1. Management System

Under the leadership of the senior management, we implements precious metals management, including countermeasures against money laundering, etc., appoints a compliance officer from among the officers as the person in charge, and establishes a centralized management system by establishing a supervisory department that clarifies the roles and responsibilities of each relevant department, works on countermeasures against money laundering, etc., and implements risk assessment (due diligence) related to the supply chain of precious metals in cooperation with relevant departments.

2. Risk Assessments of Procured Materials and Suppliers

Based on the concept of a risk-based approach and in accordance with the guidance of the LBMA and LPPM, we comprehensively and specifically assess risks such as the products and services we provide, transaction formats, countries and regions involved in transactions, and customer attributes.
We will identify and evaluate risks such as money laundering in procurement of raw materials and supply chains related to precious metals, and continuously conduct risk assessments (due diligence).
As a result, if the compliance officer determines that the risk is high, the risk will be reduced through appropriate organizational decisions. If the risk cannot be reduced, we will stop procurement immediately. We will properly record and store the results of these risk assessments.

3. Education and Training

For all Group personnel involved in responsible precious metals management, we will provide appropriate and continuous education and training necessary for precious metals management, including countermeasures against money laundering, etc., to enhance the necessary knowledge, to maintain and improve our expertise and compatibility, etc.

4. Checks at the time of transaction, Transaction Monitoring and Recording

We will appropriately implement necessary measures to conduct checks at the time of transaction, on customer identification, transaction attribute, and persons subject to asset freeze etc. We detect suspicious transactions in a timely and accurate manner.
We will establish a system that allows us to immediately notify suspicious transactions to the authorities. In addition, we will monitor that the raw materials received are consistent with the information obtained from the supplier, and appropriately store and manage the related records.

5. Internal Audit and Third-party Audit

The independent internal audit department periodically audits the status of measures against money laundering, etc., and strives to further improve the management system based on the audit results. In addition, we will periodically undergo audits by an independent third-party regarding the implementation of the responsible precious metals management and risk assessment.

^*1 LBMA: London Bullion Market Association
^*2 LPPM: London Platinum and Palladium Market
^*3 OECD Guidance Annex II risk:
• Serious abuses (including child labor) associated with the extraction, transport or trade of minerals
• Direct or indirect support to non-state armed groups
• Direct or indirect support (illegal support) to public or private security forces
• Bribery and fraudulent misrepresentation of the origin of minerals
• Money laundering
• Unpaid government taxes, fees and royalties
^*4 OECD Guidance on Minerals:
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

Established: June 25, 2012
Revised: December 1, 2022