Due Diligence Report
January 2026, Mitsui Kinzoku Co., Ltd., PVD Materials Division, Planning Department
1. Company Information
Mitsui Kinzoku Co., Ltd. Takehara PVD Materials Plant (CID number: 004403) is a smelter that produces high-purity tin and tin oxide. The manufacturing base for these products is located at 1-5-1 Shiomachi, Takehara City, Hiroshima Prefecture. The period covered by this report is from January 1, 2025 to December 31, 2025.
2. RMAP (Responsible Mineral Assurance Program) Assessment Summary
From this time (the period covered by this report), the Takehara PVD Materials Plant has become subject to the RMAP Risk-Based Assessment Program (RBAP), and this report is based on that. The results of the RMI Secretariat's certification will be made public at the link below.
( https://www.responsiblemineralsinitiative.org/tin-smelters-list/conformant-tin-smelters/ )
3. Company Supply Chain Policy
Mitsui Kinzoku Group promotes responsible minerals sourcing. As a company in the minerals supply chain, we are aware of the possibility that risks in the supply chain related to minerals sourcing could affect the business of our Group.
The scope of target risks is expanding, target areas are widening to CAHRAs*1 and other minerals are included as target minerals. In order to address such emerging demands, Mitsui Kinzoku Group has established an inclusive policy for responsible minerals sourcing. As a result of the enforcement of Regulation (EU) 2017/821, our responsible minerals sourcing policy has been updated accordingly in February 2021.
*1 Conflict Affected High-Risk Areas
Mitsui Kinzoku Group will comply with applicable laws and regulations in sourcing minerals and fulfill its corporate social responsibility in the mineral supply chain in accordance with the standards and guidance of international initiatives such as RMI*1, LBMA*2 and LME*3.
Mitsui Kinzoku Group has a policy of not using as raw materials any minerals that originate from conflict-affected and high-risk areas (CAHRAs*4) and are involved in any of the illegal activities listed in Annex II, paragraphs 1 to 14 of the OECD's (Organization for Economic Cooperation and Development) "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas." We also promote initiatives related to human rights, labor, safety and health, the environment, and ethics, and work to ensure the sustainability of our mineral supply chain.
The Group identifies CAHRAs according to the following categories:
1. Countries and regions listed on the list of CAHRAs published by the European Commission under Regulation (EU) 2017/821
2. The Democratic Republic of the Congo (DRC) and nine adjoining countries under Section 1502 of the Dodd-Frank Act
3. Countries and regions other than those listed above that the Group identifies with reference to international initiatives, etc. The Group has also identified tin, tantalum, tungsten, cobalt, gold, silver, zinc, lead, and copper as target minerals. These will be reviewed as appropriate in line with the requirements of international initiatives. The Group will conduct appropriate due diligence on its supply chain in accordance with the standards and guidance of international initiatives, and will disclose information in response to requests from customers and other stakeholders.
Mitsui Kinzoku Group will comply with applicable laws and regulations in sourcing minerals and fulfill its corporate social responsibility in the mineral supply chain in accordance with the standards and guidance of international initiatives such as RMI*1, LBMA*2 and LME*3.
Mitsui Kinzoku Group has a policy of not using as raw materials any minerals that originate from conflict-affected and high-risk areas (CAHRAs*4) and are involved in any of the illegal activities listed in Annex II, paragraphs 1 to 14 of the OECD's (Organization for Economic Cooperation and Development) "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas." We also promote initiatives related to human rights, labor, safety and health, the environment, and ethics, and work to ensure the sustainability of our mineral supply chain.
The Group identifies CAHRAs according to the following categories:
1. Countries and regions listed on the list of CAHRAs published by the European Commission under Regulation (EU) 2017/821
2. The Democratic Republic of the Congo (DRC) and nine adjoining countries under Section 1502 of the Dodd-Frank Act
3. Countries and regions other than those listed above that the Group identifies with reference to international initiatives, etc. The Group has also identified tin, tantalum, tungsten, cobalt, gold, silver, zinc, lead, and copper as target minerals. These will be reviewed as appropriate in line with the requirements of international initiatives. The Group will conduct appropriate due diligence on its supply chain in accordance with the standards and guidance of international initiatives, and will disclose information in response to requests from customers and other stakeholders.
* 1 Responsible Minerals Initiative (renamed from Conflict Free Sourcing Initiative “CFSI” in October 2017)
* 2 London Bullion Market Association
* 3 London Metal Exchange
* 4 Conflict Affected High-Risk Areas
In addition, we identify Tin, Tantalum, Tungsten, Gold, Silver, Zinc, Lead and Copper as the covered minerals. We will appropriately review the covered minerals in line with the international initiatives.
Along with the standards and guidance of the international initiatives Mitsui Kinzoku Group properly conducts supply chain due diligence for the covered minerals and discloses related information according to requests from
stakeholders including customers.
(Supply Chain Management website page: https://www.mitsui-kinzoku.com/csr/society/supplychain/ )
4.Company Management System
The Group has appointed the Chief Procurement Officer as the Chief Supply Chain Officer and established a supply chain management system. The Group has organized a Supply Chain Committee chaired by the Chief Supply Chain Officer, with members elected from each business division. The Supply Chain Committee oversees and manages the Group's supply chain initiatives, including responsible mineral sourcing. The Functional Materials Business Division, to which our division belongs, has also established a CSR Procurement Promotion Committee under the Supply Chain Committee, and our Planning Department is also a member of the committee. The General Manager of the Planning Department is responsible for establishing a system to identify, assess, and manage supply chain risks for responsible mineral sourcing in our division's sputtering target business, including the Takehara PVD Materials Plant, our tin smelting base. He has established a management system tailored to the supplier's situation and the surrounding environment. He works closely with the Takehara PVD Materials Plant to maintain a robust management system and implement supply chain management. We have also established a contact point on our official website to accept inquiries and complaints from external stakeholders at any time.
"Environmental and Social Risks Consultation Desk"
https://www.mitsui-kinzoku.com/en/contact/
Regarding due diligence activity, the Planning Department has appointed persons in charge to undergo training programs more than once per year for the purpose of improving the quality of due diligence. “The Integrated Report”, listed on our website, covers due diligence activities in our company on annual basis.
5.Management System of materials
In terms of our supply chain management system of materials, our due diligence program has been properly implemented in compliance to the international guidance as well as the initiatives such as OECD and RMI. To identify the origin of materials, we investigate Certificates of origin and other relevant documents before signing contracts. This procedure enables us to determine whether traceability of transaction is sufficiently satisfied or not. In case there is a gap between supplier’s management system and ours, we will pursue to communicate and agree with the most practical and sustainable way for each other. In case we have any requests or complains from suppliers, we will carefully handle the issue, supported by professional aspects of our internal legal department as needed.
6. Record-keeping system
Documents and data related to management system have been stored in our internal data base protected by security. It is determined to store five years by our company standard.
7. Risk Assessment・Evaluation・Mitigation
We identified CAHRAs for our business by following our procedures and utilizing multiple resources below which provide a wide variety of information with regular updates.
(Sources used for CAHRAs identification)
- Global Crisis Severity Index
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Heidelberg Conflict Barometer
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Corruption Perceptions Index
As for CAHRAs identification procedure, we conduct a primary evaluation to compare our own standard with the results of multiple resources including references such as OECD and RMI. Furthermore, a secondary evaluation shall be carried out with our KYC (KYC=Know Your Counterparty) system to identify Red Flags, support status of EITI*5 Standards and other risks. As a result of the secondary evaluation, additional due diligence program should be implemented depending on the situation. As a result of the risk analysis and evaluation, there is no critical risk.
* 5 EITI=Extractive Industries Transparency Initiative