Responsible Materials
Procurement Policy
Company Policy for the Procurement of Precious Metals
We procure gold, platinum and palladium minerals in accordance with Annex II and the Gold Supplement to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Raw material procurement is carried out taking into account risks such as ESG factors (e.g. environmental and sustainability responsibility).
1. General rules
(1)We do not tolerate the following acts and will never benefit, complement, support or promote them.
- ・ Human rights violations related to mineral mining, transportation and trading
- a. All forms of torture, cruelty, inhumane and degrading treatment
- b. All forms of forced labor
- c. The worst form of child labor
- d. Other significant human rights abuses, including widespread sexual violence
- e. War crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide
- ・ 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
(2)We do not tolerate material violations of local laws and regulations related to the environment, health, safety, labor and communities, and ESG risks that are likely to have material adverse consequences.
(3)Conduct due diligence with a focus on KYC and transaction monitoring in accordance with the five-step framework described in the Gold supplement of the OECD Guidance and the requirements of the LPPM, RMI and LBMA.
2. Establishing a management system for responsible sourcing of materials
We will build a management system that complies with LPPM’s RPG (Responsible PGM Guidance) for platinum and palladium and RMAP (Responsible Minerals Assurance Process) of RMI (Responsible Mineral Initiative) and LBMA’s RGG (Responsible Gold Guidance) for gold.
In order to effectively conduct supply chain due diligence, we will appoint a manager and establish an appropriate management system.
3. Identifying high-risk raw material procurement
We will identify high-risk areas in accordance with the OECD, LPPM, RMI and LBMA guidance, and determine transactions that are suspected of being involved in armed forces, unfair labor practices, human rights violations, money laundering, ESG risks as high-risk procurement.
4. Assessment of raw materials and suppliers
If, as a result of the risk assessment of raw materials and suppliers, a reasonable risk of involvement in human rights violations or support for non-state armed groups is identified, we will immediately suspend or terminate transactions with the supplier.
We recognize that the illegal trade of stolen PGM-containing materials is seriously damaging the reputation of the recycling business. We emphasize and implement the following commitments to maintain trust and transparency in our supply chain.
- ・We will undertake enhanced due diligence on suppliers of auto catalyst materials that have not published a responsible supply chain policy similar to or based upon OECD Annex II.
- ・If we identify a supplier suspected of handling stolen PGM-containing materials, we will conduct an immediate investigation and consider suspending business with the supplier until further due diligence is completed.
- ・We will actively cooperate with the relevant authorities to combat trade in stolen PGM-containing raw materials.
- ・We will reject cash payments (or instalment payments) for auto catalyst materials to avoid risks such as money laundering. We will also work towards eliminating cash payments from the industry.
5. Implementation of education and training
We will provide the necessary education and training to all employees involved in responsible supply chains on an ongoing basis.
6.Monitoring and record keeping of transactions
Monitor incoming gold, platinum and palladium raw materials to ensure they are consistent with information obtained from suppliers, and properly store and maintain all relevant records, including due diligence (DD) documents.
7. Third-party audits
In accordance with the guidance of RMI LPPM and LBMA, we will arrange for an independent third-party audit on the responsible supply chain management system and implementation status on a regular basis.
8. Whistleblowing and Grievance Mechanisms
We will set up a point of contact to receive reports and respond to whistleblowing and complaints. We will establish internal reporting system regulations to protect the confidentiality and personal information of informants and whistleblowers.
Revised on 26 December 2025