JAPANESE
Responsible Precious Metals Sourcing Policy
In order to maintain the trust of our customers and society, Nihon Material Co., Ltd. promotes Corporate Social Responsibility (CSR) and advances management practices that emphasize Environmental, Social and Governance (ESG) principles, conducting its business in a lawful and ethical manner.With regard to the procurement of precious metal materials, including gold, platinum and palladium, the Company complies with Annex II of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, as well as the responsible sourcing guidance established by the London Bullion Market Association (LBMA) and the London Platinum and Palladium Market (LPPM) (LBMA Responsible Gold Guidance Version 9 and LPPM Responsible Platinum and Palladium Guidance Version 5).
Based on this policy, the Company seeks to eliminate risks related to human rights abuses, conflict, environmental damage, corruption, sanctions violations and theft, and to prevent money laundering and terrorist financing. The Company also requests that its business partners establish and implement their own policies in line with this policy and with principles equivalent to, or based on, OECD Annex II and related responsible sourcing guidance.
1. Establishment of a Management Framework
To effectively implement supply chain due diligence for precious metal materials, the Company establishes a management framework centered on a designated compliance officer and subject to oversight by senior management. Reporting to senior management shall be conducted as necessary, and this policy and related procedures shall be reviewed on a regular basis.2. Identification of High-Risk Precious Metals Procurement
The Company defines as high-risk precious metals procurement any transaction that may involve precious metal materials originating from conflict-affected or human rights high-risk areas, transactions in which responsibilities related to environmental protection and sustainability are not considered to be sufficiently fulfilled, or transactions suspected of being associated with money laundering, theft, sanctions violations, direct or indirect support to illegitimate non-state armed groups or public or private security forces, bribery, fraudulent misrepresentation of the origin of precious metals, non-compliance with taxes, fees or royalties payable to governments in connection with mineral extraction, trade or export, or transactions in which involvement of anti-social forces, environmental destruction, human rights abuses, or ethical or governance-related issues is suspected, and the Company shall conduct appropriate due diligence with respect to such transactions.3. Evaluation of Precious Metal Materials and Supply Chains
Where the results of risk assessments of precious metal materials and their supply chains indicate that the procurement constitutes high-risk precious metals procurement, the Company shall suspend the relevant transactions and request corrective actions from the supplier. If risk mitigation is not feasible, the Company shall immediately terminate the transactions, and the results of the risk assessments shall be appropriately documented and retained.4. Education and Training
The Company shall provide regular and continuous education and training to all relevant internal personnel, including senior management, who are involved in responsible precious metals sourcing, in order to ensure a thorough understanding of this policy and related internal regulations.5. Transaction Monitoring and Record Keeping
The Company shall continuously monitor the consistency between received precious metal materials and information provided by suppliers, and shall maintain accurate records. Where abnormal or suspicious transactions are identified, such matters shall be reported immediately to the responsible risk management personnel, appropriate corrective measures shall be implemented, and, where necessary, notifications shall be made to the relevant authorities.6. Third-Party Audit
The Company shall periodically undergo audits by independent third-party organizations regarding the structure and implementation status of its responsible precious metals sourcing framework and related risk assessment processes.7. Environmental, Social and Governance (ESG) and Sustainability Initiatives
Through responsible sourcing practices, the Company contributes to the realization of a sustainable society by promoting environmental protection, respect for human rights, and occupational health and safety.
Nobutake Morita
President
NihonMaterial Co.,Ltd.
Establishment December 1 2014
Revision Jan 5 2026
President
NihonMaterial Co.,Ltd.
Establishment December 1 2014
Revision Jan 5 2026
