TANAKA Precious Metals
Responsible Mineral Management Policy

TANAKA Precious Metals is committed to undertaking corporate social responsibility initiatives. As part of the commitment, it implements measures to achieve responsible mineral procurement taking human rights, the environment and ethics into account.
TANAKA Precious Metals undertakes responsible mineral procurement in order to reasonably assure that it is not involved in human rights abuses including child labor, terrorist financing, money laundering, unfair dealings, conflicts, or environmental destruction in high risk areas including conflict-affected.
TANAKA Precious Metals conducts risk assessments (due diligence) of the supply chain for the tantalum, tin, tungsten, gold (known as "3TG" or "conflict minerals") and cobalt as well as other minerals used in its products and discloses measures and results of the due diligence according to customer's request.

TANAKA Precious Metals believes in the importance of risk management for material procurement, particularly for platinum, gold, silver and palladium.
For that reason, it has established "Responsible Mineral Management Policy Concerning Precious Metals".

TANAKA Precious Metals
Responsible Mineral Management Policy Concerning Precious metals

TANAKA Precious Metals establishes a management system in accordance with the guidance of LBMA*1 for gold and silver and LPPM*2 for platinum and palladium. To avoid procurement connected to human rights abuses including child labor, terrorist financing, money laundering, unfair dealings and practices or conflicts, in high-risk areas including conflict-affected, and to commit to responsibilities for environment and sustainability, we promote responsible management of precious metals (platinum, gold, silver and palladium) as follows.

1. Management System

TANAKA Precious Metals appoints a supply chain officer and establishes a system for conducting a risk assessments (due diligence) on the mineral supply chain of platinum, gold, silver, and palladium (hereinafter, precious metals under management).

2. Risk Assessments of Procured Materials and Suppliers

In accordance with the guidance of LBMA and LPPM, TANAKA Precious Metals continuously carries out risk assessment (due diligence) for procured raw materials and supply chain.
As a result, if the supply chain officer determines that the risk is high, the appropriate organizational decision will be taken to mitigate the risk, and if the risks are not mitigated despite its efforts, immediately terminates the related procurement or transactions.
The results of these risk assessments will be properly recorded and stored.

3. Education and Training

TANAKA Precious Metals carries out ongoing internal education and training for all Group personnel who are involved in responsible precious metals management.

4. Monitoring and Recording

TANAKA Precious Metals monitors material procurement to ensure its consistency with the information obtained from suppliers, and maintains the monitoring records properly.

5. Third-Party Audits

TANAKA Precious Metals regularly undergoes audits conducted by an independent third-party with respect to the management system and implementation of risk assessment of the responsible precious metals management.

*1 LBMA: London Bullion Market Association
*2 LPPM: London Platinum and Palladium Market

Established: June 25, 2012
Revised: September 1, 2020