Base Problem: Forced Labor Risks in China's Aluminum Sector by horizonadvisory

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CCP FORCED LABOR SERIES

Actionable Geopolitical Insight

April 2022

BASE PROBLEM Forced Labor Risks in China’s Aluminum Sector

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Table of CONTENTS

Introduction

Methodology

Aluminum & Xinjiang Industrial Policy

Exposure to Forced Labor

Company Profiles

Conclusion

Disclaimer: The mention of any individual, company, organization, or other entity in this report does not imply the violation of any law or international agreement and should not be construed as such.

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Introduction The Chinese Communist Party (CCP) is conducting a genocide against the Uyghur minority in the Xinjiang Autonomous Uyghur Region (XUAR).1 That genocide builds on a pervasive program of forced and abusive labor in which poor, generally Uyghur and other ethnic minority, workers are taken from their homes; re-educated in Mandarin, CCP ideology, and vocational and military skills; and assigned to work.2 The mobility of laborers is often restricted. Movements and communication are monitored. An extensive data collection infrastructure overseen by state-backed actors undergirds this process, exacerbating its coercive effect on those pulled from their families and forced into roles supporting CCP industrial policy in Xinjiang and beyond. In some cases, forced labor is also a part of larger detention programs. This is increasingly recognized, and increasingly a source of global outcry. What is less recognized is that in a globalized environment, genocide and forced labor in one country taint supply chains globally. The XUAR is a major industrial engine for China. China is a major industrial engine for the world. As a result, global supply chains across key and foundational industries are exposed to forced labor in Xinjiang. Products throughout those supply chains – even if made by recognizable Western brands or finished in trusted US facilities – may be exposed to forced labor in Xinjiang. This reality has been documented in the textiles, agriculture, and even solar energy sectors.3 But the dirty secret is that those sectors are the tip of the iceberg. Over a decade ago, Chinese industrial policy defined Xinjiang as a hub for strategic, heavy industries – the type of foundational production that undergirds most major global supply chains. The XUAR boasts abundant energy reserves that support low energy prices. Xinjiang’s coal reserves account for 40 percent of China’s total, its oil and gas about 20 percent. Far off in Northwestern China, the XUAR also offers an 1

“As Tensions with China Grow, Biden Administration Formalizes Genocide Declaration against Beijing,” Washington Post, March 30, 2021, https://www.washingtonpost.com/national-security/china-genocide-humanrights-report/2021/03/30/b2fa8312-9193-11eb-9af7-fd0822ae4398_story.html; “Dutch Parliament Becomes Second in a Week to Accuse China of Genocide in Xinjiang,” Reuters, February 26, 2021. https://www.cnn.com/2021/02/25/europe/netherlands-china-xinjiang-genocide-intl-hnk/index.html; “Canada’s Parliament Declares China’s Treatment of Uighurs ‘Genocide,’” BBC, February 23, 2021. https://www.bbc.com/news/world-us-canada-56163220; “UK Parliament Declares Genocide in China’s Xinjiang,” Reuters, April 22, 2021. https://www.reuters.com/world/uk/uk-parliament-declares-genocide-chinas-xinjiang-raisespressure-johnson-2021-04-22/ 2 Allegations also indicate that the genocide includes forced sterilization, mass detention, and torture. (See, for example, Gulbahar Haitiwaji, “’Our Souls Are Dead:’ How I Survived a Chinese ‘Re-Education’ Camp for Uighurs,” The Guardian, January 12, 2021.) 3 See, for example: Laura Murphy and Nyrola Elima, “In Broad Daylight: Uyghur Forced Labour and Global Solar Supply Chains,” Sheffield Hallam University Helena Kennedy Centre for International Justice, May 2021, https://www.shu.ac.uk/helena-kennedy-centre-international-justice/research-and-projects/all-projects/in-broaddaylight; Laura Murphy, et al., “Laundering Cotton: How Xinjiang Cotton is Obscured in International Supply Chains,” Sheffield Hallam University Helena Kennedy Centre for International Justice, November 2021, https://www.shu.ac.uk/helena-kennedy-centre-international-justice/research-and-projects/all-projects/launderedcotton.

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ideal destination in which to cordon and ignore environmental degradation: Environmental regulations in Xinjiang are far more relaxed than they are elsewhere in China. In 2010, the Chinese central government implemented “differentiated industrial policies” in Xinjiang that lowered regulatory restrictions on cement, steel, electric power, coal, chemical, and polysilicon industries.4 These features of the XUAR create prime conditions for heavy industry. And regional industrial policy has capitalized on them. For example, the 14th Five Year Plan for the Xinjiang Production and Construction Corps (XPCC) calls for “promoting the healthy development of resource- and labor- intensive industries, including metal smelting and processing, primary aluminum for auto and aerospace applications, and the chemical, petroleum, and natural gas industries.”5 The XPCC is a key state-owned economic and paramilitary organization executing central and provincial industrial policy in the XUAR; it has been sanctioned by the US government for its contributions to the forced labor regime and the broader genocide underway in Xinjiang. The foundational, heavy industries whose development has been encouraged in the XUAR undergird significant amounts of global production. As a result, forced labor in Xinjiang risks infecting global production writ large. The report that follows focuses on one, illustrative case: The primary aluminum industry.6 Aluminum production has been a priority of Xinjiang industrial policy for the past decade. In 2012, the Chinese government announced “differentiated industrial policy” to support the industry’s development in Xinjiang.7 The XPCC’s 14th Five Year Plan outlines intentions to “accelerate the development of primary aluminum” and downstream applications in the automobile, rail, aerospace, new material, solar, and information technology industries.8 The 14th Five Year Plan for the XUAR echoes the point, calling for “the extension of the industry chain for ferrous metals such as aluminum.”9 This emphasis appears to have paid off. China produces approximately 60 percent of the world’s primary aluminum.10 Approximately 17 percent of that Chinese production, or 8 million metric tons annually, comes from Xinjiang – 4

新疆工作会议举行困难地区企业获减税优惠 [Xinjiang Work Conference Held, Enterprises in Difficult Areas Receive Tax Cuts], China News, June 1, 2010. 5 新疆生产建设兵团国民经济和社会发展第十四个五年规划和二 O 三五年远景目标纲要 [The Fourteenth Five-Year Plan for National Economic and Social Development of the Xinjiang Production and Construction Corps], January 8, 2021. And the 14th Five Year Plan for the region prioritizes development of the chemical, textile, non-ferrous, steel, and building materials industries; advanced equipment manufacturing, new energy, new materials (e.g., primary aluminum), hydrogen energy, biomedicine, and new energy vehicles; and apparel, agriculture, and electronic products.(新疆维吾尔自治区国民经济和社会发展第十四个五年规划和 2035 年远景目标纲要 [The Fourteenth Five-Year Plan for the National Economic and Social Development of the Xinjiang Uygur Autonomous Region and the Outline of Long-Term Goals for 2035], Xinjiang Daily, February 5, 2021.) 6 Primary aluminum is aluminum produced directly from mined ore. 7 国家重点支持新疆兵团电解铝等 12 个产业 [The State Focuses on Supporting 12 Industries Including Primary Aluminum in Xinjiang Corps], Shanghai Securities News, June 8, 2012. 8 新疆生产建设兵团国民经济和社会发展第十四个五年规划和二 O 三五年远景目标纲要 [The Fourteenth Five-Year Plan for National Economic and Social Development of the Xinjiang Production and Construction Corps], January 8, 2021. 9 新疆维吾尔自治区国民经济和社会发展第十四个五年规划和 2035 年远景目标纲要 [The Fourteenth FiveYear Plan for the National Economic and Social Development of the Xinjiang Uygur Autonomous Region and the Outline of Long-Term Goals for 2035], February 5, 2021. 10 新疆铝企的崛起 [The Rise of Xinjiang Aluminum Enterprises], China Securities Journal, August 29, 2019; industry statistics.

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making the XUAR the second biggest producer in China, and the most rapidly growing one. If treated as a single company, Xinjiang would rank as the world’s largest aluminum producer.11 Forced Labor Indicator Overview Chart Company Name

Capacity (‘000 tns)

Xinjiang Sixth Division Aluminum

1900

Xinjiang East Hope Nonferrous Metals

1885

Eighth Division of XPCC Tianshan Aluminum Xinjiang Qiya Aluminum & Power

1400

Xinjiang Jiarun Resources Holdings

800

Xinjiang Shenhuo Coal and Electricity

800

Xinjiang Tianlong Mining

250

Xinjiang Zhonghe

180

Transfer of labor

Subordinate to XPCC

"Ethnic Policy" Leader

Coordinating labor transfer subprogram

900

This report finds pervasive exposure to indicators of forced labor across the aluminum industry in Xinjiang. The report finds that every one of the eight major aluminum companies operating in Xinjiang – which boast a combined operating capacity of almost 8 million tons – is associated with government-led transfer of labor programs or related sub-programming in the region. A host of these companies also have ties to the XPCC, which, as noted, is a state-owned economic firm and a paramilitary organization in Xinjiang that the United States government has sanctioned for its role in perpetuating human rights abuses. Moreover, these companies’ operations are reported to feature hazardous conditions and safety accidents that further point to abusive working conditions. Forced labor in the Xinjiang aluminum industry would have implications well beyond those of any industry implicated thus far in the growing attention to human rights atrocities in the region. First, aluminum is a fundamental product used across a wide range of industries. Forced labor at this upstream node would have consequences across, for example, the automotive, aerospace, rail, information technology, electronics, and polysilicon industries. In addition, the aluminum companies operating in Xinjiang, and associated with indicators of forced labor, are in many cases subsidiaries of larger Chinese conglomerates that operate across other foundational industries – and also that maintain operational partnerships with a larger network of major Chinese conglomerates. Findings about forced labor in the Xinjiang aluminum supply chain should prompt

See: https://blog.bizvibe.com/blog/top-10-largest-aluminium-companies.

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a rethinking of the normative consequences of global industrial chains that rely on upstream Chinese production.

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Methodology This report leverages open-source, publicly available Chinese materials – primarily press, corporate, and government documentation – to assess and document indicators of association with forced labor in the Xinjiang-based aluminum industry. The report finds extensive examples. These raise serious concerns about the potential scope of abuses in the industry and global exposure to them through a range of industrial supply chains that rely on Chinese aluminum. The indicators documented in this report are particularly striking, and troubling, because of the intensifying crackdown on information available to the outside world on activities in Xinjiang: As incriminating terms and programs become recognized by the international community as associated with forced labor, references to those in Chinese media, government, and corporate sources dwindle.

Indicators Importantly, the indicators assessed and findings presented in this report are not intended as conclusive evidence of forced labor. The opacity associated with industrial activity in Xinjiang precludes as much. However, these indicators and the methodology used mirror those that have been applied in other supply chains that have been internationally identified as benefitting from forced labor, including those in textiles, agriculture, and polysilicon. These indicators reflect red flags; constellations of data points that, together – and considering the limited amount of information on the region – shift the burden of proof necessary to consider aluminum operations in Xinjiang free of forced labor. The primary such red flags discussed in this report, and the reasons for highlighting them, are summarized below. They include: • • • •

Transfer of labor; Job fairs and vocational education explicitly tied to transfer of labor; Recognition as a XUAR National Unity and Progress Model Group or Individual; and Ties to the Xinjiang Production and Construction Corps (XPCC).

Transfer of Labor Programs: The so-called transfer of labor program in Xinjiang, funded and overseen by the Chinese government, collects local laborers – many of them Uyghurs – relocates them; re-trains them, including with ideological, language, and military education; and assigns them to work. Public documentation suggests that the entities to which these workers are assigned (e.g., companies) generally then implement an additional re-training program that includes military, language, etiquette, ideological, and skills components. This program transfers workers from rural parts of Xinjiang to more industrial sections of the region, as well as to locations across the 5

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country.12 The CCP labels transfer of labor, like many of the human rights abuses underway in Xinjiang, part of a “poverty alleviation” campaign. A range of provincial and local level subsidies encourage companies to participate in the program. 13 A Xinhua News article from July 2019 reported that “from January to June [2019], the total labor force transfer of labor of the entire [Xinjiang] region was 1,756,200 person times,14 achieving over 60 percent of the annual target.”15 A State Council white paper from 2020 calculated that from 2014 to 2019, the average annual transfer of Xinjiang’s “surplus rural labor” was 2.763 million person times, of which 60 percent were from southern Xinjiang. 16 In May 2020, Taiwanese press described the labor transfer program as connected to the CCP’s broader oppression of the Uyghur minority in Xinjiang: The ‘re-education camps’ in Xinjiang, China are accused of being forms of persecution of Muslims. Now, the CCP has extended the re-education camp program to force Uyghurs to work…The CCTV State media reported that in the first four months of 2020, 292,000 people in the four prefectures in Southern Xinjiang where a large number of Uyghurs live participated in organized ‘transfer of labor.’”17 The article specified that “in addition to being forcibly transferred to work in other parts of China, Uyghurs also have to take courses on China and ‘patriotic education.’ Factories send special personnel to monitor the Uyghurs and prohibit them from participating in religious service.”18 The article reported that in addition to various "trainings," the Xinjiang government also implements a

For an English language treatment of the domestic migration of this pool of labor, see Vicky Xu et al., “Uyghurs for Sale,” Australian Strategic Policy Institute, March 1, 2020. Transfer of labor programs are also initiated and implemented outside of Xinjiang. 13 As, for example, outlined in the “Employment and Poverty Alleviation Training Promotion Plan for the Deeply Poor Areas on the Four Prefectures of Southern Xinjiang (2018-2020) [南疆四地州深度贫困地区就业扶贫培训促进计划（2018—2020 年）], issued by the XUAR’s Department of Human Resources and Social Security in June 2018. Coverage of the earlier Interim Measures for the Administration of the Transfer of Surplus Agricultural Labor Forces in the Autonomous Region to Reward and Subsidy Funds specified that the reward and subsidy funds were primarily used to support transport-related expenses. (今年一季度南疆四地州转移就业近 40 万人次 [In the First Quarter of This Year, Nearly 400,000 Instances of People Transferred Labor in the Four Prefectures of Southern Xinjiang], CCTV, June 20, 2016.) 14 “Person times” as a unit refer not to the total number of people transferred, but to the total instances of individuals being transferred. 15 新疆上半年农村富余劳动力转移就业近 176 万人次 [In the First Half of the Year, Xinjiang's Rural Surplus Labor Force Transferred Nearly 1.76 Million Person Times], Xinhua News, July 19, 2019. A December 2018 report form the Xinjiang government website notes that that there were 2.8 million instances of surplus rural laborers in Xinjiang being transferred to work as of November. (前 11 月新疆近 280 万人次农村富余劳动力转移就业 [Nearly 2.8 Million Times Surplus Rural Laborers in Xinjiang Were Transferred to Labor as of November], Xinjiang Government Network, December 27, 2018.) 16 新疆的劳动就业保障白皮书（全文）[Xinjiang Labor and Employment Security White Paper (full text)], CCTV News, September 17, 2020. That white paper also specifies that upon being transferred, laborers rely on their employer for accommodation and daily necessities. 17 新疆 29.2 萬人被迫「轉移就業」學者 : 破壞維吾爾族世代連結 [292,000 People in Xinjiang Are Forced to "Transfer Jobs" Scholars: Destroy the Uyghur Generational Connection], NewTalk, May 21, 2020. 18 Ibid.

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"real-name dynamic management" system for transferred workers that collects and monitors data on them in order to ensure that they stay and integrate locally.19 Transfer of Labor Sub-Programming: Certain other programs associated with transfer of labor also raise red flags. For example, labor transfers are often set up through so-called job fairs, organized by local government entities, generally in conjunction with companies. These job fairs tend explicitly to be labeled as part of the transfer of labor program and to target migrant workers. Vocational education offers another example. This phrase is often used to refer to the re-education programs imposed on conscripted workers. This report only treats programs like job fairs and vocational education as risk indicators if they are directly linked to another major risk indicator (e.g., transfer of labor, recruitment of migrant or ethnic minority workers). Recognition as a National Unity and Progress Model Group or Individual in the XUAR: This recognition, granted by the XUAR, rewards actors that have played a leading role in implementing “the Party’s ethnic policies” in Xinjiang and promoting an “ideological great wall for safeguarding national unity and ethnic unity” in the region.20 The preamble of the government announcement for the 2021 recognition explains: Since the 18th National Congress of the Chinese Communist Party…the Party Committee and People’s Government of the Autonomous Region have united and led the cadres and masses of all ethnic groups in Xinjiang, implemented General Secretary Xi Jinping’s important thinking on strengthening and improving ethnic work… and implementing the Party’s strategies for governance of Xinjiang in the new era – firmly holding on to the general goals of social stability and long-term stability. The Party’s ethnic polices have been fully implemented in the entire region has achieved decisive victory in poverty alleviation, exchanges between ethnic groups have been deepened, the consciousness of the Chinese national community has continued to be firmly established, and the overall social situation has continued to be harmonious and stable…A number of model collectives and individuals for ethnic unity and progress have emerged in all regions and industries, and they have made outstanding contributions to promoting the cause of ethnic unity and progress in Xinjiang in the new era.21 The announcement goes on to note that the purpose of the (dubious) honor is to “encourage Party organizations at all levels and cadres of all ethnic groups in Xinjiang to forge the consciousness of the Chinese nation community and build a strong ideological wall for safeguarding national and ethnic unity.”22 One hundred fifty entities, most of them government or State-owned, and 299 individuals received the recognition in 2021. Those included the aluminum company Xinjiang

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Jiarun, as well as leaders from both Xinjiang East Hope and Xinjiang Zhonghe. 23 The aluminum company Xinjiang Tianlong received the recognition in 2019.24 The Xinjiang Production and Construction Corps (XPCC): The XPCC is a quasigovernmental, quasi-commercial, and quasi-military state-owned entity established in 1954 to assist in pacifying and governing Xinjiang after the CCP’s takeover in 1949. 25 A white paper issued by the State Council Information Office in 2014 explains that The XPCC operates a special administrative system with unified Party, government, military, and enterprise roles. Party organizations have been set up at each level of the Corps to exercise leadership over all its undertakings. The XPCC has administrative and judicial organs to handle its specific administrative and judicial affairs. The Corps is a paramilitary entity with military organs and armed forces units wherein the militias are the mainstay. It is organized in a military structure of corps, divisions, regiments, and companies, whose commanders have corresponding military titles. The XPCC . . . is a large state-owned enterprise engaged in agriculture, industry, transport, building, and commerce, and at the same time assumes state assigned economic tasks. The XPCC’s leadership combines the functions of the Party, government, military, and enterprise.26 The XPCC is a known institutional coordinator of human rights abuses in Xinjiang. A para-military group organized under the Xinjiang Autonomous Region People’s Government,27 the Corps was sanctioned by the US Treasury Department in July 2020 for its role in human rights abuses, including mass arbitrary detention and severe physical abuse of ethnic Uyghur populations in Xinjiang. 28 This report treats close ties with XPCC as a red flag. As of 2013, the Corps was responsible for administering 176 “regiments” covering more than 70,000 km of territory and nearly three million people. 29 Chinese authorities have assigned primary responsibility for implementing Xinjiang development plans to the XPCC. The organization oversees the “regiments” or “divisions” where most of Xinjiang’s new aluminum smelters have been built.30 23

Ibid. 新投集团天龙矿业荣获“全国民族团结进步模范集体”称号 [Xintou Group Tianlong Mining was awarded the title of "National Model Group of National Unity and Progress"], Xinjiang SASAC, October 21, 2019 25 Information Office of the State Council, The History and Development of the Xinjiang Production and Construction Corps (Oct. 5, 2014). 24

Ibid.

The XPCC website explains that it “undertakes the responsibilities of cultivating and defending border areas of the State…it implements a system of integration of party, government, military, and enterprise in its jurisdiction…It is under the dual leadership of the Central Government and the XUAR...The Corps is a ‘paramilitary entity’ with military agencies and armed organizations.” (Xinjiang Production and Construction Corps, http://www.xjbt.gov.cn/). 28 “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order,” US Treasury Department, July 31, 2020, https://home.treasury.gov/news/press-releases/sm1073. 29 Information Office of the State Council, The History and Development of the Xinjiang Production and Construction Corps (Oct. 5, 2014). 30

There is reason to believe that all of the major new aluminum projects since the Central Work Conference on Xinjiang are located in areas under XPCC jurisdiction, but no definitive delineation of the precise borders of the XPCC’s territory has been confirmed.

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Aluminum and Industrial Policy

Xinjiang

“Over the past ten years,” explained Sina Finance in 2020, “under the guidance of national policies, the primary aluminum industry in Xinjiang has undergone earth-shaking changes from small to large, weak to strong.” 31 In 2010, the XUAR accounted for four percent of China’s national primary aluminum operating capacity. Ten years later, Xinjiang’s operating capacity had grown 84-fold to reach approximately 8 million tons annually, or 17 percent of China’s total. This makes Xinjiang China’s second largest primary producer after Shandong Province (23 percent). 32 Aluminum is a core priority of both XPCC and larger XUAR industrial planning.33 Eight companies lead the aluminum industry in Xinjiang (see table). Together, they boast a combined production capacity of 8 million tons. Some of these companies are State-owned, others private. Six have been established since 2009. All six of those describe themselves as having launched their operations in Xinjiang in response to the “Western Development Call” and/or as a Xinjiang-aid enterprise. This report finds that every one of them is exposed to indicators associated with forced labor in Xinjiang. Xinjiang’s Major Aluminum Companies34 Company Name

Date Estd.

Xinjiang Sixth Division Aluminum Co., Ltd. Xinjiang East Hope Nonferrous Metals Co., Ltd. The Eighth Division of Xinjiang Production and Construction Corps Tianshan Aluminum Co., Ltd. Xinjiang Qiya Aluminum & Power Co., Ltd. Xinjiang Shenhuo Coal and Electricity Co., Ltd. Xinjiang Jiarun Resources Holdings Co., Ltd.

2009 2010 2010

Capacity (1,000 tons) 1900 1885 1400

2010 2010 2011

900 800 800

新疆电解铝产能的天花板已然形成中国铝产业“龙头”显现 [The Ceiling of Xinjiang's Primary Aluminum Production Capacity Has Already Taken Shape], Sina Finance, October 27, 2020. 32 Ibid 33 新疆维吾尔自治区国民经济和社会发展第十四个五年规划和 2035 年远景目标纲要 [The Fourteenth FiveYear Plan for the National Economic and Social Development of the Xinjiang Uygur Autonomous Region and the Outline of Long-Term Goals for 2035], February 5, 2021; 新疆维吾尔自治区国民经济和社会发展第十四个五年规划和 2035 年远景目标纲要 [The Fourteenth Five-Year Plan for the National Economic and Social Development of the Xinjiang Uygur Autonomous Region and the Outline of Long-Term Goals for 2035], February 5, 2021. 34 新疆电解铝产能的天花板已然形成中国铝产业“龙头”显现 [The Ceiling of Xinjiang's Primary Aluminum Production Capacity Has Already Taken Shape], Sina Finance, October 27, 2020; industry statistics.

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Xinjiang Tianlong Mining Co., Ltd. Xinjiang Zhonghe Co., Ltd.

1998 1996

250 180

The explosion in Xinjiang’s primary aluminum industry stems in large part from Chinese industrial policy and preferential measures in the region, including low-cost provision of electricity. In 2012, the Chinese government announced differentiated industrial policies in twelve key industries in Xinjiang, including aluminum.” 35 Those policies supported the development of production capacity in the region and encouraged integrated industry chains. They also hinged on low-cost electricity in the region, a function of government subsidies, lax environmental regulation, and an abundance of coal.36 That latter point is critical. The XUAR lacks the basic inputs, like bauxite, from which aluminum is produced. But that logistical disadvantage can be offset by cheap electricity: As Sina Finance explains, “electricity cost is the biggest cost differential for primary aluminum production,” accounting for 40 percent of production costs. “And Xinjiang’s primary aluminum cost control is in a leading position.” 37 Or, per China Securities Journal, “in the last round of the aluminum industry investment boom, Xinjiang and Inner Mongolia attracted a large number of new primary aluminum production capacity. Xinjiang and Inner Mongolia, and other places are neither the main source of raw materials for primary aluminum nor the main sales areas of products…The factors that attracted [companies] to take root were low electricity prices.” 38 2013 coverage of the differentiated industrial policies in Xinjiang reported, succinctly, that “industry insiders analyze that with industrial policy support and low electricity prices, capital will naturally pursue the primary aluminum industry.”39 The local industrial policy supporting the aluminum industry in the XUAR takes advantage of the region’s energy advantages by encouraging integrated production sites. All Xinjiang aluminum enterprises boast integrated coal, electricity, and aluminum facilities, including their own power plants or microgrids. And they tend to be based in close proximity to coal mines. For example, a number of the leading aluminum companies in Xinjiang are based in the Wucaiwan Zhundong Industrial Park, which is in the mining area of Xinjiang’s Zhundong Coalfield.40 35

国家重点支持新疆兵团电解铝等 12 个产业 [The State Focuses on Supporting 12 Industries Including Primary Aluminum in Xinjiang Corps], Shanghai Securities News, June 8, 2012. 36 新疆兵团民间投资 11 亿电解铝获热捧 [Xinjiang Corps Private Investment 1.1 Billion Primary Aluminum Is Popular], World Aluminum Net, April 17, 2013. 37 新疆电解铝产能的天花板已然形成中国铝产业“龙头”显现 [The Ceiling of Xinjiang's Primary Aluminum Production Capacity Has Already Taken Shape], Sina Finance, October 27, 2020. In 2020, the Xinjiang Development and Reform Commission issued a notice stipulating that electricity prices for primary aluminum production enterprises would remain constant at their government-backed level. (新疆发改委：这 10 家钢厂用电不加价 [Xinjiang Development and Reform Commission: These 10 Steel Mills Do Not Increase Electricity Prices], XUAR Development and Reform Commission, September 17, 2020.) 38 新疆铝企的崛起 [The Rise of Xinjiang Aluminum Enterprises], China Securities Journal, August 29, 2019. 39 新疆兵团民间投资 11 亿电解铝获热捧 [Xinjiang Corps Private Investment 1.1 Billion Primary Aluminum Is Popular], World Aluminum Net, April 17, 2013. 40 新疆铝企的崛起 [The Rise of Xinjiang Aluminum Enterprises], China Securities Journal, August 29, 2019.

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Exposure to Forced Labor Before even diving into the operations of specific aluminum companies in Xinjiang, the high-level layout of the industry in the region suggests systemic risks. First among those is the emphasis that the XPCC places on the aluminum industry. The XPCC is a designated human rights abuser. The US Treasury Department sanctioned it in July 2020 for its role in human rights abuses, including mass arbitrary detention and severe physical abuse of ethnic Uyghur populations in Xinjiang.41 And the XPCC has actively supported the development of the aluminum industry in Xinjiang for over a decade. When the Chinese government announced differentiated industrial policies for aluminum production in Xinjiang, the aluminum industry was described as an “industry in the XPCC.” 42 In the first quarter of 2013, the XPCC invested 1.1 billion RMB in aluminum. 43 Moreover, two of the largest aluminum companies in the XUAR are considered affiliated to the XPCC. Second, a host of the major aluminum companies in Xinjiang operate in industry parks that themselves are associated with forced labor risks. Three of the companies – Xinjiang East Hope Nonferrous Metals (Xinjiang East Hope), Xinjiang Qiya Aluminum & Power (Xinjiang Qiya), and Xinjiang Shenhuo Coal and Electricity (Xinjiang Qiya) – as well as a subsidiary of Xinjiang Sixth Division Aluminum (Xinjiang Sixth) are based in the Zhundong Economic and Technological Development Zone, an industry park that appears to play an organizational role in Xinjiang transfer of labor programs. In 2021, the Zhundong Zone was recognized by the XUAR government for its contributions to Beijing’s “ethnic policies” in the region.44 A September 2018 report indicated that “320 southern Xinjiang surplus laborers are employed in the Zhundong Economic and Technological Development Zone.” 45 In March 2020, the Secretary of the Party Working Committee of the Zhundong Zone visited Xinjiang East Hope to “investigate that company’s work in the transfer of labor in southern Xinjiang.”46 Closer investigation of the eight major companies’ operations suggest that these systemic red flags are just the beginning.

“Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order,” US Treasury Department, July 31, 2020, https://home.treasury.gov/news/press-releases/sm1073. 42 国家重点支持新疆兵团电解铝等 12 个产业 [The State Focuses on Supporting 12 Industries Including Primary Aluminum in Xinjiang Corps], Shanghai Securities News, June 8, 2012. 43 新疆兵团民间投资 11 亿电解铝获热捧 [Xinjiang Corps Private Investment of 1.1 Billion in Primary Aluminum Is Popular], World Aluminum Net, April 17, 2013. 44 关于表彰自治区第八次民族团结进步模范集体和模范个人的决定 [Decision on Commending the Eight Exemplary Groups and Individuals in the Autonomous Region for National Unity and Progress], Xinjiang Daily, September 15, 2021. 45 320 名南疆富余劳动力在准东经济技术开发区快乐就业 [320 Surplus Labor Force in Southern Zhundong Happy Source of Employment in the Economic and Technological Development Zone], Xinjiang Economic News, September 12, 2018. 46 新疆准东经济技术开发区党工委书记李绍海一行调研东方希望准东板块 [Li Shaohai, Secretary of the Party Working Committee of Xinjiang Zhundong Economic and Technological Development Zone, and his party investigated the Eastern Hope Zhundong Section], East Hope, March 31, 2020.

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Company Profiles Xinjiang Sixth Division Aluminum Co., Ltd. (Xinfa Group) Xinjiang Sixth Division Aluminum Co., Ltd (Xinjiang Sixth) is a subsidiary of the Shandongbased Xinfa Group, one of China’s biggest integrated aluminum companies. With 1.9 million tons of capacity, Xinjiang Sixth is the largest of the aluminum companies in Xinjiang. As of 2019, it also boasted the world’s largest primary aluminum workshop.47 The company has close ties to the XPCC, a key institutional player in human rights abuses in Xinjiang, and participates in transfer of labor programs in Xinjiang. Xinjiang Sixth was established in 2009 in the East Industrial Park of Wujiaqu City, in the northern part of the XUAR. The company exists as part of a larger “Xinfa Group Xinjiang Company,” composed of not only Xinjiang Sixth, but also Xinjiang Sixth Division Coal and Electricity and Xinjiang Sixth Division Carbon.48 Together, those form an integrated power generation, aluminum, and carbon project.49 Xinjiang Sixth has four Xinjiang-based subsidiaries: Two in the East Industrial Park, focused on non-ferrous metals and primary aluminum research; a coal mining company located in the Zhundong Economic and Technological Development Zone; and a software and information technology company in Wujiaqu City, registered to the Sixth Division of the XPCC. Xinjiang Sixth itself is also – as its name suggests – registered to the Sixth Division of the XPCC. As one media treatment explains the relationship, Xinjiang Sixth is “an industrialized benchmark enterprise created by the Xinjiang Production and Construction Corps.” 50 Xinjiang Sixth was established through a 2009 company-government-corps cooperation agreement among Xinfa Group, Wujiaqu City in Xinjiang, and the Sixth Agricultural Division of XPCC. XPCC commander Hu Shifei described the moment as an “extremely important foreign cooperation in 47

"山东产业援疆这些年丨信发集团新疆公司：战天斗地闯大漠行业“领头雁”是这样炼成的 [Shandong Industry Aid Xinjiang in the Past Years 丨 Xinfa Group Xinjiang Branch: This Is How the “Leading Goose” of the Industry Was Made]," Peninsula, October 26, 2019. 48 信发集团新疆公司新疆农六师煤电有限公司 [Xinfa Group Xinjiang Company Xinjiang Agricultural Sixth Division Coal Power Co., Ltd.], University Talent Network, March 19, 2020. 49 信发集团新疆公司新疆农六师煤电有限公司 [Xinfa Group Xinjiang Company Xinjiang Agricultural Sixth Division Coal Power Co., Ltd.], University Talent Network, March 19, 2020. 50 "山东产业援疆这些年丨信发集团新疆公司：战天斗地闯大漠行业“领头雁”是这样炼成的 [Shandong Industry Aid Xinjiang in the Past Years 丨 Xinfa Group Xinjiang Branch: This Is How the “Leading Goose” of the Industry Was Made]," Peninsula, October 26, 2019.

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the history of the XPCC…All relevant departments of the XPCC should go all out to help the Sixth Agricultural Division and Shandong Xinfa Group coordinate and solve problems in the project construction and provide the best guarantee for the smooth implementation of the project.”51 A 2019 profile of Xinjiang Sixth describes the company’s formation as a “response to the national western development call for Xinjiang construction.”52 And in 2021, the Corps Daily reported that “two aluminum companies of the Corps” – namely Xinjiang Sixth and Xinjiang Tianshan, discussed later in this report – “were selected into the national list of companies that meet industry standards.”53 As noted earlier, XPCC was sanctioned by the US Treasury Department in July 2020 for its role in human rights abuses, including mass arbitrary detention and severe physical abuse of ethnic Uyghur populations in Xinjiang.54 The relationship between Xinjiang Sixth and XPCC is evident in exchanges between the two parties. For example, in June 2017, the Political Commissar of the Sixth Agricultural Division of XPCC led a delegation to Shandong Xinfa Group “for an inspection.”55 Media coverage of the visit noted that “Xinfa Group has made positive contributions to the development of new industrialization of the Corps.”56 During the visit, Xinfa and the XPCC agreed to “continue to broaden the areas of cooperation between the two parties.”57 More recently, in May 2021, the Secretary of the Party Committee of the XPCC and Deputy Secretary of the Party Committee of XUAR visited the Xinjiang Sixth aluminum workshop.58 During that visit, he stressed that “all departments and units of the XPCC [must] focus on the responsibilities and missions of the XPCC, and thoroughly implement the new development concept” to “ensure the harmony and stability of the XPCC’s jurisdiction and maintain the overall stability of Xinjiang’s society.”59 Xinjiang Sixth appears to participate in transfer of labor programs. In June 2020, the company announced, through the labor transfer guidance station of Wugongtai Town, in Xinjiang, that it was looking for 400 workers aged 18-45 and in good health for three months of work.60 Moreover,

5 月 11 日,新疆兵团农六师、五家渠市与山东信发集团项目建设合作协议签订仪式在乌鲁木⻬举行 [On May 11, the Signing Ceremony of the Project Construction Cooperation Agreement Between the Sixth Agricultural Division of Xinjiang Corps], Agricultural Machinery Network, May 13, 2019. 52 "山东产业援疆这些年丨信发集团新疆公司：战天斗地闯大漠行业“领头雁”是这样炼成的 [Shandong Industry Aid Xinjiang in the Past Years 丨 Xinfa Group Xinjiang Branch: This Is How the “Leading Goose” of the Industry Was Made]," Peninsula, October 26, 2019. 53 兵团两铝企入选全国符合行业规范企业名单 [Two Aluminum Companies of the Corps Were Selected into the National List of Companies that Meet Industry Standards], Corps Daily, January 21, 2021. 54 “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order,” US Treasury Department, July 31, 2020, https://home.treasury.gov/news/press-releases/sm1073. 55 农六师五家渠市党政代表团赴信发集团考察 [The Wujiaqu City Party and Government Delegation from the Sixth Agricultural Division visited Xinfa Group], alu.cn, June 2, 2017. 56 Ibid. 57 Ibid. 58 廷君正到六师五家渠市检查 [Wang Junzheng Went to Wujiaqu City of the Sixth Division to Inspect], Corps Daily, May 4, 2021. 59 Ibid. 60 五工台镇就业转移指导站信息发布 [Information Release of Employment Transfer Guidance Station in Wugongtai Town], Sohu News, June 26, 2020. Other companies also declaring labor needs in that announcement

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Xinjiang Sixth’s sibling company, Xinjiang Agricultural Sixth Division Carbon, reports active participation in the XUAR government’s social programs, including by “support[ing] and participate[ing] in targeted poverty alleviation” by “provid[ing] skills training, and implement[ing] employment assistance” for those who are “able to work.” In 2018, the company reported that as a result of these efforts, it had “set an example of poverty alleviation in the Corps and won the commendation of the Corps.”61 Informal Chinese message boards describe Xinjiang Xinfa as a “killing enterprise.”62 One post from 2013 describes false claims with respect to salaries.63 Another from 2015 echoes the point, reporting that in many cases no labor contracts were signed with employees – and that, when they were, they had no bearing on the work reality. That post also claims that workers consistently worked overtime without compensation and experienced dangerous levels of toxins in the workplace.64 A similar post from the same year notes that “Xinjiang Xinfa Aluminum Co., Ltd blatantly violated the labor contract.”65 Another post from 2018 described “high temperatures and toxic radiation…Also unpaid overtime without compensation.” 66 Documentation of legal complaints bear out these descriptions, outlining severe health consequences from exposure to toxins and high temperatures in the workplace. 67

included Xinjiang Weimei Cotton Home Textile, Xinjiang Huasheng New Energy Technology, and Hutubu Tongyi Tomato Sauce Factory. (Ibid) 61 新疆农六师碳素有限公司 2018 年履行社会责任报告 [Xinjiang Agricultural Sixth Division Carbon Co., Ltd. Performance of Social Responsibility Report in 2018], March 27, 2019. 62 新疆信发六师铝业是重污杀企业，与职工签的劳动合同跟实际不符;而且我们手中也无合同;经常性加班 [Xinjiang Xinfa Sixth Division Aluminum Industry Is a Heavy Pollution and Killing Enterprise], Baidu Knows, March 23, 2015. 63 [电解工]骗子 [Electrolyzer Liar], job592.com, February 27, 2013. 64 新疆信发六师铝业是重污杀企业，与职工签的劳动合同跟实际不符;而且我们手中也无合同;经常性加班 [Xinjiang Xinfa Sixth Division Aluminum Industry Is a Heavy Pollution and Killing Enterprise], Baidu Knows, March 23, 2015. 65 新疆信发铝业公然违被劳动合同让工人加班加点五个月内电解工没休班怨声载道望能于重视 [Xinjiang Xinfa Aluminum Co., Ltd. Blatantly Violated the Labor Contract and Asked Workers to Work Overtime within Five Months], Baidu Knows, February 2, 2015. 66 信发裁员我说两句 [Xinfa Layoffs, Let Me Say a Few Words], Baidu Tieba, July 15, 2018. 67 新疆农六师铝业有限公司与新疆生产建设兵团农六师劳动和社会保障局、剡六斤其他二审行政判决书 [Xinjiang Agricultural Sixth Division Aluminum Industry Co., Ltd. and Xinjiang Production and Construction Corps Agricultural Sixth Division Labor and Social Security Bureau, Yan Liujin and other second-instance administrative judgments], The Intermediate People's Court of the Sixth Division of the XPCC, August 10, 2017.

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Xinjiang East Hope Nonferrous Metals Co., Ltd. Xinjiang East Hope Nonferrous Metals (Xinjiang East Hope) is a subsidiary of East Hope Group, a Shanghai-headquartered manufacturing giant with operations in not only aluminum, but also agriculture, silicon, chemicals, energy, and real estate. As of 2018, the East Hope Group was “the largest so-called “Xinjiang-aid enterprise” in Shanghai’s Pudong Area.68 In June 2021, the US Department of Commerce placed Xinjiang East Hope on the Entity List for “participating in the practice of, accepting, or utilizing forced labor.” 69 That decision likely stemmed from attention to East Hope’s operations in the polysilicon industry in Xinjiang. But the company is also the XUAR’s second largest aluminum company, with a production capacity of almost 1.9 million tons annually. And as this section will show, East Hope not only directly engages in transfer of labor – and corresponding re-education programming – for its aluminum operation, but also helps to develop the institutions undergirding labor transfer in Xinjiang. Established in 2010, Xinjiang East Hope describes itself as having “responded to the national Western Development Call and actively participated in the development and construction of Xinjiang.”70 The company is based in the Wucainan Industrial Park of Zhundong Economic and Technological Development Zone. Xinjiang East Hope has three Xinjiang-based subsidiaries, all of them also based in the Zhundong Zone: Xinjiang Hantai Energy, focused on coal sales, transportation, storage, and investment; Yongtai Metallurgical Manufacturing, engaged in nonferrous metal casting production and relevant research; and Xinjiang Tianlong Hope Energy, a State-controlled coal mining and washing company whose other shareholders include China Shenhua Energy Corporation and Xinjiang Energy (Group) Co. The East Hope Group partners with the Zhundong Economic and Technological Development Zone – where Xinjiang East Hope and its subsidiaries are located – in developing institutions that undergird transfer of labor and corresponding re-education programs. Shanghai East Hope, an East Hope subsidiary, holds a ten percent stake in the Wucai Vocational Training School Co., Ltd in Zhundong Economic and Technological Development Zone. That school trains poor laborers as part of transfer of labor programming.71 The largest shareholder of the school is the government entity that owns the Zhundong Zone. Xinjiang Qiya Aluminum and Power, discussed later in this report, also holds a ten percent stake.

东方希望集团为民族团结贡献正能量 [East Hope Group Contributes Positive Energy to National Unity], Pudong Government Affairs, May 22, 2018. 69 https://www.federalregister.gov/documents/2021/06/24/2021-13395/addition-of-certain-entities-to-the-entity-list 70 东方希望 [East Hope], Recruitment WeChat Public Account. 71 助力脱贫攻坚，服务社会发展--学院 42 名学生赴准东开发区开展教学实习 [Help Alleviate Poverty and Serve Social Development: 42 Students from the College Went to Zhundong Development Zone for Teaching Practice], Changji College, July 14, 2020.

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Broadly speaking, so-called “vocational training” institutions can be associated with risks of forced labor in Xinjiang. And the Zhundong Economic and Technological Development Zone is associated with a host of risk indicators. Further exacerbating the case, Chinese coverage of the Wucai Vocational Training School associates it with transfer of labor, surplus labor absorption, and re-education of migrant and poor workers. For example, a 2020 press release form Changji University described a program in which the college coordinated with the Zhundong Development Zone and the Wucai Vocational School to send its students to “assist the national language training for transferred employees…so as to achieve poverty alleviation” and, at a larger level, to “establish a national common language training group” that would standardize the training systems for enterprises across the Zone.72 Further supporting this indication that Xinjiang East Hope plays an institutional role in labor abuses, in 2021 the XUAR recognized the Director of Human Resources of Xinjiang East Hope, Xie Hua, as a “national unity and progress model individual” of the region.73 That recognition rewards leaders in implementing “the Party’s ethnic policies” and promoting an “ideological great wall for safeguarding national unity and ethnic unity” in Xinjiang.74 150 entities, most of them government or State-owned, and 299 individuals received the (dubious) honor. Those included Xinjiang Jiarun, discussed later in this report, as well as the Zhundong Zone itself.75 Xinjiang East Hope also absorbs workers through transfer of labor programs. In 2016, the People’s Government of Shache County, XUAR signed a “labor export cooperation framework agreement” with Xinjiang East Hope.76 A 2017 piece on the labor transfer work of Laotai Township, Jimsar County, Xinjiang reported that, "focusing on Zhundong Wucai Bay, Beiting Industrial Park, and new energy companies, the township continued to accelerate the pace of labor transfer and…organized connections between more than 240 people and East Hope, as well as Shendong Tianlong, Tianyu Huaxin, and other companies.” 77 Press coverage the next year documented Xinjiang East Hope “absorb[ing] five Uyghur youths.”78 According to that article, “this is the second time that Xinjiang East Hope has absorbed surplus labor from southern Xinjiang and transferred labor. Up to now, East Hope Xinjiang Aluminum has absorbed and employed 21 Uyghur youths.” 79 This participation in transfer of labor programming pertains directly to aluminum production: A 2018 article in Xinjiang Economic News describes a laborer, with a Uyghur name, who came “to Zhundong Economic and Technological Development Zone with the 72

Ibid. 关于表彰自治区第八次民族团结进步模范集体和模范个人的决定 [Decision on Commending the Eight Exemplary Groups and Individuals in the Autonomous Region for National Unity and Progress], Xinjiang Daily, September 15, 2021. 74 Ibid. 75 Ibid. 76 东方希望集团新疆铝业公司在莎车县召开专场招聘会 [East Hope Group Xinjiang Aluminum Company Held a Special Job Fair in Shache County], September 5, 2016. 77 新疆吉木萨尔县老台乡劳动力转移工作显成效 [The Labor Transfer Work in Laotai Township, Jimsar County, Xinjiang Has Achieved Results], Asia Heart Network, October 27, 2017. 78 东方希望集团为民族团结贡献正能量 [East Hope Group Contributes Positive Energy to National Unity], Pudong Government Affairs, May 22, 2018. 79 Ibid. 73

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labor transfer personnel from southern Xinjiang…and was assigned to work in East Hope’s aluminum workshop.”80 As is the norm, Xinjiang East Hope re-educates its transferred laborers. Media coverage from March 2020 noted that “recently,” Xinjiang East Hope had “accepted 235 ethnic minority employees from southern Xinjiang. In response to their generally low academic qualifications, weak national language skills, and insufficient skills, the company opened Mandarin training classes and job safety training.” 81 That article describes the site at which the training was implemented as the “training site of ‘southern transfer personnel’ [南转人员].’” 82 First-hand accounts of the genocide in Xinjiang consistently describe “re-education” programs of abusive language and ideological training designed to break targets’ spirits and ability independently to think.83 The 2018 article also reported that: On March 30, Li Shaohai, Secretary of the Party Working Committee of Zhundong Economic and Technological Development Zone of Xinjiang Uygur Autonomous Region, and his entourage came to Xinjiang East Hope Nonferrous Metals Co., Ltd. to investigate the company's work in the transfer of labor in southern Xinjiang and requested that the company continue to actively respond to the central government’s call for poverty alleviation, implement Xinjiang’s poverty alleviation decision-making and deployment, continue to pay close attention to the epidemic prevention and control measures, stabilize work and resume production, and contribute more to the full fight against poverty as scheduled.84 The East Hope Group also appears to have a relationship with the XPCC. In 2019, a delegation from the 13th Division of the XPCC visited East Hope (Sanmenxia) Aluminum, a Henan-based subsidiary, for what press coverage described as “inspection and exchange.” 85 The delegation included the head of the United Front Work Department of the 13th Division. During the visit, East Hope and XPCC leadership discussed the aluminum industry chain – as well as “the [East Hope] group’s future industrial layout in Xinjiang and cooperation with the XPCC.” 86 As previously noted, XPCC was sanctioned by the US Treasury Department in July 2020 for its role in human 80

320 名南疆富余劳动力在准东经济技术开发区快乐就业 [320 Southern Xinjiang Surplus Laborers Are Happily Employed in Zhundong Economic and Technological Development Zone], Xinjiang Economic News, September 12, 2018. 81 新疆准东经济技术开发区党工委书记李绍海一行调研东方希望准东板块 [Li Shaohai, Secretary of the Party Working Committee of Xinjiang Zhundong Economic and Technological Development Zone, and His Party Investigated the Eastern Hope Zhundong Section], East Hope, March 31, 2020. 82 Ibid. 83 See, for example, Gulbahar Haitiwaji, “’Our Souls Are Dead:’ How I Survived a Chinese ‘Re-Education’ Camp for Uighurs,” The Guardian, January 12, 2021. 84 新疆准东经济技术开发区党工委书记李绍海一行调研东方希望准东板块 [Li Shaohai, Secretary of the Party Working Committee of Xinjiang Zhundong Economic and Technological Development Zone, and His Party Investigated the Eastern Hope Zhundong Section], East Hope, March 31, 2020. 85 新疆生产建设兵团十三师考察东方希望渑池铝业 [The 13th Division of Xinjiang Production and Construction Corps Inspected East Hope Mianchi Aluminum], Sohu News, July 11, 2019. 86 Ibid.

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rights abuses, including mass arbitrary detention and severe physical abuse of ethnic Uyghur populations in Xinjiang.87 In addition, discussion on informal Chinese message boards suggests hazardous and unsafe work conditions at Xinjiang East Hope. For example, a 2016 post aired a complaint about East Hope’s Xinjiang operation failing to pay migrant workers. 88 In a 2017 post, a former worker at the company explained that his arm was caught in an air duct at the factory while working there.89

“Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order,” US Treasury Department, July 31, 2020, https://home.treasury.gov/news/press-releases/sm1073. 88 外包劳务拖欠农民工工资怎么办 [What to Do If Xinjiang East Hope Owes Wages to Migrant Workers?], Baidu Knows, July 19, 2016. 89 新疆东方希望铝厂上班 [Xinjiang East Hope Aluminum Factory Goes to Work], June 23, 2017.

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The Eighth Division of Xinjiang Production and Construction Corps Tianshan Aluminum Co., Ltd. The Eighth Division of Xinjiang Production and Construction Corps Tianshan Aluminum (Xinjiang Tianshan) is a subsidiary of Tianshan Aluminum Group, a market listed, but Stateinvested, Chinese aluminum giant with a market cap of 35.96 billion USD. Xinjiang Tianshan has an annual production capacity of 1.4 million tons. The company is affiliated with the XPCC and partners with the XPCC in transfer of labor programs. Xinjiang Tianshan has also been named a so-called “national employment poverty alleviation base” in Xinjiang by the Chinese government.90 Established in 2010, Xinjiang Tianshan is based in the Shihezi Development Zone. It has seven active subsidiaries, of which four are based in Xinjiang. Three of those are located in the Shihezi Development Zone – with operations focused on non-ferrous metal smelting and rolling processing, power generation and electricity production, and non-metallic mineral products. Xinjiang Tianshan’s fourth Xinjiang-based subsidiary, which produces and sells aluminum and other nonferrous and ferrous metals, Alar Nanjiang Carbon New Material Co., Ltd., is located in the University Student Pioneer Park of Alar, Xinjiang, and registered to the First Division of the XPCC. As that registration, and Xinjiang Tianshan’s name, suggest, the company is considered part of the Eighth Division of the XPCC. Xinjiang Tianshan’s recruitment materials describe it as a “Xinjiang-aid enterprise that responds to the national call and supports the Xinjiang Production and Construction Corp” – also as a “new growth point for the development of the XPCC’s industrial economy.”91 The company’s 2020 annual report further emphasizes alignment with the Chinese government’s industrial policy in Xinjiang, noting that Xinjiang Tianshan “actively responded to national policy and invested in the construction of South Xinjiang Carbon New Material Co., Ltd in Alar, Southern Xinjiang. It strongly supported the government’s poverty alleviation plan.” 92 When Xinjiang Tianshan was listed on the Shenzhen Stock Exchange, the Corps Daily celebrated the event as the first listing of a private enterprise in the XPCC. That article also quoted the director of the XPCC’s Local Financial Supervision and Administration Bureau Financial Development Division explaining the processes by which XPCC had ensured the

人力资源社会保障部办公厅国务院扶贫办综合司关于公布全国就业扶贫基地名单的通知 [Notice of the General Office of the Ministry of Human Resources and Social Security and the Comprehensive Department of the Poverty Alleviation Office of the State Council on Announcement of the List of National Employment Poverty Alleviation Bases], Ministry of Human Resources and Social Security, June 21, 2017. 91 新疆生产建设兵团第八师天山铝业有限公司 [Tianshan Aluminum Co., Ltd., Eighth Division of Xinjiang Production and Construction Corps], Central South University, March 23, 2021. 92 天山铝业集团股份有限公司 2020 年度报告 [Tianshan Aluminum Group Co., Ltd. Annual Report 2020], April 2021.

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successful listing of Xinjiang Tianshan.93 As previously noted, XPCC was sanctioned by the US Treasury Department in July 2020 for its role in human rights abuses, including mass arbitrary detention and severe physical abuse of ethnic Uyghur populations in Xinjiang.94 The tie between Tianshan and the XPCC plays out in transfer of labor cooperation. A 2019 article offers a clear example, outlining the processes by which the XPCC coordinates the export of workers to Xinjiang Tianshan and companies like it: On January 23, Xu Zhixin, the commander of the Eighth Division [of the XPCC], issued clear instructions; Transfer the surplus labor force of the regiment farm to industrial enterprises in the Shihezi Development Zone….On March 6, Yang Ling, deputy political commissar and chairman of the Trade Union of the Eighth Division, Fourth and Ninth Regiment, personally escorted more than 50 surplus laborers from the regiment to Shihezi Development Zone. Under the coordination of the Social Development Bureau of Shihezi Development Zone, more than 50 surplus laborers were assigned to work in Tianshan Aluminum, Huaxing Glass Co., Ltd, and Jinmailing Food Co., Ltd on that day… Sang Jinrong, director of the Social Development Bureau of Shihezi Development Zone, said that this year, the Bureau will focus on placing surplus labor in the industrial enterprises of the development zone, so that it [the zone] can become a “reservoir” for surplus labor.95 A December 2020 XPCC meeting dedicated to “organizing private enterprises to take multiple measures to help poverty alleviation” further underlines the cooperation between the para-military organization and Xinjiang Tianshan in labor policies. That meeting covered everything from urban development projects to labor transfer in Xinjiang. And on the latter front, it highlighted Tianshan’s efforts: “In addition to helping two companies of the 102 regiment, Xinjiang Tianshan Aluminum also helped the Sixth Division’s Beitashan Pasture to transfer herders.” The meeting also featured discussion between Xinjiang Tianshan and XPCC on cooperation in economic construction tasks “to solve the local employment problem.”96 Xinjiang Tianshan’s participation in transfer of labor programs, and corresponding cooperation with XPCC, is long-standing. A 2013 article described a labor transfer partnership between the Shihezi National Economic Development Zone and Tianshan Aluminum, as well as three other companies. That piece also noted that the 149th Regiment of the XPCC had “reached employment intentions with several companies in Shihezi Development Zone, including Wahaha Expulsion,

天山铝业挂牌上市！兵团民企上市实现零突破 [Tianshan Aluminum Is Listed! XPCC's Private Enterprises Listed on the Market to Achieve Zero Breakthroughs], Corps Daily, November 2, 2020. 94 “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order,” US Treasury Department, July 31, 2020, https://home.treasury.gov/news/press-releases/sm1073. 95 劳动力就地转移开启破冰之旅 [The Transfer of Labor Force to Start the Ice-Breaking Journey], Wenmi, May 17, 2019. 96 新疆生产建设兵团光彩会：组织民企多措并举助力脱贫攻坚 [Guangcai Meeting of Xinjiang Production and Construction Corps: Organizing Private Enterprises to Take Multiple Measures to Help Alleviate Poverty], China Business Times, December 22, 2020.

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Tianshan Aluminum, Hesheng Silicon, and Huafang Textile,” with plans to “export 1,000 surplus laborers this year.”97 In 2017, the Chinese Ministry of Human Resources and Social Security named Tianshan Aluminum a “national employment poverty alleviation base” in Xinjiang.98 The government’s announcement on the subject suggests that such status entails playing a core role in the Chinese government’s labor policies: The employment poverty alleviation base is an important carrier for absorbing the employment of poor rural labor force. Organizing and guiding poor rural laborers to work in poverty alleviation bases is an important part of promoting employment and poverty alleviation and developing labor cooperation. All localities shall widely release and make full use of the job information provided by employment poverty alleviation bases, actively carry out organized labor export, and encourage and support poor rural laborers to seek employment independently.... It is necessary to strengthen communication with employment poverty alleviation bases, understand the situation of absorbing poor laborers, collect information about vacancies in a timely manner and upload it to the China Public Recruitment Network.99

八师石河子开发区安置团场富余劳动力四百人就业 [Four Hundred Surplus Laborers from the Regiment Field in Shihezi Development Zone of Eight Division Were Employed], Sohu, March 8, 2013. 98 人力资源社会保障部办公厅国务院扶贫办综合司关于公布全国就业扶贫基地名单的通知 [Notice of the General Office of the Ministry of Human Resources and Social Security and the Comprehensive Department of the Poverty Alleviation Office of the State Council on Announcement of the List of National Employment Poverty Alleviation Bases], Ministry of Human Resources and Social Security, June 21, 2017. 99 Ibid.

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Xinjiang Qiya Aluminum & Power Co., Ltd. Xinjiang Qiya Aluminum and Power Co (Xinjiang Qiya) is a subsidiary of Sichuan Qiya Aluminum Group Corporation, a private Chinese company. 100 Xinjiang Qiya has an annual production capacity of 900,000 tons. Backed by local industrial policy, the company participates in labor transfer programs in Xinjiang, as well as corresponding re-education efforts. Xinjiang Qiya was established in 2010. It operates an integrated coal-electricity-aluminumaluminum processing project in Wucaiwan Industrial Park of the Zhundong Economic and Technological Development Zone. Xinjiang Qiya has one State-invested subsidiary in Yunnan Province, a joint venture with the local government, and invests in at least three Xinjiang-based entities: The Wucai Vocational School, discussed earlier in this report; a coal and a cargo company also in the Zhundong Zone, and an aluminum sales company in Urumqi. In every one of those cases, Xinjiang Qiya invests alongside State or State-owned players, including Shandong Energy Group, Xinjiang Energy Group, and Xinjiang Shenhuo Coal and Electricity Co., another major aluminum company in the XUAR. Xinjiang Qiya’s aluminum operation is well enshrined in government industrial policy. Xinjiang Qiya describes itself as having been established “in response to China’s call for the development of Xinjiang and in accordance with the XUAR’s development of the coal-electricity-smelting industry in Zhundong.”101 The company’s 23.6 billion RMB project in the Wucaiwan Industrial Park is one of the key projects of the XUAR’s 11th and 12th Five Year Development Plans.102 The project itself responds to the Ministry of Industry and Information Technology’s 2010 “Several Policy Opinions on Promoting Xinjiang’s Industrial Communication and Informatization.”103 As already noted, Xinjiang Qiya is a ten percent shareholder, alongside East Hope, in the Wucai Vocational School in the Zhundong Economic and Technological Zone. As discussed earlier in this report, that school is associated with labor transfer-tied re-education programs.104 In addition, Xinjiang Qiya also appears to acquire workers through transfer of labor programs. As recently as June 2021, the company attended an employment fair organized by the Quanzijie Township Government and Jimsar County Employment Bureau, Xinjiang. 105 The event was attended by at least 50 “surplus laborers.” The Propaganda Department of Jimsar County reported that it had specifically targeted Xinjiang Qiya to participate: “Based on the actual conditions of 100

"新疆其亚铝电有限公司简介及 2021 招聘简章 [Introduction to Xinjiang Qiya Aluminum & Power Co., Ltd. and 2021 Recruitment Guide]," Xi'an Electric Power College, September 21, 2020. 101 Ibid. 102 Ibid. 103 Ibid. 104 助力脱贫攻坚，服务社会发展--学院 42 名学生赴准东开发区开展教学实习 [Help Alleviate Poverty and Serve Social Development: 42 Students from the College Went to Zhundong Development Zone for Teaching Practice], Changji University, July 14, 2020. 105 精准就业招聘会走进泉子街镇 [Precise Employment Recruitment Fair Enters Quanzijie Town], Jimsar County Propaganda Department, June 4, 2021.

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the age and gender of the surplus labor force in Quanzijie Township, the Employment Bureau screened Xinjiang Qiya Aluminum and Power Co., Ltd to enter and carry out targeted recruitment to maximize employment.”106 The Department also described this event as part of a larger set of government trainings and programming for the “masses” in the area: We will continue to promote the ‘I Do Practical Work for the Masses’ activities. In the next step, Quanzijie Town will continue to carry out Party history learning and education.”107 Reviews of Xinjiang Qiya on informal Chinese message boards further suggest abusive working conditions there. “There is no salary for the first two months,” reads one such post, from 2013, “and the first month’s salary is not paid until the third month, which means that you will be imprisoned for two months’ salary.”108

106

Ibid. Ibid. 108 "新疆其亚铝电公司怎么样，外界评论不是很好 [How about Xinjiang Qiya Aluminum & Power Company, the External Comments Are Not Very Good]," Baidu Knows, August 23, 2013. 107

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Xinjiang Jiarun Resources Holdings Co., Ltd. Xinjiang Jiarun Resources Holdings (Xinjiang Jiarun) is majority-owned by Manas County Taixin Trading Co., Ltd., a private, Xinjiang-based company. Established in 2011, Xinjiang Jiarun has an annual primary aluminum production capacity of 800,000 tons. Chinese industrial registry documents describe Xinjiang Jiarun as “a key Xinjiang-aid enterprise introduced by the Xinjiang Uyghur Autonomous Region.”109 The company participates in labor transfer, as well as in reeducation of absorbed workers. It has also been recognized by the XUAR government as a model enterprise in implementing Beijing’s “ethnic policies” in the region. A track record of safety issues further suggests hazardous, abusive working conditions at the company. Xinjiang Jiarun is headquartered in the Jiarun Industrial Park of Manas County, Changji Hui Prefecture, the same prefecture that houses the Zhundong Economic and Technological Zone. The company operates two wholly-owned subsidiaries in Xinjiang: Xinjiang Jiuliyuan Trading and Manas County Runjia Trading Co. Xinjiang Jiarun is also the majority (51 percent) shareholder of Manas County Jiaxin Resources Development Co., Ltd., a coal-focused joint venture with the Manas County government. In addition, Xinjiang Jiarun holds a 24 percent stake in Manas County Biyuan Water Supply, which is majority owned by Manas County, and a 10 percent stake in Xinjiang Lianqiao Logistics, whose largest shareholder (36 percent) is the State Council’s China National Railway Group Co., Ltd and which is also invested in by the Xinfa Group – discussed earlier in this report. Xinjiang Jiarun has been recognized by the Xinjiang government as a model enterprise in promoting Beijing’s “ethnic policies” in Xinjiang. In September 2021, Xinjiang Jiarun was awarded the title of “national unity and progress model group” of the Xinjiang Autonomous Region.110 That recognition rewards leaders in implementing “the Party’s ethnic policies” and promoting an “ideological great wall for safeguarding national unity and ethnic unity” in Xinjiang.111 150 entities, most of them government or State-owned, and 299 individuals received the (dubious) honor. Xinjiang Jiarun was one of eight recipients in Changji Hui Autonomous Prefecture. Those eight also included the Management Committee of Xinjiang Zhundong Economic and Technological Development Zone.112 Xinjiang Jiarun is documented to have participated in government-organized transfer of labor programs in Xinjiang as early as 2013. An article from that year in Tianshan Net News reported 109

新疆嘉润资源控股有限公司简介 [Introduction to Xinjiang Jiarun Resources Holdings Co., Ltd.], xjmic.com, July 27, 2017. 110 关于表彰自治区第八次民族团结进步模范集体和模范个人的决定 [Decision on Commending the Eight Exemplary Groups and Individuals in the Autonomous Region for National Unity and Progress], Xinjiang Daily, September 15, 2021. 111 Ibid. 112 Ibid.

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that Baojiadown Town, Manas County had “exported 1,130 laborers to the enterprises in the town” -- including Xinjiang Jiarun Resources -- through government coordination with local companies.113 The article describes the government’s approach as adopting the “‘one household, one person’ transfer employment model” and resting on “a good labor service cooperation relationship [between the local government and] more than 10 enterprises based in the town, including Jiarun, Dezhiyuan, and Shunquan Chemical Fiber.” The director of the Human Resources Department of Jiarun Resources Holdings Co., Ltd is quoted in the article as saying that the company “built an employee family building in Manas County.”114 Xinjiang Jiarun’s role in transfer of labor programs appears to be ongoing. An April 2020 article reported that Xinjiang Jiarun had incorporated “factory classrooms” into its “daily management of migrant workers.”115 These classrooms are part of Manas County government labor programming designed “better to integrate urban and rural surplus laborers into enterprises.”116 They focus on language and ideological training. The 2020 article describes them as part of a larger system of labor oversight on the part of the County Party Committee: The County Party Committee establishes the employment account of migrant workers, strictly implements the system of ‘daily reports, weekly research and judgment, and monthly meetings;’ strengths communication and coordination with enterprises… Through ‘national language + skills + position,’ carry out ‘factory classroom’ training on a regular basis and continuously improve the national language and employability of migrant workers. Set up a work team stationed in the enterprise to cooperate with the enterprise to do a good job int he promotion of policies for migrant workers, Mandarin education, ideological guidance, and safety inspections.117 More specific descriptions of the Xinjiang Jiarun “classrooms” note that they implement “ethnicChinese pairings so that they [migrant workers] can master work skills and improve communication skills.” 118 First-hand accounts of the ongoing genocide underway in Xinjiang consistently describe “re-education” programs of abusive language and ideological training, carried out in so-called classrooms but designed to break targets’ spirits and ability independently to think.119 Xinjiang Jiarun also regularly participates in transfer of labor job fairs organized by the Public Employment Service Bureau of Manas County, Xinjiang. In December 2020, the company attended such a job event advertised as designed “to help the transfer of surplus labor from urban 113

"玛纳斯县包家店镇劳动力输出一项实现人均增收 980 元 [Labor Export in Baojiadian Town, Manas County Achieved a Per Capita Income Increase of 980 Yuan]," Tianshan Net, October 12, 2013. 114 Ibid. 115 "玛纳斯县：'工厂课堂'助力富余劳动力稳定就业 [Manas County: 'Factory Classroom' Helps Stable Employment of Surplus Labor]," Sohu News, April 19, 2020. 116 Ibid. 117 Ibid. 118 Ibid. 119 See, for example, Gulbahar Haitiwaji, “’Our Souls Are Dead:’ How I Survived a Chinese ‘Re-Education’ Camp for Uighurs,” The Guardian, January 12, 2021.

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and rural areas.”120 Four other companies attended. 225 laborers were placed, primarily in “general worker” and security guard posts.121 In March 2021, Xinjiang Jiarun participated in another Manas County job fair, this one designed “to continue to absorb surplus labor…and adhere to orderly transfer of labor” and “meet the job needs of major companies.”122 At the event, Xinjiang Jiarun sought aluminum workers, security guards, and firefighters. A total of 238 employees were placed at six different companies through the job fair.123 Xinjiang Jiarun also has a history of safety issues. These have been sufficient to prompt government rebuke. In March 2017, an investigation into Jiarun’s safety practices by the Changji Prefecture Work Safety Supervision Bureau found inadequate safety education and training – including fraud as to the education and training offered – hazard management, and accident investigations. For those failures, the company was fined 60,000 RMB.124 That rebuke does not appear to have resolved the safety situation at the company. In October 2019, an accident with the electrolyte crusher at Xinjiang Jiarun’s aluminum plant anode assembly workshop killed at least one person, who had become stuck in the belt feed opening.125 The victim, named in the accident report as Dawuleti Entemark, is likely of Uyghur ethnicity based on his name. So is the worker who reported the accident. That accident took place at 1:00 in the morning. Dawuleti was declared dead at 8:30 am.126 Public labor disputes with Xinjiang Jiarun have documented severe burns suffered “due to the explosion of molten aluminum,” 127 as well as a ruptured eyeball resulting from aluminum powder.128 Informal Chinese message boards further indicate unsafe and abusive work conditions

120

玛纳斯县每周五举行微型招聘会促进就业(图) [Manas County Holds Mini-Job Fairs Every Friday to Promote Employment (Figure)], Xiaoxiang Morning News, December 16, 2020. 121 Ibid. 122 "玛纳斯县公共就业服务局举办春风行动招聘会:昌吉回族自治州人民政府 [Manas County Public Employment Service Bureau Held a Spring Breeze Action Job Fair: Changji Hui Autonomous Prefecture People's Government]," Manas Government Site, March 23, 2021; "玛纳斯县公共就业服务局举办春风行动招聘会: 满足群众就业需求解决企业招工难题 [Manas County Public Employment Service Bureau holds Spring Breeze Action Job Fair: Meeting People's Employment Needs and Solving Corporate Recruitment Problems]," Changji Daily, March 23, 2021. 123 Ibid. 124 "紧急通知：昨天 13 死 18 伤！'安全培训不到位是重大安全隐患'，终于找到依据了！[Urgent Notice: 13 Dead and 18 Injured Yesterday! 'Inadequate Safety Training Is a Major Safety Hazard,' Finally Found a Basis!]," Sohu News, August 10, 2021. 125 新疆嘉润资源控股有限公司“10.21”机械伤害事故调查报告 [Xinjiang Jiarun Resources Holdings Co., Ltd. "10.21" Machinery Injury Accident Investigation Report], Manas County People's Government, March 26, 2020. 126 Ibid. 127 王顺宇与新疆嘉润资源控股有限公司劳动争议一审⺠事判决书 [Judgment of the first instance of the labor dispute between Wang Shunyu and Xinjiang Jiarun Resources Holdings Co., Ltd.], Manas County Court, May 18, 2017. 128 新疆维吾尔自治区玛纳斯县人⺠法院⺠事判决书 [Manas County, Xinjiang Uygur Autonomous Region, court judgment], 2324(153), 2020.

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at the company. They have described Xinjiang Jiarun as a “garbage company.”129 They report failure to pay wages, extreme working hours, and unsafe working conditions. “The temperature is extremely high, and it is said that the temperature in the electrolysis room has reached 65 degrees [Celsius],” or 149 degrees Fahrenheit, reads one post. “There is no rest time, you won’t be paid for overtime, and they often make you do voluntary labor. On average there is one voluntary labor every ten days.”130

129 130

新疆嘉润资源控股有限公司 [Xinjiang Jiarun Resources Co., Ltd], Baidu Knows, July 20, 2013. Ibid.

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Xinjiang Shenhuo Coal and Electricity Co., Ltd. Xinjiang Shenhuo Coal and Electricity Co., Ltd is a Xinjiang-based subsidiary of the Shenhuo Group, a State-owned enterprise supported by Henan province and specialized in coal, power generation, and primary aluminum production and processing. Xinjiang Shenhuo, which has an annual primary aluminum production capacity of 800,000 tons, is located in the Zhundong Economic and Technological Development Zone’s Wucaiwan Industrial Park.131 The company organizes transfer of labor programming in conjunction with the local government. Xinjiang Shenhuo’s recruiting documents describe it as a “Xinjiang-aid enterprise supported by the Henan Provincial Government,” and as “actively responding to the call for the development of the western region of the country.” Those documents also note that Xinjiang Shenhuo combines the advantages of the larger State-owned conglomerate with the “resource advantages and preferential policies in Xinjiang.”132 Xinjiang Shenhuo has one wholly owned aluminum company in Sanmenxia, Henan, the same city that houses East Hope (Sanmenxia) Aluminum. Xinjiang Shenhuo also has three joint ventures in Xinjiang: Xinjiang Fenghua Times Technology (35 percent), a coal company majority (64 percent) owned by State-owned Xinjiang Yihua Mining; Xinjiang Jiuhuatian, Logistics (15 percent), a State-owned cargo company; and Xinjiang Shenxing Energy (40 percent), a new energy technology company majority owned (50.97 percent) by the State-owned Shenhua Group. Xinjiang Shenhuo’s parent company also has another subsidiary in Xinjiang: Xinjiang Shenhuo Carbon Products, an anode company located in Fukang Industrial Park, Changji Prefecture. Xinjiang Shenhuo organizes transfer of labor programming in conjunction with the local Xinjiang government as well as other companies that have been identified as exposed to forced labor risks. In March 2017, Jimusaer Town and Xinjiang Shenhuo – in partnership with eight other companies, including Xinjiang East Hope -- held a “special job fair for the transfer and employment of the surplus labor force.”133 That job fair explicitly targeted migrant workers and was framed in the context of “poverty alleviation.” Media coverage of the job fair described it as an effort to “support Zhundong and serve Zhundong.” 134 In February 2016, the Xinjiang government described Xinjiang Shenhuo as one of 14 state-controlled enterprises in the Zhundong Zone to have installed “real-time monitoring.”135 131

新疆神火资源投资有限公司， 2020 年高校招聘简章 [Xinjiang Shenhuo Resources Investment Co., Ltd., 2020 College Recruitment Guide], Central South University. 132 Ibid. 133 新疆吉木萨尔县吉木萨尔镇开专场招聘会 [A Special Job Fair Was Held in Jimsar Town, Jimsar County, Xinjiang], Asia Heart Network, March 31, 2017. 134 Ibid. 135 昌吉州：准东 14 个国控企业全部实现实时监控 [Changji Prefecture: All 14 State-Controlled Enterprises in Zhundong Realize Real-Time Monitoring], xinjiang.gov.cn, February 1, 2016.

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Xinjiang Tianlong Mining Co., Ltd. Xinjiang Tianlong is a subsidiary of the Xinjiang Xintou Group, a State-owned entity under the Xinjiang SASAC.136 Established in 1998, the company is one of the oldest aluminum producers in Xinjiang. It acquires workers through labor transfer and re-educates them, cooperates with XPCC, and, like Xinjiang Jiarun, has been recognized by the XUAR as a model promoter of “ethnic policies” in the region. Xinjiang Tianlong is headquartered in Ganhezi Town, Fukang City. It reports counting approximately half of that town among its more than 1,800 employees. At least a third of those are ethnic minorities and about 1,500 lack a college degree.137 Xinjiang Tianlong has three whollyowned subsidiaries in Xinjiang. One engages in coal production and sales, another in agricultural as well as chemical productions, and the third on mining and sales of bauxite and refractory clay. In September 2019, Xinjiang Tianlong was awarded the title of “national unity and progress model group” of the Xinjiang Autonomous Region.138 As already discussed, that recognition rewards leading players in implementing “the Party’s ethnic policies” and promoting an “ideological great wall for safeguarding national unity and ethnic unity” in Xinjiang.139 Tianlong participates in transfer of labor programs targeting ethnic minorities in Xinjiang – as well as the re-education programming that accompanies them. A 2017 CCTV article headlined “Southern Xinjiang’s surplus labor force transferred out of Xintiandi” describes Xinjiang Tianlong as a destination company for the laborers.140 That article also describes “four-month intensive” ideological and language training taking place in Xinjiang Tianlong’s “classroom” for transferred laborers: In the training classroom of Xinjiang Tianlong Mining Co., Ltd in Fukang City, after the “Red Song” competition, the teachers carried out training proceeding from Chinese everyday expressions to labor law. After nearly half a month of training, the students’ Chinese abilities have been significantly improved. In the training, I learned that the company currently has more than 1,700 employees….It is understood that the four-month intensive training mainly helps them in bilingual ability, skill improvement work, life, and other aspects.141

136

新疆天龙矿业股份有限公司 [Xinjiang Tianlong Mining Co., Ltd.], XJ Monitor, Accessed November 7, 2021. http://www.xjmic.com/xj-monitor-pub/org_jbxx/10351.do 137 Ibid. 138 新投集团天龙矿业荣获“全国民族团结进步模范集体”称号 [Xintou Group Tianlong Mining was awarded the title of "National Model Group of National Unity and Progress"], Xinjiang SASAC, October 21, 2019. 139 Ibid. 140 南疆富余劳动力转移就业“转”出新天地 [South Xinjiang's Surplus Labor Force Transfers Employment out of Xintiandi], CCTV, June 23, 2017. 141 Ibid.

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First-hand accounts of the genocide in Xinjiang consistently describe “re-education” programs of abusive language and ideological training designed to break targets’ spirits and ability independently to think.142 More recently, in 2020, Xinjiang Tianlong was reported in Fukang Municipal Government documents as having received 126,000 RMB in subsidies for “absorbing” 63 workers in identified “key employment groups.”143 Tianlong also has a relationship with the XPCC. As early as 2006, the company – as well as the Economic and Trade Commissions of the XUAR, Changji Prefecture, Altay Prefecture, and the Xinjiang Non-Ferrous Metal Research Institute — cooperated with XPCC in outlining plans for developing metal mining, processing, and production in Xinjiang.144 XPCC was sanctioned by the US Treasury Department in July 2020 for its role in human rights abuses, including mass arbitrary detention and severe physical abuse of ethnic Uyghur populations in Xinjiang.145 In addition, formal labor complaints about Xinjiang Tianlong issued to the local government describe a failure to pay workers.146

142

See, for example, Gulbahar Haitiwaji, “’Our Souls Are Dead:’ How I Survived a Chinese ‘Re-Education’ Camp for Uighurs,” The Guardian, January 12, 2021. 143 2020 年度用人单位吸纳重点就业群体就业奖励审核情况 [Review of employment incentives for employers to absorb key employment groups in 2020], Fukang Municipal Government, December 11, 2020. 144 我校应邀参加新疆产学研展洽会并取得可喜成果 [Our School Was Invited to Participate in the Xinjiang Industry-University-Research Exhibition Fair and Achieved Gratifying Results], Department of Science and Technology, August 28, 2006. 145 “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order,” US Treasury Department, July 31, 2020, https://home.treasury.gov/news/press-releases/sm1073. 146 辞职不给批自离以后手续办完了半个月工资扣完不给发 [No Approval for Resignation. After the Procedure Is Completed, Half a Month’s Salary Deduction Will Not Be Issued], Fukang Government, January 17, 2020.

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Xinjiang Zhonghe Co., Ltd. Xinjiang Zhonghe Co., Ltd (Xinjiang Zhonghe) is a long-standing pillar of Xinjiang’s industrial sector – and key player in China’s aluminum industry. The oldest of the Xinjiang aluminum companies, it was established in 1995 by the XUAR and Xinjiang Nonferrous Metals Industry Corporation and listed on the Shanghai Stock Exchange in 1996. The company is affiliated to the XPCC, closely tied to vocational education programs as well as government “ethnic policy” in Xinjiang, and supports both the Chinese government’s propaganda in the region and the Chinese military. Though its existing annual primary aluminum production capacity is only 18,000 tons, Xinjiang Zhonghe is China’s, and the world’s, largest manufacturer of high-purity aluminum, according to Chinese industry sources. It exports its products to Japan, Europe, South Korea, and the United States for use in aviation, aerospace, home appliances, information equipment, and other fields. The company has thirteen subsidiaries, of which twelve are based in Xinjiang. They include graphene, property management, magnesium, equipment manufacturing, logistics, rubber and plastic, non-ferrous metal smelting, and import and export companies. They also include a joint venture with TBEA Co., Ltd (85 percent stake) in a coal mining company. Xinjiang Zhonghe is a darling of Chinese government industrial policy, and a subsidized one.147 The 12th Five Year Plan Outline for Urumqi City emphasized support for Xinjiang Zhonghe. That plan outlined eight priority industries for the city: coal, machinery and equipment manufacturing, light industry and textiles, wind power, photovoltaics, biopharmaceuticals, energy saving and environmental protection, and new materials.148 The latter section focused exclusively on Xinjiang Zhonghe: Vigorously promote the construction of the Xinjiang Zhonghe Electronic New Material Circular Economy Industrial Park, improve supporting industries, and expand and strengthen the “coal-electricity-high purity aluminum-electronic aluminum foil-electrode foil” integrated circular economy industrial chain. Relying on independent innovation and technological transformation, we will accelerate the construction of the primary highpurity aluminum project with a projected annual production of 360,000 tons, dedicated to new functional and structural parts, providing cutting-edge high-purity aluminum metal for national electronic information materials, aviation, aerospace, defense and military industry, rail transit, and other fields. Build Xinjiang Zhonghe into an internationally competitive world-class electronic new material industry base.149 Descriptions of Xinjiang Zhonghe’s projects consistently describe it as affiliated with the XPCC.

147

See, for example, Xinjiang Zhonghe’s 2020 annual report. 乌鲁木齐十二五规划纲要 [Urumqi Twelfth Five-Year Plan Outline]. http://www.chinaaudit.com/lhd_0ivyw2n5lq3xy6q95j7a_1.html 149 Ibid. 148

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For example, a 2019 article in the Corps Daily describes Xinjiang Zhonghe’s New Material Industry Base in the Shihezi Economic and Technological Development Zone as “the first major project built by the Corps.” 150 That project focuses on aluminum capacitators for new energy vehicles and 5G applications.151 XPCC was sanctioned by the US Treasury Department in July 2020 for its role in human rights abuses, including mass arbitrary detention and severe physical abuse of ethnic Uyghur populations in Xinjiang.152 And Xinjiang Zhonghe appears to carry out the ethnic policies of the Xinjiang government entities to which it is connected. The company is tied to so-called vocational training programs in Xinjiang. In September 2019, the Chinese Ministry of Education identified the company as part of the first batch of national vocational education enterprise teacher practice bases. 153 The next month, Xinjiang Zhonghe launched a new vocational training program in conjunction with the Urumqi Human Resources and Social Security Bureau. Responsive to the XUAR Vocational Skills Improvement Action Implementation Plan (2019-2021) as well as the Urumqi City Vocational Skills Improvement Action Implementation Plan (2019-2021), that Xinjiang Zhonghe program targets “rural migrant workers…urban and rural junior and high school graduates and other young people…and children from poor families.”154 The program includes vocational training as well as job transfer training.155 In 2021, the XUAR recognized the Assistant to the General Manager of Xinjiang Zhonghe Co., Ltd. as a “national unity and progress model individual” of the region. 156 That recognition is intended to reward leading players in implementing “the Party’s ethnic policies” and promoting an “ideological great wall for safeguarding national unity and ethnic unity” in Xinjiang.157 150 entities, most of them government or State-owned, and 299 individuals received the (dubious) honor.158 Xinjiang Zhonghe also supports the Chinese government’s propaganda about its practices in Xinjiang. In September 2020, in response to global outcry over the atrocities underway in the

150

新疆众和投资逾 6 亿元在兵团发展新材料产业 [Xinjiang Zhonghe Invests More than 600 Million Yuan in the Development of New Materials Industry in the XPCC], Corps Daily, April 19, 2019. 151 Ibid. 152 “Treasury Sanctions Chinese Entity and Officials Pursuant to Global Magnitsky Human Rights Executive Order,” US Treasury Department, July 31, 2020, https://home.treasury.gov/news/press-releases/sm1073. 153 教育部等四部门关于公布首批全国职业教育教师企业实践基地名单的通知 [Notice of the Ministry of Education and Four Other Departments on the Announcement of the First Batch of National Vocational Education Teacher Enterprise Practice Bases], Ministry of Education, December 1, 2019. 154 乌鲁木齐动职业技能提升行动 [Urumqi Launches Professional Skills Improvement Action], Urumqi Evening News, October 14, 2019. 155 Ibid. 156 关于表彰自治区第八次民族团结进步模范集体和模范个人的决定 [Decision on Commending the Eight Exemplary Groups and Individuals in the Autonomous Region for National Unity and Progress], Xinjiang Daily, September 15, 2021. 157 Ibid. 158 Ibid.

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XUAR, the Chinese State Council issued a white paper on “Employment Security in Xinjiang.”159 That white paper argued that all labor and employment policies in Xinjiang are “in line with international labor and human rights standards,” and supported by all ethnic groups in the region. In an interview with Urumqi Radio and Television Financial Media on the subject, the deputy director of Xinjiang Zhonghe’s Human Resources Department “said that the white paper describes how Xinjiang protects the basic rights of workers in accordance with the law, and this is what our company [Xinjiang Zhonghe] has been doing.”160 Xinjiang Zhonghe is also tied to the Chinese military. It is codified in Chinese industrial policy as a “military supporting enterprise.”161 Zhonghe receives support from a host of high-profile and military-relevant Chinese national science, technology, and industrial programs, including the National Torch Plan, China’s high-tech industrialization plan, and its 863 Program, which seeks to develop dual-use technological capacity.162

159

新疆劳动就业保障惠民生顺民意得民心 [Xinjiang’s Labor and Employment Security Benefits the People’s Livelihood, Obeys Public Opinion and Wins the Hearts of the People], Sohu News, September 22, 2020. 160 Ibid. 161 关于新疆众和 [About Xinjiang Zhonghe], Guangfa Securities, May 16, 2019. 162 新疆众和股份有限公司 [Xinjiang Zhonghe Co., Ltd], May 20, 2021, http://www.gqp.gov.cn

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Conclusion The findings presented in this report are not intended as conclusive evidence of forced labor. However, the indicators and methodology used mirror those that have been monitored and applied in assessments of other Xinjiang-based supply chains found to be benefitting from forced labor (e.g., textiles, agriculture). Both the extent of exposure to indicators of forced labor identified in this analysis, and the nature of the aluminum industry, may make the implications particularly severe and problematic. Aluminum is among the most common metals used worldwide. Its low density, high conductivity, and corrosion resistance make it a critical input in everything from aircraft fuselages to utensils, semiconductor manufacturing to significant use in nearly all modern vehicles. China is the world’s largest producer of aluminum; Xinjiang the second most significant aluminum-producing region in China. If treated as a single company, Xinjiang would rank as the world’s biggest aluminum producing firm. At a first order, the findings presented in this report, which implicate every aluminum producer in Xinjiang, implicate all the production into which they feed – with consequences for the automotive, aerospace, electronics, and appliance industries, to name just a few. At a next level, the aluminum value chain in China, like most in the country, is highly integrated. Findings about this subset of eight Chinese aluminum companies may therefore raise concerns about and underscore the need for additional scrutiny of the larger ecosystem of Chinese aluminum companies, even outside of Xinjiang.

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