ASAHI METALFINE contributes to the realization of a sustainable society through business activities that consider the environment and society based on the “Asahi Way” which is made up of our Purpose and Code of Conduct of ARE Holdings Group and the “Sustainable Procurement Policy” which defines our basic approach to procurement.
In order to avoid human rights abuses, terrorist financing, money laundering, fraudulent transactions, contribution to conflict, and to fulfill our responsibilities for environment and sustainability in the precious metals supply chain, we will promote responsible precious metals management in line with the policies set out below.

1. General Provisions

We will avoid the risks outlined in Annex II of the OECD^*1 Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

• Human rights abuses associated with the extraction, transport or trade of minerals
• Direct or indirect support to non-state armed groups
• Direct or indirect support to illegitimate public or private security forces
• Bribery and fraudulent misrepresentation of the origin of minerals
• Money laundering
• Non-compliance with taxes, fees and royalties due to governments

In the precious metals supply chain, we will comply with the guidance of the LBMA^*2, LPPM^*3 and RJC^*4, and avoid the risks that adversely affect sustainability including ESG factors (Environmental, Social, Governance).

2. Establishment of management system

1. The business divisions will procure the precious metal materials and supply them to the refining and manufacturing facilities.
2. We will set up a committee to promote responsible precious metals management and appoint a compliance officer who has responsibility for the responsible sourcing. The compliance officer oversees the whole management system and has the authority and responsibility as specified in the manual.

3. Determination of high-risk supply chain

We will consider any transactions that lead to human rights abuses, terrorist financing, money laundering, fraudulent transactions,

contribution to conflict, and environmental destruction in conflict-affected and high-risk areas as high-risk.

4. Identification and assessment of risks in the precious metals supply chain

We will conduct due diligence to all of the suppliers and materials to identify and assess risks in the precious metals supply chain. As a result, if the transaction is considered as high-risk, we will mitigate the risk. If the risk is not mitigated, we will terminate the transaction.

5. Monitoring and recording of transactions

We will monitor the transactions and ensure that responsible precious metals management is performed appropriately. All transaction records will be maintained appropriately.

6. Education and training

We will periodically provide necessary education and training to all employees engaged in responsible precious metals management.

7. Third-party audit

We will periodically carry out an independent third-party audit for our responsible precious metals management system and practices.

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*1 OECD: Organisation for Economic Co-operation and Development
*2 LBMA: The London Bullion Market Association
*3 LPPM: The London Platinum and Palladium Market
*4 RJC: The Responsible Jewellery Council

Established on April 1, 2012
Revised on March 1, 2024
Nobuo Tajima
Representative Director and President
ASAHI METALFINE, Inc.

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