Tanaka Kikinzoku Group
Responsible Mineral Management Policy

The Tanaka Kikinzoku Group 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.
The Tanaka Kikinzoku Group 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.
The Tanaka Kikinzoku Group 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.

The Tanaka Kikinzoku Group believes in the importance of risk management for material procurement, particularly for gold, silver, platinum and palladium.
For that reason, it has established a Responsible Mineral Management Policy Concerning Gold, Silver, Platinum and Palladium.

Tanaka Kikinzoku Group
Responsible Mineral Management Policy Concerning Gold, Silver, Platinum and Palladium

The Tanaka Kikinzoku Group conducts risk management for its transactions of gold, silver, 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, it implements the following measures.

1. Management System

The Tanaka Kikinzoku Group establishes a management system for conducting risk assessments (due diligence) in the mineral supply chain, appoints a supply chain officer to conducts responsible mineral management.

2. Risk Assessments of Procured Materials and Suppliers

The Tanaka Kikinzoku Group continuously conducts risk assessments (due diligence) with respect to procured gold, silver, platinum and palladium materials as well as supply chain under its responsible mineral management system in accordance with the LBMA*1 and LPPM*2 guidance for good delivery refiners and maintains assessment records properly. In the case it becomes clear that any procured material is connected to conflict or that any supplier is involved in human rights abuses including child labor, terrorist financing, money laundering, unfair dealings and practices, conflicts in high-risk areas, or non-compliance with environmental and sustainable responsibilities, the Group immediately takes risk mitigation measures, and if the risks are not mitigated despite its efforts, terminates the related procurement or transactions.

3. Education and Training

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

4. Monitoring and Recording

The Tanaka Kikinzoku Group monitors material procurement to ensure its consistency with the information obtained from suppliers, and maintains the monitoring records properly.

5. Third-Party Audits

The Tanaka Kikinzoku Group regularly undergoes audits conducted by an independent third-party with respect to the system and implementation of the responsible mineral management.

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

Established: June 25, 2012
Revised: July 1, 2019
Akira Tanae
Representative Director & CEO
TANAKA HOLDINGS Co., Ltd