November 14, 2023

Company Policy on Procurement of Precious Metal Raw Materials
Chugai Mining Co., Ltd. will fulfill its obligations to society by promoting initiatives forresponsible procurement of precious metal raw materials in consideration of human rights,
the environment, and ethics in accordance with the RBA Code of Conduct and Corporate
Social Responsibility (CSR) in the sourcing of raw materials for precious metals.
We will promote the responsible procurement of precious metals by complying with "OECDDue Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected andHigh-Risk Areas" and national laws, and by providing reasonable assurance that we do notdirectly or indirectly support non-government armed groups, directly or indirectly support any
non-governmental or private security forces, engage in or contribute to money laundering,illegal transactions, or contribute to conflict or funding of terrorism.
We will implement risk avoidance measures as set forth in Annex II of the "OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas" against the risks set out below.
We will also undertake to comply with the Annex (Supplement on Gold).
1.

Any forms of torture, cruel, inhuman and degrading treatment;

2.

Any forms of forced or compulsory labor, i.e., labor or rendering of services which isforced by any person under threat of punishment and which is not performed
voluntarily by the person concerned;

3.

The worst forms of child labor;

4.

Other gross human rights violations and abuses including widespread sexual violence;

5.

Money laundering or terrorist financing;

6.

War crimes or other serious violations of international humanitarian law, crimes against
humanity or genocide;

7.

Non-payment of taxes, fees and royalties to governments;

8.

Bribery and fraudulent misrepresentation of the origin of raw materials; and9.

Direct or indirect support to non-state armed groups;•

Establishment of management system
In order to address the precious metal raw material supply chain and to conduct risk
assessments (due diligence), we will appoint a manager to promote the establishmentof an ongoing management system for the procurement of precious metal raw materials.

•Assessment of procurement channels and suppliers, and implementation ofmanagement reviews
Under a responsible precious metal management system, we will continuously conduct
risk assessments (due diligence) of our precious metal procurement channels and supply
chain, and properly store and manage the records of such assessments.
At the same time, management reviews are conducted by the management team toensure sustainable improvements.
If a supplier is found to be involved in or likely to be involved in conflict or human rights
abuses, terrorist financing, money laundering, or illicit transactions in high-risk areas,
and we are unable to mitigate those risks, we will immediately cease purchases ortransactions. After that, we will conduct no transactions unless the basis for
remediation of the problem is provided for the identified transaction and we certify thatthe problem has been resolved.

•Implementation of education and training
We will provide ongoing education and training as required for all personnel involved in
responsible precious metal management.

•Monitoring and record keeping of transactions
We will monitor incoming precious metal raw materials for consistency with information
obtained from suppliers, and maintain records appropriately.

•Third-party audits
In accordance with the RMI guidance, we will arrange for an independent third-party
audit on the responsible supply chain management system and implementation status
on a regular basis.
(End of document)