Established date : September 29, 2023
Onahama Smelter & Refinery of Onahama Smelting & Refining Co., Ltd. manufacture copper cathodes. In procuring raw materials for copper cathodes, Onahama Smelting & Refining Co., Ltd. (hereinafter referred to as the "Company") establishes and operates a control system in accordance with the Responsible Sourcing Policy of the London Metal Exchange as well as the Joint Due Diligence Standard of The Copper Mark, and will undergo independent third party assessment of its risk assessment.
The Company hereby sets out its Responsible Minerals Sourcing Policy for Copper as follows and will implement the following measures.
（1）The Company implements the five-step due diligence process defined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Annex Ⅰ for its copper raw material.
（2）The Company identifies, assesses and responds to risks of adverse impacts and actual adverse impacts in its mineral supply chains including those listed in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Area Annex Ⅱ (as listed below).
① Direct or indirect support to non-state armed groups
② Serious abuses associated with the extraction, transport or trade of minerals
③ Direct or indirect support to public or private security forces
④ Bribery and fraudulent misrepresentation of the origin of minerals
⑤ Money laundering
⑥ Payment of taxes, fees, and royalties due to governments
（3）If a serious abuse of human rights or any support to non-state armed groups is identified, the Company will immediately terminate the transaction or cancel the contract. Risks other than serious abuse of human rights or support to non-state armed groups will be mitigated. If it is determined that the risk cannot be mitigated, the Company will immediately terminate the transaction. A risk management plan will be used as a framework for procedures to be implemented to manage and mitigate the risks of adverse impacts and actual adverse impacts. The risk management plan will enable the Company to manage risks through engagement with suppliers that could exercise their influence further upstream of the supply chain, initiatives with business alliances and diverse stakeholders, and involvement with local and central governments. It will also monitor and track performance through feedback from stakeholders.
（4）We will undergo an independent third party assessment of the risk assessment of the supply chain for the procurement of raw materials including copper, and will also provide an annual report on the implementation status of the management system for procurement of raw materials including copper.
Contact the Responsible Minerals Control Hotline if you identify any act in violation of the provisions of our Responsible Minerals Control Policy.
Establishment date : April 1, 2025
Onahama Smelting & Refining Co., Ltd. (hereinafter the "OSR") engages in bullion manufacturing for platinum and palladium. The OSR 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. In keeping with this strict nonuse practice and ESG considerations, the OSR has adopted a control system that follows the London Platinum Palladium Market (LPPM) guidance for responsible platinum/palladium undergoes regular audits by third-party bodies.
The OSR hereby sets out its responsible minerals control policy applicable to platinum and palladium as follows and will implement the following measures.
1．General Provisions
（1）The OSR will respect human rights and avoid direct or indirect involvement with inhumane acts. For this purpose, the OSR 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.
（2）The OSR will perform risk controls on material procurement and will immediately stop a transaction when it becomes known that the MERC is purchasing minerals originating from and connected to those in power in conflict-affected and high risk areas.
（3）The OSR annually receives third-party assurance on its procurement of materials containing platinum and palladium, and reports the audit results concerning to LPPM.
2．Control System and Responsibility
（1）The OSR's PGM section deals with all operations for mineral control smelters.
（2）The compliance officer appointed by the OSR assumes authority and responsibility stipulated in the control manual, including those for overseeing relevant sections and divisions and for operating the control system.
（3）The supply chain officer appointed by the OSR 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 OSR considers procurement of materials containing platinum and palladium with definite or highly suspicious connections to specific conflict-affected areas as determined by the OSR and high risk areas connected to human rights abuses, terrorist financing, money laundering and illegal trade as high risk.
4．Implementation of Due Diligence on Material Suppliers
The OSR will practice due diligence and perform risk assessments on all suppliers of materials containing platinum and palladium. The OSR 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
（1）Materials purchased by OSR are supplied to the PGM section, which will check the actual goods and analyze the content of platinum, palladium and/or other metals for every lot, to examine consistency with the information from suppliers provided in advance and manage the results.
（2）The OSR 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 OSR 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）The compliance officer will provide education and training to the PGM section and the relevant sections of the OSR and to the smelters and refineries as needed.
（2）The compliance officer will perform at least one internal monitoring per year of the relevant sections and divisions of the OSR 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）In the event of starting transactions with a new supplier for material procurement, the OSR will ensure that the information is communicated to the compliance officer in an effort to prevent contamination with high risk minerals.
（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.
Contact the Responsible Minerals Control Hotline if you identify any act in violation of the provisions of our Responsible Minerals Control Policy.
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