LB八IAResponsible Gold Guidance compliance Report
The ι召Aι1πesp0口Sihle GoldGuidaむCehasbeenestabHsbedfor GoodDeHveryReflnerstoadopthigh
Standards of due dili宮ence in order to combat systelnatic or widespread abuses of human rights, to
avoid contributing to con且ict, to comply W北h high standards of anti・money laundehng and
Combatin宮 terTorist financing practice.
Thisreportsummarizes how' Tan日ka Kikinzoku K0部O K,K. a)ereafter"TKK') hascompliedwith the
requirements ofthe l'B入仏Responsible Gold Guid日nce
Table l: Refiner's details
Refiner's name
Tan且ka 1酎.kinzoku K0部O K,K.
工Ocation
フ-3 Marunouchi2・chome, chiyoda・ku, Toky0100・6422, Japan
Reporting year・end
31March 2015
Date ofReport
23 June 2015
目
イ
Senior management responsible for this report
ク
司
、、
C
勺
Masakazu T且n且k且, ManagingDirector, precious Metals Division
Tanaka lo.kinzoku K0釘O K.K.'s evaluation
Table 2: summary ofactivities undert且ken to demonstrate compliance
Step l: Est日blish8t叉on今Company mana宮ementsystems
ComP賊抑Ce statement Mth Requirement:
^e have {U11y comp]ied W北h stepl; Establish stTong management systems.
1. TANAI【A HOLDINGS CO., Ltd., TKK'S P町entcomP抑y, has adopted a group policy re目ardi11g
due djligence for 8Upplycha血S ofgold.
Comments and Demonstration ofcompliance:
TANAI【AHOLDINGS CO., Ltd. Yevised inApri12014 its con且ict MineralM且n且gement policy, which
Was established in 2012, in order for the policy to becolne consistent with the modelset out in the
Annexn ofthe oECD Due Diligence Guidance. This policy, whichappliestoTKK, Tanak日 1墾kinzoku
Hanbai and Tanaka 壬墾kinzoku lnternational G)erea丘er the "Tanak且 Group companies"), sets out
the T且naka Group companies' responsibility to establish its lnanagement system for supeNising
Suppliers, carry out risk assessments w'ith respect to supplied materials and suppliers, and nlonitor
the materials l.eceived.
2. The Tanaka Group comP日nies have set up an intenlal ma11agement S力ructure 力O suppor'8Upply
Cha加 due diligence.
Comments andDemon8trationofcomPⅡ且nce:
Anintern且lmanagementsystemhas been setup to define the governance, Toles andresponsibilities,
Internalaudit, communication 日nd senior mana宮ementreview as perthe adopted policy.
A compliance officer W且S assigned to manage the process, who has a direct line of reporting to the
Supply cha血 0丘icer (senior m日nagemenり.
3. The Ta11aka Group comP日11ies have established a 8trong hlternal system of due diligence,
Controls and tr釦Sparency over gold supply ch日il), includi11g traceabi1北y and identi6.cation of
Othersupplych且in actors.
CommentS 抑d Demonstration ofcompliance:
The Tanaka Group companies have established andimplemented a man且gementsystem forthe due
diligence ofsupplieN that might have some connection with conaict・Affected and High,RiskAreas
and/or mightbe involvedW北h moneylaunderin宮, for the purpose ofconaict mineTalscontroland for
the prevention ofprocurin宮 Contlict miner且Is originated hom con丑ict・Affectθd and High.RiskAreas.
The Tanaka Group companies assign the supply chain officer,the compliance officer,the purch日Se
Of丘Cers and storage officer of宮old materials to implementthe system.
^e make active use ofour materia]s acceptance monitoring system forrecycled materials,今oldbars
and coinsin order to monitor the m且teri日Is received.
4, The Tanaka Group companies have strengしhened eng且gement Mth 宮old supplyin套
Countel'P且rties, and where possible, assisted 宮old supplyhlg counterparties in building due
dⅡi牙ence capabiⅡ伍es.
Comments a11d Demonstration of compliance:
TANA1くAHOLDINGS CO., Ltd. makes publicits conaictMineralManagement policy to deC1且reits
Commitmentto fU1丘11requirements set outin the LB入IAResponsible Gold Guidance.
In tMsre宮ard, TANAI【AHOLDINGS CO., Ltd. h且S written orverbalcommU11ication with our gold
Suppliers and has Tequested thatthe gold supplierscomplyW北h our conaict入lhleralManagement
Policy.
5. The T抑aka Group comP日nies have established a 号τOUP・Mde communiC日tion mecha11ism to
Promotebroad・based employee participation 且ndriskident過Cationto m師日gement.
Comments and Demonstration ofcompli日nce:
The existin宮 internalreporting system is used t0 且110w employees to voice concerns over the gold
Supply chain or a newly identi6.ed risk. when the lnternalReporting comm北tee receives such a
Teport,北 Wi11Set up an investigation team colnp08ed ofmembers bl an impattialposition.
Education to fU1丘11the requirements set outin the LB入IAResponsible Gold Guidance was provided
to the employeesinvolved in the purch日Se 且nd receipt ofgold materials in the reporting year.
SteP 2:1dentify and asse鵠 risksin the supply ch且in
ComPⅡance statementwithRequirement:
工Ne have {'UⅡy complied with steP 2:1dentify and assess hsks in the supply chain.
1. TheTanaka Group companies have aprocesstoidenti6,'risksinthe 8Upply chain.
Comments a11d Demonstra土ion ofcompliance:
The Tanak日 Group colnpanies identify 日nd assess risksin the supply chain. For every supplier, the
PUTchase of丘Cersinve8tig日tetheinformationofcounterpa此y 且nd a110cated aHskpr0丘le accordingto
Our risk profile cr北eria. T11is pYocess is now a forma1τequirement before enterin宮 any business
relationsMp with a gold 8Upplying counterparty Engagin宮 in over・the・counteY purchases ofgold
bUⅡion, coins,jeweby, etc., Tanaka 1ζikinzoku Jeweby has been c011ecting customer information at
the time ofpuTchase 日nd has been ilnplementin套 the review ofperson日lidentification such as
driver's licenses and other public certiflcates.
2. The Tanaka Group compa11ies assesses risk8 in light of the stand日rds of their due diligence
System.
Comlnents al)d Demonstration ofcomplia11Ce:
The Tanaka Group companies conduct supply chain due diligenCθ ComP亘Sing of a11 measures
required by the LB八1仏 Responsible Gold Guidance before enteTin曾 into a gold supply business
relationship.
3. T1証【reportsrisk assessmentto the desi目na力edmanager.
CommentS 且11d Demonstration ofcompliance:
^en we identify a hi宮hrisk supplier, which is suspected to source the gold mateHa1丘om the
Democr且tic Republic ofthe conΞo or adjoinin宮 Countries, or have connection with money laundeTers,
terrorists or other 且nti・social groups, the compliance 0伍Cer wi11Consultthe supply ch且in 0仟icer and
Conduct enhanced due diligence untilwe canjudge whether we can comlnence or continue the
business relationship. W'e did not identify a high risk supplier in the reporting year.
SteP 3: Design andimplement 日 m日nagementsystem to respond to ident憧edl.isks
Compliance statemen力 Mth Requirement:
^e have fUⅡy complied with steP 3: Desi曾n and implement a m且na牙ement system to respond to
identi丘ed risks.
1. The T且naka group comP日11ies devised a strate宮y for risk man且gement of 且n ident過ed risk by
either ① mitigation ofthe risk while continuing to trade,(五) nlitigation ofthe risk while suspending
tradeor (蛍) disengagement丘omtherisk.
Comments and Demonstration ofcompliance:
The Tanaka group comP日nies perform risk contr010n material procurement 且nd wi11immediately
Stop a tranS日Ction as soon as it is found that the materialcontains c0τ寸lict miner且10riginated from
the so・ca11ed con丑ict・Affected 日nd High・Risk Areas. There was no supplier that the compliance
0伍Cer classi丘ed as a hi宮h・risk supplier 血 the reporting year.
2. where a m即agement8trate部 ofrisk mitigation is undertaken,itshould include measureable
Stepstobetaken 日11dacMeved, m011itori11gofperform田Ice, periodicreassessmentofHskandregular
reportingto desi即ated seniorm日na宮ement.
CommentS 抑dDemonstrationofcompliance:
Based on a clear set of cr北eria, we decide whether we should miti宮且te the identi6ed risk while
Continuing trade, m北igate the risk while suspendin套 tTade, or immediately discontinue trade. Asthe
result of the risk assessment on the 宮0]d・containing materials which we purchased during the
reporting year, we did not identify the possibility that we purch且Sed con丑ict minerals originated
from con且ict・a丘'ected areas,
SteP 4: Arrange for an血dependentt11ird・party audit ofthe supply chain due dili今ence
Compliance statement MthRequirement:
We have fU11y complied with steP 4: Arrange for an independent third・party audit of the supply
Chail) due diligence.
CommentS釦dDemonstra伍onofcompliance:
TKKen客aged the services ofthe assurance provider, KP入IGAZSA sustainabi1北y co,, Ltd. and their
Independent LimitedAssurance Rep0此 is aV且i1日ble on our web site.
h此P:11WWW.tanaka.CO.jplenglishlabouV日Ssur日nce・rep0此.pdf
SteP 5: Report on supply chain due dⅡigθnce
Compliance statementMthRequirement:
We have61ⅡycompliedMth steP 5: Rep0北on supply chain duediligence
Comments
Ourconaict mbleralmanagementp0ⅡCy 且nd thiscompliance report are aV日ilable on our web site,
htt :11WWW.tanaka.CO
Ien lishlsourcin
htt ゾ/WWW.tanak日.CO
Ien lish/aboutAbm且・re ort. df
Olic /
Overa11Condusion
Table 3: Managementconclusion
Isthe Re丘11erin compliance with the requirements ofthe ιB/1ι1πe旦P0訂Sible ooldGUI'da11Ceforthe
reporヒing period?
Yeg
Conlnlents
In conclusion, TKKimplemented e丘ective managementsystems, procedures, PI'oceS8e8 and pr且Ctices
toconform totherequirementsofthe ιβヨ4AπesponS1るle coldGuidance, as explained aboveinT日ble
2, for the Teporting ye且r ended 31 March 2015.
Table 4: otherreportcomments
If users of this report wish to provide any feedback to TKK with respect to this report, they can
Cont日Ct via the f0110wing elnailaddress: CSR・[email protected]且k日.CO.jp
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