Conflict Material Management Policy
Nihon Material Co.,Ltd will continue to promote corporate social responsibility.
We will execute the following fundamental measure in order to avoid contributing to conflict,
terrorist financing and human rights abuse, and to comply with high standards of anti-money laundering
in the procurement of gold and gold bearing materials (“gold”).
1. Management System
We establish an appropriate risk management system and internal controls in order to implement effective due diligence for supply chain of gold.
2. Determination of High-Risk Transactions
We recognize the purchasing of gold that originates from conflict affected or human rights abuse high-risk area and/or is suspected to have any connection with money laundering, terrorist financing, anti social acts, as a high-risk transaction.
We will implement appropriate due-diligence in accordance with the LBMA Responsible Gold Guidance in order to avoid our involvement in such areas of activity.
3. Identification of Materials and Suppliers
We will immediately suspend or terminate the transactions of any materials when we become aware,
as a result of our evaluation of materials and suppliers, that the purchasing of gold is a high-risk transaction.
4. Employee Training
We will continue to provide periodical education and training to ensure that all staff members recognize our Conflict Material Management Policy and relevant regulations.
5. Monitoring and Record Keeping
We will monitor all supplied materials by collating all information acquired from suppliers.
Records of all transactions shall be managed appropriately.
6. Third Party Audit
We will continue to be audited by an independent third party periodically concerning the design and implementation of our conflict materials management system.
Establishment December 1 2014
Revision April 20 2016