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 system improvements and promoting initiatives towards realization with the cooperation of procurement partners.

• 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 procurement partners and obtain responses regarding the supply chain to verify the country of origin.
Additionally, based on the responses from procurement partners, 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 the FY2020, we have requested all company-wide materials procurement partners to conduct self-assessments using the CSR Procurement Guidelines' SAQ over a three-year plan.
We verify the absence of child labor and forced labor based on the results of procurement partners' SAQ.

• CSR Self-Assessment

Survey Results

Maxell employs the CMRT and EMRT survey templates provided by RMI to conduct investigations and identify and assess risks. Based on the survey results, when RMAP non-conformant smelters are found to be in use, we request procurement partners to switch to RMAP conformant smelters and recommend avoiding the use of high-risk smelters. In cases where responses are incomplete or insufficient, we provide individual feedback and request resubmission. Through these efforts, we aim to enhance the effectiveness of responsible mineral sourcing across the entire supply chain and to increase the proportion of sourcing from RMAP conformant smelters.

Confirmed Risks
・There are smelters that cannot be identified.
・There are smelters that have not been certified as conforming to RMAP (including smelters in high-risk areas).

Risk Management Plan
・Promote hearings and requests for improvement regarding risk reduction to procurement partners.