OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk-Areas
TANIOBIS Group Due Diligence Report for Raw Materials Supplies in Year2023 (OECD 5-Step Report)
Reporting period 01-12/2023

1. Group Information
TANIOBIS GmbH is a leading global producer with over 60 years of experience in processingof a broad range of high-quality tantalum and niobium-based materials. Since July 1st, 2018,
TANIOBIS GmbH has been a part of the JX Nippon Mining & Metals Group
Our Locations:

Site information’s:
TANIOBIS GmbHIm Schleeke 78-91; D-38642 Goslar
RMI smelter ID: CID002545 for Tantalum
TANIOBIS Smelting GmbH & Co. KG
Ferroweg 1; D-79725
RMI smelter ID: CID002550 for Tantalum
RMI smelter ID: CID002542 for Tungsten
TANIOBIS Co., Ltd.
5, I-3A Road, Map Ta Phut; Industrial Estate Rayong 21150
RMI smelter ID: CID002544 for Tantalum
Assessment Company: Arche Advisors
TANIOBIS Japan Co., Ltd.
Hitachi Ohmiya-shi; Iberaki 319-2134 MitoRMI smelter ID: CID002549 for Tantalum
For more details see
our-sites

2. RMAP Assessment
TANIOBIS GmbHRMI smelter ID: CID002545 for Tantalum
Assessment Scope: Tantalum
Assessment period: 09.10.2021 – 31.01.2023
Assessment Date: 27.03.2023 – 29.03.2023
Assessment Company: Arche Advisors
Result: TANIOBIS GmbH was non-conformant with the Assessment Standard for Tantalum(2017).
Two non-commences were identified.
a) CAHRAS procedure was not sufficiently detailed in some criteria.
b) No clear statement of support for the Extractive Industry Transparency Initiative (EITI) in
the policy
Both non-conformances were successfully closed by the auditor and RMI during the CAP
process.
TANIOBIS GmbH is conformant with the Assessment Standard for Tantalum (2017).
TANIOBIS Smelting GmbH & Co. KG
Ferroweg 1; D-79725
RMI smelter ID: CID002550 for Tantalum
RMI smelter ID: CID002542 for Tungsten
Assessment Scope: Tantalum and Tungsten
Assessment period: 10.01.2021 – 31.01.2023
Assessment Date: 31.03.2023
Assessment Company: Arche Advisors
Result: TANIOBIS Smelting GmbH & Co. KG was non-conformant with the Assessment
Standard for Tantalum (2017) and non-conformant with the Assessment Standard for
Tungsten (2017).
Two non-commences were identified.
a) CAHRAS procedure was not sufficiently detailed in some criteria.
b) No clear statement of support for the Extractive Industry Transparency Initiative (EITI) in
the policy
Both non-conformances were successfully closed by the auditor and RMI during the CAP
process.
TANIOBIS Smelting GmbH & Co. KG is conformant with the Assessment Standard for
Tantalum (2017) and conformant with the Assessment Standard for Tungsten (2017).

TANIOBIS Co., Ltd.
5, I-3A Road, Map Ta Phut; Industrial Estate Rayong 21150
RMI smelter ID: CID002544 for Tantalum
Assessment Scope: Tantalum
Assessment period: 15.10.2021 – 28.02.2023
Assessment Date: 09.05.2023 -12.05.2023.
Assessment Company: Arche Advisors
Result: TANIOBIS Co., Ltd. Was non-conformant with the Assessment Standard for Tantalum(2017).
Three non-commences were identified.
a) CAHRAS procedure was not sufficiently detailed in some criteria.
b) No clear statement of support for the Extractive Industry Transparency Initiative (EITI) in
the policyc) One sub-supplier did not correctly declare the material to be exported to the Congolese
authorities, the analysis of the tantalum content deviated significantly from the invoiced
content.
All non-conformances were successfully closed by the auditor and RMI during the CAP
process.
TANIOBIS Co., Ltd. is conformant with the Assessment Standard for Tantalum (2017).
TANIOBIS Japan Co., Ltd.
Hitachi Ohmiya-shi; Iberaki 319-2134 Mito
RMI smelter ID: CID002549 for Tantalum
Assessment Scope: Tantalum
Assessment period: 30.10.2021 – 31.03.2023
Assessment Date: 16.05.2023 – 17.05.2023
Assessment Company: Arche Advisors
Result: TANIOBIS Japan Co., Ltd. Was non-conformant with the Assessment Standard for
Tantalum (2017).
Two non-commences were identified.
a) CAHRAS procedure was not sufficiently detailed in some criteria.
b) No clear statement of support for the Extractive Industry Transparency Initiative (EITI) in
the policy
Both non-conformances were successfully closed by the auditor and RMI during the CAP
process.
TANIOBIS Smelting GmbH & Co. KG is conformant with the Assessment Standard for
Tantalum (2017) and conformant with the Assessment Standard for Tungsten (2017).

RMAP Assessment summary:
TANIOBIS GmbH, TANIOBIS Smelting GmbH & Co., KG and TANIOBIS Co., Ltd. are a memberof the ITRI Tin Supply Chain Initiative (iTSCi), that has developed a due diligence system for atransparent raw material supply chain in conflict regions and monitors the implementation of
the system in their member companies. TANIOBIS GmbH is also a full member of the
Responsible Mineral Initiative.
Since 2011 the TANIOBIS GmbH and its affiliates TANIOBIS Smelting GmbH & Co.KG;
TANIOBIS Japan Co., Ltd. and TANIOBIS Co., Ltd. are a continuously approved Conflict Free
Smelter / Responsible Smelter.
Summary non-conformances for the RMAP audits:
1. CAHRAS procedure was not sufficiently detailed in some criteria:
The CAHRAS Process was adapted according to the auditor's recommendations. A
appropriate CAHRAS analysis was carried out. The CAHRAS process is performed
centrally, so it was the same non-conformance in all RMAP audits.
2. No clear statement of support for the Extractive Industry Transparency Initiative (EITI) in
the policy:
TANIOBIS Group is not a mining company and therefore has no direct contact with the
EITI. The policy includes that TANIOBIS, where appropriate, supports its suppliers and thecountries from which raw materials are sourced in reporting to the EITI.
The Policy is for the group, so it was the same non-conformance in all RMAP audits.
3. One sub-supplier did not correctly declare the material to be exported to the Congolese
authorities, the analysis of the tantalum content deviated significantly from the invoiced
content. As a corrective measure, the tax process of some countries was determined anddocumented. The correct taxation is now part of the check for each goods receipt. The
direct suppliers were requested to carry out this check at the sub-suppliers.
This non-conformance was only in one RMAP audit.
Also some points for improvement are identified.
These include, for example, the revision of the Grievance Mechanism, and the optimizationof procedures.

3. Company Management System
Besides the RMAP assessments (Responsible Minerals Assurance Process by Responsible
Minerals Initiative) the TANIOBIS Group is certified according to ISO 9001, ISO 14001, someof its legal entities according to ISO 50001, and ISO 45001 as well. In addition to the HSEQ
aspects the Senior Management has appointed a Manager for Raw Material Complianceresponsible for supply chain management (RSCM) including the raw material due diligenceprocess.
The Management Representative reports directly to the CEO / COO of the company. Within
the RSCM, the Manager Raw Material Compliance coordinates the work of the relevant
departments (incl. Supply Chain Management, Procurement, Quality Management, Customer

Service) to ensure that each department follows up on its roles and responsibilities toimplement the due diligence process. The process is documented in an IT document
management system. Quality control was done by ISO 17025 certified own laboratory in Map
Ta Phut and contracted laboratories. All relevant departments undergo due diligence
management system training when changes or risk have been identified. In 2023 was acontinue process on improving due diligence control documentation at each approval of
single deliveries by Manager Raw Material Compliance in a database called Osiris. Started
first at TANIOBIS GmbH and for TANIOBIS Smelting GmbH & Co., KG. In 2023 also the system
was implemented at TANIOBIS Co., Ltd..

4. Internal Systems of control
4.1 Company Supply Chain Policy
This policy is valid for the TANIOBIS GmbH and its affiliates TANIOBIS Smelting GmbH &Co.KG; TANIOBIS Japan Co., Ltd.; TANIOBIS Co., Ltd. and TANIOBIS USA LLC.
As responsible corporate citizens, we pursue excellence in fulfilling governmental, industrial
and environmental standards worldwide. We are committed to comply to all relevant
sanctions, in particular UN resolutions, as well as all national and international legislations.
With this policy, update in 2023, the whole TANIOBIS Group fully commits to the OECD Due
Diligence Guidance on Responsible Supply Chains of Minerals from Conflict-Affected andHigh-Risk Areas. As elaborated in Annex 2 of the guidance.
The acceptance of our Raw Material Policy is part of each order.
Raw Material Policy
4.2 Supplier Qualification
Before starting business with a new supplier (also sub-supplier), there is a detailed checkconducted by Raw Material Compliance together with Procurement to identify risk in the
supply chain according Annex 2 of the OECD Guidance and the EU regulation for Conflict
Minerals. This is described in our supplier qualification system. This procedure as for
qualification system is also used to requalify active suppliers and sub-suppliers yearly.
4.3 Know Your Counterpart (Supplier)
All suppliers (Companies, Manager, Owners and beneficial Owners) undergo the Know YourCounterpart process as first step of the qualification. For the KYC Process we use informationfrom supplier and from external source. This check is done in our SAP GTS system based on
governmentally approved and own sanction lists. Where possible, subcontractors are also
checked in the same way.
For suppliers under the due diligence systems of ITSCI and BSP the KYC Check is done by ITSCIand BSP and therefore as an improvement we started also to make the KYC check at this
suppliers.
The KYC data are collected also in the OSIRIS System.

4.4 Identification of CAHRAs
CAHRAs are identified by using different sources in the internet and are checked for links tothe supplier. The sources are listed in the company guidance for CAHRA’s check.
Furthermore, the indicative EU CAHRAS list is used for assessment. If a potential risk is found,an onsite visit and audit at the supplier is mandatory. The process based on the EURegulation and the COMMISSION RECOMMENDATION (EU) 2018/1149 of 10 August 2018
In 2023, sourcing out of CAHRAs done within RMI and OECD approved due diligence systems
and with additional measurements for some areas. Several mines in North Kivu are blocked
during 2023.
In end of 2022 TANIOBIS conducted together with Arch Advisors a Risk Assessment for
suppliers out of Ethiopia (Oromia south region, Kenticha mining area). The result was a low
risk for this region, the transport route and the suppliers.
During the On The Ground Assessment, the following improvement points were identified:- Implementation of management systems, policies and processes- Know Your Counterpart process below the trader level among the cooperatives and theirmembers- Install a chain of costody/traceabillity system between mines and traders.
The implementation of the required measures will be supported by TANIOBIS. A second Risk
Assessment was done by Arche Advisors in 2023 ordered by a supplier for new sub-suppliersin Ethiopia. Result is the same as before.
4.5 Scope of Risk Assessment
For each raw material supplier, we do a risk mitigation according to Annex III of the OECD
Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected andHigh-Risk-Areas.
4.6 Internal Control
Each raw material delivery is internally controlled by the Manager Raw Material Complianceduring internal audits and must fulfill the RMAP Standard and the EU Regulation for Conflict
Minerals.
All relevant documents and data are stored for a minimum of 5 years. All due diligence
documents for the deliveries are stored also in electronic files on a server.
The traceability of all procured and used raw materials including quantities, analyses etc. isguaranteed by the SAP system.
4.7 Intermediates
All intermediates processed by the group in 2022 were sourced from smelters/refiners thatare listed by the RMI as RMAP conformant tantalum and tungsten smelters. Tin Slag is only
sourced from smelters/refiners that are listed by the RMI as RMAP conformant tin smelters.

5. Risk Assessment (only High-Risk sourcing)
As an active member of ITSCI during this reporting period we received the following
documents from ITSCI for each high-risk sourcing transaction:
1) ITSCI Traceability reports including Baseline Audit Reports for the mines2) Incident summary reports (monthly)3) Mine Visit Recommendations including a list of mine sites with potential risks (it is advisedthat companies sourcing from these mine sites conduct enhanced due diligence and risk
assessment)
4) Monthly country and region report, which review the general situation to the bottom
5) ITSCI Alerts for risk in the supply chain
6) Data summary and other reports
This information is reviewed by the Manager Raw Material Compliance who informs the
management and relevant people about due diligence risk he has identified in the
documents.
The iTSCi documents listed above have been visible to all relevant persons in the document
management system since 2020 and are archived there.
The Company did not utilize the Better Sourcing Program (BSP) to assess risk for each highrisk sourcing transaction during this reporting period, as no procurements were made under
this due diligence system. The program maps the company's upstream supply chain andprovides the information/documents listed below. The information relates to each materialdelivery and can be accessed directly through the BSP software platform:
1) Mining company supplier due diligence program (e.g. KYC questionnaire, company
registration, mining license, certificate of payment of taxes)2) Governance information relating to operating/ country context of mining company
supplier (e.g. political, economic and security situation, due diligence standards)
3) Mining company supplier baseline assessment report (BSP field agents conduct an initialbaseline assessment of the OECD Guidance Annex II risks at each mine site)4) Mining company supplier dynamic evaluation report (for each mine site, BSP field agents
continuously monitor risks and incidents on the ground using a mobile application)
In 2022, there were no deliveries under the BSP system.
6. Risk Mitigation (only High-Risk sourcing)
ITSCI
We check with the iTSCi secretariat to obtain details of the risk mitigation process:
1) iTSCi identify the specific source of the material including the name of the producer andexporter2) We are informed by iTSCI about the progress of risk mitigation for the reported risks inthe subsequent reporting period.
3) We are informed by iTSCi about the methodology for addressing the risks including who
performed risk mitigation activities
4) We get are regular updates by iTSCi of the risk mitigation activities for relevant supply
chains
We check, if necessary, also with other source risk in the supply chain. As an example thecorrect taxation of the exported materials.
We check every iTSCi Traceability Report and ask iTSCi if anything is unclear or errors in orderto rule out risks in our supply chain.

BSP
Based on the findings of the initial baseline report and the dynamic evaluation report, BSP
provides technical advice and helps the participating mining companies to close any gaps indue diligence management systems (e.g. develop a supply chain policy, establish amanagement structure), achieve traceability (e.g. develop an electronic tagging system) and
respond to identified risks. Each identified risk is reviewed and scored on the basis of its
severity (minor, moderate and major) while BSP provides a standardized protocol for how
the risk can be mitigated in the short term and long term by the mining company. The
effectiveness of mitigation is tracked and reported periodically by BSP field agents who arealso involved in related engagement with affected stakeholders (e.g. local communities). The
company assesses this data in consultation with BSP and supply chain participants as needed
to infer whether additional risk mitigation action is required.
7. Grievance Mechanisms
If anyone presents grievances (employees as well as externally interested) in the
procurement of raw materials in the supply chain of the TANIOBIS Group, he could contact
TANIOBIS via “contact us” on our homepage. The message is then forwarded to the Manager
Raw Materials Compliance who will reviews it for plausibility and forward it to the
management for further decision.
Or
The complainant uses the Grievance mechanism of the Responsible Minerals Initiative
RMI Grievance Mechanism
There, the RMI, as an independent institution, decides on the further course of action andfollows the further course of action.
In 2023 there were no grievances related to the raw material supply chain of the TANIOBISGroup. In 2022, the Grievance process was checked according to the new German law
Whistleblower Protection Act. The Grievance process fulfilled the law. This German law is theimplementation of Directive (EU) 2019/1937.
8. Reporting on Risks beyond Annex II
In addition, supply chain risk assessment includes evaluating the location of a resource(mine) in relation to a protected area or world heritage site.
9. Summary:
The implemented procedures and delivery checks are according to OECD guidance andaccording to the REGULATION (EU) 2017/821 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 17 May 2017 laying down supply chain due diligence obligations for Union
importers of tin, tantalum and tungsten, their ores, and gold originating from conflictaffected and high-risk areas. No unknown risks have been identified.

Space for improvement is identified as well and will be incorporated according to JX
regulation.
-

Analysis of the European Supply Chain Act after implementation for all procurement
activities.
Implement additional plausibility check for sources in CAHRAS

Goslar, May 31st, 2024
Frank Habig
Manager Raw Material Compliance
TANIOBIS GmbH