THE DOWA GROUPCSR PROCUREMENT GUIDELINEVERSION 1.6

MAY 2022

TABLE OF CONTENTS

Ⅰ．To Our Suppliers .................................................................................... 2
Ⅱ．DOWA Group CSR Procurement Policy ....................................................... 3
Ⅲ．DOWA Supplier Code of Conduct .............................................................. 5(1) Legal Compliance and Fair Trade ........................................................... 5(2) Optimal Quality and Fair Price................................................................ 6(3) Establishing a Stable Supply System ....................................................... 6(4) Sustainability ...................................................................................... 61) Human rights and labor .................................................................... 62) Occupational health and safety .......................................................... 83) Environmental conservation .............................................................. 94) Contribution to society and local communities .................................... 11(5) Information Protection........................................................................ 11(6) Management System.......................................................................... 11
Ⅳ. Compliance with “DOWA Supplier Code of Conduct” ................................... 13
Ⅴ. DOWA Group Responsible Minerals Procurement Policy ............................... 141

I. TO OUR SUPPLIERS

Following our corporate Mission —“Contribute to creating an affluent, recyclingoriented society through our business activities worldwide.” —the DOWA Group carries
out its corporate social responsibilities (CSR) by implementing CSR activities based on
the “DOWA Group CSR Policy”.
Demand is increasing to promote CSR activities throughout the entire supply chain
associated with a series of business processes from procurement of raw materials todevelopment, production, sales, and services. This demand in the society has also
become part of the procurement activities of corporations, and is expected to groweven stronger. Under these circumstances, the DOWA Group developed and released
the DOWA Group CSR Procurement Policy in FY2013. Furthermore, realizing the needto seek understanding and cooperation from our suppliers, our valued business
partners, to promote CSR activities throughout the entire supply chain, we haveformulated this DOWA Group Supply Chain CSR Procurement Guideline (“theGuideline”).
Also, the DOWA Group, as a member of the global supply chain, have added the“DOWA Group Responsible Minerals Procurement Policy” to the Guideline in March
2019.
This Guideline summarizes the basic principles we would like to share with our
suppliers when promoting CSR. We ask our suppliers to work hard in hand with us in
following the Guideline to further strengthen CSR activities throughout the supply chain.
Thank you for your understanding.

May 2022
DOWA Management Service Procurement Group,
Sustainability Sec., Corporate Strategy Dept., DOWA Holdings Co., Ltd.

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II. DOWA GROUP CSR PROCUREMENT POLICY

We, the DOWA Group, try to deepen the understanding of business partners in our CSR
procurement policy and disseminate our policy. When we select our partners, weconsider Q (Quality), C (Cost) and D (Delivery), as well as S (Sustainability (*1)), which
represent the initiatives taken to carry out CSR activities, including environmental
protection and respect for human rights. With this in mind, we evaluate and selectpartners in a fair, impartial, and comprehensive manner.
We work to build mutually dependable relationships with our partners and aim toachieve mutual prosperity as partners by creating excellent products that effectively
meet the diverse needs of customers.

1. LEGAL COMPLIANCE AND FAIR TRADE
We consider not only legal compliance but also fairness and impartiality as top priorities,
and engage in fair trade with our partners. We ask all our partners to comply with all
relevant laws, regulations, and social norms prior to trading with us.

2. OPTIMAL QUALITY AND FAIR PRICE
We ensure the quality required by our customers and provide products at fair prices incollaboration with our partners. We ask our partners to put a quality assurance system inplace and provide us with materials and services at competitive prices in the market.

3. ESTABLISHING A STABLE SUPPLY SYSTEM
We are preparing Business Continuity Plans (BCP) at each business entity within the
DOWA Group, to ensure stable supplies of products to our customers, even in an
emergency. To ensure timely delivery, we ask our partners to put in place a system tostably supply materials and services, and to exercise risk management for emergencies.

34. SUSTAINABILITY (*1)
We recycle resources based on the 3R’s (Reduce, Reuse and Recycle) (*2) to contributeto a sustainable society and promote purchases of resources and materials that impose asmaller environmental burden (Green Procurement.) We ask our partners to ensure
environmental conservation, respect for human rights, and workplace health and safety.
Also, to prevent being complicit in human rights abuse or injustice, we ask our partners tounderstand the “DOWA Group Responsible Minerals Procurement Policy “and takeaction in accordance to its policies.
When we select our partners, we place value on a management system that cancontinuously improves sustainability.

5. INFORMATION PROTECTION
We do not disclose confidential information of our partners to third parties without
permission. We ask our partners to keep confidential and personal information obtained in
the course of business with the DOWA Group in strict confidence, and not to disclose suchinformation to in-house and external third parties without our permission.

6. CSR PROCUREMENT GUIDELINE
We promote procurement based on the DOWA Group’s CSR Procurement Guideline. We
ask our partners to implement CSR procurement as a part of our supply chain, notify
relevant parties of this policy to deepen their understanding, and obtain their cooperation.

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Ⅲ．DOWA SUPPLIER CODE OF CONDUCT(1) Legal Compliance and Fair Trade(i) Prohibition of corruption, bribery, etc.
・All transactions shall be carried out transparently and in good faith, and recorded
accurately in accounting ledgers.
・We shall have no involvement whatsoever in corruption, bribery, extortion, orembezzlement.
・We shall take surveillance and corrective measures to ensure compliance with laws andregulations on preventing corruption.

(ii) Preventing abuse of superior bargaining position
Superior bargaining position as a purchaser shall not be abused to cause any
disadvantage to suppliers.

(iii) Unfair profits
No acts shall be taken whatsoever to gain unfair profits through corruption or othermeans.

(iv) Fair business, advertising, competition
・Efforts shall be made to maintain fair levels of business, advertising, and competition.
・We shall take appropriate measures to protect customer information.

(v) Provision of accurate information on products and services
Accurate information on products and services shall be provided to partners (suppliersand customers).

(vi) Intellectual property rights
Intellectual property rights are to be respected. We shall execute any transfer oftechnology or know-how while ensuring protection of their intellectual property rights.

(vii) Appropriate export management
A clear management system shall be put in place for the export and import oftechnologies and goods subject to regulations.

(viii) Information disclosure
・We shall disclose information on business activities, financial standing, performance, etc.
in accordance with applicable regulations and industrial practices.
・There shall be no manipulation of records or falsification of reports whatsoever.

(ix) Prevention and early detection of unfair acts
Steps shall be taken to prevent unfair acts. We shall put in place a system to promote
early detection and responses against any unfair practices.

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(x) Protection of whistleblowers
We shall preserve the confidentiality of any whistleblowing partners or workers, andshall protect such whistleblowers.

(xi) Responsible procurement of minerals
・Minerals (tin, tantalum, tungsten ,gold and silver) that could be a source of funds fororganizations linked to risks such as infringement of human rights, supply of funds toterrorists, money laundering and corruption, or to other forms of misconduct in
conflict-affected and high-risk areas shall not be used as raw materials.
・Due diligence (*3) shall be conducted for all suppliers of materials containing gold, silver
and materials containing tin† and perform risk assessment proportionate to theidentified risk. †*Excludes recycled tin materials
・In response to requests from partners, means for researching suppliers of materials shallbe disclosed.

(xii) Prohibition of retaliation
We shall provide a mechanism for workers to report workplace grievances without any
fear of retaliation.

(2) Optimal Quality and Fair Price(i) Ensuring product safety
We shall ensure that products which supplier is responsible for designing satisfy thesafety standards set forth in laws and regulations of each relevant country.

(ii) Quality management system
We shall seek to promote the establishment of a quality management system.

(3) Establishing a Stable Supply System(i) Ensuring timely deliveries
We shall offer stable supplies of raw materials, facilities, and services at all times, andmeet delivery deadlines.

(ii) Formulation of Business Continuity Plan (BCP)
We shall seek to promote the formulation of a BCP, in order to maintain a stable supply
system even under unforeseeable circumstances.

(4) Sustainability (*1)1) Human rights and labor6

(i) Freely chosen employment
・Forced, bonded, or indentured labor, involuntary prison labor, slavery, or trafficking of
persons shall not be undertaken.
・Workers shall be free to leave employment at any time.
・Workers shall not be required to surrender any government-issued identification,
passports, or work permits as a condition of employment.

(ii) Humane treatment
・There is to be no harsh and inhumane treatment whatsoever, including any sexual
harassment and power harassment.
・We shall clearly define the disciplinary policies and procedures regarding such
inappropriate acts and shall be communicated to workers.

(iii) Prohibition of child labor
・Child labor is not to be applied.
(The term “child” refers to a person under the age of 15 (or 14) where the law of thecountry permits) or under the age for completing compulsory education, or under theminimum age for employment in the country, whichever is older.)・Workers under the age of 18 shall not be employed with work that is likely to jeopardize
the health or safety of young workers.

(iv) Non-discrimination
・We shall take effort to commit to a workforce that is free from harassment and unlawful
discrimination.
・In recruitment and employment practices, there is to be no discrimination based on race,skin color, national origin, age, gender, sexual orientation, gender identity, ethnicity,disability, pregnancy, religion, political affiliation, union membership, or marital status.
・Workers or applicants shall not be subjected to health examinations and medical tests
purposed for any discrimination including the above matters.

(v) Wages and benefits
・We shall pay salary to workers in compliance with all applicable wage laws, including
those relating to minimum wages, overtime hours, and legally mandated benefits.
・Workers shall be paid for overtime labor in compliance with local laws, which include theminimum wage, overtime labor and legal payment.
・The basis on which workers are paid is to be provided in a timely manner through a pay
stub or similar documentation.

(vi) Working hours
・We shall take effort to ensure that weekly working hours do not exceed the legal ceilingunder local laws and regulations.

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・We shall ensure that weekly working hours do not exceed 60 hours, including overtime,
except in emergency or unusual situations.
・Workers shall be allowed at least one day off a week.
・In addition to managing weekly working hours, we and our suppliers shall take effort toexercise proper management over working hours on the whole using a compensation
day off or flextime system.

(vii) Freedom of association
・We shall respect the rights of workers to associate freely, join labor unions, stage aprotest, or participate in workers’ councils.
・Workers shall be able to communicate openly with management regarding working
conditions and management practices without threat of reprisal, intimidation, or
harassment.

2) Occupational health and safety(i) Safety measures for machines and equipment
We shall assess risks associated with production and other machinery and equipment,
and take safety measures such as adopting safety devices and interlocks.

(ii) Workplace safety and hygiene
・Acknowledging that “safety takes priority over all business activities,” all workers shallcarry out their respective roles and work and try to secure safety in the workplace.
・A system shall be put in place whereby workers are able to promptly and actively reportpotential risks in workplaces through “Hiyari-Hatto (close call)” activities and risk
assessments.
・We shall manage potential risks by implementing preventive measures, safety measuresand training, and adopting proper designs and technologies and means of control.
・When potential risks cannot be adequately controlled, we shall provide workers withappropriate protective gear to complement safety.
・Workers shall not be disciplined for raising safety concerns and we shall encourage
workers who have contributed to enhancing safety in a workplace such as by giving
awards.

(iii) Industrial hygiene
・We shall identify and evaluate the status of workers’ exposure to chemical, biological,
and physical factors, and properly manage conditions.
・Engineering and administrative controls shall be used to control overexposure.
・When exposure risk cannot be adequately controlled, workers’ health is to be protectedwith appropriate personal protective gear, etc.

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(iv) Occupational injury and illness
・We shall take effort to put in place procedures and systems to prevent, manage, track,and report occupational injury and illness.
(Encourage workers to report, classify, and record injuries and illnesses; provide necessary
medical treatment, investigate and implement corrective actions; and facilitate thereturn of workers to work, etc.)(v) Emergency preparedness
・Potential emergency situations and events are to be identified and assessed in advance.
・To minimize the impact of emergency situations, efforts shall be made to perform andput in place appropriate measures, including emergency reporting, worker notification,
evacuation method, training, automatic fire detectors, fire extinguishing systems, andproper emergency exits.

(vi) Physically demanding work
We shall properly identify and assess risks associated with physically demanding tasks,
including manual material handling, lifting heavy objects, prolonged standing, andhighly demanding assembly tasks, and manage risks so that such tasks do not lead to
injury or illness.

(vii) Sanitation facilities, food, and housing
・Workers are to be provided with clean sanitation facilities and safe drinking water.
・We shall make efforts to store emergency food supplies
・Employee dormitory facilities shall provide users with a clean, safe environment,
emergency exits, hot water for bath or shower, proper temperature control and air
conditioning facilities, and a personal space with an appropriate entrance.

(viii) Management of worker health・We shall provide all workers with appropriate health management programs.
・We shall support workers to maintain good health by offering welfare benefits and otherprograms.

3) Environmental conservation(i) Regulations on substances in products
・We shall respect all applicable laws, regulations, and customer requirements regarding
prohibition and restriction of specific substances, including labeling for recycling anddisposal.
・We shall aspire to comply with RoHS directive (*4) and REACH regulations (*5) evenoutside of applicable EU regions.

(ii) Hazardous materials

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We shall identify hazardous chemical substances emitted into the environment andensure safe handling, transfer, storage, and use, as well as promote 3R (*2) andappropriate treatment.

(iii) Environmental management system
We shall develop and operate an environmental management system.

(iv) Resource saving and energy saving
・Efforts shall be made to improve production, maintenance, and facility operation
processes and promote substitution, conservation, and 3R (*2) of materials, in order tosave resources and energy.
・We shall try to reduce and eliminate as much as possible waste regarding all resources,
including water and energy, and aspire for zero waste.

(v) Wastewater・Wastewater generated from corporate activities and waste treatment facilities is to be
categorized, monitored, controlled, and treated as required by relevant laws andregulations of the local country prior to discharge or disposal.
・If necessary, We shall make effort to reinforce voluntary management by adopting
additional standards and reducing the burden on public water.

(vi) Waste
・We shall be responsible for waste generated from their corporate activities by exercising
appropriate management or outsourcing treatment to external service companies incompliance with relevant laws and regulations of the local country.
・Efforts shall be made to ensure appropriate waste treatment by performing onsite checksof the service provider to which the waste treatment process is outsourced and taking
other steps.
・We shall continuously reduce waste by setting voluntary targets to restrict thegeneration of waste and reduce landfill waste.

(vii) Air emissions
・VOC (*6), aerosols, corrosives, particulates, ozone depleting chemicals, and combustion
by-products generated from conducting business are to be categorized, monitored,
controlled, and treated as required prior to discharge.
・If necessary, We shall make effort to reinforce voluntary management by adopting
additional standards to reduce atmospheric burdens.

(viii) Environmental permits and reporting・In accordance with the relevant laws and regulations of the local country, necessary
approvals and permits from the authorities shall be obtained.
・We shall submit a management report to the authorities without delay if they so request.

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(ix) Greenhouse gas reduction
We shall endeavor to define voluntary targets for reducing greenhouse gases andimplement continuous activities for their reduction.

(x) Disclosure of environmental conservation initiatives
We shall disclose, when necessary, the results of environmental activities such as nature
conservation and reducing environmental burden.

4) Contributions to society and local communities
We shall endeavor to voluntarily engage in activities that contribute to the developmentof international and local communities.

(5) Information Protection(i) Defense against threats on computer networks
We shall implement defensive measures against threats on computer networks to avoid
damage to itself and other parties.

(ii) Protection of personal information
・Personal information of partners, customers, consumers, workers, and all otherbusiness-related parties shall be protected.
・Compliance with laws and regulations concerning privacy and information security shallbe ensured when collecting, storing, processing, transferring, and sharing personal
information.

(iii) Preventing leakage of confidential information of customers and third parties
Confidential information obtained from customers and third parties shall beappropriately managed and protected.

(6) Management System(i) Company commitment (*7)
A corporate social and environmental responsibility policy statement affirming
commitment to compliance and continual improvement shall be declared.

(ii) Management accountability and responsibility (*8)
・We shall clearly identify company representative(s) in charge of ensuring operation andimplementation of the management system and associated plans.
・The management system shall be periodically evaluated.

(iii) Legal and customer requirements

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A process to identify, monitor, and understand applicable laws and regulations, rules
and customer requirements, including requirements in this Guideline shall be
constructed and executed.

(iv) Risk assessment and risk management
・Risks associated with environment, occupational safety and health, labor practices, andethics in business activities are to be specified.
・We shall judge the relative significance of each of those risks, manage specified risks,and ensure legal compliance.

(v) Improvement objectives
・To improve initiatives for carrying out social and environmental responsibility, objectives
and actions plans shall be clarified.
・The performance in achieving those objectives shall be periodically assessed.

(vi) Training
Programs for training managers and workers shall be conducted to implement policies,
procedures, and improvement targets, and meet applicable legal and regulatory
requirements.

(vii) Communication
Information concerning management policy, implementation, expectations, andinitiatives shall be communicated to workers, partners, and customers in an accurate
and easy-to-understand manner.

(viii) Worker feedback and participation
Processes to identify, monitor, and understand applicable laws, regulations, rules, andrequirements of customers, including requirements in this Guideline, shall be
constructed and implemented.

(ix) Audits and assessments
Periodic self-evaluations to confirm compliance with legal and regulatory requirements,
conditions in this Guideline, and customer requirements related to social andenvironmental responsibility shall be performed.

(x) Corrective action process
Deficiencies and weaknesses identified in internal and external assessments,
inspections, and examinations shall be appropriately corrected within the set timeframe.

(xi) Documentation and records
We shall create and maintain documents and records to ensure regulatory complianceand conformity with company requirements along with appropriate confidentiality toprotect personal information.

(xii) Suppliers’ responsibilities

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We shall have a process to communicate requirements provided in this Guideline topartners and to monitor compliance by partners.

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Ⅳ. COMPLIANCE WITH “DOWA SUPPLIER CODE OF CONDUCT”

This Guideline aims to promote CSR management through cooperation between the
DOWA Group and suppliers by presenting matters that we would like our suppliers to
pursue jointly with us from the perspective of CSR based on the DOWA Group CSR
Procurement Policy.

・This Guideline defines standards to ensure that the environment in which our suppliers’
operations are safe, that workers are treated with respect and dignity, and that businessactivities are environmentally responsible and conducted ethically.
・Fundamental to adopting this Guideline is the understanding that suppliers, in all of theirbusiness activities, must operate in full compliance with the laws, rules, and regulationsof the countries in which they operate.
・This Guideline clearly encourages suppliers to go beyond legal compliance, drawing uponinternationally recognized standards, in order to advance social and environmental
responsibility.
・Suppliers must regard this Guideline as a total supply chain initiative. Suppliers shall alsopass on and require its secondary and tertiary suppliers to implement this Guideline.

We would greatly appreciate your cooperation in promoting CSR activities throughout
the entire supply chain.

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Ⅴ. DOWA GROUP RESPONSIBLE MINERALS PROCUREMENT POLICY
In order to establish a responsible supply chain in line with its corporate philosophy, the policyof the DOWA Group is to refrain from using raw materials minerals (tantalum, tungsten, gold,tin, silver, and zinc) with risks as specified in Annex II of the Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (hereinafter,
the “Guidance”) issued by the Organisation for Economic Co-operation and Development(OECD).
1. General Provisions(1) The DOWA Group avoids the procurement of minerals (tantalum, tungsten, gold, tin,silver and zinc) with risks as specified in Annex II of the Guidance.
The risks specified in Annex II of the Guidance include the following:■

Serious abuses associated with the extraction, transport or trade of minerals:■

Direct or indirect support to non-state armed groups■

Direct or indirect support to public or private security forces■

Bribery and fraudulent misrepresentation of the origin of minerals■

Money laundering■

Payment of taxes, fees and royalties to governments(2) The DOWA Group performs risk management in the procurement of raw materials(tantalum, tungsten, gold, tin, silver, and zinc). If it is found that the raw material is amineral with risks as specified in AnnexⅡof the Guidance, and if such risks cannot be
mitigated, that trade shall immediately be suspended.
(3) The DOWA Group performs regular audits using an independent third party to ensure
responsible mineral procurement management regarding the smelting, refining andrecycling of gold, tin, silver, and zinc.
2. Control System and Responsibility(1) The headquarters of the DOWA Group deals with the procurement of mineralmaterials used by the Group’s smelting and refining divisions and recycling divisions,
supplying materials to the smelters and refineries and the recycling plants that they
manage. The Resource Development & Raw Materials Department at DOWA METALS &MINING CO., LTD. and the Recycling Business Unit at DOWA ECO-SYSTEM CO., LTD.
controls the procurement of materials.
(2) The headquarters of the DOWA Group or the manufacturing subsidiaries themselves
are responsible for the proper procurement of mineral materials used by the Group’s
manufacturing subsidiaries, supplying materials to the manufacturing subsidiaries thatthey manage. The Metal-Processing Division at DOWA METALTECH CO., LTD., DOWA

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HIGHTECH CO., LTD., DOWA SEMICONDUCTOR AKITA CO., LTD. and other DOWA
Group subsidiaries control the procurement of materials.
(3) DOWA Group companies each appoint a manager with responsibility for ensuring
compliance with the Responsible Minerals Procurement Policy. The manager withresponsibility for the responsible procurement of minerals oversees the wholemanagement system and assumes the authority and responsibility stipulated in thecontrol manual.
3. Judgment Criteria for Material Procurement from Conflict-Affected and High-Risk Areas
The DOWA Group considers the material procurement of tantalum, tungsten, gold, tin,silver and zinc with risks as specified in Annex II of the Guidance to be high-riskmaterial procurement.
4. Operation of the Conflict Minerals Control System(1) Due Diligence relating to Material Suppliers
・The DOWA Group implements due diligence for all suppliers of materials containing
gold, tin*, silver, and zinc, and performs risk assessment proportionate to the identified
risk. The DOWA Group discontinues transactions that the manager with responsibility
for the control of conflict minerals deems to be high risk.
* Excludes recycled tin materials(2) Monitoring of Transactions
1) Materials Accepted at Smelters and Refineries
・Smelters and refineries check materials received to ensure the actual goods are thosedescribed in transaction information at the time of procurement and report thefindings on non-conformance to the division in charge at headquarters.
・The DOWA Group conducts regular internal monitoring to ensure due diligence of
suppliers is executed properly. The DOWA Group engages independent third-party
auditors to perform audits regarding gold, tin, silver, and zinc materials.
2) Materials Accepted at Recycling Plants
・Recycling plants check with the supplier to confirm that the recycled materials
accepted (recycled materials or scrap) have lost their original function or are nolonger required and report the findings to the division in charge at headquarters.
3) Materials Accepted at Manufacturing Subsidiaries
・Manufacturing subsidiaries check materials accepted for consistency of the actual
goods with the transaction information at the time of procurement and report thefindings to the division in charge at headquarters.

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・The DOWA Group conducts regular internal monitoring to ensure that due diligencefor suppliers is executed soundly.
(3) Training
The DOWA Group provides the education and training necessary for headquarters
divisions, smelters and refineries, recycling plants and manufacturing subsidiaries on aregular basis to conduct their operations in conformance with the responsible
procurement policy.
(4) Retention of Records
The manager responsible for the responsible procurement of minerals stipulates therecords that must be retained concerning the control of conflict minerals, establishes theperiod of retention and manages the records.

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*1 Sustainability
・Sustainability refers to the permanence of environmental, social, and economic paths inharmony to achieve sustainable development, which is development that meets theneeds of the present without compromising the ability of future generations to meettheir own needs.
・Source: Based on the concept of Sustainable Development presented in “Our Common
Future,” a report issued by the United Nations World Commission on Environment andDevelopment (Brundtland Commission) in 1987.

*2 3R (Reduce, Reuse, Recycle)
・Reduce: To cut the amount of materials used and generation of waste in the
manufacturing of products.
・Reuse: To repeatedly make use of a used product, its components, and packing material.
・Recycle: To use waste as raw materials or source of energy.

*3 Due diligence: To objectively identify potential risks of a company to society andtake steps to mitigate adverse impacts.
*4 RoHS directive (Restriction of the use of certain Hazardous Substances in electricaland electronic equipment Directive):
・EU legislation restricting the use of specified hazardous substances in electrical andelectronic equipment to minimize the risk of damaging the environment and harming
human health.
(It is spreading to regions outside the EU and similar regulations are being enforced inother countries.)
・Six substances subject to restriction:lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr6+), polybrominatedbiphenyls (PBB), polybrominated diphenyl ether (PBDE)<Compliance determination>
Cadmium: Less than 100 ppm
Lead, mercury, hexavalent chromium, polybrominated biphenyls and polybrominateddiphenyl ether: Less than 1,000 ppm(Exceptions apply to products and components from which removal of substances istechnically difficult.)*5 REACH Regulation (Registration Evaluation Authorization and Restriction ofChemicals):

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・Regulation on registration, evaluation, authorization, and restriction of chemicals
enforced in the European Union (EU).
・Applicable to chemical substances produced or imported into the EU in quantities over 1
ton per business operator, regardless of whether the substances are new or existing.
・Applicable to substances on their own, those in preparation, and in molding.

*6 VOC: Volatile Organic Compounds*7 Company commitment: Promise(s) involving a company’s responsibility*8 Accountability and Responsibility:
・Accountability: Duty to report. It is the concept of having the duty to properly report thecontents, results, etc. of activities to all stakeholders.
・Responsibility: Duty, obligation. Being responsible for the contents, results, etc. of
activities.

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Guidelines and documents used as reference:■United Nations “Global Compact”■Responsible Business Alliance（RBA） Code of Conduct
EICC (Electronic Industry Citizenship Coalition) Becomes RBA (Responsible Business
Alliance) in October 2017
■Japan Electronics and Information Technology Industries Association (JEITA) “Supply-Chain
CSR Deployment Guidebook”■London Bullion Market Association（LBMA）” LBMA Responsible Gold Guidance”,” LBMA
Responsible Silver Guidance”■Organisation for Economic Co-operation and Development (OECD) “Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas”

Document history
First Edition – Released in March 2015
Version 1.1 – Released in February 2018 with revisions to RBA
Version 1.2 – Released in March 2019 with revisions to DOWA Group Responsible Minerals
Procurement Policy
Version 1.3 – Released in April 2020 with revisions to the change of the internal
department
Version 1.4 – Released in November 2020 with revisions to the change of our corporate
Mission, anti-discriminatory items and the contact address
Version 1.5 – Released in April 2021 with revisions to the change of the internal
department
Version 1.6 – Released in May 2022 with revisions to DOWA Group Responsible Minerals
Procurement Policy

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CONTACT REGARDING THE GUIDELINEDOWA Holdings Co., Ltd.
22F, Akihabara UDX, 4-14-1, Sotokanda, Chiyoda-ku, Tokyo 101-0021, Japan

Sustainability Sec.
Corporate Strategy Dept.
Telephone: +813-6847-1006
FAX: +813-6847-1272
E-mail: csr_et@dowa.co.jp22