Initiatives in Response to the Issue of Conflict Minerals

The Dodd-Frank Wall Street Reform and Consumer Protection Act came into effect in the US in July 2010, and includes a “conflict minerals” provision, requiring all companies listed in the US to disclose whether their products contain “conflict minerals,” defined in the provision as gold, tin, tantalum and tungsten, along with details of producing countries, in an effort to prevent minerals mined in the conflict-stricken Democratic Republic of Congo (DRC) or its neighboring countries from being used to fund the activities of armed groups responsible for human rights violations and other acts of violence.
As our smelting and refining operations involve three of these minerals – gold, tin and tungsten – we are stepping up initiatives in this area, and in 2013 formulated a companywide policy on conflict minerals and published it on our website.

Initiatives with respect to gold, silver and tin

The Metals Company has pledged its support for a campaign to ensure a transparent flow of funds related to mineral resources, as promoted by the Extractive Industries Transparency Initiative (EITI)*1 since June 2011.
In August 2013, we obtained certification of our use of conflict-free minerals in our gold products from the London Bullion Market Association (LBMA)*2 and have had this certification renewed every year since.
And we have started operations to obtain the certification in our silver products.
Since February 2014, moreover, we have also received annual certification of our use of conflict-free tin from RMAP(former CFS program) of Responsible Minerals Initiative (RMI*3, former CFSI).

  • *1 Extractive Industries Transparency Initiative (EITI):
    The EITI is a global framework established to improve the transparency of financial flows from extractive industries engaging in the development of oil, gas and mineral resources to the governments of resource-producing countries. Its aim is to prevent corruption and conflicts, and thus to promote responsible resources development that can facilitate growth and help to reduce poverty.
  • *2 London Bullion Market Association (LBMA):
    The LBMA implements and oversees compliance with quality requirements for gold and silver bullion circulated in the market.
  • *3 Responsible Minerals Initiative (RMI)
    Electronics Industry Citizenship Coalition (EICC) was renamed Responsible Business Alliance (RBA) and CFSI was renamed Responsible Minerals Initiative (RMI), Conflict-Free Smelter (CFS) program was renamed Responsible Minerals Assurance Process (RMAP) on October 2017.

The Responsible Gold/Silver Guidance issued by LBMA applies to all refiners producing LBMA good delivery gold/silver bars to have a mechanism that enables all employees or external stakeholders to anonymously voice concerns over the gold/silver supply chain. As a gold/silver refiner complying with the Responsible Gold/Silver Guidance, we accepts inquiries about its gold/silver supply chain from its internal and external stakeholders. Please contact the "Responsible Minerals Sourcing Hotline".

Metals Company Responsible Minerals Control Policy

Establishment date:19th June 2013
Last revised date (Rev.5):22nd May 2020

The Metals Company (hereinafter the "Company") engages in bullion manufacturing for gold, silver and tin. The Company does not procure materials originating from high risk areas, such as conflict-affected areas, connected to human rights abuses, terrorist financing, money laundering and illegal trade. Also, the Company recognizes the importance of addressing Environment and Sustainability responsibilities for procurement of materials. To rigidly maintain this practice, the Company has adopted a control system that follows the London Bullion Market Association (LBMA) guidance for gold and silver, and the Responsible Mineral Initiative (RMI) Responsible Minerals Assurance Process (RMAP) for tin and undergoes regular audits by third-party bodies.
The Company hereby sets out its responsible minerals control policy applicable to gold, silver and tin as follows and will implement the following measures.

1. General Provisions
  1. (1)The Company will respect human rights and avoid direct or indirect involvement with inhumane acts. For this purpose, the Company will not use suspicious minerals which may be connected to conflict-affected and high risk areas where armed conflict, widespread violence and other risks may harm individuals. Also, the Company will not procure suspicious minerals against its Environment and Sustainability responsibilities.
  2. (2)The Company will immediately stop a transaction when its risk controls on material procurement detects that the minerals are connected to those in power in conflict-affected and high-risk areas, or suspicious against Environment and Sustainability responsibilities of the Company.
  3. (3)The Company annually receives third-party assurance on its procurement of materials containing gold, silver and tin, and reports the audit results concerning gold and silver to LBMA and those concerning tin to RMI.
2. Control System and Responsibility
  1. (1)The Company's headquarters deals with all operations for mineral control. Smelters and refineries do not procure materials independently.
  2. (2)The compliance officer appointed by the Company assumes authority and responsibility stipulated in the control manual, including those for overseeing relevant sections and divisions and for operating the control system.
  3. (3)The supply chain officer appointed by the Company assumes authority and responsibility stipulated in the control manual, including those for overseeing the entire control system and for regularly conducting management reviews.
3. Judgment Criteria for Material Procurement from Conflict-Affected and High-risk Area

The Company considers the procurement of materials containing gold, silver and tin as a high-risk when those materials are determined or highly suspected to be connected to the conflict-affected and high-risk areas defined by the Company where human rights abuses, terrorist financing, money laundering, illegal trade, and non-compliance with Environment and Sustainability legal requirements are present.

4. Implementation of Due Diligence on Material Suppliers

The Company will practice due diligence and perform risk assessments on all suppliers of materials containing gold and silver and all suppliers of materials containing tin. The Company will immediately stop a transaction when it is deemed by the supply chain officer as being high risk, as a result of the risk assessment.

5. Monitoring of Materials Purchased by the Company's Headquarters
  1. (1)Materials purchased by the Company headquarters are supplied to smelters and refineries, which will check the actual goods and analyze the content of gold, silver, tin and/or other metals for every lot, to examine consistency with the information from suppliers provided in advance by the Company headquarters and to report the findings to the Company headquarters.
  2. (2)The Company will effectively utilize the monitoring system for incoming materials, which has long been in place, for the purpose of responsible minerals procurements control at the Company headquarters and operate it as a system for the prevention of contamination with high risk minerals.
6. Operation of the Responsible Minerals Sourcing Control System
  1. (1)The compliance officer will provide education and training to the relevant sections and divisions of the Company headquarters and to the smelters and refineries as needed.
  2. (2)The compliance officer will perform at least one internal monitoring per year of the relevant sections and divisions of the Company headquarters and of the smelters and refineries to assess if operations are properly performed in accordance with the responsible minerals sourcing control system or if there are any deviances from the system.
  3. (3)In the event of starting transactions with a new supplier for material procurement, the Company will ensure that the information is communicated to the compliance officer in an effort to prevent contamination with high risk minerals.
  4. (4)The compliance officer will keep the records of all operations concerning responsible minerals sourcing control and retain them for five years. The relevant documents of the control manual will be revised as needed and properly managed.

Japan New Metals Co., Ltd. (Advanced Materials & Tools Company jurisdiction)(Tungsten initiatives)

At Japan New Metals Co., Ltd., a group company whose operations include smelting and refining tungsten, we began working to obtain independent certification for the non-use of conflict minerals at an early stage, including measures such as visiting supplying smelters and refineries in China in person.
Having also worked to obtain certification at Japan New Metals itself, we formulated a Conflict Mineral Management Policy in April 2014, before going on to obtain CFS certification for tungsten in December that same year.

Japan New Metals Co., Ltd. [Conflict Mineral Management Policy]Japan New Metals Co., Ltd. [Conflict Mineral Management Policy]

Obtaining Certification for Conflict-Free Tungsten

Akira KawaguchiAkira Kawaguchi
Director and Manager, Business Department,
Japan New Metals Co., Ltd.
The title and position are as of the publication date of this article.

More than 80% of the world's tungsten raw materials are currently produced in China. We procure a large percentage of our own raw materials from China too. Having explained the spirit of the legislation in the US to smelters and refineries that we deal with in China and dedicated time to ensuring their understanding, we have repeatedly emphasized the importance of initiatives throughout the supply chain and have managed to get suppliers on board.
You can't form relationships with raw material suppliers overnight. They are the result of trusting relationships built up by our predecessors. We are determined to keep on maintaining relationships with our suppliers in the future.