Procurement Policies of Conflict Minerals

CSR

Dowa Group Conflict Minerals Control Policy

Formulated: August 28, 2012
Revised: July 30, 2014

In order to establish a responsible supply chain in line with its corporate philosophy, the Dowa Group does not use conflict minerals (tin, tantalum, tungsten and gold) involving acts against humanity that are produced in the Democratic Republic of the Congo and its neighboring countries.

1. General Provisions

  1. The Dowa Group will not be a party to assisting acts against humanity either directly or indirectly in the mining, trading, handling or export of conflict minerals that originate from the conflict-affected areas (the Democratic Republic of the Congo and its nine neighboring countries).
  2. The Dowa Group will perform risk management on material procurement and immediately stop a transaction as soon as it is determined that the minerals originate from mining that involves acts against humanity in the conflict-affected areas.
  3. The Dowa Group will undergo regular independent third-party audits regarding gold smelting and gold recycling and refining.

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 it manages. The Resource Development & Raw Materials Department at Dowa Metals & Mining Co., Ltd. and the Environmental Management and Recycling Division 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 deal with the procurement of mineral materials used by the Group’s manufacturing subsidiaries, supplying materials to the manufacturing subsidiaries that it manages. The Metal-processing Davison at Dowa Metaltech Co., Ltd., Dowa Hightech Co., Ltd. and Dowa Semicondutor Akita Co., Ltd. will control the procurement of materials containing gold and materials containing tin.
  3. The Dowa Group will appoint a manager with responsibility for the control of conflict minerals. The manager with responsibility for the control of conflict minerals will oversee the control structure 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 tin, tantalum, tungsten and gold from the conflict-affected area (the Democratic Republic of the Congo and nine neighboring countries) as 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 and materials containing tin, except for recycled materials (recycled materials or scrap), and perform risk assessment. The Dowa Group will discontinue material purchase transactions that the manager with responsibility for the control of conflict minerals deems to involve high risk as a result of the risk assessment.

(2) Monitoring of Transactions

1) Materials Accepted at Smelters and Refineries
  • Smelters and refineries 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. The Dowa Group will undergo independent third-party audits regarding gold 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 stipulated to be necessary for headquarters divisions, smelters and refineries, recycling plants and manufacturing subsidiaries on a regular basis.

(4) Retention of Records

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

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