Preventive（P）预防性控制/
控制层级 Daisuke
控制活动责任人 Yamaki
- 控制类型
Manual 控制文档 Preventive
Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - Automatic Preventive

Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - Manual Preventive

Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)
Daisuke Yamaki - Manual Preventive
Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - ITDM Preventive Preventive

Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - ITDM Preventive Preventive

Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - Manual Preventive

Project Manager Preventive
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)
Daisuke Yamaki - ITDM Detective Detective
Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - ITDM Detective Detective

Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - Manual Preventive

Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - Manual Detective

Project Manager Detective
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)
Daisuke Yamaki - Manual Preventive
Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - Manual Detective

Project Manager Detective
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)

Daisuke Yamaki - ITDM Preventive Preventive

Project Manager
(Niobium)
Liu Yuanqi -
Project Manager
(Phosphates
Catalao)
 Control Self Assessment Documentation
控制自测

Control Frequency Assessment 自测评估

Per
控制频率event

Application Control

Per event
Per event

Per event

Per event

Per event
Monthly

Monthly

Per event

Weekly
Per event

Weekly

Per event
 Remediation Plans
整改计划
PwC comments

Description of Target Date Responsible

remediation plan if 整改日期 Department/Person