Sustainable Management

Conflict Minerals

Description of conflict minerals and background of restriction

They indicate 4 minerals such as (3TG: gold, tin, tungsten and tantalum) from which Democratic Republic of the Congo and other adjoining countries are considered to have profited through mining.

The profits created by the conflict minerals are related to the war, crime, child and forced extortion, human right violation and other bloody conflict. So, in order to regulate the profit from trading of conflict minerals and thus realize the corporate social responsibility and ethical values and get the fair trading, the acts for regulating the conflict minerals have been introduced. US Congress have passed a bill in 2010 (Dodd-Frank Wall Street Reform and Consumer Protection Act) which forces the users of these minerals to report the use of them. According to the law above (Section 1502), any companies listed on US stock markets are supposed to check out whether they use the conflict minerals and the country of origin and make the due diligence on the supply chain before reporting them to US Securities and Exchange Commission (SEC).

  • The definition of conflict minerals according to SEC's Act on the restriction of conflict minerals is as follows.

    1) Coltan, cassiterite, gold, wolframite and other derivatives

    2) Minerals and their derivatives which are designated by US Secretary of State as providing benefits to the armed groups of Democratic Republic of the Congo and other adjoining countries

  • Dodd-Frank Wall Street Reform and Consumer Protection Act defined Democratic Republic of the Congo and other adjoining countries (or 10 countries in total) as the conflict area and the area may be expanded in the future. In addition, the draft bill of EU's restriction of conflict minerals specifies that the conflict area shall be specified in the list of OECD.

  • Target countries for conflict minerals : Democratic Republic of the Congo, Republic of Congo, South Sudan, Rwanda, Burundi, Uganda, Zambia, Angola, Tanzania, and Central African Republic.

Policy on conflict minerals

NH RECYTECH considers the damage to the environment and human right and other social problems which are related to the armed group in the conflict area as very serious ethical issues and prohibits the use of conflict minerals unethically mined in the Democratic Republic of the Congo and other adjoining countries. We will make effort so that the conflict minerals are not contained in the supply chain of our production chain and actively cooperate in the effort of prohibiting the use of conflict minerals. We will also make our social and ethical responsibilities so that the human rights can be protected in Democratic Republic of the Congo and other adjoining countries. For this goal, NH RECYTECH will conduct the followings.

  • We will set up the documented management policy so that the conflict minerals which would contributed to the profit of armed groups in Democratic Republic of the Congo and other adjoining countries are not included in our production chain.
  • We will ask our trading partners to submit the statement showing that they submit the use of conflict minerals and that they do not use the conflict minerals.
  • We will actively handle the issue of conflict minerals and will establish the procedure which is based on the EU instruction on due diligence.
  • We will not contribute to the profit which is obtained from the minerals involved in the disputed area and nor contain the conflict minerals in the supply chain for the production of our products.
  • We will actively support the EICC's activities for prohibiting the use of conflict minerals and make the active cooperation with CFSI (Conflict Free Sourcing Initiative) as to the due diligence, reporting and discussion of the refinery.
If we are not sufficiently provided with the required information from our trading partners or a significant risk is found in the supply chain, we may stop the trading.
NH RECYTECH will comply with this policy in an honest and fair way and actively participates in the international effort prohibiting the use of conflict minerals in a way that the armed groups in Democratic Republic of the Congo and other adjoining countries do not get the profit from any illegal elements involving the conflict minerals.
Through this conduct, we will make efforts to become a company which takes the social responsibility of protecting the human rights in Democratic Republic of the Congo and other adjoining countries.