Responsible materials procurement policy

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Company Policy for the Sourcing Precious Metals


We follow the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
Avoid risks such as human rights violations, terrorist financing, money laundering, illegal trade in conflict or high-risk areas, and source raw materials without embracing ESG(such as environmental and sustainability responsibility) risk factors.

  • General rules
  • ①We do not tolerate the following acts and will never benefit, compliment, support or promote them.

    • Human rights violations related to mineral mining, transportation and trading
      • All forms of torture, cruelty, inhumane and degrading treatment
      • All forms of forced labor
      • The worst form of child labor
      • Other significant human rights abuses, including widespread sexual violence
      • War crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide
    • Direct or indirect support for non-governmental armed groups
    • Direct or indirect support for public or private security forces committing illegal activities
    • Bribery and misrepresentation of mineral origin
    • Money laundering
    • Unpaid government taxes, fees, and mining rights fees

    ②We do not tolerate material violations of local laws and regulations related to the environment, health, safety, labor and communities, and ESG risks that are likely to have material adverse consequences.

  • Establishing a management system for responsible sourcing of materials
  • We will build a management system that complies with LPPM's RPPG (Responsible Platinum and Palladium Guidance) for platinum and palladium, and RMAP (Responsible Minerals Assurance Process) of RMI (Responsible Mineral Initiative) for gold.
    In order to effectively conduct supply chain due diligence, we will appoint a manager and establish an appropriate management system.

  • Identifying high-risk raw material procurement
  • We will identify high-risk areas in accordance with the OECD, LPPM and RMI guidance, and determine transactions that are suspected of being involved in armed forces, unfair labor practices, human rights violations, money laundering, ESG risks as high-risk procurement.

  • Assessment of raw materials and suppliers
  • If risk assessment of raw materials and suppliers reveals that they may be involved in human rights abuses, contributing to conflicts, money laundering, , or ESG risks mitigation is undertaken. If risk mitigation is not possible, transaction is immediately suspended.

  • Implementation of education and training
  • We will provide the necessary education and training to all employees involved in responsible supply chains on an ongoing basis.

  • Monitoring and record keeping of transactions
  • We will monitor incoming gold, platinum and palladium raw materials for consistency with information obtained from suppliers, and maintain records appropriately.

  • Third-party audits
  • In accordance with the guidance of RMI and LPPM, we will arrange for an independent third-party audit on the responsible supply chain management system and implementation status on a regular basis.

  • Whistleblowing and Grievance Mechanisms
  • We will set up a point of contact to receive reports and respond to whistleblowing and complaints. We will establish internal reporting system regulations to protect the confidentiality and personal information of consulters and whistleblowers.

    Revised on April 1, 2023