Due Diligence Report
<OECD Due Diligence Guidance for Responsible Supply Chains of
Minerals from Conflict -Affected and High Risk Areas>
Aug, 2024
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 May 1st 2023 to July 31st 2024.
2. RMAP(Responsible Mineral Assurance Program) Assessment Summary
RMI will conduct assessment to verify our conformance of RMAP in the beginning
of September 2024. Assessment period is May 1st 2023 to July 31st 2024.
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 Engineered Powders 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. 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) INFORM Severity Index
2) Heidelberg Conflict Barometer
3) Corruption Perceptions Index
4) Fragile States Index
5) Global Peach 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