May 16, 2022
Chugai Mining Co., Ltd.
Tokyo Plant
Precious Metal Division
Responsible Minerals Initiative (RMI) Diligence Report

1.

Corporate profile
Chugai Mining Co., Ltd. (CID No.: CID000264)
Mochikoshi Mine Co., Ltd. was established in 1932 and merged with Yakumo Mine Co. andtwo other companies in 1936, changing its name to the current Chugai Mining Co. Ltd. The
Company owns one refining facility (Tokyo Plant), which is located at 2-12-16 Keihinjima,Ota-ku, Tokyo, Japan. Our smelting facilities produce gold products from gold raw materials.

2.

RMAP Assessment SummaryThe Tokyo Plant underwent a Responsible Minerals Assurance Process (RAMP) assessment
from August 19 to 21 in 2020. The period covered by this assessment is September 1, 2018
through May 31, 2020. This assessment is valid for three years. This evaluation wasconducted by SCS Global Services.

3.

Corporate Policy on Supply Chain
We have established a supply chain policy with the objective of avoiding the use of conflictminerals that may, directly or indirectly, benefit or finance armed groups in high-risk andconflict areas or result in other gross human rights violations.
This supply chain policy is fully compliant with the third edition of the OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas (OECD Guidance). The policy also covers all risks identified in Annex II of the OECD
Guidance and is intended to cover the entire world.
We will make every effort to address the risks enumerated in Annex II as they are identified.
The policy has been reviewed and approved by senior management who have committed
their support to the implementation of the policy. This policy is widely available tostakeholders (suppliers, customers, employees, etc.) and is also available on our official
website (https://www.chugaikogyo.co.jp/csr/materials/).

4.

Corporate Management System
Management Structure
In addition to ensuring compliance with our own supply chain policies, we have establishedinternal procedures for due diligence that include the following items.
・ Oversight of the design and implementation of the due diligence program and risk
management practices is the responsibility of our Head of Precious Metals Division.
・ We have designated a Due Diligence Program Manager who is responsible for theoperational coordination between each relevant department (including sales,manufacturing, and administrative departments) in order to properly execute the roles
and responsibilities of each department with respect to implementing the due
diligence program and reporting identified red flags and potential risks.
・ Key employees in all applicable departments required for our due diligence programon our due diligence management system are trained on an annual basis. As the due
diligence program is updated, we will provide additional training as needed.
Internal Management System
・ In October 2018, the Company developed and updated the content of its due
diligence management system in compliance with the OECD Guidance and RMAP.
Since then, we have notified all identified upstream suppliers of this updated supply
chain policy and procurement requirements.
We include due diligence-related requirements as legally binding agreements in thecontracts we enter into with our direct suppliers.
We refer to the RMI's grievance mechanism to gather information on the handling ofgrievances from related parties.
Record Keeping
・ We will maintain all records related to our due diligence program for a minimum of
10 years, and will also keep them in a database through a system that has been inplace since April 2019.

5.

Identification of Risks
The Company employs a robust process for identifying risks in the supply chain.
First, we have procedures in place to identify Conflict-Affected and High-Risk Areas(CAHRAs) by reference to the risks in our supply chain policy. This procedure includes theresources to be used, the conditions defining "conflict and high-risk areas," and thefrequency of review of our decisions.
We refer to the following resources to determine whether the area falls within thedefinition of CAHRA.

1） The Heidelberg Conflict Index, which provides a conflict map showing the locations ofarmed conflict in each year;
2） Fragile State Index, which provides a country-by-country listing related to human rights
violations and the rule of law;
3） OECD's Financial Action Task Force list, which provides a list of high risks for money
laundering and corruption among others.
We refer to our supply chain policy and information from external specialized agencies todevelop the conditions and benchmark indicators to determine CAHRA.
Secondly, we have created a supplier know-your-supplier (KYS) document that includes
information on the legal status and identity of suppliers, supplier mapping, and potentialrisks
All of the smelters we subcontract to have already completed and submitted their KYS tous.
Our Due Diligence Program Manager, in conjunction with the Sales Department, reviews
the information provided by suppliers against the UN Sanctioned Countries List. If we
discover any discrepancies, errors, or incomplete information on a KYS form submitted bya supplier, we will notify the supplier of the items that need to be corrected and requestthat they resubmit the form.
Should red flags be identified, we will ask the supplier to further clarify and remedy theissues in the documentation, as needed. No red flags associated with supplier-submitted
KYS forms were identified in this reporting period.
Thirdly, we require the information on the origin of all material transactions to besubmitted to us, and we ensure that this information enables us to determine the originof the transaction, the transportation route, as well as the name and location of the direct
suppliers. Basically, we comply with the laws of Japan, and the majority of ourtransactions are with domestic vendors, and therefore, we do not directly handle any
imported goods. We deal primarily with recycled products and require our suppliers toagree to our supply chain policy in a written confirmation.
Finally, we review all information collected against CAHRA, sanctions lists, local laws, andinternal procurement requirements.
The Company identifies risks according to the above four categories.
During this reporting period (April 2021 to May 2022), no red flags were identified ordetected in all transactions or suppliers. The information collected has been reviewed
periodically against the risks described in section 5 (Identification of Risks).
(End of document)