In the transaction of precious metals (Gold, Silver, Platinum and Palladium), Matsuda Sangyo Co., Ltd. (hereinafter referred to as ”The Company”) sets as basic policy to avoid transaction to a company located in high-risk area of human rights abuse, money laundering, etc., to prohibit provision of fund for conflict and terrorism, and to address a responsibility of sustainability, including ESG (environment, social and governance) factors.
In accordance with the responsible guidance1 established by LBMA2 and LPPM3, The Company conducts due diligence of the supply chain for precious metals as follows.

Establishment of Management System

The Company shall set an executive officer for precious metals management. The Company shall conduct responsible management of precious metals in accordance with management system established by management representative who is appointed by the executive officer.

Identification and Assessment of Risks

The Company defines a company who has either the risks outlined in Annex II of the OECD Due Diligence Guidance4 or the risk of affecting an adverse impact on ESG factors as a high-risk counterparty. The Company shall conduct risk assessment to counterparties periodically. If an executive officer judges a counterparty as high-risk company, The Company devises a mitigation of that risk, otherwise The Company shall not deal with that counterparty.

Monitoring the Transactions and Retaining Records

The Company shall monitor that the documents received in advance and incoming materials are consistent with each other, and shall retain relevant records appropriately.

Employee Training

The Company shall provide necessary training for all employees who are involved in the responsible management of precious metals.

Third-party Audits

The Company shall periodically undergo audits conducted by independent third-party for the system of responsible precious metals management and its operational status.

Established: April 1, 2014
Revised : December 16 2022
Yoshiaki Matsuda
Matsuda Sangyo Co., Ltd.

  1. LBMA Responsible Gold Guidance, LBMA Responsible Silver Guidance and LPPM Responsible Platinum and Palladium Guidance
  2. London Bullion Market Association
  3. London Platinum and Palladium Market
  4. It is referred to:
  • serious abuses associated with the extraction, transport or trade of minerals,
  • direct or indirect support to non-state armed groups,
  • direct or indirect support to public or private security forces,
  • bribery and fraudulent misrepresentation of the origin of minerals,
  • money laundering, and
  • the payment of taxes, fees and royalties due to governments.