Due Diligence Report
<OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict -Affected and High Risk Areas>

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June, 2021
Mitsui Mining & Smelting Co., Ltd.
Engineered Powders Division
Sales Department

1. Corporate Profile
Mitsui Mining & Smelting Co., Ltd. (CID No. 001192) is a worldwide leading smelter of high purity Tantalum Oxide as well as Tantalum Carbide. Its production facility is located at 2081 Oaza Tosen, Omuta City, Fukuoka, Japan. This report covers the period from November 1st 2019 to March 31st 2021.

2. RMAP(Responsible Mineral Assurance Program) Assessment Summary
RMI will conduct assessment to verify our conformance of RMAP on 16th and 17th of June 2021. Assessment period is November 1st 2019 to March 31st 2021. Assessment result shall be publicly available through the link.
(http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/smelter-refiner-lists/tantalum-smelters-list/conformant-tantalum-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 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.

With regard to minerals sourcing, Mitsui Kinzoku Group fulfills its corporate social responsibility in its mineral supply chain in compliance with applicable laws and regulations and in accordance with standards and guidance of international initiatives such as RMI*1, LBMA*２ and LME*３.
Regarding the covered　minerals originating in Conflict Affected High-Risk Areas (CAHRAs), Mitsui Kinzoku Group does not use minerals involving any injustices specified in paragraph 1-14 of Annex II of “the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”.
Mitsui Kinzoku Group identifies CAHRAs according to three categories as below:
1. Countries and/or areas in the CAHRAs list based on REGULATION (EU) 2017/821 that is released by the Europe Commission
2. The Democratic Republic of the Congo (DRC) and its nine adjoining countries as defined in Section 1502 of the Dodd Frank Act
3. Countries and/or areas other than the above-mentioned that are identified by Mitsui Kinzoku Group referring to the requirements of the international initiatives

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.
*1 Responsible Minerals Initiative
*2 London Bullion Market Association
*3 London Metal Exchange
*4 Conflict Affected High-Risk Areas　
(HP: https://www.mitsui-kinzoku.com/csr/society/supplychain/)

4. Company Management System
CSR procurement promotion committee has been formed, playing a role of supervising due diligence activities of business sectors. Sales Department, under Engineered Material Sector, is a member of CSR procurement promotion committee.
Management system of Engineered Material Sector including Sales Department and Miike Rare Metal Plant has been established adjusting to various surroundings. In addition, General Manager of Sales Department is responsible for establishing a risk assessment system of supply chain for tantalum raw material. Besides, we have opened a website for inquiries and complaints from suppliers, customers and people involved to reflect it to our management system.
「Environmental and Social Risks Consultation Desk」
https://www.mitsui-kinzoku.com/en/contact/

Regarding due diligence activity, the Sales 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 Minerals Sourcing
In terms of our supply chain management system of minerals sourcing, 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 minerals, we investigate availability of ITSCI tag system, 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 ITA Tin Supply Chain Initiative

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
CAHRAs are identified by following our procedures and by utilizing multiple resources which provide a wide variety of information with regular updates.

1) Global Crisis Severity Index
2) Heidelberg Conflict Barometer
3) 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 Standards and other risks. As a result of the secondary evaluation, additional due diligence program should be implemented depending on the situation. In case a supplier is in a situation of high risk described on OECD Due Diligence Guidance Annex II, we will cooperate with ITSCI and execute a risk mitigation plan. As a result of the risk analysis and evaluation, there is no critical risk.

*7 EITI=Extractive Industries Transparency Initiative