Procurement policy for Tin containing raw materials

In order to meet the requests from our customers, stakeholders and international community, we, Mitsui Mining & Smelting, hereby establish the following policy with respect to a procurement of Tin containing raw materials, and keep informed about the policy all directors, officers and employees being responsible for and/or engaging in the transaction:

• Our division complies with the OECD (Organization for Economic Cooperation and Development) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Appendix II, Paragraphs 1 to 14 of the Due Diligence Guidance.
  (1) Responding to systematic or widespread human rights violations associated with the extraction, transportation, or trading of tin raw materials; (2) Responding to direct or indirect support for non-governmental groups; (3) Responding to bribery and misrepresentation of the origin of products; (4) Responding to non-payment of taxes and fees associated with the extraction or trading of tin raw materials; (5) Responding to the prevention of money laundering and terrorist financing; (6) Responding to contributions to conflicts.

We will implement a five-step framework for due diligence to manage risks related to these issues, based on the OECD (Organization for Economic Cooperation and Development) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

1. Establishment of a management system

We will establish a system to implement a supply chain traceability system for mineral raw materials, appoint a person in charge of the tin raw materials supply chain, clarify responsibilities and authority, and promote responsible procurement management of mineral raw materials.We will establish a system to implement a supply chain traceability system for tin raw materials, and promote responsible procurement management of tin raw materials.

2. Implementation of education and training

We will continually plan and implement education and training for employees involved in tin raw material procurement.

3. Supply Chain Due Diligence Assessment

With regard to tin raw materials, the division conducts supply chain risk assessment by identifying conflict-affected and high-risk areas (CAHRAs) as defined in the OECD's "Annex II of the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas" and conducting know-your-customers (KYC) procedures.

4. Recording of transactions

Records will be stored and managed appropriately in accordance with regulations.

5. Managing and taking action on identified risks

We conduct risk assessments and do not procure from any of the affected countries/regions.
If the risk assessment reveals that a business partner has violated this policy, or if the division determines that there is a high risk in areas such as compliance with laws and regulations, respect for human rights, elimination of antisocial behavior, or environmental conservation, we will work to mitigate the risk through supplier engagement, and will terminate transactions with the supplier if risk mitigation is not possible.

6. Communication

We will establish and promote a mechanism through which all employees or external stakeholders can anonymously voice their concerns about the tin raw material supply chain or newly identified risks.

7. Implementation of third-party audits

We undergo audits by a third-party organization, obtain third-party certification, and report the audit results.

July 2025