SUSTAINABILITY

Environment

Environmental management

ARE Holdings Group contribute to protect Earth's natural resources through business activities of precious metal recycling and environment preservation, in which activities we consume resources and energies meanwhile.
Setting our "Environmental Policies" to aim for minimizing environmental burdens, we pursue the environment-conscious operations in which an optimal balance can be achieved between environmental burden controls and generated economic values.
In addition, the Group encourages acquisition of ISO14001 certification, the international standard for environmental management, and works to reduce global environmental impact in accordance with this standard.

Environmental policies

We, ARE Holdings Group, will contribute to the environmental preservation of the earth and establish a sound material-cycle society through the company's businesses on recycling of precious and rare metals and industrial waste treatment.

  1. In all business activities we will strive to conserve resources and energy and reduce, reuse, and recycle waste to minimize the environmental burden.
  2. We will promote the recycling of resources of precious and rare metals to achieve a more effective use of the limited resources of the earth.
  3. We will adequately and safely perform our operations for the collection, transportation, and treatment of industrial waste to prevent environmental pollution.
  4. We will prioritize a harmonious coexistence with nature and regional communities. We will strictly follow the relevant environmental laws and regulations and other requirements which we recognize.
  5. We will establish environmental objectives and targets and periodically review them to continue improving our activities.
  6. We will educate all our employees and increase their environmental awareness as members of the community, promote their understanding of environmental preservation activities, and participate in such activities.

These environmental policies shall be conveyed to all of our employees and all those working for the company and announced to the public as our commitment.

Environmental Management Promotion System

Every year we develop Company-wide Environmental Goals based on our Environmental Policy, which sets out our environmental preservation philosophy.According to the above-established purposes and goals, each ISO 14001 certified site in Japan develops its own Annual Environmental Goals and implements environmental preservation activities closely related to their business tasks. In addition, the Environment Committee of each site deliberates on such matters as compliance with environmental laws and regulations, revisions of plans and environmental education, and provides reports to management. While the ISO Office controls the environmental management system (EMS), an environmental preservation administrator is also assigned for each site in order to ensure thorough implementation of environmental initiatives.

Social

Respect for Human Rights

ARE Holdings Group has been committed to legal compliance and respect for human rights in all aspects of our corporate activities. As awareness of human rights increases worldwide, we will further strengthen our efforts to respect human rights in accordance with international human rights initiatives.

Human Rights Policy

ARE Holdings Group Human Rights Policy

In accordance with the Asahi Way, the ARE Holdings Group (hereinafter "the Group") is committed to compliance with all applicable laws and regulations and respect for human rights in all aspects of its corporate activities as a company of good people with high ethical standards and social conscience, thereby contributing to the development of a sustainable society.
This ARE Holdings Group Human Rights Policy (hereinafter "the Policy"), which clearly defines the Group's views on human rights, applies to all employees of the Group including directors and executives. We pledge to comply with the Policy in all of our corporate activities.
We also support and respect international norms on human rights, such as the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights), the ILO Declaration on Fundamental Principles and Rights at Work of the International Labour Organization (ILO), and the United Nations Guiding Principles on Business and Human Rights. Furthermore, we expect all the stakeholders involved in our business activities to work together to promote respect for human rights, by understanding and practicing respect for human rights in accordance with the Policy.

1.Prohibition of discrimination
In accordance with the basic principle that all people are entitled to respect for their individuality and human rights, to fair treatment, and to equal opportunity, we do not tolerate any form of discrimination or disadvantageous treatment based on age, gender, nationality, race, religion, ideological beliefs, sexual orientation, gender identity, or disability. We promote a workplace environment in which diverse human resources are empowered to participate energetically, with equal opportunity in terms of recruitment, assessment, training, assignments and postings, and pay rises and job promotions.

2.Prohibition of harassment
We do not tolerate any form of behavior such as sexual harassment and abuse of authority that offends the dignity of an individual or causes him/her discomfort. At the same time, we strive continually to prevent such harassment through employee education and other means.

3.Prohibition of forced labor and child labor
As part of our effort to defend fundamental human rights, we prohibit any form of forced labor, child labor, or hazardous work for children under 18 years of age in any place that we do business, making sure to always conduct our business activities in compliance with applicable laws and regulations.

4.Management of working hours and pay
In accordance with the Labor Standards Act, labor-management agreements, and all applicable laws and regulations, we endeavor to prevent overwork and limit overtime work by carefully considering appropriate working hours and rest periods, appropriate overtime work, work-life balance, and the maintenance and promotion of employee health. In compliance with all legal requirements regarding minimum wages, statutory benefits and deductions, overtime work, etc., we establish salary regulations to ensure that we pay minimum wage or higher remuneration, taking into account the income necessary to ensure a stable livelihood. We also pay our employees directly.

5.Ensuring employee health and safety
In accordance with all applicable laws and regulations relating to work safety and health, we strive to ensure and maintain a healthy and safe work environment so that each and every employee enjoys the peace of mind to work energetically and fully demonstrate their abilities.

6.Respect for freedom of association and the right to collective bargaining
In compliance with all applicable laws and regulations, we respect the freedom of association and right to collective bargaining of our employees.

The Policy was approved by the Board of Directors of ARE Holdings.

January 31,2024
Tomoya Higashiura
Representative Director,
President&CEO
ARE Holdings, Inc.

Human Rights Due Diligence

In order to promote initiatives based on the Human Rights Policy, ARE Holdings Group is working to identify human rights risks that may cause human rights violations resulting from its business activities. For example, we have established a "Responsible Precious Metals Management Policy" with the aim of avoiding human rights violations in conflict zones, money laundering, fraudulent transactions, and funds going to terrorists. To achieve this, we have set up a responsible precious metals management system that complies with LBMA, LPPM and RJC guidance. This system is also maintained and improved by obtaining certification from a relevant third-party organization and by undergoing regular independent audits. To respond to one of our priority SDG-related goals "supplying precious metals in ways that are friendly to people, society, and the environment" we are striving to build and maintain the "Asahi Brand," which can be trusted by customers around the world, allowing them to procure precious metal products that help protect human rights and the environment.

Responsible Precious Metals Management Policy
https://www.asahimetalfine.com/en/responsible-sourcing/

Dialogue

ARE Holdings Group will engage in dialogue and consultation with stakeholders who have actual or potential adverse effects on human rights resulting from our business activities.

Correction and Remediation

When it becomes clear that ARE Holdings Group has caused adverse effects on human rights through our business activities, we will work to remedy such impacts through appropriate procedures.

Education and Awareness

ARE Holdings Group posts human rights-related documents such as the Human Rights Policy, the Asahi Way, the Harassment Prohibition Policy, and the Asahi Hotline on the company intranet at all times for access and dissemination. In addition, to deepen understanding of the prohibition of discrimination and respect for human rights, we provide education and training on the prohibition of harassment and respect for diversity (e-learning/for all officers and employees).

Information Disclosure

ARE Holdings Group will disclose information on its efforts to respect human rights through its website and other means.

Governance and Promotion Structure

ARE Holdings Group will report to its Sustainability Committee and its Board of Directors regularly the status of compliance with the Human Rights Policy and our efforts to respect human rights.

Consultation and Reporting Desk

ARE Holdings Group has established the Asahi Hotline in accordance with the internal reporting system "whistle -blowing system" to directly receive reports from all employees in and outside of Japan regarding organizational or individual violations of laws and regulations, misconduct, and human rights violations, including harassment and to appropriately resolve such issues. The Asahi Hotline has internal and external contact points and the external contact point is an outside law firm to ensure independence and anonymous reporting is also accepted. The in-house consultation service is also readily available for the purpose of prevention. We will respond impartially to the reported case, conduct a prompt and appropriate investigation, and take appropriate corrective measures. No one will be disadvantaged as a result of reporting or consultation, and all information will be kept confidential. In addition, we have established a contact point on its website where internal and external stakeholders can anonymously report concerns or problems related to "Responsible Precious Metals Management.

Sustainable Procurement

As ARE Holdings Group sets "Totally Committed to Protecting the Natural Environment and Preserving Resources" as its purpose, the Group regards it indispensable to create a sustainable supply chain to achieve the purpose. To ensure sustainable business development for our business partners and suppliers as well as us, we aim to fulfill social responsibilities regarding legal compliance, human rights, ethics, labor, health and safety, and the environment together with them. We have established the "Sustainable Procurement Policy" as our basic approach to procurement, and have further established material-specific and company-specific procurement policies to achieve the basic policy.

Sustainable Procurement Policy

ARE Holdings Group Sustainable Procurement Policy

ARE Holdings Group has established the “Sustainable Procurement Policy” in its procurement activities and aims to enhance the corporate value of both parties and build a sustainable supply chain based on mutual cooperation and trust with our suppliers and business partners.

1.Compliance with laws, regulations, and social norms
We will comply with local and international laws, regulations, and social norms applicable to our business activities.

2. Respect for human rights
We will eliminate all human rights violations, such as forced labor, child labor, harassment, and discrimination in our supply chain.

3.Occupational Health and Safety
We will understand local and international labor conditions applicable to our business activities and strive to maintain and improve the working environment and health and safety.

4. Environmental Considerations
We will take into consideration the impact on climate change and biodiversity, and promote procurement activities with minimal impact on the global environment.

5. Ensuring quality and safety of products and services
We will ensure the quality and safety management of our products and services, and strive to continuously maintain and improve them.

6. Fair and impartial transactions
We will conduct fair and impartial transactions in accordance with corporate ethics, sound business practices, and social norms.

7. Information security
We will properly manage confidential information and personal information obtained in procurement activities and strive to prevent leaks.

Established in January 2024

Responsible Management of Precious Metals

To ensure that our customers around the world can use our precious metal products free from concerns, we have established a control system in accordance with guidance from bodies such as the OECD, the LBMA and the LPPM, with inspection and certification by third-party organizations.

In July 2019, We became the first Japanese refiner to obtain the Code of Practices (COP) certification from the Responsible Jewellery Council (RJC). In July 2021, the company also obtained the Chain of Custody (COC) certification. The RJC is an international non-profit organization that promotes ethical, socially responsible and environmentally responsible handling of gold, platinum, diamonds and other precious metals in the jewelry industry from mining to retail. Our operations meet the RJC's strict standard for code of practices on ethics, human rights, society, and the environment, due diligence and traceability, and the company is now the only refiner in Japan to achieve both the RJC's COP and COC certifications. We will continue to undertake business activities and initiatives in compliance with RJC standards and fulfill its responsibilities as a member of the precious metals supply chain.

Responsible Management of Precious Metals

We have established a Responsible Precious Metals Management Policy for the precious metals supply chain, with the aim of avoiding human rights violations in conflict zones, money laundering, fraudulent transactions, and funds going to terrorists. To achieve this, we have set up a responsible precious metals management system that complies with LBMA, LPPM and RJC guidance. The system is also maintained and improved by obtaining certification from a relevant third-party organization and by undergoing regular independent audits.
In order to support one of the Group's priority SDG-related goals -- supplying precious metals in ways that are friendly to people, society, and the environment -- We are striving to help build and maintain the Asahi brand. We want to ensure that our brand can be trusted by customers around the world, allowing them to procure precious metal products that help protect human rights and the environment.

Responsible Precious Metals Management Policy
https://www.asahimetalfine.com/en/responsible-sourcing/
G.Governance

Risk management

Compliance

We consider compliance a priority issue in delivering fair business activities and ensuring legal compliance and high ethical standards. Particularly, operations related to appropriate processing of wastes are based on environmental laws and regulations as well as governmental licenses, and each and every employee is required always to act with a highly compliant mindset. We are conducting activities to raise the legal compliance awareness of each and every employee through education and mutual communication, along with rules and manuals related to compliance.

Internal Reporting System (Whistle-Blowing System)

To quickly identify and resolve problems such as unlawful and unjust behavior, we have set up the Asahi Hotline. All employee s in and outside of Japan can directly report to either an intern al desk or an external law firm anonymously. We take corrective actions to address the reported matters after investigation, without revealing the identity of the disclosing or disclosed parties.

Business Continuity Management (BCM)

Various factors such as large-scale disasters entail the risk of impairing the functions needed for business continuity. As an action plan to achieve quick restoration of mission-critical functions even after a disaster, we created a business continuity plan (BCP). In addition to the BCP, we are conducting systematic business continuity management activities to constantly improve the BCP and business continuity endeavors.

Information Security

The laptops and tablets used by the Group's sales force are equipped with the latest security measures. Even if a device is lost or stolen, the possibility of information leakage is virtually zero thanks to technology such as remote data wiping.

Avoiding All Interactions with Organized Crime and other Anti-social Forces

The following statement is part of our Corporate Governance Policies, and is understood by all our executives and employees. "We will never have any relationship, including business relationships, with anti-social forces which threaten the social order and sound corporate activities. In the event of an illegal request, we will take a firm attitude and respond to it organizationally in accordance with the law and internal rules."