When executing procurement and management of minerals from conflict-affected and high-risk areas, it is necessary to prevent becoming a source of funding for conflicts through mining operations or trade and to avoid any involvement in human rights violations or child labor.
Minerals related to Maxell Group products include tin contained in solder used on printed circuit boards, tantalum contained in capacitors, tungsten contained in super-hard materials, gold used in lead frames of electronic components, and cobalt contained in electrodes of lithium-ion batteries.

Basic Policy

We have established in our "Maxell Group Code of Conduct" that we respect human rights and promote procurement with due regards for corporate social responsibility, and does not procure from companies that engage in child labor or forced labor. Furthermore, in our "Supply Chain CSR Procurement Guidelines" we stipulate that we do not purchase minerals that could cause social issues such as human rights violations, and request compliance with the guidelines through our supply chain for our products.

• "Maxell Group Codes of Conduct"
  Respect for human rights
• Supply-Chain CSR Procurement Guidelines

Efforts to follow guidance

At Maxell, we make efforts to adhere to the guidance provided by the OECD. We conduct due diligence on high-risk minerals, including tin, tantalum, tungsten, gold, and cobalt, which are produced in conflict-affected and high-risk areas, in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas *.
* 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.pdf

Promoting Responsible Sourcing of Minerals

Survey and results of high-risk minerals use

Initiatives for Continual Risk Mitigation (Collaboration with Suppliers)

Building upon our basic policy, we conducted self-assessments of 818 material suppliers across our entire company in a three-year plan starting in FY2020 using the SAQ of the CSR Procurement Guidelines. As a result, the following points were confirmed.
・The results of the supplier's SAQ confirm that there are no instances of child labor or forced labor.
・For the 603 suppliers who procure high-risk minerals, we have conducted a survey on responsible mineral procurement activities. Among them, about 70% (414 companies) were excellent suppliers who responded that they have disclosed their conflict-free procurement policy and have documented and continuously implemented programs to reasonably ensure it. The remaining 30% of suppliers were found to have insufficient activities. We will conduct an annual survey of these suppliers and work together with them on responsible mineral procurement activities, led by the Energy Division. Our goal is to complete the establishment of a conflict-free procurement policy and policy disclosure by the end of FY2023.

• CSR Self-Assessment

Investigation of High-Risk Minerals' Origin Countries and Smelters

In parallel, we request relevant suppliers to investigate the countries of origin and smelters of high-risk minerals using the industry-standard RMI (Responsible Minerals Initiative) Conflict Mineral Response Template (CMRT) and the Extended Minerals Reporting Template (EMRT), to identify and assess risks.
The table below shows the results of the survey of compliant smelters at the Ono Works of the Energy Division in FY2022 and FY2023. In the 2023 3TG survey results, we identified 342 smelters recognized by the RMI, of which 158 were confirmed to have obtained RMAP certification (as of September 2024).
Based on supplier responses, we will request suppliers to transition to certified smelters and avoid using high-risk smelters. Our goal is to continuously improve the ratio of certified smelters.
Although the results were compiled only for this work site, they will be expanded to include other work sites in the future to advance responsible mineral sourcing. Regarding the investigation method, we conducted conflict mineral investigations in accordance with RMI procedures in both FY2022 and FY2023, achieving a 100% completion rate. The results of the smelter investigation for FY2023 are being prepared.

※Target Plant: Ono Works, Energy Division

*1　Smelters certified by the RMI's Responsible Minerals Assurance Program(RMAP)
※Target Plant: Ono Plant, Energy Business Division
※Target Period: FY2022 to FY2023
※Refer to the RMI-certified smelter list as of July 25, 2024.

・The identified smelters are distributed across various countries globally. The results indicate that Asia and North America are the predominant sourcing regions.