Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Mitutoyo Corporation
Green Procurement Guidelines

3rd Edition

August 22, 2023
Mitutoyo Corporation

1

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Contents
Chapter 1

Introduction.………………………………………………………………….…3

Chapter 2

Policy Orientation of Mitutoyo Group Green Procurement Efforts …....4

Chapter 3

Management Standards for Chemical Substances…………………….….5

3.1 Objectives
3.2 Scope of Application
3.2.1 Scope of application to products
3.2.2 Scope of application to parts and materials
3.3 Definition of Terms
3.3.1 Chemical substances
3.3.2 Management standards
3.3.3 Prohibited substances
3.3.4 Managed substances
3.3.5 Upcoming regulated substances
3.3.6 Contained
3.3.7 Intentionally added
3.3.8 Impurities
3.3.9 Threshold value
Chapter 4 Requests for Suppliers ………………………………………………………….7
4.1 Prohibition of containing prohibited substances
4.2 Assessment of Chemical Substances Contained in Delivered Parts and/or
Materials
4.2.1 Scope of assessment
4.2.2 Assessment forms
4.2.3 Assessment and contact
4.3 Management of “Managed substances” and “Upcoming regulated substances”
4.4 Submission of Check Sheet for Chemical Management System
4.5 Inspection Structure for Acceptance of Parts and/or Materials
4.6 Product Substitution Proposals
4.7 Handling of Guidelines2

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Chapter 1: Introduction
The Mitutoyo Group, consisting of Mitutoyo Corporation, its Japan-based subsidiaries(with the exception of Mitutoyo Foods Corporation) and its overseas affiliates (referred tohereinafter as the Mitutoyo Group), strive to achieve its goal of contributing to society
through precision measurement technologies, as outlined in the Mitutoyo group’s
management philosophy. Out of the six guidelines in Mitutoyo’s management principles is"Support and promote global peace, human happiness and harmony with the environment"in line with our environmental policy, Mitutoyo Group prioritize reducing the impact on
the environment throughout all our business processes, recognizing global environmental
conservation as a crucial aspect.
In recent years, there has been a growing trend of an increasing number of chemical
substances being prohibited or restricted in teams of their use and content by laws andregulations related to chemical substances in various contrives and regions, including the
Stockholm convention on Persistent Organic Pollutants (POPs convention).
These Guidelines are based on Article 31 (Environmental Compliance) of the Mitutoyo
Corporation Basic Business Contract, Article 21 (Green Procurement) of the Mitutoyo
Master Purchase Agreement and/or the Green Procurement Contract, and require suppliers
to ensure compliance with the applicable chemical substance restrictions.
Understanding on the part of suppliers is essential to the promotion of this activity, and weare committed to moving forward together with our suppliers to further strengthen ourbusiness relationships in the interest of environmental protection. We ask for the support
and cooperation of all concerned.
In order to undertake our responsibilities toward the environment together with our
suppliers, Mitutoyo Corporation looks forward to building preferential relationships withthose suppliers who respect the standards contained in the Guidelines. Furthermore, in ourtransactions generally, we will be implementing assessment of chemical substances
contained in delivered components and materials and submission of Absence Declaration.
Again, we ask for the support and cooperation of all concerned.
August 22, 2023
Mitutoyo Corporation

3

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Chapter 2: Policy Orientation of Mitutoyo Group Green Procurement Efforts

In seeking to achieve the Mitutoyo Group management principles to “support and promote
global peace, human happiness and harmony with the environment,” we understand global
environmental conservation to be an important element of our business activities, and the
Mitutoyo Group as a whole is thus engaged in efforts aimed at environmental conservation.
(1) We strictly observe legal regulations and other requirements with respect to theenvironment, and seek to prevent contamination.
(2) We seek to develop environmentally compatible products that are considerate of theenvironment.
(3) With respect to our suppliers and the materials, etc., that we procure, we conduct
environmental impact assessments and evaluations, and promote materials procurement
activities that are considerate of the environment.

4

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Chapter 3: Management Standards for Chemical Substances
3.1 Objectives
In order to strictly observe legal regulations concerning chemical substances containedin materials and parts constituting products of the Mitutoyo Group, management standards
for such substances shall be clearly delineated, the content thereof shall be understood by
all persons associated with green procurement both within and outside the specificcompany concerned, shall be strictly observed, and furthermore, methods of facilitating
understanding shall be appropriately updated and administratively maintained. The
objectives of the foregoing are strict observance of legal regulations on the part ofcustomers, suppliers and Mitutoyo Group companies, reduction of environmental impact
and the assurance of safety with respect to risks stemming from harmful substances.
3.2 Scope of Application
These Guidelines shall be applied to suppliers delivering parts and materials for the
products indicated below to the Mitutoyo Group via purchasing divisions.
3.2.1 Scope of application to products(1) Products designed and/or manufactured and sold by the Mitutoyo Group.
(2) Products for which design and/or manufacturing is consigned to a third party, andwhich are sold under trademarks of the Mitutoyo Group.
(3) Products of other companies that are purchased by Mitutoyo Group and areassembled into and/or connected and then sold as final products (including personal
computers, printers, etc.).
(4) Products for which design and/or manufacturing is consigned to the Mitutoyo Groupby a third party. Guidelines shall not apply to parts and materials that are
specifically designated by such third parties.
For products to which Guidelines apply as stated above, the scope of application shall
include products procured from overseas, including the country(ies) in which theGroup company is located.
3.2.2 Scope of application to parts and materials
Applied to parts, materials, and other articles used in products subject to “3.2.1 Scopeof application to products” above.
Applicable parts and/or materials, etc., are as follows:(1) Materials and semi-processed parts.
(2) Semi-finished products (parts for assembly including but not limited to functional
units, modules, and mounting boards).
(3) Parts (including but not limited to electrical and/or electronic components,
mechanical components, screws, terminals, semiconductor devices, printed circuitboards, and recording media).
(4) Accessories for using equipment (such as external power supply apparatus including
but not limited to power cables, harnesses, and AC adaptors, and accessories
including but not limited to remote controls and computer mouse devices).
(5) Secondary materials used in products (such as compositional materials including but
not limited to adhesives, adhesive tape, soldering materials, putty materials, glues
and explanatory labels).
(6) Product related documentation including but not limited to user’s manuals,
warrantees, and catalogs (for promotional use).
(7) Packaging and packing materials (including but not limited to bags, cushioning
materials, rust-resistant packing materials, sheets, industrial wrap, cardboard, tape,banding materials, labels, printing ink, paint, lumber, nails and staples).

5Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

For items to which Guidelines apply as stated above, the scope of application shall
include items procured from overseas, including the country(ies) in which the Group
company is located.
3.3 Definition of Terms
Terms are defined below with respect to these management standards for chemical
substances.
3.3.1 Chemical substancesThose chemical substances for which management standards have been established by
the Mitutoyo Group, due to legal regulations in Japan or overseas affecting such
substances that may be contained in parts and/or materials from which Mitutoyo Group
products are composed, and/or in consideration of customer requests for substancemanagement.
3.3.2 Management standards
Management standards are applied to "prohibited substances", "managed substances"and "Upcoming regulated substances" as represented respectively by substance names,
CAS numbers, etc., appearing in the separate “List of Relevant Chemical Substances.”
3.3.3 Prohibited substances
Substances that are prohibited for use and intentional addition to components, materials,
and packaging materials that constitute products, depending on their intended application.
3.3.4 Managed substances
Substances for which use or content is not restricted, but whose content data should bemonitored and managed from the perspective of environmental impact and proper
disposal.
3.3.5 Upcoming regulated substances
Substances that are currently under deliberation for regulatory measures and have thepotential to become prohibited in the future. It is recommended to explore alternative
options before they are officially stipulated by laws and regulations.
3.3.6 Contained
The addition, filling, mixing and/or affixing to component parts or materials of a
product, or a raw material used in such parts or materials, regardless of whether or not
such addition is intentional. (This includes cases of unintentional mixing or affixing in
the product manufacturing process.)
3.3.7 Intentionally added
The intentional use during product and/or parts manufacture, in cases where its
continued presence is desirable in order to facilitate specific properties, appearance
and/or quality.
3.3.8 Impurities
Naturally occurring substances contained in industrial materials that cannot betechnologically removed during purification processes, and substances that form in theprocess of synthesis reactions and which cannot be technologically removed.
3.3.9 Threshold value
The concentration limit for a contained chemical substance, which, if surpassed, must
be managed or monitored in accordance with these standards, regardless of whether or
not the addition of the substance is intentional.

6

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Chapter 4 Requests to Suppliers
4.1 Prohibition of containing the prohibited substances and Submission of Absence
Declaration
Parts and/or materials delivered to the Mitutoyo Group (excepting those parts andmaterials originally supplied by the Mitutoyo Group) shall not contain any prohibited
substances on the separate “List of chemical Substances” in an attached format. Thisrequirement is concerned with product quality and in cases where the delivered parts
and/or materials contain any prohibited substances without the consent of MitutoyoGroup, this will be regarded as non-conformity and the supplier shall assume liability for
non-conformity of contract (claims, losses, damages). The same shall apply in cases
where the delivered parts and/or materials contain any prohibited substances at or above
their respective threshold values if specified.
4.2 Assessment of Chemical Substances Contained in Delivered Parts and/or Materials
4.2.1 Scope of assessment(1) To be applied to parts and/or materials, etc., delivered by suppliers, that willcomprise products of the Mitutoyo Group.
Note, however, that the following parts and/or materials, etc., shall be exempt fromassessment:- Packaging materials used by the supplier for transportation to Mitutoyo
purposes.
- Parts and materials supplied by the Mitutoyo Group.
(2) Glues, soldering materials, putty materials, paints, explanatory labels, etc., used for
products shall be within the scope of assessment.
Furthermore, for substances and/or applications not specified in these Guidelines, local
legal regulations shall be followed in cases where use is prohibited or restricted by such
local legal regulations.
4.2.2 Substances requiring assessment"Prohibited Substances" listed in the attached “List of Relevant Chemical Substances”
are applied.
Also, due to local legal regulations and/or customer requests, there are cases whereassessment may be applied to substances that are not on the separate “List of Relevant
Chemical Substances.”
4.2.3 Assessment
Suppliers are required to ensure that the parts and materials (excluding those suppliedby Mitutoyo Group) delivered to all Mitutoyo Group comply with the following
regulations. It is imperative that they do not contain any prohibited substances listed in
the attached “List of relevant chemical substances” or exceed the specified threshold.
To provide confirmation of compliance, suppliers are requested to submit a “Certificate
of Non-Inclusion.”
Please note that even if suppliers don't submit it, does not exempt any party fromcontractual non-compliance liability. Additionally, suppliers may be asked to provide
component data (such as analytical data or chemSHERPA etc.) if necessary. Prompt
submission of this information is appreciated.
In the event that the presence of prohibited substances is discovered, suppliers arerequested to notify Mitutoyo Group immediately. Furthermore, Mitutoyo Group ask forconsideration of alternative options.
Mitutoyo Group may also request assessment to ensure compliance with the laws andregulations of each country or region, or to fulfill customer requests from all MitutoyoGroup.

7

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition(Note) We may request assessments in response to the status of laws and regulations ineach country or region, or requests from customers of all Mitutoyo Group companies.
4.3 Management of controlled substances and upcoming regulated substances
While there’s no requirement for submitting a “non-inclusion certificate” for managed
substances, it may occasionally need to verify the presence of such substances. Suppliers
during such instances would be greatly appreciated.
For substances planned for addition, if their inclusion is confirmed, Mitutoyo Group kindle
ask that you promptly notify us. These substances fall within the category of chemicals
currently being deliberated for potential future legal regulations, including possible
prohibition. Mitutoyo Group also recommend considering alternative options prior to any
regulatory stipulations.
4.4 Submission of Check Sheet for Chemical Management System
In order to confirm the state of environmentally-oriented activities on the part of suppliers,
suppliers shall cooperate and submit to Mitutoyo Group the assessment using the separate“Check Sheet for Chemical Management System” in an attached format.
Furthermore, so as to ensure that substances of concern appearing on the separate “List of
Relevant Chemical Substances” in an attached format are not contained in delivered
products, suppliers shall set up the organization of a chemical management system, as
indicated below.
(1) Understanding on the part of all employees with regard to chemical substancemanagement.
(2) Periodical review of chemical substance information for parts and materials used.
(3) Monitoring and control of processes using chemical substances.
(4) Structuring and maintenance of a compliance framework for legal regulations
concerning chemical substances.
4.5. Inspection Structure for Acceptance of Parts and/or Materials
The diagram below indicates the schematic flow for cases where acceptance inspection
is applied by the Mitutoyo Group to products, parts, and/or materials delivered bysuppliers.

8

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Fig. 4.1 Acceptance inspection structure for parts and/or materials
Delivery(Analysis data attached) *1

Mitutoyo Corp.

Products
Rejection

Parts
Materials
Suppliers

NG
NG

OK

Analysis

Assembly

Acceptance Inspection
Screening Inspection

Guidance

Shipment

Customers

OK
Concern

External analysis organization
Determination using other analysis<Flow of acceptance inspection by Mitutoyo Group>- When deemed necessary, products, parts, and/or materials received from suppliers are
subjected to acceptance inspection and screening inspection via fluorescent analysis
apparatus.
- In cases where acceptance inspection and screening inspection conclusively determines
the presence of prohibited substances, the Mitutoyo Group will notify the supplier(s)thereof, and is entitled to return the products, parts, and/or materials to suppliers andseek damage compensation with respect thereto. Further, the Mitutoyo Group may
request suppliers to take appropriate countermeasures.
- In cases where screening inspection indicates that the prohibited substance content isin the vicinity of the threshold value (gray zone indicated by ‘concern’ in figure
above), a more detailed analysis at an external organization may be requested by the
Mitutoyo Group to suppliers.
(*1) In cases where it is difficult for suppliers to attach analysis data at the time ofdelivery, Mitutoyo Group will determine the necessity of attaching analysis data,by consultation between suppliers and the relevant Mitutoyo Group purchasing
division.
4.6 Product Substitution Proposals
In cases where suppliers apply for modification to a substitute item for a product, part
and/or material supplied to the Mitutoyo Group, suppliers shall fill out and submit therequired portions of the “Product/Process Change Application Form ” in an attached form
to the relevant Mitutoyo Group purchasing division.
Following the designated procedures, the Mitutoyo Group quality control division will
undertake performance evaluation of the substitute item, and will adopt parts and/or
materials that pass scrutiny.
In cases where substitution is proposed for a part or material that contains a prohibited or
discontinued substance, the Mitutoyo Group quality control division may request
submission of required documentation, samples, etc.

9

Mitutoyo Corporation Green Procurement Guidelines, 3rd Edition

Product, part, or material supplier

Substitute item change request“Parts/Materials Change Request” form

N
G

Returned

Confirmation by quality control division (Performance evaluation)O
K
Adoption for product by relevant entity
4.7 Handling of Guidelines
Guidelines for suppliers are to be handled as follows:(1) Relevant purchasing division staffs notify the suppliers of the revision has been
published.
For the details, feel free to check out Mitutoyo website.
(2) Whenever transactions are initiated with a new supplier, Guidelines are to beprovided by the relevant purchasing staff.

Revision History
Enactment: Revision 1
Amendments: Revision 2
Revision 3

August 2, 2004
December 12, 2012
August 22, 2023

Author: Mitutoyo Corporation
Date of revision: August 22,2023
Address: 20-1, Sakado 1-Chome, Takatsu-ku, Kawasaki-shi, Kanagawa 213-8533, Japan

10