Responsible Minerals Assurance Process
Due Diligence Public Report[ 2023 edition ]1. Company information (all origins)
The company name is Asaka Riken Co., Ltd. ,We have the following two refiningfactories.
1) Headquarters plant [CID:000090]

Handling Item: gold

(address : 47 Aza Maseguchi, Kanaya, Tamura-machi, Koriyama-shi, Fukushima,963-0725, Japan )2) Iwaki plant [CID:000092]

Handling Item: no item

(address : 246-23 Aza Egoshi, Kurosuno, Izumi-machi, Iwaki-shi, Fukushima,971-8184, Japan).
* Iwaki factory is not active now.

2. RMAP evaluation summary (all origins)
We have gotten RMAP audit at Headquarters plant, and the latest evaluation results
were as follows.
Target material: gold
Evaluation date: April 12th 2022
Evaluation period: January 2019 to December 2021
Auditor: Intertek Certification Japan Ltd.
Evaluation result: Conformant
Validity of this evaluation: 3 years*As for the period from January 2022 to December 2022, it falls within theabove valid period, so We only submitted an annual report.
3. Corporate policy on supply chain (all origins)We have established a basic policy on raw material procurement in order to avoid theuse of conflict minerals that may directly or indirectly benefit or fund armed groups, and/ or cause other serious human rights violations in conflict-affected and high-risk areas.
This supply chain policy is fully compliant with the third edition of the OECD Due
Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected andHigh- Risk Areas (OECD Guidance) . This policy covers all risks identified in Annex II ofthe OECD guidance and covers the entire world. We will do our best to address any risks
identified in Annex II . This policy has been reviewed and approved by senior
management committed to supporting the implementation of this policy. This policy is
widely provided to relevant stakeholders (suppliers, customers, employees, etc.) and isalso available from our website ( http://www.asaka.co.jp/company/08.html ) .

4. Company management system (all origins)[Management structure]
We are committed to comply with our supply chain policy and have establishedinternal procedures for due diligence that includes the following items:• Our raw materials procurement manager is responsible for overseeing the design
and practice of due diligence programs and risk management.
• In order to execute the roles and responsibilities properly that each department
should play in the implementation of due diligence program and reporting ofidentified red flags and potential risks, we have determined and assigned roles ofeach related department(including the sales department, manufacturing

department, and quality assurance department).
• We conduct due diligence management system training required for the due
diligence program more than once a year for key employees in all relevant
departments. If the due diligence program is updated, we will provide additional
training as needed.
[Internal management system]
In December 2021, we reviewed our due diligence management system based on
OECD guidance and RMAP. And in March 2022, we have notified identified upstream
suppliers of this updated supply chain policy and procurement requirements.
In addition, we have included due diligence-related requirements in the contract
content as a legally binding agreement.

Since April 2022, no new program updates have occurred.

[Contact for complaints]
We refer to RMI 's grievance mechanism in order to collect information related tocomplaints and mitigation from related parties. And we have a grievance page on ourcompany's website where external complaint information can be entered.
In addition, a contact point has been established to accept information from
whistleblowers.
[Record keeping system]
We maintain all records related to the due diligence program for at least five years,
and we stipulate that such records be used appropriately and kept safely in our database.

5. Identification of risks (all origins)
We use the following robust process to identify risks in our supply chain.
1) We refers to the indicated risk in our supply chain policy, and defines procedure foridentifying conflict-affected and high-risk areas (CAHRAs). This procedure includes
the resources used, the definition of “conflict and high risk areas”, and thefrequency of reviews for our decisions. In determining CAHRAs, we refer to thefollowing resources:
・ Conflict regions - Heidelberg dispute barometerhttps://hiik.de/conflict-barometer/current-version/?lang=en
・ Human rights violation - Fragile States Index
https://fragilestatesindex.org/global-data/
・ Money Laundering Risk Area - Knowyourcountry
https://www.knowyourcountry.com/country-ratings-table
・ Resource governance- Resource Governance Index(RGI)
https://resourcegovernance.org/- Human Freedom Index
https://www.cato.org/human-freedom-index
・ The Indicative List of CAHRAs Provided by the European Commission Pursuant

to Article 14.2 of the European Union Regulation 2017/821was published. (Latestupdate: December 2021)
https://www.cahraslist.net/cahras
We are referring to our supply chain policy and external resources and havedeveloped conditions and benchmark indicators for determining CAHRAs.
2) We have developed a Know Your Supplier(KYS) process that includes

information about the legal status and identity of suppliers, supplier mappingsand potential risks. We have commissioned an external research organization tocheck the ownership of all suppliers, corporate structure, identification of related
businesses, financial status, and whether there are any violations of laws. Inaddition, for the refining company, we ask and collect information through CMRT.
*In the reporting period from January 2022 to December 2022, there were no red
flags for suppliers.
3) We require submission of origin information for all material transactions, and wehave a system in place that allows us to know the origin of the material, thetransport route, and the name and location of the direct supplier.
4) We require submission of origin information for all material transactions, and wemaintain a system that allows us to know the origin of the material, thetransport route, and the name and location of the direct supplier.
5) We review all collected information against CAHRAs, sanctions lists, local laws,
and internal procurement requirements.

6 ．Risk assessment (high risk origin only)
We have implemented the enhanced due diligence on materials and supply chains
designated as “high risk”. The contents are as follows.
-Assessment of CAHRAs status .

-Clarification of production logistics management.

-Questionnaire survey of risks listed on OECD Guidance Annex II.

- Assessment of upstream supplier activities and relationships .
-Identification and assessment of raw material suppliers by CMRT survey.

In addition, we will perform due diligence by assessing the risk level for thedocument based on the upstream company's due diligence program for public andactual transaction information.
Furthermore, we conduct the due diligence by completing the comparison between
the documents based on the diligence program by the upstream companies and thepublic, actual transaction information and by evaluating the risk level.

7 . Risk mitigation
Our supply chain policy defines risk mitigation strategies that can be adopted inaccordance with the OECD Guidance Annex II Model Policy. Risks identified inhigh-risk supply chains are mitigated by following steps:
We will get more information about the risk mitigation process by asking thesupplier directly. We will endeavor to implement the following items using them.
-Identify information, including the names of producers and exporters, for specificsources of materials.

-

Confirmation of whether the reported risk has been addressed and / or rereported during the next reporting period.

-

Make inquiries about how to deal with risks, including who is responsible for
implementing risk mitigation actions.

-Regularly request the latest information on risk mitigation measures for related
supply chains.

Published

September 1th 2023Asaka Riken Co., Ltd.