Responsible Minerals Procurement Policy of DMM
In order to establish a responsible supply chain in line with its corporate philosophy, the policy of theDOWA METALS & MINING CO.,LTD. (DMM) is to refrain from using raw materials minerals (tantalum,tungsten, gold, tin, silver, and zinc) with risks as specified in Annex II of the Due Diligence Guidancefor Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (hereinafter,
the “Guidance”) issued by the Organisation for Economic Co-operation and Development (OECD). We
are committed to conducting due diligence in accordance with the five-step framework described in
the Gold/Tin/Tantalum/Tungsten supplement of the OECD Guidance.

1. General Provisions
1. The DMM avoids the procurement of minerals (tantalum, tungsten, gold, tin, silver and zinc)with risks as specified in Annex II of the Guidance.
The risks specified in Annex II of the Guidance include the followingSerious abuses associated with the extraction, transport or trade of mineralsDirect or indirect support to non-state armed groups

Direct or indirect support to public or private security forces

Bribery and fraudulent misrepresentation of the origin of mineralsMoney launderingPayment of taxes, fees and royalties to governments

2. The DMM performs risk management in the procurement of raw materials (tantalum, tungsten,gold, tin, silver, and zinc). If it is found that the raw material is a mineral with risks as specified in
Annex II of the Guidance, and if such risks cannot be mitigated, that trade shall immediately besuspended.
3. The DMM performs regular audits using an independent third party to ensure responsible
mineral procurement management regarding the smelting, refining and recycling of gold, tin,silver, and zinc.

2. Control System and Responsibility
1. The headquarters of the DMM deals with the procurement of mineral materials used by theDMM’s smelting and refining divisions, supplying materials to the smelters and refineries thatthey manage. The Resource Development & Raw Materials Department at DMM controls theprocurement of materials.
2. The headquarters of the DMM or the manufacturing subsidiaries themselves are responsible forthe proper procurement of mineral materials used by DMM’s manufacturing subsidiaries,

supplying materials to the manufacturing subsidiaries that they manage.
3. DMM appoint a manager with responsibility for ensuring compliance with the Responsible
Minerals Procurement Policy. The manager with responsibility for the responsible procurementof minerals oversees the whole management system and assumes the authority andresponsibility stipulated in the control manual.

3. Judgment Criteria for Material Procurement from Conflict-Affected and High-Risk
Areas
The DMM considers the material procurement of tantalum, tungsten, gold, tin, silver and zinc withrisks as specified in Annex II of the Guidance to be high-risk material procurement.

4. Operation of the Conflict Minerals Control System(1) Due Diligence relating to Material Suppliers
The DMM implements due diligence for all suppliers of materials containing gold, tin(*), silver,and zinc, and performs risk assessment proportionate to the identified risk. DMM discontinues
transactions that the manager with responsibility for the control of conflict minerals deems tobe high risk.

(*) Excludes recycled tin materials(2) Monitoring of Transactions
1) Materials Accepted at Smelters and Refineries
Smelters and refineries check materials received to ensure the actual goods are those describedin transaction information at the time of procurement and report the findings on nonconformance to the division in charge at headquarters.

DMM conducts regular internal monitoring to ensure due diligence of suppliers is executed
properly. DMM engages independent third-party auditors to perform audits regarding gold, tin,silver, and zinc materials.

2) Materials Accepted at Recycling Plants


Recycling plants check with the supplier to confirm that the recycled materials accepted(recycled materials or scrap) have lost their original function or are no longer required andreport the findings to the division in charge at headquarters.

3) Materials Accepted at Manufacturing Subsidiaries


Manufacturing subsidiaries check materials accepted for consistency of the actual goods withthe transaction information at the time of procurement and report the findings to the division

in charge at headquarters.
DMM conducts regular internal monitoring to ensure that due diligence for suppliers is executedsoundly.

(3) Training

DMM provides the education and training necessary for headquarters divisions, smelters andrefineries, recycling plants and manufacturing subsidiaries on a regular basis to conduct theiroperations in conformance with the responsible procurement policy.

(4) Retention of Records

The manager responsible for the responsible procurement of minerals stipulates the records
that must be retained concerning the control of conflict minerals, establishes the period ofretention and manages the records.