Green Procurement Guidelines(Version 3.0)

Document number: FGE-B00-001
Established: October 1, 2001
Revised: March 31, 2024

FIGARO ENGINEERING Inc.

Introduction

Since the Earth Summit in 2002 set a goal of "Minimizing the adverse effects of theproduction and use of chemicals on human health and the environment by 2020," global
regulations on chemical substances have been made stricter. EU regulations, such as the ELV
Directive, RoHS Directive, and REACH Regulation, have made an impact on many othercountries. In Japan, the Act on Confirmation, etc. of Release Amounts of Specific ChemicalSubstances in the Environment and Promotion of Improvements to the Management Thereof(PRTR system) and the Chemical Substances Control Law (CSCL) were significantly revised in2009. This trend toward more stringent regulations is expected to continue to accelerate.

We have been asking our business partners for their understanding and cooperation in ourgreen procurement policy to promote environmental conservation activities. In order to respondto these regulations and the associated requirements from our customers, it has become
essential to build an even stronger cooperation with the upstream suppliers in our supply chain.
For this reason, we have revised our "Green Procurement Guidelines" to set them as theguidelines for our overall chemical substance control and have revised the chemical substances
to be controlled.
In addition to the Green Supplier System, our requests regarding chemical substance control
are set forth in this document. Please thoroughly read this guideline. We would appreciate yourcontinued understanding and cooperation in promoting our green procurement efforts.

Figaro Engineering Inc.

Toshihiro Udaka
President
Yasuhiro Setoguchi
Head of the Quality Assurance Department

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Table of Contents

1. Figaro's Environmental Initiatives ... 3

2. Green Procurement Guidelines... 4(1) Positioning of the Guidelines(2) Our approach to green procurement(3) Requests to our business partners(4) Scope

3. Chemical Substance Control... 4(1) Concept(2) "Chemical substances to be controlled"(3) Investigation of chemical substances21. Figaro's Environmental Initiatives《Environmental initiatives》
Figaro Engineering Inc. (hereinafter referred to as “Figaro”, "our company", “we”, or “us”) is
continuously working to reduce the environmental impact of our company’s business activities
by combining various methods and evaluation criteria.

=Figaro's Environmental Policy=● Figaro is committed to contributing to the creation of an earth-friendly
environment through our gas sensing technology and collaborative businessinitiatives together with our partner companies.
● We will continue to carry out improvement activities based on our own
environmental management system to provide products and services thatincorporate various environmental impact reductions.

◆Action Guidelines◆
1. Building a sustainable environmentally friendly management system
2. Contributing to the mitigation of climate change and the achievement of carbon
neutrality
3. Sustainable use of natural resources
4. Scrutinizing influencing factors for environmental assessment
5. Compliance with environment-related laws and regulations《Product initiatives》
We have been providing gas sensors and gas detection devices with various detection
methods. Going forward, in addition to pursuing further energy savings and miniaturization of ourproducts, we will work to continuously reduce environmental impacts, such as active
development of leak detection devices for green refrigerant gases.
《Initiatives at our offices and factories》
We will implement autonomous management in accordance with ISO14001 to establish ourenvironment management system, raise awareness among our employees, and work to reduce
the environmental impact continuously.

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2. Green Procurement Guidelines(1) Positioning of the Guidelines(i) These guidelines outline our basic approach to procuring materials that have a minimal
impact on the global environment (hereinafter referred to as "Green procurement") as we
promote environmental conservation activities based on our environmental policy.
(ii) By promoting Green procurement with the cooperation of our suppliers (business partners)
who are proactive in protecting the global environment, we aim to comply with the applicablelaws and regulations and fulfill our responsibilities as a business entity, and achieve managementthat allows for sustainable development.
(2) Our approach to Green procurement
We have included "Environmental considerations" in our material procurement criteria, inaddition to "Quality," "Cost," "Delivery," and "Service". Moreover, we will preferentially procurematerials that meet these requirements.
*"Environmental considerations" refers to compliance with applicable laws and regulations
regarding chemical substances, the 3Rs, etc.
(3) Requests to our business partners
We ask for your understanding of our Green procurement approach and your cooperation in
addressing the following requests:- Active efforts to protect the environment- Consideration and efforts in reduction of the environmental impact of the materials
used in delivered goods, manufacturing processes and auxiliary materials related todelivered goods- Control of chemical substances contained in delivered goods and materials(4) Scope
As a general rule, these guidelines will apply to all of our business partners.

3. Chemical Substance Control(1) Concept
One of our initiatives, based on the concept of the Green Procurement Guidelines mentioned
above, is the control of chemical substances used in our products. Due to stricter regulations on
chemical substances in recent years, the control of chemical substances has become an
important element in conducting business. We expect that the number of chemical substances
subject to applicable regulations will continue to increase, especially in the EU. In order toensure compliance with the applicable laws and regulations and to prevent any hindrance to ourproduct sales, we will provide our business partners with our criteria for chemical substanceinvestigation and control, and improve our chemical substance control system.

4(2) Chemical substances to be controlled
The chemical substances that have been designated for control by our company are as
follows:(i) RoHS Directive
Substances designated in the latest RoHS Directive must be controlled.
(ii) REACH Regulation- Candidate List of SVHC for Authorization (Candidate substances subject to authorization)- Annex XIV (Substances subject to authorization)- Annex XVII (Substances subject to restriction)
For the latest information on substances to be controlled and regulated concentrations(thresholds), please check the website of the ECHA* or the Ministry of the Environment ofJapan: Network for Strategic Response on International Chemical Management.
*ECHA: European Chemicals Agency(iii) Substances designated by our company
Please see the table in the next page for the chemical substances to be controlled.
(3) Investigation of chemical substances
Please investigate whether these chemical substances to be controlled are contained or not.
- Who should conduct investigation:
Business partners who supply raw materials, parts, or other goods purchased thatmake up our products, as well as auxiliary materials and packaging materials, etc.
- When investigation should be conducted:
Whenever laws and regulations change, when substances to be investigated specified inthis guideline change, when new products are delivered, etc.
- How to provide us with investigation results:
For chemical substances to be controlled in (2) (i) and (ii), please provide them using
chemSHERPA.
For chemical substances to be controlled in (2) (iii), please provide them using the nonuse guarantee form*.
*Non-use guarantee form: Please obtain the latest version from our website.
* Other substances
Regarding any other chemical substances that may be designated by our customers
In the business relationships with our customers, we will appropriately investigate any
applicable laws or regulations, or chemical substances to be controlled according to ourcustomers' control criteria.
*Example: IMDS: for automobiles, Conflict Minerals Survey, etc.
◇For any questions, please contact the following◇5

Substances designated by our company *Not covered by the RoHS Directive andREACH Regulation
Prepared on May 27, 2024

No.

Substance nameRemarks
EU POPs Regulation Annex I, CSCL, POPs
Convention

1

Short-chain chlorinated paraffins (SCCP, C10–13)

2

Polychlorinated naphthalenes (substances with 1 or more EU POPs Regulation Annex I, CSCL, POPs
chlorine atoms)
Convention

3

Polychlorinated biphenyls (PCBs)

EU POPs Regulation Annex I, CSCL, POPs
Convention

4

Ozone-depleting substances (excluding HCFCs)

Ozone Layer Protection Law, Montreal Protocol,
US Fluorocarbon Tax

5

Hydrochlorofluorocarbons (HCFCs)

EU ODS Regulation, US Clean Air Act, Ozone Layer
Protection Law, Montreal Protocol, EU F-GasRegulation

6Formaldehyde

German Chemical Prohibition Regulation, Danish
Formaldehyde Regulation, US TSCA

7

Perfluorooctane sulfonic acid (PFOS) and its salts

EU POPs Regulation Annex I, CSCL, POPs
Convention

8Specific benzotriazoles

CSCL

9

Hexabromocyclododecane (HBCD)

EU POPs Regulation Annex I, CSCL, POPs
Convention

10

Chlorinated phosphate ester flame retardants(3 types: TDCPP, TCEP, TCPP)

US domestic laws (including municipal laws)

11 Hydrofluorocarbons (HFCs)

Canadian Environmental Protection Act 1999, EU FGas Regulation

12

Perfluorooctanoic acid (PFOA), its salts and PFOA-related
EU POPs Regulation Annex I, CSCLsubstances

13

Perfluorohexane sulfonic acid (PFHxS) and its salts andPOPs Convention
PFHxS-related substances

14 Tris (isopropylphenyl) phosphate (PIP(3:1))

US TSCA

15 Dechlorane plusTM

POPs Convention

16 UV-328

POPs Convention≪Where to send investigation reports and other documents≫
Heya / Igarashi, Quality Assurance Department, Figaro Engineering Inc.
TEL: +81 072 (728) 7200, FAX: 072 (728) 2630
e-mail: heya@figaro.co.jp / chika-igarashi@figaro.co.jp≪Contact≫
Heya / Amano, Quality Assurance Department, Figaro Engineering Inc.
TEL: +81 072 (728) 7200, FAX: 072 (728) 2630
e-mail: heya@figaro.co.jp / amano@figaro.co.jp

6Revision history
Version

Revision dateReason for revision / details ofrevision

Approved
byReviewed
byPreparedby

1.0

October 1,2001

1st edition

Konomi

Ueno

Suzuki

2.0

January 6,2022

Completely revised

Udaka

Setoguchi

Amano

3.0

March 31,2024

Completely revised

UdakaSetoguchi

Heya

7