Compliance with the RBA Code of Conduct and Promotion of Responsible Minerals Procurement

Each company of the Senju Metal Industry Group (Senju Metal Industry Co., Ltd. and its affiliated companies) is a member of the RBA (Responsible Business Alliance, formerly the EICC) *1, and acts or confirms as follows:

1. Each company of the Senju Metal Industry Group comply with the Code of Conduct established by the RBA and respects the OECD Due Diligence Guidance for Responsible Business Conduct by the OECD (Organisation for Economic Co-operation and Development).

2. Each company of the Senju Metal Industry Group complies with Section 1502 of the Dodd-Frank Act, the SEC’s final rule *2, as well as the Regulation (EU) 2017/821 *3. We confirm that tin, tantalum, tungsten and gold (hereinafter referred to as 3TG) from conflict-affected high-risk areas (CAHRAs), including the Democratic Republic of the Congo (DRC) and its nine adjoining countries, are free of risk minerals. In addition to 3TG, we undertake due diligence on cobalt within the framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas to promote the procurement of safe minerals.

3. Each company of the Senju Metal Industry Group agrees with the purpose of the RMI (Responsible Minerals Initiative, formerly the CFSI) *4, and requests that all refineries supplying tin (Sn) metal participates in and adheres to the RMAP (Responsible Minerals Assurance Process, formerly the Conflict-Free Smelter Program) *5 implemented by RMI.

4. Currently, each company of the Senju Metal Industry Group confirmed that all products are manufactured using conflict free materials. For tin (Sn) metal, all the smelters have been validated as RMAP-conformant, and on-site audits are conducted as necessary.

5. If any new raw material is found to be a conflict material, each company of the Senju Metal Industry Group will immediately cease the purchasing and using of such raw materials.

6. Each company of the Senju Metal Industry Group accepts an audit by a third-party institution designated by RBA.

7. Each company of the Senju Metal Industry Group will, upon request from a customer, provide the customer with the list of smelters using the Conflict Minerals Reporting Template (CMRT) and Extended Minerals Reporting Template (EMRT) issued by RMI.

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February 2024
Senju Metal Industry Co., Ltd.
Operating Officer / Counselor
CSR Committee General Manager
Motoyuki Ohtake

 

*1 : RBA (Responsible Business Alliance, formerly the EICC)

http://www.responsiblebusiness.org/

*2 : Section 1502 of the U.S. Dodd-Frank Act and the SEC final rules

https://www.govinfo.gov/content/pkg/COMPS-9515/pdf/COMPS-9515.pdf
https://www.sec.gov/rules/final/2016/34-78321.pdf

*3 : Regulation (EU) 2017/821

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R0821
https://op.europa.eu/en/publication-detail/-/publication/8b0e378b-3c59-11e7-a08e-01aa75ed71a1/language-en

*4 : RMI (Responsible Minerals Initiative, formerly the CFSI)

http://www.responsiblemineralsinitiative.org/

*5 : RMAP (Responsible Minerals Assurance Process, formerly the CFSP)

https://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/