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Nippon Tungsten's Policy on Procurement of Conflict Minerals

1. Dodd-Frank Wall Street Reform and Consumer Protection Act

 In the wake of the global financial crisis of 2009, the Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted on July 21, 2010 in the United States in order to maintain financial stability. This law provides not only the supervisory authority of regulatory agencies, regulations on banks, insurance, securities, and hedge funds, and regulations on consumer protections, it also contains within Title XV (Miscellaneous Provisions) Section 1502, a provision on conflict minerals.

2. Conflict Minerals

 Conflict minerals are mineral resources that are mined in the Democratic Republic of the Congo (DRC) and nine surrounding countries which have the potential to be used as a means of financing armed militia groups. Four substances are identified as conflict minerals - tin, tantalum, tungsten, and gold - which are also collectively known as 3TG. The identification of these conflict minerals also aims to prevent human rights violations such as massacres, assaults, and child labor carried out by armed militia groups in conflict zones.

 Against this background, Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act stipulates that companies that are publicly traded in the US must conduct surveys to determine that the conflict minerals they procured are not involved with armed militia groups from the DRC at any point in the supply chain, report it to the Securities and Exchange Commission (SEC), and disclose it on their websites.

3. Nippon Tungsten's Procurement Policy

 Nippon Tungsten Co., Ltd. sells products mainly using tungsten to customers in a wide range of globally expanding industries, forming a part of their supply chain.

 From the perspective of compliance, we have established the Nippon Tungsten Corporate Behavior Charter as well as the Nippon Tungsten Employee Code of Ethics in order to ensure that we remain a company that has both the trust and support of society.

 To that end, we conduct surveys of the conflict minerals we procure using a CMRT (Conflict Minerals Reporting Template) developed and provided by the RMI (Responsible Minerals Initiative), one of the leading organizations involving conflict minerals. This survey is conducted from the supplier selection stage, and additional surveys are conducted periodically after the start of procurement. The results of these surveys are published and are available to our customers.


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