Responsible Mineral Sourcing Policy

Profits generated from the mining and trade of tin, tantalum, tungsten, and gold (collectively known as 3TG) in conflict regions such as the Democratic Republic of the Congo (DRC) and neighboring countries serve as financial support for armed groups and anti-government forces. These conflict zones, as well as EU-designated high-risk areas (CAHRAs), are plagued by severe human rights issues, including child labor and forced labor. Furthermore, mineral mining leads to soil contamination and environmental destruction.

Maxell has established the "Maxell Group Code of Conduct," which emphasizes respect for human rights and the conservation of the global environment. Under this policy, it considers understanding the supply chain in mineral procurement as a critical issue. Recognizing that responsible mineral sourcing contributes to resolving social issues, Maxell is advancing the establishment of a framework with the cooperation of our partners and promoting initiatives towards its realization.

• Respect for Human Rights
  Maxell Group Human Rights Policy
  Human rights due diligence
• Supply-Chain CSR Procurement Guidelines

Promoting Responsible Sourcing of Minerals

Responsible Minerals Survey Program

1. Promotion of a survey program in accordance with the "OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas." *

Using the Conflict Minerals Reporting Template (CMRT) for 3TG surveys and the Extended Minerals Reporting Template (EMRT) for other minerals, including cobalt and mica, provided by the Responsible Minerals Initiative (RMI), we identify upstream smelters/refiners of the relevant minerals (3TG and cobalt/mica) with the cooperation of our suppliers and obtain responses regarding the supply chain to verify the country of origin.
Additionally, based on the responses from our suppliers, Maxell requests them to switch to RMI-certified smelters/refiners (CFS) under the Responsible Minerals Assurance Process (RMAP) program, which certifies smelters/refiners as risk-free, and to avoid high-risk smelters (Active and others), thereby working on risk avoidance and mitigation.

* OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
https://www.mofa.go.jp/mofaj/gaiko/csr/pdfs/oecd_ddg_jp.pdf

2. Since fiscal 2020, we have requested material suppliers for the enttire company to conduct self-assessments using the CSR Procurement Guidelines' SAQ over a three-year plan. We confirmed that there were no facts regarding child labor and forced labor based on the results of the suppliers' SAQ.

• CSR Self-Assessment

Survey Results

Maxell conducts investigation using the CMRT and EMRT survey templates provided by RMI to identify and assess risks. In fiscal 2022 and 2023, surveys was limited to the Ono Plant in the Energy Division. However, in fiscal 2024, we expanded the surveys to encompass all business divisions, examining 3TG as well as cobalt and mica. As a result, we obtained responses from 83％ of our suppliers for 3TG and 80％ for cobalt and mica. In the upcoming fiscal year, we aim to improve response rates and provide individual feedback to each supplier, ensuring the effectiveness of our due diligence.

Confirmed Risks
・There were smelters that could not be identified.
・There were smelters that had not been certified as RMAP compliant (including smelters in high-risk areas).

Risk Management Plan
・We will promote hearings with suppliers regarding risk reduction and request improvements.