| <CSR> Responsible Minerals Procurement Policy |
1. YAMAGUCHI MICA aims to realize a sustainable and responsible supply
chain, and comply with all applicable laws and
regulations while giving due consideration to human rights, the environment, ethics, etc.
2. In procuring mineral raw materials such as mica, we will promote CSR
activities with the understanding and cooperation
of our supply chain to avoid risks (*) such as child labor and other human
rights violations, financing of terrorists, money
laundering, illicit transactions, and involvement in conflicts in high risk areas, so that our customers can use our products
with confidence.
（*）For risks, we follow the OECD Due Diligence Guidance AnnexⅡfor Responsible Supply Chains of Minerals from
Conflict and High Risk Areas.
--- Human rights violations related to mineral mining, transportation
and trading
--- Direct or indirect support for non-governmental armed groups
--- Direct or indirect support for public or private security forces
committing illegal activities
--- Bribery and misrepresentation of mineral origin
--- Money laundering
--- Unpaid government taxes, fees, and mining rights fees
Specific initiatives to achieve responsible mineral procurement include:
(a) Establishment of control systems
With regard to the procurement of raw materials such as mica, we will establish
a system for conducting risk assessment
(due diligence) of the raw materials procured and the supplier
(b) Identifying high-risk raw material procurement
Identify high-risk areas in accordance with guidance from the OECD and
other organizations, and determine transactions
suspected of involvement in risks such as human rights violations, financing of terrorism, money laundering, illicit transactions,
and complicity in conflicts as high-risk procurements。
(c) Assessment of raw materials and suppliers
If the risk assessment of raw materials or suppliers determines that the
risk is high, cooperate with suppliers in consultation
to mitigate the risk. If risk mitigation is not possible, immediately discontinue
the transaction
(d) Monitoring and record keeping of transactions
We monitor incoming raw materials for consistency with information obtained from suppliers, and maintain their records
appropriately.
(e) Implementation of training
We will continuously educate and train our personnel involved in the procurement
of raw materials to ensure responsible
mineral procurement. We will also communicate our approach to raw material procurement to our suppliers and educate
them to engage in responsible mineral procurement throughout the supply
chain.
(f) Third-party audits
We arrange for an independent third-party audit on the responsible supply
chain management system and implementation
status on a regular basis. We also conduct regular audits of our suppliers,
either by us or by an independent third party.
(g) Annual Reporting
Report the details of due diligence conducted on raw materials and suppliers
on an annual basis in the Company's CSR
report, etc.
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Nov. 2022
YAMAGUCHI MICA CO., LTD.
CSR Secretariat |
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