Measures for Conflict Minerals
To prevent a source of funding for armed groups responsible for inhumane actions, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act on July 2010. Its Section 1502 mandates that all companies listed in the United States report whether or not their products contain any conflict minerals sourced from the Democratic Republic of the Congo (DRC) or its nine adjoining countries to the U.S. Securities and Exchange Commission (SEC), where "conflict minerals" are defined as columbite-tantalite (coltan), cassiterite, wolframite, their derivatives such as tantalum, tin, and tungsten, or gold, regardless of their origin. The act also specifies that the SEC prepares rules for specific procedures used for reporting that information and other requirements, which were officially adopted on August 22, 2012.
Though not subject to the SEC rules on disclosing conflict minerals, the Shimadzu Group is nevertheless in favor of the rules and, therefore, established an internal organization for conflict minerals and, in terms of social responsibility, has established this Shimadzu Group Policy Regarding Conflict Minerals to ensure the Shimadzu Group does not use any conflict minerals that involve inhumane activities as raw materials in Shimadzu products.
Shimadzu Group Policy Regarding Conflict Minerals
The Shimadzu Group will not use the following minerals in Shimadzu products: columbite-tantalite (coltan), cassiterite, wolframite, their derivatives such as tantalum, tin, and tungsten, or gold that directly or indirectly funds armed groups or contributes to inhumane actions involving human trafficking, slavery, forced labor, child labor, abuse, or war crimes in the Democratic Republic of the Congo or its nine adjoining countries. If any parts or raw materials used in Shimadzu products are discovered to contain any of these conflict minerals, appropriate actions will be implemented, such as discussing a solution with the applicable supplier or immediately discontinuing the use of such part or raw material.
That does not mean Shimadzu will not accept any conflict minerals produced in the DRC or its adjoining countries at all, but rather that Shimadzu will only accept those that are procured in accordance with appropriate laws and that do not fund armed groups in those regions (certified as DRC conflict-free).
- Supply chains will be managed and operated appropriately, in accordance with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
- The Conflict Minerals Reporting Template (CMRT), the conflict-free sourcing information (CFSI) template developed by the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative (EICC/GeSI), will be used to survey current supply chains.
- Parts and materials will be procured from suppliers that source materials from conforming smelting and refining vendors identified under the Conflict-Free Smelter Program (CFS program).
Therefore, we are also asking Shimadzu Group suppliers to cooperate with implementing this Shimadzu Group Policy Regarding Conflict Minerals.
Shimadzu Group Organization for Implementing the Conflict Minerals Policy
Shimadzu Corporation has established a corporate risk management organization that deliberates and decides important issues regarding Group risk management and compliance. This organization is headed by a Risk Management and Corporate Ethics Board chaired by the president. Within this organization, the respective departments with applicable responsibilities are in charge of promoting corporate and Group activities in accordance with the Shimadzu Group Policy Regarding Conflict Minerals.
Requests to Suppliers
- Shimadzu is holding a series of meetings to explain the Policy Regarding Conflict Minerals, with each meeting attended by representatives from about 500 companies. We ask suppliers to perform due diligence and, as much as possible, procure parts and materials from conflict-free smelters.
- To have our suppliers better understand Shimadzu's corporate conduct guidelines, such as not trading with suppliers associated with human rights infringement and refraining from transactions that would fund such suppliers, we have distributed a copy of Shimadzu's Corporate Code of Ethics. Moreover, we are also asking our suppliers to act in a manner consistent with our conduct guidelines.
Conflict Minerals Survey
The CMRT conflict-free sourcing information template is used to survey the current status of conflict mineral use and information about smelters. This survey is intended to confirm information such as that parts and materials are procured from suppliers that source materials either from smelters identified by the Conflict-Free Smelter Program or, if not identified by the program, smelters that do not use minerals complicit with armed conflicts.
If a smelter or refiner is judged inappropriate, we ask that the relevant suppliers cooperate in removing the inappropriate minerals from the supply chain for the applicable products, parts, and materials.