Responsible Precious Materials Management Policy
In order to build trust with customers and in society, Nihon Material Co., Ltd. promotes Corporate Social Responsibility (CSR) and conducts business in ethical and legally compliant manner.
With regard to the procurement of precious metals, we set up measures to avoid materials from high risk supply chains which contribute to conflict and human rights abuse, and to comply with high standards of anti-money laundering and combating the finance of terrorism.
1. Management System
We establish an appropriate risk management system and internal controls in order to implement effective due diligence for supply chain of precious metals.
2. Determination of High-Risk Transactions
We recognize the purchasing of precious metals that originates from conflict affected or human right 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 order to avoid our involvement in such areas of activity.
3. Identification of Materials and Supply Chain
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 precious metals 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 Responsible Precious Metals 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 February 19 2018