Responsible Precious Materials Management Policy

In order to build trust with customers and in society, Nihon Material Co., Ltd. promotes Corporate Social Responsibility (CSR) and conducts business in ethical and legally compliant manner.
With regard to the procurement of precious metals, we set up measures to avoid materials from high risk supply chains which contribute to conflict and human rights abuse, and to comply with high standards of anti-money laundering and combating the finance of terrorism, addressing environmental and sustainability responsibilities.

1. Management System

We establish an appropriate risk management system and internal controls in order to implement effective due diligence for supply chain of precious metals.

2. Determination of High-Risk Transactions

We recognize the purchasing of precious metals that originates from conflict affected or human right abuse high-risk area and/or is suspected to have any connection with money laundering, terrorist financing, anti social acts as a high-risk transaction, addressing environmental and sustainability responsibilities. We will implement appropriate due-diligence in order to avoid our involvement in such areas of activity.

3. Identification of Materials and Supply Chain

We will immediately suspend or terminate the transactions of any materials when we become aware, as a result of our evaluation of materials and suppliers, that the purchasing of precious metals is a high-risk transaction.

4. Employee Training

We will continue to provide periodical education and training to ensure that all staff members recognize our Responsible Precious Metals Material Management Policy and relevant regulations.

5. Monitoring and Record Keeping

We will monitor all supplied materials by collating all information acquired from suppliers. Records of all transactions shall be managed appropriately.

6. Third Party Audit

We will continue to be audited by an independent third party periodically concerning the design and implementation of our conflict materials management system.

Meiwa Morita
NihonMaterial Co.,Ltd.
Establishment December 1 2014
Revision May 26 2020

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