Responsible Minerals Procurement Policy

CSR

DOWA Group Responsible Minerals Procurement Policy

In order to establish a responsible supply chain in line with its corporate philosophy, the policy of the DOWA Group is to refrain from using as raw materials minerals (tantalum, tungsten, gold, tin, and silver) that could be a source of funds for organizations linked to risks such as infringement of human rights, supply of funds to terrorists, money laundering and corruption, or to other forms of misconduct in conflict-affected and high-risk areas.

1. General Provisions

  1. The DOWA Group will not directly or indirectly contribute to the mining, trading, handling, and export of minerals (tantalum, tungsten, gold, tin, and silver) that could be a source of funds for organizations linked to risks such as infringement of human rights, supply of funds to terrorists, money laundering and corruption, or to other forms of misconduct in conflict-affected and high-risk areas.
    This includes specifically:
    Serious abuses associated with the extraction, transport or trade of minerals:
    • Any forms of torture, cruel, inhuman and degrading treatment
    • Any forms of forced or compulsory labor
    • The worst forms of child labor
    • Other gross human rights violations and abuses such as widespread sexual violence
    • 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 that are conducting illegal activities
    Bribery and fraudulent misrepresentation of the origin of minerals
    • Money laundering
    • Non-payment of taxes, fees and royalties to governments
  2. The DOWA Group will perform risk management in the procurement of raw materials and immediately discontinue transactions when it is judged that minerals (tantalum, tungsten, gold, tin, and silver) could be a source of funds for organizations linked to risks such as infringement of human rights, supply of funds to terrorists, money laundering and corruption, or to other forms of misconduct in conflict-affected and high-risk areas.
  3. The DOWA Group will engage independent third-party auditors on a regular basis to review the smelting, refining and recycling of gold, tin, and silver.

2. Control System and Responsibility

  1. The headquarters of the DOWA Group will deal with the procurement of mineral materials used by the Group’s smelting and refining divisions and recycling divisions, supplying materials to the smelters and refineries and the recycling plants that they manage. The Resource Development & Raw Materials Department at DOWA METALS & MINING CO., LTD. and the Recycling Business Unit at DOWA ECO-SYSTEM CO., LTD. will control the procurement of materials.
  2. The headquarters of the DOWA Group or the manufacturing subsidiaries themselves will be responsible for the proper procurement of mineral materials used by the Group’s manufacturing subsidiaries, supplying materials to the manufacturing subsidiaries that they manage. The Metal-processing Division at DOWA METALTECH CO., LTD., DOWA HIGHTECH CO., LTD., DOWA SEMICONDUCTOR AKITA CO., LTD. and other DOWA Group subsidiaries will control the procurement of materials.
  3. The DOWA Group will appoint a manager with responsibility for ensuring compliance with the Responsible Minerals Procurement Policy. The manager with responsibility for the responsible procurement of minerals will oversee the whole management system and assume the authority and responsibility stipulated in the control manual.

3. Judgment Criteria for Material Procurement from High-risk Countries

The DOWA Group considers the material procurement of tantalum, tungsten, gold, tin and silver from conflict-affected and high-risk areas that could be a source of funds for organizations linked to risks such as infringement of human rights, supply of funds to terrorists, money laundering and corruption, or to other forms of misconduct to be high-risk material procurement.

4. Operation of the Conflict Minerals Control System

(1) Due Diligence relating to Material Suppliers

  • The DOWA Group will implement due diligence for all suppliers of materials containing gold, silver, and tin(*), and perform risk assessment proportionate to the identified risk. The DOWA Group will discontinue transactions that the manager with responsibility for the control of conflict minerals deems to be high risk.
    (*)Excludes recycled tin materials

(2)Monitoring of Transactions

1)Materials Accepted at Smelters and Refineries
  • Smelters and refineries will check materials received for to ensure the actual goods are those described in transaction information at the time of procurement and report the findings on non-conformance to the division in charge at headquarters.
  • The DOWA Group will conduct regular internal audits to ensure due diligence of suppliers is executed properly. The DOWA Group will engage independent third-party auditors to perform audits regarding gold, tin and silver materials.
2)Materials Accepted at Recycling Plants
  • Recycling plants will check with the supplier to confirm that the recycled materials accepted (recycled materials or scrap) have lost their original function or are no longer required and report the findings to the division in charge at headquarters.
3)Materials Accepted at Manufacturing Subsidiaries
  • Manufacturing subsidiaries will check materials accepted for consistency of the actual goods with the transaction information at the time of procurement and report the findings to the division in charge at headquarters.
  • The Dowa Group will conduct regular internal audits to ensure whether due diligence for suppliers is executed soundly.

(3)Training

  • The DOWA Group will provide the education and training necessary for headquarters divisions, smelters and refineries, recycling plants and manufacturing subsidiaries on a regular basis to conduct their operations in conformance with the responsible procurement policy.

(4)Retention of Records

  • The manager responsible for the responsible procurement of minerals will stipulate the records that must be retained concerning the control of conflict minerals, establish the period of retention and manage the records.

Enactment : August, 2012
Final revision : March, 2019

Please refer below for the results of the audit on responsible minerals procurement.


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