Materials Eco-Refining Co., Ltd Responsible Minerals Control Policy

Establishment date:1th Jan 2020
Last revised date:2nd Apr 2024
The Materials Eco-Refining Co., Ltd (hereinafter the "MERC") engages in bullion manufacturing
for platinum and palladium. The MERC does not procure materials originating from high risk
areas, such as conflict-affected areas, connected to human rights abuses, terrorist financing,money laundering and illegal trade. In keeping with this strict nonuse practice and ESG
considerations, the MERC has adopted a control system that follows the London PlatinumPalladium Market (LPPM) guidance for responsible platinum/palladium undergoes regular audits
by third-party bodies.
The MERC hereby sets out its responsible minerals control policy applicable to platinum andpalladium as follows and will implement the following measures.
1. General Provisions(1)The MERC will respect human rights and avoid direct or indirect involvement withinhumane acts. For this purpose, the MERC will not use suspicious minerals which may
be connected to conflict-affected and high risk areas where armed conflict, widespread
violence and other risks may harm individuals.
(2)The MERC will perform risk controls on material procurement and will immediately
stop a transaction when it becomes known that the MERC is purchasing minerals
originating from and connected to those in power in conflict-affected and high riskareas.
(3)The MERC annually receives third-party assurance on its procurement of materials
containing platinum and palladium, and reports the audit results concerning to LPPM.
2. Control System and Responsibility(1)The MERC's headquarters deals with all operations for mineral control smelters andrefineries do not procure materials independently.

(2)The compliance officer appointed by the MERC assumes authority and responsibility
stipulated in the control manual, including those for overseeing relevant sections anddivisions and for operating the control system.
(3)The supply chain officer appointed by the MERC assumes authority and responsibility
stipulated in the control manual, including those for overseeing the entire controlsystem and for regularly conducting management reviews.
3. Judgment Criteria for Material Procurement from Conflict-Affected and High-risk Area
The MERC considers procurement of materials containing platinum and palladium withdefinite or highly suspicious connections to specific conflict-affected areas as determinedby the MERC and high risk areas connected to human rights abuses, terrorist financing,money laundering and illegal trade as high risk.
4. Implementation of Due Diligence on Material Suppliers
The MERC will practice due diligence and perform risk assessments on all suppliers ofmaterials containing platinum and palladium. The MERC will immediately stop atransaction when it is deemed by the supply chain officer as being high risk, as a resultof the risk assessment.
5. Monitoring of Materials Purchased by the MERC's Headquarters(1)Materials purchased by the MERC headquarters are supplied to smelters andrefineries, which will check the actual goods and analyze the content of platinum,
palladium and/or other metals for every lot, to examine consistency with theinformation from suppliers provided in advance by the MERC headquarters and to report
the findings to the MERC headquarters.
(2)The MERC will effectively utilize the monitoring system for incoming materials, which
has long been in place, for the purpose of responsible minerals procurements control at
the MERC headquarters and operate it as a system for the prevention of contamination
with high risk minerals.
6. Operation of the Responsible Minerals Sourcing Control System

(1)The compliance officer will provide education and training to the relevant sections
and divisions of the MERC headquarters and to the smelters and refineries as needed.
(2)The compliance officer will perform at least one internal monitoring per year of therelevant sections and divisions of the MERC headquarters and of the smelters andrefineries to assess if operations are properly performed in accordance with theresponsible minerals sourcing control system or if there are any deviances from thesystem.
(3)In the event of starting transactions with a new supplier for material procurement,
the MERC will ensure that the information is communicated to the compliance officer inan effort to prevent contamination with high risk minerals.
(4)The compliance officer will keep the records of all operations concerning responsible
minerals sourcing control and retain them for five years. The relevant documents of thecontrol manual will be revised as needed and properly managed.