Approaches for Responsible Minerals Procurement

The considerations for responsible minerals procurement are heightened lately, following the enactment of The US Dodd-Frank Wall Street Reform and Consumer Protection Act in July 2010. Especially the concern regarding conflict minerals (tin, tantalum, tungsten, and gold commonly known as "3TG") that are mined from the Democratic Republic of the Congo and surrounding areas and used by an armed group or anti-government force as a source of funds.
According to the Article 1502 of The Securities and Exchange Commission (SEC), companies listed on securities exchanges in the US are required to investigate/report usage conditions regarding conflict minerals that are mined from the Democratic Republic of the Congo and surrounding areas that are used by an armed group or anti-government force as a source of funds.

Policy

From the standpoint of the protection of human rights, the ROHM Group makes it a rule not to use conflict minerals (tantalum, tin, tungsten, and gold) in target countries, where the conflict minerals are used as a source of funds by an armed group that has violated human rights in these areas, as materials for the Group's products.

Furthermore, we request that our suppliers respect ROHM's policy not to use such minerals as materials for our products and to make efforts to comply with this policy. If it is found that a conflict material used as a source of funds to support acts of human rights violations has been used as a raw material in the ROHM Group's supply chain, we ask that our suppliers immediately inform us and take corrective action, in accordance with our instructions, to establish a responsible supply chain.

System

The Group aims to be "conflict-free" by product unit, so that customers can use our products without worry. The procurement department plays a key role in this effort, and establish management system in line with "OECD Due Diligence Guidance." Every year, we summarize the results of a survey on conflict minerals and report it to the management, together with details of activities, to formulate future plans.

Responsible Minerals Procurement Survey

ROHM has been conducting a survey regarding the supply chain risk and evaluation using CMRT(Conflict Minerals Reporting Template) provided by the RMI(Responsible Mineral Initiative)

Cooperation with Industrial Associations

We have been participating in the JEITA's "Responsible Minerals Trade Working Group" since its establishment in 2012, to cooperate and coordinate with industrial associations. Through this participation, we have collected extensive information, addressed "Responsible Minerals Procurement" issues, and held an explanatory meeting.