Mitsui Kinzoku Group
Procurement Guidelines

Second Edition
February 2021

Mitsui Kinzoku Group Procurement Guidelines
Introduction
Mitsui Kinzoku Group’s supply chain management pursues sound business management, improvement of technical competence, excellent quality, price competitiveness,and stable supply in its procurement as well as responsible supply chain. Mitsui Kinzoku
Group works to ensure the social and environmental sustainability in its entire supply
chain.
Mitsui Kinzoku Group’s procurement approach follows internationally recognized rules
and guidelines, such as the United Nations Global Compact, and especially in line with
the Responsible Business Alliance (RBA) Code of Conduct. Suppliers are also expected
to observe the Mitsui Kinzoku Group Procurement Guidelines.
The Mitsui Kinzoku Group Procurement Guidelines, which are based on the RBA Codeof Conduct, provide standards for us and our supply chain to ensure that working conditions are safe, that workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically.
The guidelines are made up of five sections. Sections A, B, and C outline standards forLabor, Health and Safety, and the Environment, respectively. Section D adds standards
relating to business ethics; Section E outlines the elements of an acceptable system tomanage conformity to the guidelines.

A. LABOR
Participants are committed to uphold the human rights of workers, and to treat them with
dignity and respect as understood by the international community. This applies to all
workers including temporary, migrant, student, contract, direct employees, and any othertype of worker. The recognized standards, as set out in the References, were used in
preparing the Code and may be useful sources of additional information.
The labor standards are:1) Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative
prison labor, slavery or trafficking of persons is not permitted. This includes transporting,1

harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions
on workers’ freedom of movement in the facility in addition to unreasonable restrictions
on entering or exiting company- provided facilities including, if applicable, workers’ dormitories or living quarters. As part of the hiring process, all workers must be provided
with a written employment agreement in their native language that contains a descriptionof terms and conditions of employment. Foreign migrant workers must receive the employment agreement prior to the worker departing from his or her country of origin andthere shall be no substitution or change(s) allowed in the employment agreement upon
arrival in the receiving country unless these changes are made to meet local law andprovide equal or better terms. All work must be voluntary, and workers shall be free toleave work at any time or terminate their employment without penalty if reasonable notice
is given as per worker’s contract. Employers, agents, and sub-agents’ may not hold orotherwise destroy, conceal, or confiscate identity or immigration documents, such as
government-issued identification, passports, or work permits. Employers can only holddocumentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents. Workers shall not be required to pay employers’
agents or sub-agents’ recruitment fees or other related fees for their employment. If any
such fees are found to have been paid by workers, such fees shall be repaid to theworker.

2) Young Workers
Child labor is not to be used in any stage of manufacturing. The term “child” refers to any
person under the age of 15, or under the age for completing compulsory education, or
under the minimum age for employment in the country, whichever is greatest. Participants shall implement an appropriate mechanism to verify the age of workers. The useof legitimate workplace learning programs, which comply with all laws and regulations,is supported. Workers under the age of 18 (Young Workers) shall not perform work thatis likely to jeopardize their health or safety, including night shifts and overtime. Participants shall ensure proper management of student workers through proper maintenanceof student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable laws and regulations. Participants shall provide appropriate support and training to all student workers. In the absence of local law,
the wage rate for student workers, interns, and apprentices shall be at least the samewage rate as other entry-level workers performing equal or similar tasks. If child labor is
identified, assistance/remediation is provided.
23) Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased
turnover, and increased injury and illness. Working hours are not to exceed the maximum
set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. All overtime must be voluntary. Workers shall be allowed at least one day off every seven days.

4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including
those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greaterthan regular hourly rates. Deductions from wages as a disciplinary measure shall not be
permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation
for work performed. All use of temporary, dispatch and outsourced labor will be within
the limits of the local law.

5) Humane Treatment
There is to be no harsh or inhumane treatment including violence, gender-based violence,
sexual harassment, sexual abuse, corporal punishment, mental or physical coercion,
bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any
such treatment. Disciplinary policies and procedures in support of these requirements
shall be clearly defined and communicated to workers.

6) Non-Discrimination/Non-Harassment
Participants should be committed to a workplace free of harassment and unlawful discrimination. Companies shall not engage in discrimination or harassment based on race,color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Workers
shall be provided with reasonable accommodation for religious practices. In addition,
workers or potential workers should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way.
This was drafted in consideration of ILO Discrimination (Employment and Occupation)3

Convention (No.111).

7) Freedom of Association
In conformance with local law, participants shall respect the right of all workers to formand join trade unions of their own choosing, to bargain collectively, and to engage inpeaceful assembly as well as respect the right of workers to refrain from such activities.
Workers and/or their representatives shall be able to openly communicate and shareideas and concerns with management regarding working conditions and management
practices without fear of discrimination, reprisal, intimidation, or harassment.

B. HEALTH and SAFETY
Participants recognize that in addition to minimizing the incidence of work-related injury
and illness, a safe and healthy work environment enhances the quality of products andservices, consistency of production and worker retention and morale. Participants also
recognize that ongoing worker input and education are essential to identifying and solving health and safety issues in the workplace.
Recognized management systems such as ISO 45001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and may be
useful sources of additional information.
The health and safety standards are:1) Occupational Safety
Worker potential for exposure to health and safety hazards (chemical, electrical andother energy sources, fire, vehicles, and fall hazards, etc.) are to be identified and assessed, mitigated using the Hierarchy of Controls, which includes eliminating the hazard,
substituting processes or materials, controlling through proper design, implementing engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and providing ongoing occupational health and safety
training. Where hazards cannot be adequately controlled by these means, workers areto be provided with appropriate, well-maintained, personal protective equipment, andeducational materials about risks to them associated with these hazards. Reasonable
steps must also be taken to remove pregnant women and ‘nursing mothers from working
conditions with high hazards, remove or reduce any workplace health and safety risks to4

pregnant women and nursing mothers, including those associated with their work assignments, and provide reasonable accommodations for nursing mothers.

2) Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and theirimpact minimized by implementing emergency plans and response procedures including
emergency reporting, employee notification and evacuation procedures, worker training,and drills. Emergency drills must be executed at least annually or as required by local
law, whichever is more stringent. Emergency plans should also include appropriate fire
detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, contact information for emergency responders, and recovery plans. Such plansand procedures shall focus on minimizing harm to life, the environment, and property.

3) Occupational Injury and Illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to encourage worker reporting, classify
and record injury and illness cases, provide necessary medical treatment, investigate
cases and implement corrective actions to eliminate their causes, and facilitate the returnof workers to work.

4) Industrial Hygiene
Worker exposure to chemical, biological, and physical agents is to be identified, evaluated, and controlled according to the Hierarchy of Controls. If any potential hazards wereidentified, participants shall look for opportunities to eliminate and/or reduce the potential
hazards. If elimination or reduction of the hazards is not feasible, potential hazards areto be controlled through proper design, engineering, and administrative controls. Whenhazards cannot be adequately controlled by such means, workers are to be provided
with and use appropriate, well-maintained, personal protective equipment free of charge.
Protective programs shall be ongoing and include educational materials about the risks
associated with these hazards.

5) Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive orforceful assembly tasks is to be identified, evaluated, and controlled.

56) Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards,
interlocks, and barriers are to be provided and properly maintained where machinerypresents an injury hazard to workers.

7) Sanitation, Food, and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water andsanitary food preparation, storage, and eating facilities. Worker dormitories provided by
the Participant or a labor agent are to be maintained to be clean and safe, and provided
with appropriate emergency egress, hot water for bathing and showering, adequate lighting and heat and ventilation, individually secured accommodations for storing personaland valuable items, and reasonable personal space along with reasonable entry and exit
privileges.

8) Health and Safety Communication
Participants shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but notlimited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety
related information shall be clearly posted in the facility or placed in a location identifiable
and accessible by workers. Training is provided to all workers prior to the beginning ofwork and regularly thereafter. Workers shall be encouraged to raise any health andsafety concerns without retaliation.

C. ENVIRONMENTAL
Participants recognize that environmental responsibility is integral to producing worldclass products. Participants shall identify the environmental impacts and minimize adverse effects on the community, environment, and natural resources within their manufacturing operations, while safeguarding the health and safety of the public. Recognizedmanagement systems such as ISO 14001 and the Eco Management and Audit System(EMAS) were used as references in preparing the Code and may be a useful source ofadditional information.
The environmental standards are:61) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals, and registrations are to be obtained, maintained, and kept current and their operational and reporting
requirements are to be followed.

2) Pollution Prevention and Resource Reduction
Emissions and discharges of pollutants and generation of waste are to be minimized oreliminated at the source or by practices such as adding pollution control equipment;
modifying production, maintenance, and facility processes; or by other means. The useof natural resources, including water, fossil fuels, minerals, and virgin forest products, isto be conserved by practices such as modifying production, maintenance and facility
processes, materials substitution, re-use, conservation, recycling, or other means.

3) Hazardous Substances
Chemicals, waste, and other materials posing a hazard to humans or the environment
are to be identified, labeled, and managed to ensure their safe handling, movement,
storage, use, recycling or reuse, and disposal.

4) Solid Waste
Participants shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).

5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion byproducts generated from operations are to be
characterized, routinely monitored, controlled, and treated as required prior to discharge.
Ozone-depleting substances are to be effectively managed in accordance with the Montreal Protocol and applicable regulations. Participants shall conduct routine monitoringof the performance of its air emission control systems.

6) Materials Restrictions
Participants are to adhere to all applicable laws, regulations, and customer requirements
regarding the prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.
77) Water Management
Participants shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve
water; and controls channels of contamination. All wastewater is to be characterized,
monitored, controlled, and treated as required prior to discharge or disposal. Participants
shall conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

8) Energy Consumption and Greenhouse Gas Emissions
Participants are to establish a corporate-wide greenhouse gas reduction goal. Energy
consumption and all relevant Scopes 1 and 2 greenhouse gas emissions are to be
tracked, documented, and publicly reported against the greenhouse gas reduction goal.
Participants are to look for methods to improve energy efficiency and to minimize theirenergy consumption and greenhouse gas emissions.

9) Conservation of biodiversity
Participants are to be placed particular emphasis on the sustainable use of natural resources, the introduction of technologies and the use of raw materials that take into account biodiversity, and product development that is conscious of biodiversity conservation.

D. ETHICS
To meet social responsibilities and to achieve success in the marketplace, Participants
and their agents are to uphold the highest standards of ethics including:1) Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption,
extortion and embezzlement.

2) No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised,8offered, authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third
party, in order to obtain or retain business, direct business to any person, or otherwise
gain an improper advantage. Monitoring, record keeping, and enforcement procedures
shall be implemented to ensure compliance with anti-corruption laws.

3) Disclosure of Information
All business dealings should be transparently performed and accurately reflected on theParticipant’s business books and records. Information regarding participant’s labor,
health and safety, environmental practices, business activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations andprevailing industry practices. Falsification of records or misrepresentation of conditions
or practices in the supply chain are unacceptable.

4) Intellectual Property
Intellectual property rights are to be respected, transfer of technology and know-how is
to be done in a manner that protects intellectual property rights, and customer and supplier information is to be safeguarded.

5) Fair Business, Advertising and Competition
Standards of fair business, advertising, and competition are to be upheld.

6) Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity, and protection of supplier and employee whistleblowers 1 are to be maintained, unless prohibited by law. Participants
should have a communicated process for their personnel to be able to raise any concerns
without fear of retaliation.

7) Responsible Sourcing of Minerals
Participants shall adopt a policy and exercise due diligence on the source and chain ofcustody of the tantalum, tin, tungsten, and gold in the products they manufacture to reasonably assure that they are sourced in a way consistent with the Organisation for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chainsof Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized

Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of acompany, or by a public official or official body.
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due diligence framework.

8) Privacy
Participants are to commit to protecting the reasonable privacy expectations of personal
information of everyone they do business with, including suppliers, customers, consumers, and employees. Participants are to comply with privacy and information security
laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

E. MANAGEMENT SYSTEMS
Participants shall adopt or establish a management system with a scope that is related
to the content of this Code. The management system shall be designed to ensure: (a)compliance with applicable laws, regulations and customer requirements related to theparticipant’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitatecontinual improvement.
The management system should contain the following elements:

1) Company Commitment
Corporate social and environmental responsibility policy statements affirming Participant’s commitment to compliance and continual improvement, endorsed by executive
management, and posted in the facility in the local language.

2) Management Accountability and Responsibility
The Participant clearly identifies senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management systems on a regularbasis.

3) Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations, and customer
requirements, including the requirements of this Code.

104) Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety2 and labor
practice and ethics risks associated with Participant’s operations. Determination of therelative significance for each risk and implementation of appropriate procedural andphysical controls to control the identified risks and ensure regulatory compliance.

5) Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Participant’s social, environmental, and health and safety performance, including a periodic
assessment of Participant’s performance in achieving those objectives.

6) Training
Programs for training managers and workers to implement Participant’s policies, procedures, and improvement objectives and to meet applicable legal and regulatory requirements.

7) Communication
A process for communicating clear and accurate information about Participant’s policies,
practices, expectations, and performance to workers, suppliers, and customers.

8) Worker Feedback, Participation and Grievance
Ongoing processes, including an effective grievance mechanism, to assess workers’ understanding of and obtain feedback on or violations against practices and conditions
covered by this Code and to foster continuous improvement. Workers must be given asafe environment to provide grievance and feedback without fear of reprisal or retaliation.

9) Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, thecontent of the Code, and customer contractual requirements related to social and environmental responsibility.

10) Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.
Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse andstorage facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms),
kitchen/cafeteria and worker housing/dormitories.
21111) Documentation and Records
Creation and maintenance of documents and records to ensure regulatory complianceand conformity to company requirements along with appropriate confidentiality to protect
privacy.

12) Supplier Responsibility
A process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.

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REFERENCES
The following standards were used in preparing the RBA Code of Conduct and may be
a useful source of additional information. The following standards may or may not beendorsed by each Participant.
Dodd-Frank Wall Street Reform and Consumer Protection Act
http://www.sec.gov/about/laws/wallstreetreform-cpa.pdf



Eco Management & Audit System
http://ec.europa.eu/environment/emas/index_en.htm

Ethical Trading Initiative
www.ethicaltrade.org/

ILO Code of Practice in Safety and Healthwww.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf



ILO International Labor Standards
www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm



ISO 14001
www.iso.org



National Fire Protection Associationwww.nfpa.org

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict- Affected and High Risk Areas
https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf

OECD Guidelines for Multinational Enterprises
http://www.oecd.org/investment/mne/1903291.pdf

Universal Declaration of Human Rights
https://www.un.org/en/universal-declaration-human-rights/

United Nations Convention Against Corruption
https://www.unodc.org/unodc/en/treaties/CAC/



United Nations Convention on the Rights of the Childhttps://www.ohchr.org/en/professionalinterest/pages/crc.aspx



United Nations Convention on the Elimination of All Forms of Discrimination Against
Women
https://www.ohchr.org/EN/ProfessionalInterest/Pages/CEDAW.aspx
13

United Nations Global Compact
www.unglobalcompact.org



United States Federal Acquisition Regulationwww.acquisition.gov/far/

SA 8000
https://sa-intl.org/programs/sa8000/



Social Accountability International (SAI)
www.sa-intl.org

DOCUMENT HISTORY First Edition April 2018: Based on the Responsible Business Alliance Code of Conduct v6.0(2018) released January 2018

 Second Edition February 2021: Based on the Responsible Business Alliance Codeof Conduct v7.0(2021) released January 2021

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