Responsible materials procurement policy

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Company Policy for the Sourcing Precious Metals

gold

We follow the Due Diligence Guidance for Responsible Supply Chains of Minerals from OECD Conflict and High-Risk Areas. We avoid risks such as human rights violations, terrorist financing, money laundering, and fraudulent transactions in conflict areas and high-risk areas, and promote corporate activities so that customers can be assured for using our products.

  • We 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 and other types of severe abuses, including 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
  • Establishing a management system for responsible sourcing of materials
  • We establish an appropriate management system to effectively conduct supply chain due diligence on gold, platinum and palladium raw materials.

  • Identifying high-risk raw material procurement
  • We 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, and money laundering 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, or money laundering, risk mitigation is undertaken. If risk mitigation is not possible, transaction is immediately suspended.

  • Implementation of training
  • We provide the necessary training to all employees involved in responsible supply chains continuously.

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

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

    Revised on January 1, 2022