Tanaka Kikinzoku Group
Responsible Mineral Management Policy

The Tanaka Kikinzoku Group is committed to undertaking corporate social responsibility initiatives. As part of these efforts, it implements measures to achieve socially responsible raw mineral procurement that takes human rights, the environment and ethics into account.
The Tanaka Kikinzoku Group undertakes responsible raw material procurement in conflict-affected and other high-risk areas in such a manner that it can be reasonably assured that it is not involved in human rights abuses, terrorist financing, money laundering, unfair dealings, or conflicts.
The Tanaka Kikinzoku Group conducts risk assessments (due diligence) of the supply chain for the tantalum, tin, tungsten, and gold (known as "3TG" or "conflict minerals") as well as other minerals used in its products and discloses its due diligence measures and results of investigations upon customer request.

The Tanaka Kikinzoku Group believes in the importance of risk management in raw minerals procurement, particularly gold and silver, and for this reason it has established a Responsible Mineral Management Policy Concerning Gold and Silver. In 2014, with updates in each subsequent year, the Shonan plant passed a third-party audit in accordance with the Responsible Gold Guidance developed by the LBMA.*

Tanaka Kikinzoku Group
Responsible Mineral Management Policy Concerning Gold and Silver

The Tanaka Kikinzoku Group conducts risk management concerning its gold and silver trading activities. To avoid procurement that may be connected to human rights abuses, terrorist financing, money laundering or unfair dealings and practices in conflict-affected and other high-risk areas, it implements the following responsible mineral management measures.

1. Creation of Management System

The Tanaka Kikinzoku Group has established a management system for conducting risk assessments (due diligence) in the mineral supply chain, has appointed a supply chain officer, and conducts responsible mineral management.

2. Risk Assessments of Procured Raw Materials and Suppliers

The Tanaka Kikinzoku Group continuously conducts risk assessments (due diligence) with respect to procured gold and silver materials and the supply chain under its responsible mineral management system in accordance with the LBMA guidance on good delivery for refiners and properly manages and maintains records of those assessments. In the case it becomes clear that any material is connected to conflict or that any supplier to the Group is involved in human rights abuses, terrorist financing, money laundering or unfair dealings and practices in a high-risk area, the Group immediately takes risk mitigation measures, and the risks cannot be mitigated, terminates the purchases or trades.

3. Education and Training

The Tanaka Kikinzoku Group carries out ongoing internal education and training for all Group personnel who are involved in our responsible mineral management system.

4. Monitoring and Recording

The Tanaka Kikinzoku Group monitors procured materials to ensure that they are consistent with the information obtained from suppliers and properly manages and maintains records.

5. Third-Party Audit

The Tanaka Kikinzoku Group periodically undergoes audits conducted by an appropriate independent third-party organization with respect to the maintenance and implementation of the responsible mineral management system established within the Group.

* London Bullion Market Association

Established: June 25, 2012
Revised: July 1, 2018
Akira Tanae
Representative Director & CEO
TANAKA HOLDINGS Co., Ltd.