Conflict Mineral Policy

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Company Policy for the Sourcing Precious Metals


Recognizing that risks of significant adverse impacts which may be associated with obtaining, refining and trading gold bearing materials from conflict-affected and high-risk areas, and recognizing that we have the responsibility not to contribute to any armed group, we commit not to adopt, distribute and incorporate in contracts and/or agreements with suppliers sourcing of gold and/or gold-bearing materials from conflict-affected areas. We commit to refraining from any action which contributes to the financing of conflict. We state not to obtain any materials originating from conflict-affected areas.

  • Management System for Sourcing Conflict Free Materials
    • We will maintain the Management System in effective way to avoid trading, refining and handling conflict materials that directly or indirectly finance or benefit armed groups from conflict-affected regions.
  • Sourcing Gold Bearing Materials
    • Gold and/or gold bearing materials originating from the Democratic Republic of the Congo (DRC) and adjoining countries are sometimes mined and sold by armed groups to finance unfair labor practices or human rights violations. Some of these minerals and/or derivatives can make their way into the supply chains of the products used around the world. It is our policy to avoid conflict mineral(s) that directly or indirectly finance or benefit armed groups from conflict-affected regions.
  • Evaluation of Gold Bearing Material and Supplier
    • We evaluate gold bearing materials and the suppliers to avoid sourcing from such areas. If by any chance gold bearing materials from these areas were found in our supply chain, we immediately discontinue sourcing the materials.
  • Employee Training
    • We continue to exercise and encourage our employees to understand conflict-free policy.
  • Record Keeping
    • We maintain record keeping of each gold and gold bearing material transaction to confirm that each transaction is transparent and complies with our policy.
  • Third Party Audit
    • We continue to be audited by an auditing firm appointed by EICC in regulated period for purpose of confirming that the management system is effectively conducted for trading, refining, and handling gold and gold bearing materials.

Revised on March 2, 2015