For decades, China has exploited ethnic minorities in the name of economic growth. To become a global leader in mass-producing and exporting inexpensive goods, it relies on a steady supply of cheap labor. The Chinese Communist Party (CCP) has found this labor supply in its occupied territories, such as the Uyghur Region.1 There, it has forced more than a million Uyghur Muslims to produce goods ranging from cotton to seafood, which it then exports around the world.2 If workers refuse, they are often threatened with imprisonment.3Such practices have been referred to by the UN Special Rapporteur on Contemporary Forms of Slavery as possible “enslavement as a crime against humanity.”4
But the Uyghur Region isn’t the only Beijing-controlled territory where the CCP targets and exploits colonized minorities. The CCP has a long history of repression in another occupied territory: Tibet. Now, with China’s ambitions to extract and export new resources, especially related to the renewable energy sector, the risk of forced labor is rising in Tibet, specifically in its mining industry.
Tibet is situated on a resource-rich plateau in the southwest of modern-day mainland China.5 The Tibetan people have lived there since the 7th century, historically pursuing a nomadic lifestyle.6 They have been ruled by the Dalai Lama in an independent theocratic state centered on the practice of Tibetan Buddhism.7
In 1949, the People’s Republic of China was established,8 and from late 1949 into 1950, China invaded Tibet, dissolved its government, and subjugated its institutions to Beijing’s regime.9 Since then, the CCP has been forcibly assimilating Tibetans through numerous repressive tactics such as compelling Tibetan monks to undergo religious reeducation, separating more than a million Tibetan children from their parents, and forcing the youth to attend colonial boarding schools.10
A key motive behind China’s invasion of Tibet was to seize control of its natural resources.11Currently, the CCP is interested in Tibet’s abundant stores of minerals such as copper and lithium.12 Such minerals are essential for the so-called “green energy transition”: the global shift away from fossil fuels and towards renewable energy sources.13
To grow its economic strength, China aims to become a global leader in exploiting these minerals to develop renewable energy sources.14
To extract these minerals, Chinese state-owned companies have been recruiting Tibetan laborers, including herders and farmers, into industrial-sector jobs.15 The recruitment of farmers and herders is usually referred to as “rural surplus labor transfer” and is sometimes done according to a broader regime policy of “poverty alleviation through labor transfer.”16 The theoretical intent is that by facilitating the transition of workers in subsistence industries, such as herding and farming, to sectors with more “profitable” jobs, such as mining, the regime can grow key industrial sectors while also providing jobs to workers who are at risk of being “left behind” in Tibet’s economic growth.17 While ostensibly meant to promote societal progress, the industrialization of Tibetan lands and recruitment of local communities also disrupt traditional Tibetan livelihoods and raise questions about the extent to which Tibetans freely participate in the recruitment process.18 More broadly, such mining could be seen as infringing on Tibetans’ autonomy over their homeland, especially given the CCP’s ongoing campaign of repression in the region.
A Brief History of Chinese Mining in Tibet
China started mining in Tibet as early as the 1960s,19 but greatly increased its activity in the mid-2000s.20
Most of these mines in Tibet originated as joint Chinese-Canadian ventures, with
Canada providing key technical expertise and China supplying the majority of Han Chinese workers.21 China subsequently bought out the Canadian companies, turning these mines into state-owned enterprises.22
In its recent efforts to develop the mining industry and extract resources, China has been forcibly relocating rural Tibetans into houses,23 and constructing mines that pollute the dispossessed land. For instance, in establishing a mine near the southeastern town of Jiama in 2010, a company called China National Gold forced 100 Tibetan nomad families to relocate to a regime-built village.24 Operations at the mines contaminated waters in the Jiama Valley, resulting in local Tibetans becoming ill and their animals dying off.25 Tibetans who protested the mining operations were brutally gunned down, arrested, or tortured by police.26 This forced resettlement and sedentarization makes formerly self-sufficient farmers and nomads dependent on the regime’s markets and social support programs to survive, hindering their customary way of life.
Consolidating CCP Influence Over Tibetan Mining
Currently, the Chinese Communist Party is consolidating its influence over Tibetan mining through policies concerning the “labor transfer” of “surplus rural laborers.”27 Labor transfer is when someone working in the primary sector (herding, for instance) starts working in the secondary or tertiary sector (such as a miner or a chemist).28 In the context of mining, companies may employ Tibetan herders and other people working in the primary sector as miners or in other secondary and tertiary sector jobs.29
While there is a lack of transparency over the nature of these labor transfer programs, it appears that labor transfer can be implemented in compliance with the CCP state policy of poverty alleviation through the labor transfer (转移就业脱贫) of rural surplus laborers (农村富余劳动力).30 This state policy is often defined by regime-imposed employment quotas of said rural surplus laborers, which in the case of Tibet likely refers to farmers and herders.31 Poverty alleviation through surplus rural labor transfer is also characterized by state-sponsored cadres going door to door to recruit villagers to their company.32 In the process, they may also select other locals to participate in vocational education programs, who ultimately work in sectors relevant to Tibet’s industrialization, such as construction and mining.33
Potentially Coercive Conditions
While the CCP and its defenders claim these practices are simply meant to help Tibetans obtain new jobs, the labor transfer of surplus rural laborers in accordance with poverty alleviation policies has raised concerns of coercive conditions, as thoroughly documented in the Uyghur Region.34
Labor transfer programs, as implemented in the Uyghur Region, can entail forced
relocations and land confiscation.35 Regime-run agencies or regime-owned private companies put in orders for the kinds of workers they require, and local townships enforce the heavily securitized transportation of such workers to the job site or training site.36 The vast majority of transferred Uyghur workers are pressured by the regime into being recruited and report dire working conditions, such as being locked in the factory complexes at night.37Accounts also exist of the regime imprisoning individuals who refuse to be transferred.38
Since the Chinese regime has severely restricted access to Tibet,39 no testimony currently exists from people who have undergone labor transfer in Tibet, and there is scant opportunity for on-the-ground investigation. Consequently, there is no direct evidence that Tibet’s labor transfer program is as coercive as the Uyghur Region’s labor transfer program.40Yet certain parallels can be drawn between Tibet and the Uyghur Region in terms of policy terminology and implementation. The rural surplus labor transfer policies of Tibet contain the same key phrases (tifa) as those in the Uyghur Region.41 Tifa are CCP-approved terms that are euphemisms for specific and often sinister policies, and function like codewords. They refer to various, strictly-defined policies, and it is mandatory for regime officials to use tifa whenever discussing such policies and their implementation,42 to ensure total conformity in policy implementation.43 In both Tibet and the Uyghur Region, tifa for rural surplus labor transfer include language, such as labor absorption (“吸纳当地农牧民就业力”), surplus rural labor transfer (“牧区富余劳动力转移”), labor export (“劳务输出”),
transfer employment (“转移就业”), and other such phrases.44
In addition to containing the same key phrases or tifa, the rural labor transfer programs in Tibet and the Uyghur Region appear to have similar implementation: employment being arranged by the state and the use of village cadres going door to door to recruit villagers.45
State-arranged employment suggests that such employment may not always be voluntarily sought out by rural Tibetans. Door-to-door recruitment, where regime officials go door to door to identify recruits, can result in a Tibetan villager feeling pressure to acquiesce.46
In Tibet, if labor transfer is done in the context of the regime’s poverty alleviation program, it may raise questions about whether participation in such labor transfer was truly voluntary—questions that merit further investigation, such as in the following case studies.
Case Study #1: Zijin Mining Group Ltd.
Zijin Mining Group Ltd. is a state-owned Chinese company that mines gold, lithium, and copper.47 This company has been previously linked to labor transfer and assimilation of Uyghurs in the Uyghur Region.48 In Tibet, Zijin owns two mines. The first is Julong Copper Mine, which it acquired in 2020,49 and the second is the lithium mine Lakkor Tso, which it acquired in 2022.50 Julong is one of the largest copper mines owned by China and is expected to operate until 2067.51
Zijin’s Julong mine provided vocational training and “exported” laborers in Maizhokunggar County, indicating potential engagement in labor transfer programs.52 An April 2023 article published by state media describes how Julong, along with another mining company (Tibet Huatailong) and the Chikang Village Party Committee, engaged in trainings and that “laborers were exported”53 as part of a locally-driven program–recalling the tifa, or standardized language associated with labor transfer programs.54
Additionally, in 2018 (before Julong was acquired by Zijin), Julong Mine exported 38 laborers,55 according to Menba Township’s 2018 poverty alleviation objective.56 This document mentions that such labor export was done with the support of Maizhokunggar County’s government and the human resources and social security bureaus.57 Whether these labor transfers and other professional offerings were done in accordance with broader CCP poverty alleviation through labor transfer policies warrants further investigation.58
Case Study #2: China Gold International Resources
China Gold International Resources is a mining company based in Canada and owned by China.59 It is the parent company of Tibet Huatailong, which owns and operates Jiama mine, one of the biggest copper-gold polymetallic mines in Tibet.60
After China Gold International acquired the Jiama mine and China’s poverty alleviation campaign began in 2012,61 Tibet Huatailong more than doubled the number of Tibetans employed at Jiama mine, recruiting around 377 Tibetans by 2018.62 Though it is unclear if the 377 Tibetans were rural surplus laborers, China Gold International’s 2018 Annual Report cited Tibet Huatailong’s employment of the 377 Tibetans as a case study of how the company “has absorbed and arranged”63 employment of local Tibetan farmers and herders–echoing the tifa associated with labor transfer programs.64 Indeed, Tibet Huatailong engaged in this example of possible labor transfer in accordance with a government poverty alleviation scheme as outlined in the Lhasa City government’s Thirteenth Five-Year Plan Characteristic Industry Development Plan (2017).65 In a separate instance, Tibet Huatailong “absorbed”66435 farmers and herdsmen by 2020.67 In this second case, the word “absorb” is a key indicator that this employment may have been implemented as part of a labor transfer program.68
Without direct evidence of threats or force in the case of this company’s activities in Tibet, it cannot be concluded that China Gold International’s labor transfers are coercive. However, their occurrence in the context of the regime’s poverty alleviation policies–as well as the direct usage of tifa associated with other instances of forced labor in Chinese-occupied territories–calls for further investigation.
Additional Risk Factors
A January 2023 Chinese law applying to the entire Tibetan Autonomous Region states that if Tibetans refuse to accept state-arranged employment three times, the regime will reduce or suspend subsistence allowances on which many Tibetans have come to depend for survival.69 This financial penalty, though not directly mentioned in rural labor transfer policies, should be examined as an additional potential risk factor for state-imposed coercive labor conditions in Tibet.70
Mining is also a notoriously perilous industry, and Zijin Mining and China Gold International both have track records of poor working conditions in their operations. In Serbia, for instance, Zijin maintains a mine site where miners have reported being confined to their living quarters, having to work 12-hour days, and facing intimidation if they protest.71 China Gold International was also previously accused of being responsible for a landslide that killed 83 workers at its Jiama mine due to malfunctioning emergency infrastructure.72
There is a total lack of transparency and access to working conditions of mines in Tibet.73However, a 2023 post on the Chinese site Zhihu describes a difficult work environment in the Julong mine,74 12-hour shifts without breaks, and mandatory pre- and post-shift meetings that further prolong miners’ workday.75
In general, mines feature strong security measures.76 For instance, China Gold International’s Jiama mine is heavily surveilled. A work tender from 2022 calls for 33 security guards whose responsibilities include handling incidents including vandalism/sabotage and illegal assembly or activity.77 Tibet Huatailong has maintained a militia since as early as 2014,78 but created an Armed Forces Department in 2021, and was the first private company on the Tibetan plateau to do so.79 While it is increasingly standard for Chinese companies to have armed forces, their specific role in mining sites is not clear. However, their presence does demonstrate a company’s capacity to monitor and suppress any “undesired” activity and assembly if needed.
Given the complete lack of transparency in Tibet, the resulting atmosphere of impunity, and the broader risk factors associated with labor transfer programs and mining, it is possible that the living conditions of Tibetans have not improved under the CCP’s poverty alleviation efforts. In fact, Tibetans may be suffering misery and mistreatment as miners in the name of China’s industrial growth.
Recommendations
-Independent investigations by international civil society organizations–such as, for
example, the International Consortium of Investigative Journalists–should be undertaken to obtain first-hand testimony and direct field evidence to confirm whether or not forced labor is occurring in Tibet, and whether it is done according to state-sponsored initiatives involving labor transfer and/or threats of financial penalty.80
-Zijin has ties with Canada and America that should be scrutinized more closely. For
instance, Zijin recruited from Canadian universities like the University of Alberta and the University of British Columbia in 2023, and American universities like the Colorado School of Mines and the Virginia Polytechnic Institute and State University.81 In January 2022, the Canadian government authorized Zijin to acquire a Canadian lithium miner, Neo Lithium Corp for $960 million.82
-The potential for forced labor in Tibet isn’t confined to just these two mining companies. Other mines based in Tibet should also be investigated, such as the Luobusa chromite mine. This mine’s parent company, Tibet Mining, published a 2020 Social Responsibility Report which explicitly admits to concentrating “surplus labor” and engaging in the “relocation” of households in Qamdo in the context of governmental poverty alleviation laws.83 Tibet Mining’s own parent company, Baowu, also describes Tibet Mining as engaging in labor transfer and has even been linked to forced labor in the Uyghur Region.84
1 Commonly referred to as “Xinjiang.”
2 “Against Their Will: The Situation in Xinjiang.” Bureau of International Labor Affairs. Accessed July 10, 2024. https://www.dol.gov/agencies/ilab/against-their-will-the-situation-in-xinjiang; Ian Urbina et al., “The Uyghurs Forced to Process the World’s Fish,” The Outlaw Ocean Project, October 9, 2023,
https://www.theoutlawocean.com/investigations/china-the-superpower-of-seafood/the-uyghurs-forced-to-process-the-worlds-fish/.
3 Some are detained in “re-education camps,” prisons using force, threats, and torture to make Uyghurs give up their religion and assimilate to Chinese culture. Id; Adrian Zenz, “The Conceptual Evolution of Poverty Alleviation Through Labour Transfer in the Xinjiang Uyghur Autonomous Region,” Central Asian Survey, 2023, https://doi.org/10.1080/02634937.2023.2227225.
4 “51st regular session of the Human Rights Council: Reports.” United Nations Human Rights Council. Accessed July 10, 2024. https://www.ohchr.org/en/hr-bodies/hrc/regular-sessions/session51/list-reports, A/HRC/51/26, P. 8.
5 The Human Rights Foundation, “100 Years of Suppression: The CCP’s Strategies in Tibet, the Uyghur Region, and Hong Kong,” The Human Rights Foundation, 2021: 9. https://hrf.org/wp-content/uploads/2021/12/CCP-100-Years-of-Suppression-FINAL-VERSION.pdf.
6 Id., 9.
7 Id., 9.
8 Id., 10.
9 Conversation with Chemi Lhamo, December 7, 2023; John F. Avedon, In Exile from the Land of Snows: The Definitive Account of the Dalai Lama and Tibet since the Chinese Conquest (New York, NY: Vintage Books, a division of Random House LLC, 2015).
10 Freedom House, “Freedom in the World 2023: Tibet,” Freedom House, 2024,
https://freedomhouse.org/country/tibet/freedom-world/2023.
11 Warren Smith, “China’s Exploitation of Tibet’s Mineral Resources, Based Upon the Book Spoiling Tibet: China and Resource Nationalism on the Roof of the World, by Gabriel Lafitte,” Radio Free Asia, 2016: 2-3. https://www.rfa.org/english/news/tibet/warrensmithbooks/Warren1.pdf. At that time, China also used Tibetan prison-labor to extract such resources.
12 Rukor.org (formerly run by Gabriel Lafitte), “China’s Extractivism Ideology,” Rukor.org, 2023,
https://rukor.org/frontline-tibet/.
13 S&P Global, “What is Energy Transition?”, S&P Global, 2020, https://www.spglobal.com/en/research-insights/articles/what-is-energytransition#:~:text=Energy%20transition%20refers%20to%20the,well%20as%20lithium%2Dion%20batteries.
14 Rukor.org (formerly run by Gabriel Lafitte), “China’s Extractivism Ideology,” Rukor.org, 2023,
https://rukor.org/frontline-tibet/.
15 Adrian Zenz, “Xinjiang’s System of Militarized Vocational Training Comes to Tibet,” China Brief, Volume 20 Issue 7 (2020): https://jamestown.org/program/jamestown-early-warning-brief-xinjiangs-system-of-militarized-vocational-training-comes-to-tibet/.
16 Id. Poverty alleviation through labor transfer falls under the broad umbrella of Xi Jinping’s overall “poverty alleviation” policies.
17 Department of Commerce of the Tibet Autonomous Region, “宝“藏”故事丨西藏农牧民就业结构出现历史性变 化 (Treasure "Tibet" Story丨History of employment structure of farmers and
herdsmen in Tibet),” April 25, 2021,
https://web.archive.org/web/20240708165451/http://swt.xizang.gov.cn/xwzx/xzxw/202104/t20210425_200606.html.
18 Adrian Zenz, “Xinjiang’s System of Militarized Vocational Training Comes to Tibet,” China Brief, Volume 20 Issue 7 (2020): https://jamestown.org/program/jamestown-early-warning-brief-xinjiangs-system-of-militarized-vocational-training-comes-to-tibet/.
19 Warren Smith, “China’s Exploitation of Tibet’s Mineral Resources, Based Upon the Book Spoiling Tibet: China and Resource Nationalism on the Roof of the World, by Gabriel Lafitte,” Radio Free Asia, 2016: 3.
https://www.rfa.org/english/news/tibet/warrensmithbooks/Warren1.pdf.
20 Michael Buckley, “Mining & Canadian Companies,” Meltdown in Tibet,
https://meltdownintibet.com/q_mining.htm. 2006 was the year when China finished construction of a railroad between Golmund and Lhasa which made mining in Tibet feasible. Email correspondence with Michael Buckley, January 2024.
21 Edward Wong, “Fatal Landslide Draws Attention to the Toll of Mining on Tibet,” The New York Times, April 2, 2013, https://www.nytimes.com/2013/04/03/world/asia/deadly-tibetan-landslide-draws-attention-to-mining.html#:~:text=Establishing%20the%20mine%20at%20Gyama,the%20widespread%20resentment%20it%20causes; Michael Buckley, “Mining & Canadian Companies,” Meltdown in Tibet,
https://meltdownintibet.com/q_mining.htm; email correspondence with Michael Buckley, January 2024.
22 Id.
23 “China: End Involuntary Rehousing, Relocation of Tibetans,” Human Rights Watch, December 9, 2020, https://www.hrw.org/news/2013/06/27/china-end-involuntary-rehousing-relocation-tibetans. For more recent evidence of forcible relocation, see “‘Educate the Masses to Change Their Minds’: China’s Forced Relocation of Rural Tibetans,” Human Rights Watch, May 21, 2024, https://www.hrw.org/report/2024/05/22/educate-masses-change-their-minds/chinas-forced-relocation-rural-tibetans.
24 Edward Wong, “Fatal Landslide Draws Attention to the Toll of Mining on Tibet,” The New York Times, April 2, 2013, https://www.nytimes.com/2013/04/03/world/asia/deadly-tibetan-landslide-draws-attention-to- mining.html#:~:text=Establishing%20the%20mine%20at%20Gyama,the%20widespread%20resentment%20it%20causes.
25 Tibetan Centre for Human Rights and Democracy, “Annual Report Human Rights Situation in Tibet 2013,” Tibetan Centre for Human Rights and Democracy, 2013: 75.
https://www.ecoi.net/en/file/local/1036278/1788_1390214250_200837998-2013-annual-report-human-rights-situation-in-tibet.pdf.
26 Tibetan accounts tell of the mining company Tibet Huatailong seizing water from Jiama village
during a 2009 drought. This resulted in clashes, military police being called in to
surround and patrol the village, the year-long imprisonment of the village chief,
and the torture of Tibetan villagers by members of the mining company (with the
Tibet Huatailong boss actively encouraging the killing of Tibetan villagers):
Radio Free Asia,“甲瑪人講述甲瑪開礦帶來的災難 (Jiama people talk about the disaster
caused by Jiama mining),” Tibet Bulletin May-June 2013, (12-13), https://xizang-
zhiye.org/wp-content/uploads/2017/09/2013-5-6.pdf; Simon Denyer, “Tibetans in Anguish as Chinese Mines Pollute
Their Sacred Grasslands,” The Washington Post, December 26, 2016,
https://www.washingtonpost.com/world/asia_pacific/tibetans-in-anguish-as-chinese-mines-pollute-their-sacred-
grasslands/2016/12/25/bb6aad06-63bc-11e6-b4d8-33e931b5a26d_story.html.
27 Conversation with Adrian Zenz, January 23, 2024.
28 Id.
29 Adrian Zenz, “Xinjiang’s System of Militarized Vocational Training Comes to Tibet,” China Brief, Volume 20 Issue 7 (2020): https://jamestown.org/program/jamestown-early-warning-brief-xinjiangs-system-of-militarized-vocational-training-comes-to-tibet/.
31 Farmers and herders are identified as a key target group for labor transfer in
documents like The Fourth Session of the Eleventh People’s Congress of the Tibet
Autonomous Region,“西藏自治区国民经济和社会发展第十四个五年规划和二〇三五年远景目标纲要
——2021 年 1 月 24 日西藏自治区第十一届人民代表大会第四次会议通过 (The 14th Five-Year Plan
for the National Economic and Social Development of the Tibet Autonomous Region
and the Outline of the Long-Term Goals for 2035—January 2021),” 45 and 47-48:
https://perma.cc/4ZSZ-MADF. (P. 45: “第一节 多渠道增加农牧民收入 建立劳务输出精准对接机制和工作协调 联系机制，加大农牧 民转移就业和有组织劳务输出力度，引导农牧民参加各类工程项 目，推动劳动力转移 就业增收，支持留乡返乡农牧民工就地就近 创业就业，发展乡村旅游、农畜产品加工、商贸、运输、建筑 等 产业，推动政府投资项目、国有企业、对口援建项目优先吸纳当 地劳动力就业，采取生产奖补、劳务补 助、以工代赈等多种方式， 增加农牧民工资性收入。” P. 47: “突出做好高校毕业生、农牧区劳动力、城镇 困难人员、残疾人和退役军人等重点群体就业工作。" and P.48: “持续推进农牧民组织化、规模化转移就 业，正确处理好城镇就业 和就近就便、不离乡不离土、能干会干的关系，建立健全劳务输 出对接机制，推 进农牧区富余劳动力转移就业基地建设，加大国 家投资项目吸纳当地农牧民就业力度。”)
32 Tibet Autonomous Region Development and Reform Commission, “拉萨市”十三五“特色产
业发展规划 (Lhasa City’s ‘Thirteenth Five-Year Plan’ Characteristic Industry
Development Plan),” June 29, 2018, https://perma.cc/V592-ZS5L; The Fourth Session of the
Eleventh People’s Congress of the Tibet Autonomous Region,“西藏自治区国民经济和社会
发展第十四个五年规划和二〇三五年远景目标纲要——2021 年 1 月 24 日西藏自治区第十一届人民代表大 会第四次会议通过 (The 14th Five-Year Plan for the National Economic and Social
Development of the Tibet Autonomous Region and the Outline of the Long-Term
Goals for 2035—January 2021),” https://perma.cc/4ZSZ-MADF; “西藏自治区“十三五”时期脱贫攻坚规
划（2016—2020年）(Tibet Autonomous Region’s Poverty Alleviation Plan during the
13th Five-Year Plan Period (2016-2020))”: https://perma.cc/W6EK-MELH. See also Adrian Zenz,
“Xinjiang’s System of Militarized Vocational Training Comes to Tibet,” China Brief, Volume 20 Issue 7 (2020):
https://jamestown.org/program/jamestown-early-warning-brief-xinjiangs-system-of-militarized-vocational-training-
comes-to-tibet/.
33 Id.; People’s Government of Mozhugongka County, “墨竹工卡县门巴乡乡村振兴战略2018-
2022年实施规划 (2018-2022 Implementation Plan of the Rural Revitalization Strategy of
Menba Township, Mozhugonka County),” December 9, 2021, https://perma.cc/TF7U-HXUE;
Mozhugongka County People’s Government Office, “墨竹工卡县2021年政府工作报告
(Mozhugongka County Government Work Report 2021),” January 23, 2022,
https://web.archive.org/web/20240224164640/http://www.xzmzgk.gov.cn/mzfkxzf/zfgzbg/202201/1eda1d68e0384f768a2ac53c0fbb4cf4.shtml; Ministry of Human Resources and Social Security of the
People’s Republic of China, “西藏：转移就业保增收 (Tibet: Transferring Jobs to Ensure
Income Increase),” June 19, 2020,
https://web.archive.org/web/20240328210035/http://www.mohrss.gov.cn/SYrlzyhshbzb/ztzl/rsfp/gzdt/202006/t20200619_377009.html; Tibet Daily,“用’转移就业’来促进脱贫 (Use ‘Transfer Employment’ to Promote Poverty Alleviation),” June 11, 2019,
https://web.archive.org/web/20240328210242/https://www.xzzwfw.gov.cn/xz/xwzx_406/xwrp/201911/t20191114_123175.html.
34 Labor transfer is emphatically not the same as Uyghur internment/re-education camps, even if those camps also cite their purpose as being vocational training: Adrian Zenz, “The Conceptual Evolution of Poverty Alleviation Through Labour Transfer in the Xinjiang Uyghur Autonomous Region,” Central Asian Survey, 2023,
https://doi.org/10.1080/02634937.2023.2227225.
35 Ilham Tohti, “当前新疆民族问题的现状及建议（全文) (Current Situation and Suggestions
on Ethnic Issues in Xinjiang (Full Text))” (2013-2015), 19: https://chinachange.org/wp-
content/uploads/2015/05/e4bc8ae58a9be59388e69ca8efbc9ae5bd93e5898de696b0e79686e6b091e6978fe997aee9a298e79a84e78eb0e78ab6e58f8ae5bbbae8aeae2.pdf: “发生在韶关”626”事件中的新疆劳务输出，原本是一个积极、有价值的尝试，但在动员过 程中，类似内地八十年代拆房、牵牛、收回土地的强制行为时有发生，基层 执政能力的低 下，使之一开始就处于强烈的猜疑和抵制之中.”
36 Adrian Zenz, “Coercive Labor and Forced Displacement in Xinjiang’s Cross-Regional Labor Transfers: A Process-Oriented Evaluation,” The Jamestown Foundation, (2021), 21-22, https://jamestown.org/wp-content/uploads/2022/03/Coercive-Labor-and-Forced-Displacement-in-Xinjiangs-Cross-Regional-Labor-Transfers-A-Process-Oriented-Evaluation_Updated-December-2021_.pdf?x32853; Adrian Zenz, “The Conceptual Evolution of Poverty Alleviation Through Labour Transfer in the Xinjiang Uyghur Autonomous Region,” Central Asian Survey, 2023, https://doi.org/10.1080/02634937.2023.2227225.
37 Id.
38 Ian Urbina et al., “The Uyghurs Forced to Process the World’s Fish,” The Outlaw Ocean Project, October 9, 2023,
https://www.theoutlawocean.com/investigations/china-the-superpower-of-seafood/the-uyghurs-forced-to-process-the-worlds-fish/. Adrian Zenz also documents testimony given by an Uyghur woman detained in a re-education camp whose two cellmates had been detained for refusing to accept rural labor transfer arranged by the government:
Adrian Zenz, “The Conceptual Evolution of Poverty Alleviation Through Labour Transfer in the Xinjiang Uyghur Autonomous Region,” Central Asian Survey, 2023, https://doi.org/10.1080/02634937.2023.2227225. For further
testimony from people transferred to employment from re-education camps in the Uyghur Region, see: “‘Like We Were Enemies In a War’: China’s Mass Internment, Torture and Persecution of Muslims in Xinjiang,” Amnesty International (2021), 126-128, https://xinjiang.amnesty.org/wp-content/uploads/2021/06/ASA_17_4137-2021_Full_report_ENG.pdf.
39 Freedom House, “Freedom in the World 2023: Tibet,” Freedom House, 2024,
https://freedomhouse.org/country/tibet/freedom-world/2023.
40 Adrian Zenz, “Xinjiang’s System of Militarized Vocational Training Comes to Tibet,” China Brief, Volume 20 Issue 7 (2020): https://jamestown.org/program/jamestown-early-warning-brief-xinjiangs-system-of-militarized-vocational-training-comes-to-tibet/.
41 Adrian Zenz, “The Conceptual Evolution of Poverty Alleviation Through Labour Transfer in the Xinjiang Uyghur Autonomous Region,” Central Asian Survey, 2023, https://doi.org/10.1080/02634937.2023.2227225; “Tibet: A Glossary of Repression,” Human Rights Watch, April 27, 2022, https://www.hrw.org/video-photos/interactive/2017/06/20/tibet-glossary-repression.
42 Gloria Davies, “A Dream of Perpetual Rule,” in China Dreams, ed. Jane Golley et. al. (Canberra: Australian National University Press, 2020), 20-23.
43 “Tibet: A Glossary of Repression,” Human Rights Watch, April 27, 2022, https://www.hrw.org/video-photos/interactive/2017/06/20/tibet-glossary-repression.
44 “Labor absorption”: The Fourth Session of the Eleventh People’s Congress of the
Tibet Autonomous Region,“西藏自治区国民经济和社会发展第十四个五年规划和二〇三五年远景目标
纲要——2021 年 1 月 24 日西藏自治区第十一届人民代表大会第四次会议通过 (The 14th Five-Year
Plan for the National Economic and Social Development of the Tibet Autonomous
Region and the Outline of the Long-Term Goals for 2035—January 2021),” 48:
https://perma.cc/4ZSZ-MADF. “Transfer employment”: “西藏自治区“十三五”时期脱贫攻坚规划
（2016—2020年）(Tibet Autonomous Region’s Poverty Alleviation Plan during the 13th
Five-Year Plan Period (2016-2020)),” 48: https://perma.cc/W6EK-MELH. “Labor export”: Id., 64.
Also discussed in conversation with Adrian Zenz and mentioned in the context of the Uyghur region in: Adrian
Zenz, “Coercive Labor and Forced Displacement in Xinjiang’s Cross-Regional Labor Transfers: A Process-Oriented
Evaluation,” The Jamestown Foundation, 2021, https://jamestown.org/wp-content/uploads/2022/03/Coercive-Labor-
and-Forced-Displacement-in-Xinjiangs-Cross-Regional-Labor-Transfers-A-Process-Oriented-Evaluation_Updated-December-2021_.pdf?x32853; Adrian Zenz, “The Conceptual Evolution of Poverty Alleviation Through Labour Transfer in the Xinjiang Uyghur Autonomous Region,” Central Asian Survey, 2023, https://doi.org/10.1080/02634937.2023.2227225; Adrian Zenz, “Xinjiang’s System of Militarized Vocational Training Comes to Tibet,” China Brief, Volume 20 Issue 7. 2020, https://jamestown.org/program/jamestown-early-warning-brief-xinjiangs-system-of-militarized-vocational-training-comes-to-tibet/.
45 Adrian Zenz, “Submission to the U.S. Department of State Office to Monitor and Combat Trafficking in Persons 2024 Trafficking in Persons (TIP) Report,” Victims of Communism Memorial Foundation (2024), 9-10, https://victimsofcommunism.org/wp-content/uploads/2024/02/2024-01-VOC-TIP-Submission-for-publication.pdf.
46 Adrian Zenz, “Xinjiang’s System of Militarized Vocational Training Comes to Tibet,” China Brief, Volume 20 Issue 7. 2020, https://jamestown.org/program/jamestown-early-warning-brief-xinjiangs-system-of-militarized-vocational-training-comes-to-tibet/.
47 Zijin Mining Group Co., Ltd., “Company Profile-Zijin Mining Group Co., Ltd.,” Zijin Mining Group Co., Ltd., 2022, https://perma.cc/64TT-PYQM.
48 C4ADS, “Fractured Veins: The World’s Reliance on Minerals From the Uyghur Region,” (2023): 25,
https://c4ads.org/wp-content/uploads/2023/10/Fractured-Veins-spreads-final.pdf: “Likewise, official media reports indicate that Zijin’s mines have been the site of labor transfers, with one report stating it had ‘solved the employment’ of up to 800 workers [….] Both companies are paired with local villages where they carry out assimilative programs […] while the government has recognized Zijin for programs associated with assimilation initiatives.”
49 “Zijin Mining to Acquire Majority Stake in Tibet Julong Copper for $548M,” NS Energy, June 8, 2020, https://www.nsenergybusiness.com/news/zijin-mining-majority-stake-tibet-julong-copper/.
50 Zijin Mining Group Co., Ltd., “Zijin Mining to Acquire the Lakkor Tso Lithium Project in Tibet,” Zijin Mining Group Co., Ltd., 2022, https://web.archive.org/web/20240310055820/https://www.zijinmining.com/news/news-
detail-119325.htm.
51 GlobalData, “The Five Largest Copper Mines in Operation in China,” Mining Technology, July 21, 2023,
https://www.mining-technology.com/marketdata/five-largest-copper-mines-china/?cf-view.
52 China Tibet News Network, “拉萨市墨竹工卡县赤康村提升共商共议共治共享水平 (Chikang
Village, Mozhugongkar County, Lhasa City Improves the Level Of Consultation,
Discussion, Governance and Sharing),” Sina Finance, 2023, https://perma.cc/RQA7-NVPE.
53 Id.: “输出劳动力170人,”.
54 Id.: (“在村党委领导下，在驻地两大矿企的支持和全体村民的共同努力下，2022年，村集体收入增长至 217万元，完成了180人次的各类培训，输出劳动力170人，实现劳务创收3200万元”).
55 People's Government of Menba Township, Mozhugongka County, “门巴乡2019年人民政府
工作报告 (Menba Township 2019 People's Government Work Report),” People's
Government of Menba Township, Mozhugongka County, 2021,
https://web.archive.org/web/20240301210116/http://www.xzmzgk.gov.cn/mzfkxzf/zfgzbg/202112/f55b2bc3f6fe4f309ba602931c232bd4.shtml: “位转移就业38人,”.
57 Id.
58 Zijin’s 2022 semi-annual report also mentions the company and its subsidiaries
cooperating with governmental poverty alleviation agencies, with Julong Copper
promoting “border prosperity and ethnic unity” in Tibet, and paying relocation
compensation to people in Maizhokunggar County: “案例：西藏巨龙铜业围绕促进兴边富民和
民族团结工作，2022 年上半年在墨竹工卡县甲玛乡 社会捐赠、产业扶持、搬迁补偿、南北山绿化工程、环 境恢复等方面累计支出约 1,700 余万元， 招聘当地藏族大学生和员工约 200 余人，为当地经济社会、环境 、民生就业做出了突出贡献。” Relocation performed according to governmental poverty
alleviation efforts is another potential risk factor for the disruption of Tibetan
traditional livelihoods. Zijin Mining Group Co., Ltd., “紫金矿业集团股份有限公司 2022 年半
年度报告 (Zijin Mining Group Company Limited Interim Report 2022),” (2022): 26,
https://perma.cc/9J2F-9TZZ?type=standard; Correspondence with Adrian Zenz, February 29, 2024.
59 China Gold International Resources Corp. Ltd., “Company Overview,” (2021),
https://web.archive.org/web/20240310060759/https://www.chinagoldintl.com/corporate/overview/.
60 Tibet Huatailong is the same mining group that had seized water from Jiama village during a 2009 drought, whose members had tortured Tibetan villagers, and whose boss had encouraged the killing of Tibetan villagers. Radio Free Asia,“甲瑪人講述甲瑪開礦帶來的災難 (Jiama people talk about the disaster caused by Jiama mining),” Tibet Bulletin May-June 2013, (12-13), https://xizang-zhiye.org/wp-
content/uploads/2017/09/2013-5-6.pdf. According to CCP media, many Tibetan villagers were also opposed to
mining in Jiama town because it was disrespectful to the spirits—until they all miraculously changed their minds
and went to work in the mines. Du Juan, “Mining to become key to Tibet’s economy,” China Daily, 2012,
https://perma.cc/SDA2-LTZR. Relevant citations regarding China Gold International: China Gold International
Resources Corp. Ltd., “Jiama Copper Gold Polymetallic Mine,” (2023),
https://perma.cc/W9XD-PJFL; Beijing Zhonghuan Geyi Technology Consulting Co. Ltd., “西藏华泰龙矿业开发有
限公司甲玛铜多金属矿项目环保技术咨询服务 (Environmental protection technology
consulting services for the Jiama Copper Polymetallic Mine Project of Tibet
Huatailong Mining Development Co., Ltd.),”
https://web.archive.org/web/20240310040633/https://www.china-
eia.com/bjzhgy/sy_11525/fwal/202306/t20230602_1032337.shtml; Cynthia D’Cruz and Carole Samdup, “Request
for Review Submitted to Canada’s National Contact Point Pursuant to the OECD Guidelines for Multinational
Enterprises, Specific Instance Regarding: The Operations of China Gold International Resources Corp. Ltd., at the
Copper Polymetallic Mine at the Gyama Valley, Tibet Autonomous Region,” Canada Tibet Committee (2014): 2,
https://www.ohchr.org/sites/default/files/Documents/Issues/FAssociation/NaturalResource/Canada_Tibet_Committe
e1_E.pdf; GlobalData, “The Five Largest Copper Mines in Operation in China,” Mining Technology, July 21, 2023,
https://www.mining-technology.com/marketdata/five-largest-copper-mines-china/?cf-view; Conversation with the
Canada-Tibet-Committee December 19, 2024.
61 Ministry of Agriculture and Rural Affairs of the People's Republic of China, “习近平
论脱贫攻坚 (Xi Jinping on Poverty Alleviation),”
https://web.archive.org/web/20240404185939/http://www.moa.gov.cn/ztzl/xjpgysngzzyls/zyll/202106/t20210615_6369587.htm.
62 For 377 Tibetans by 2018, and for them engaging in such employment in the context of government policy, see P.62-63 of China Gold International Resources Corp., Ltd., “ 环境、社会及管治报告2018 (Environmental, Social, and Governance Report 2018),” (2018), https://perma.cc/XJ39-8J6U: “公司在西藏、內蒙古兩個少數民族地區大 量吸納和安排當地勞動力就業，積極支持和帶動地方經濟發展。截至 2018 年底，內蒙古太平公司和西藏華 泰龍公司少數民族員工比例分別為 10% 和 36%。”, with the recruitment of the 377 Tibetans being described as a case study of such absorption and arrangement of employment: “截至 2018 年，公司錄用藏族員工 達 377 人， 約占公司職工總人數的 36%” and with the government policy being “两年脱贫，三 年巩固”.
63 Id.: “大量吸納和安排當地勞動力就業”
64 Id., 62-63.
65 Lhasa Municipal Development and Reform Commission, Beijing Tsinghua Tongheng
Planning and Design Institute Co., Ltd., Urban Development Planning Institute, “拉萨
市‘十三五’特色产业, (2017), https://perma.cc/V592-ZS5L. See P. 10 (“三年脱贫、两年巩固”) “poverty alleviation in three years, consolidation in two years,” and P. 83 (“两年脱贫，三年巩固”) “poverty alleviation in two years, consolidation in three years” in the context of employing Tibetans in poverty. For instance, P.83: “围绕”两年脱贫、三年巩固”的目标，通过产业扶贫，实现12028 建档立卡贫困人口以业脱贫，带动 59280 名贫困人口通过发展产业脱贫;实现到2020年，建档立卡贫困人口年人均可支配收入达到 6150 元。”
Both wordings have been seen, and it is assumed that these objectives are interchangeable. For further
references to policy mentioning “两年脱贫，三年巩固,” and “三年脱贫、两年巩固” see: Lhasa
Municipal Government Website, “拉萨市召开精准扶贫精准脱贫 (Lhasa holds a meeting on targeted
poverty alleviation), People’s Government of the Tibet Autonomous Region, 2016,
https://web.archive.org/web/20240310042605/https://www.xizang.gov.cn/xwzx_406/ztzl_416/gdzt/tpgj/201901/t20190117_48449.html; Tibet Daily, “因地制宜才能 ‘‘搬得出留得住” (Only by adapting to local conditions can we ‘move out and stay’),” Tibet Autonomous Region People’s
Government (2018),
https://web.archive.org/web/20240705152611/http://www.xizang.gov.cn/xwzx_406/xwrp/201812/t20181217_29762.html.
66 “该公司共吸纳转移就业农牧民435人” from China Tibet News Network, “西藏华泰龙吸纳转移就业
农牧民435人 (Tibet Huatailong absorbs 435 farmers and herdsmen who have transferred to work),” Ali District Administrative Office (2020),
https://archive.is/XiZfl#selection-1017.485-1017.626.
67 For 435 transferred herdsmen by 2020: “自脱贫攻坚工作开展以来，西藏华泰龙矿业开发有限公司在脱贫攻 坚工作中，通过有力措施助力农牧民转移就业。截至目前，该公司共吸纳转移就业农牧民435人，每月增加 劳务收入逾300万元。” Id.
68 For additional cases of labor transfer in 2023, see China Tibet News Network, “拉萨
市墨竹工卡县赤康村提升共商共议共治共享水平 (Chikang Village, Mozhugongkar County, Lhasa
City Improves the Level Of Consultation, Discussion, Governance and Sharing),” Sina
Finance, 2023, https://perma.cc/RQA7-NVPE. Finally, see Tibet Daily, “嘎玛泽登在西藏华泰龙矿业和巨龙
铜业调研时强调落实高质量发展要求 勇扛政治责任 体现国企担当 推动矿山企业依法安全绿色健康发展
(During his research at Tibet Huatailong Mining and Julong Copper, Gama Tsedeng
stressed the need to implement high-quality development requirements, shoulder political responsibilities, and demonstrate the responsibility of state-owned enterprises to promote the safe, green and healthy development of mining enterprises in accordance with the law),” Tibet Autonomous Region Ethnic Affairs Committee, (July 2024),
https://archive.is/On4jT#selection-275.0-275.347, where Karma Zeden, the Executive Vice Chairman of the Tibet Autonomous Region, visited Tibet Huatailong and Julong Copper and instructed both companies to “absorb employment” (“吸纳就业”).
69 This key form of financial assistance is known as “minimum living security
allowance”: “第六十四条 最低生活保障家庭中有就业能力但未就业的成员,应当接受人力资源社会保障
等有关部门介绍的工作。无正当理由连续3次拒绝接受介绍与其健康状况、劳动能力等相适应的工作的,县 级人民政府民政部门应当决定减发或者停发其本人的最低生活保障金。” Such Tibetans will also be
ineligible to reapply for minimum living security allowances. See General Office of
the Autonomous Region People’s Government, “西藏自治区人民政府关于印发《西藏自治区最低
生活保障实施办法》的通知 (Notice of the People's Government of the Tibet Autonomous Region on Issuing the ‘Implementation Measures for Minimum Living Security in the Tibet Autonomous Region’),” Tibet Autonomous Region People’s Government (March 2023),
https://web.archive.org/web/20240423033159/https://www.xizang.gov.cn/zwgk/xxfb/zfwj/202303/t20230322_347178.html. For an example of Tibetans’ reliance on minimum living security allowance, see Li Zaili, “Authorities Use Welfare Payments Against Tibetan Buddhists,” Bitter Winter, 2019, https://bitterwinter.org/welfare-payments-used-against-tibetan-buddhists/.
70 An earlier 2017 law explicitly states that Tibetans who refuse to participate in
labor transfer/export (“就业培训和劳务输出的”) will be ineligible to apply for minimum
living security allowance: General Office of the People’s Government of the
Autonomous Region, “西藏自治区人民政府办公厅关于印发《西藏自治区城乡最低生活保障实施办法
（试行）》的通知 (Notice of the General Office of the People’s Government of the Tibet
Autonomous Region on the issuance of the ‘Implementation Measures for Urban and Rural Minimum
Living Security in the Tibet Autonomous Region (Trial),” Tibet Autonomous Region People’s Government, (November 2017), https://perma.cc/P4VD-P6GQ.
71 These events took place in 2021. Sasa Dragojlo, “‘Like Prisoners’: Chinese Workers in Serbia Complain of Exploitation,” Balkan Insight, 2021, https://balkaninsight.com/2021/01/26/like-prisoners-chinese-workers-in-serbia-complain-of-exploitation/; “Workers At Chinese-Owned Mine In Serbia Protest For Better Wages, Working Conditions,” Radio Free Europe Balkan Service, 2023, https://www.rferl.org/a/serbia-bor-mine-protests-working-conditions-wages/32221562.html.
72 Cynthia D’Cruz and Carole Samdup, “Request for Review Submitted to Canada’s National Contact Point Pursuant to the OECD Guidelines for Multinational Enterprises, Specific Instance Regarding: The Operations of China Gold International Resources Corp. Ltd., at the Copper Polymetallic Mine at the Gyama Valley, Tibet Autonomous Region,” Canada Tibet Committee (2014),
https://www.ohchr.org/sites/default/files/Documents/Issues/FAssociation/NaturalResource/Canada_Tibet_Committee1_E.pdf.
73 Freedom House, “Freedom in the World 2023: Tibet,” Freedom House, 2024,
https://freedomhouse.org/country/tibet/freedom-world/2023.
74 (“班里面9/10是藏族人，需要克服的很多很多……”) From “在「紫金矿业」工作或实习是一种怎样的体 验? (What is it like to work or intern at Zijin Mining?),” Zhihu (2023),
https://perma.cc/L3PH-LAWU.
75 Id. This post has not been verified.
76 Also, in May 2024, Zijin signed a strategic agreement with the U.S.-sanctioned company Huawei to develop AI: “紫金矿业集团与华为签署战略合作框架协议 (Zijin Mining Group and Huawei sign strategic cooperation framework agreement),” Securities Times, 2024,
https://web.archive.org/web/20240708154839/https://www.stcn.com/article/detail/1214755.html.
77 China National Gold Group Co., Ltd. Centralized Procurement Tendering Center, “西藏华泰龙
矿业开发有限公司保安劳务服务项目招标公告 (Tibet Huatailong Mining Development Co., Ltd.
Security Labor Service Project Tender Announcement),” China National Gold
(Shanghai) Trading Co., Ltd. (2022), https://perma.cc/YQX6-6766: “盗窃、抢劫、斗殴、破坏等治安
刑事事件” and “非法集会或活动.”
78 China Gold, “扎根雪域铸伟业 开发建设树丰碑–中国黄金集团华泰龙公司服务西藏发展稳定大局、建设绿 色和谐先锋矿山的专题调研 (Taking root in the snowy region, creating great achievements, developing and constructing monuments–China National Gold Group Huatailong Company’s special research on serving the overall development and stability of Tibet and building a green and harmonious pioneer mine),” Tibet Huatailong Mining Development Co., Ltd., (2014), https://perma.cc/F6N8-KGWD.
79 Ren Baorong, “西藏自治区首个企业型基层人武部成立 (The Tibet Autonomous Region’s first
enterprise-based grassroots People’s Armed Forces Department was established),”
The Lhasa Municipal People’s Government, (2021), https://perma.cc/62PV-D4VS; Yang Bao Cizen,
“华泰龙矿业开发有限公司人民武装部揭牌仪式举行 (The unveiling ceremony of the Ministry of
People’s Armed Forces of Huatailong Mining Development Co., Ltd. was held),” Lhasa Daily, Lhasa Municipal Committee of the Communist Party of China, (2021),
https://perma.cc/9G2L-LBRR.
80 Testimony also exists about children of pastoral Tibetans being coerced into vocational training schools such as the Tibet Vocational and Technical College. See: Dan Zhen, “西藏农牧民子女遭强制‘爱国’教育 (Children of Tibetan farmers and herders are forced to receive “patriotic” education),” Radio
Free Asia, 2019, https://www.rfa.org/mandarin/yataibaodao/shaoshuminzu/dz-10292019122807.html. One graduate from the Tibet Vocational and Technical College was described as joining Julong Copper in the context of their rural labor transfer schemes: China Tibet
News Network, “拉萨市墨竹工卡县赤康村提升共商共议共治共享水平 (Chikang Village,
Mozhugongkar County, Lhasa City Improves the Level Of Consultation, Discussion,
Governance and Sharing),” Sina Finance, 2023, https://perma.cc/RQA7-NVPE. Given this dynamic,
a potential connection between these vocational schools and company recruiting initiatives deserves further investigation. If such a connection is present, it could suggest the existence of a second, possibly-related coercive pipeline, beginning with Tibetan children being forced into vocational skills training institutes, and ending with them graduating directly into these companies’ workforces.
81 “Zijin Mining Group,” Linkedin, (2024), https://perma.cc/M6JA-AW7D.
82 Yana Ermak, “Canadian government allows Chinese acquisition of Canadian lithium miner,” Foreign Investment and National Security Blog, Baker McKenzie, (2022),
https://foreigninvestment.bakermckenzie.com/2022/02/16/canadian-government-allows-chinese-acquisition-of-canadian-lithium-miner/.
83 “剩余劳动力” and “搬迁” Tibet Mining Development Co., Ltd., “Full Text of Tibet Mining
Development Co., Ltd. 2020 Annual Report,” Sohu.com, (2021), https://perma.cc/RD2V-TMBA.
84 Sheffield Hallam University et. al, “Steel,” Driving Force: Automotive Supply Chains and Forced Labor in the Uyghur Region, (2022), https://www.shuforcedlabour.org/drivingforce/sector/steel/; Baowu/Tibet Mining Development Co., Ltd., “西藏矿业发展股份有限公司2023年半年度报告 (Tibet Mining Development Co., Ltd. 2023 Semi-Annual Report),” sohu.com, (2023),
https://perma.cc/U3VD-4WD5: P. 24, explicitly refers to labor transfer, and P. 1 implicates Baowu as a parent organization of Tibet Mining. See also entry number 28 in the first attachment (“转移就业基地名单”) at https://perma.cc/RW8U-FCKF from Municipal Human Resources and Social Security Bureau, “关于农牧民转移就 业基地奖励资金申报的公告 (Announcement on Application for Reward Funds for Farmers and Herdsmen’s Transfer of Employment Bases),” Shannan Municipal People’s Government, (2024),
https://web.archive.org/web/20240422224931/http://www.shannan.gov.cn/zwgk/zfxxgkml/gsgg/202404/t20240412_133959.html, which lists Tibet Mining’s Shannan branch as a “relocation employment base” in 2024.
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