Management Policy for Handling Conflict Minerals

Matsuda Sangyo Co., Ltd., (hereinafter referred to as “our company”) upholds a corporate philosophy of “effectively utilizing global resources and contributing to society through our business,” and we engage in our business activities with the aim of realizing this corporate philosophy.
In order to implement the principles of this company, when we procure raw materials, our basic policy is to avoid procuring disputed minerals from areas in conflict that take part in inhumane and/or illegal acts such as committing human rights violations or money laundering as established in regulations concerning business ethics and compliance, as well as to prohibit the financing of terrorism. We control our supply chain as shown below.

  • Management system and responsibilities
    Our company implements management of conflict minerals by appointing a supervisory manager for mineral procurement who constructs a management system.
  • Criteria for high-risk suppliers
    We judge that a supplier is a high risk if they deal in minerals coming from an area in conflict that takes part in inhumane and/or illegal acts such as committing human rights violations or money laundering, or when they provide funds for disputes or terrorism.
  • Due diligence regarding suppliers of materials
    Our company conducts due diligence regarding suppliers of raw materials and evaluates the risk. Our company does not proceed with a transaction in the event that it becomes clear, as a result of our evaluation, that the materials are conflict materials originating from a conflict-affected area.
  • Monitoring of transactions and storage of records
    To supervise the appropriate implementation of the aforementioned due diligence, our company suitably manages the records related to transactions and conducts periodic internal audits.
    Moreover, a third-party person implements an audit based on the LBMA’s Responsible Gold Guidance.
  • Education
    Our company implements the necessary education and training for personnel involved in the management of conflict minerals.

Furthermore, our company acquired certification for the Gold Conflict-Free Smelter Program through EICC-GeSI in July 2012.

Yoshiaki Matsuda,
Matsuda Sangyo Co., Ltd.
April 1, 2014

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