Policy for Responsible Mineral Sourcing

The Yokohama Metal Group shall promote action for responsible mineral sourcing that takes account of human rights, the environment, ethics,related laws and regulations, international rules, and other items, based on the RBA Code of Conduct, the Charter of Corporate Behavior, and corporate social responsibility (CSR).
In accordance with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, we shall not be a party to support, whether direct or indirect, for the mining, transaction, handling, or export of minerals (tantalum, tungsten, gold, tin, silver, and cobalt) that could be sources of funding for organizations involved in all sorts of risks and improprieties in conflict-affected and high-risk areas, including child labor and other infringements of human rights, funding for terrorists, money laundering, unlawful transactions, corruption, support for armed conflict, and other kinds of illegal acts.
The Yokohama Metal Group has determined policy for responsible mineral sourcing in recognition of the importance of　managing risks in transactions related to gold in its sourcing of raw materials.

The aforementioned risks and improprieties include the following.

●Serious abuses of human rights in connection with the mining, transportation, and transaction of minerals

1. 1.Any forms of torture, cruel, inhumane, and degrading treatment
2. 2.Any forms of forced or compulsory labor
3. 3.The worst forms of child labor
4. 4.Other gross human rights violations and abuses such as widespread sexual violence
5. 5.War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide

●Direct or indirect support to non-state armed groups

●Direct or indirect support to public or private security forces engaged in illegal activity

●Giving or taking of bribes, and fraudulent misrepresentation of the origin of minerals

1. – Money laundering
2. – Non-payment of taxes, fees and royalties due to governments

1. Construction of a system for control

Upon instituting a secretariat to implement risk assessment (due diligence) for the mineral supply chain and preparing a system for related control, we shall appoint a corporate director to be in charge of such control, and execute it for responsible mineral sourcing.

2. Specification of high-risk raw material sourcing

In accordance with the guidance of the OECD and other organizations, we shall specify the sourcing of raw materials from conflict-affect and high-risk areas that could be sources of funding for organizations involved in all sorts of risks and improprieties, including child labor and other infringements of human rights, funding for terrorists, money laundering, unlawful transactions, corruption, support for armed conflict, and other kinds of illegal acts, as high-risk raw material sourcing.

3. Assessment of sourced raw materials and suppliers

Under our system of control for responsible mineral sourcing and in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of　Minerals from Conflict-Affected and High-Risk Areas, we shall implement risk assessment (due diligence) for raw materials sourced and supply chains for gold on a continuous basis, and properly store and manage the assessment records.
In the event that the assessment finds an involvement with armed conflict or that the mineral is, or has a high possibility of being, a source of funding for organizations involved in all sorts of risks and improprieties, including child labor and other infringements of human rights, funding for terrorists, money laundering, unlawful transactions, corruption, support for armed conflict, and other kinds of illegal acts, we shall have the supplier in question take steps to mitigate such risks. If the supplier is unable to mitigate such risks, we shall immediately suspend the transactions in question.

4. Implementation of education and training

We shall implement the requisite education and training on a continuous basis for all organizational units and assigned personnel involved in responsible mineral sourcing.

5. Transaction monitoring and retention of records

We shall monitor transactions to ensure that the raw materials sourced correspond with the information obtained from the supplier, and properly store and manage the records from this monitoring.

6. Implementation of third-party audits

In accordance with the Responsible Minerals Initiative (RMI) guidance, we shall have an independent third-party organization periodically audit our system for and implementation of responsible supply chain management.

Date of formulation: December 1, 2012
Date of last revision: February 1, 2020
Yokohama Metal Co., Ltd.