Exhibit 1.01
Canon Inc.
Conflict Minerals Report
For the Period from January 1, 2018 to December 31, 2018
This Conflict Minerals Report for the period from January 1, 2018 to December 31, 2018, is presented as an exhibit to the Specialized Disclosure Report on Form SD, to comply with Rule13p-1 under the Securities Exchange Act of 1934.
| 1. | Introduction (Background to the disclosure of the Conflict Minerals Report) |
Established in 1937, Canon Inc. is a Japanese corporation with its headquarters in Tokyo, Japan. Canon Inc. is one of the world’s leading manufacturers of office multifunction devices (“MFDs”), plain paper copying machines, laser printers, cameras, inkjet printers, diagnostic equipment and lithography equipment. Canon Inc. earns revenues primarily from the manufacture and sale of these products domestically and internationally. For details of corporate activities please refer to our annual report filed on Form20-F.
Canon Inc. is listed on the New York Stock Exchange and is subject to the final rules issued by the United States Securities and Exchange Commission (“SEC”) to implement Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).
In response to Rule13p-1, Canon Inc. conducted a “Reasonable Country of Origin Inquiry” (“RCOI”) for products manufactured or contracted to manufacture by Canon Inc. and its consolidated subsidiaries (“Canon” or “Canon Group”) from January 1, 2018 to December 31, 2018 (“reporting period”). The inquiry identified four minerals classified as conflict minerals—namely tin, tantalum, tungsten, and gold (“3TG”)—that originated in the Democratic Republic of the Congo and adjoining countries (“covered countries”) and did not come from recycled or scrap minerals, that are used in some of the parts or materials that make up Canon Group’s products. Further, Canon Inc. conducted due diligence on the source and chain of custody of 3TG (“due diligence”) identified as originating from covered countries.
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| 2. | Application of Conflict Minerals Report on Canon and products subject to disclosure |
As of December 31, 2018, Canon Inc. had 379 consolidated subsidiaries, of which 53 subsidiaries manufactured products or contracted to manufacture products in the reporting period for which 3TG were necessary to the functionality and production, and were subject to the reporting requirements under the SEC’s final rules regarding the Dodd-Frank Act. In total, 54 companies of the Canon Group, including Canon Inc. and those 53 consolidated subsidiaries conducted the RCOI. The subsidiaries that conducted the RCOI include certain marketing companies that contracted with manufacturers outside the Canon Group to manufacture items for sale outside the Canon Group.
The business operations of Canon can be divided into the following four categories: the Office Business Unit, the Imaging System Business Unit, the Medical System Business Unit and the Industry and Others Business Unit. The Office Business Unit includes office MFDs, printers, and copying machines for personal and office use as well as production print products for print professionals. The Imaging System Business Unit includes digital cameras and digital camcorders, as well as lenses and various related accessories. It also includes photo printers, projectors, broadcast HDTV lenses, inkjet printers, and large-format inkjet printers. The Medical System Business Unit includes Computed tomography (CT), Magnetic resonance imaging (MRI), ultrasound,X-ray systems, and clinical laboratory systems, as well as digital radiography systems and ophthalmic equipment. The Industry and Others Business Unit includes semiconductor lithography equipment, flat panel display (FPD) lithography equipment, organic light-emitting diode (OLED) panel manufacturing equipment, and network cameras.
In each of these units, electronic components and substrates which contain 3TG are used in the majority of products manufactured by or contracted to manufacture by Canon.
Canon Group purchases raw materials, parts and components which include 3TG and manufactures products. Canon Group is located downstream in the 3TG supply chain, and does not directly purchase 3TG from mines. Therefore, Canon Group had to rely on information provided by the first-tier suppliers to the Canon Group (“first-tier suppliers”) in identifying the source country of the 3TG.
| 3. | Basic principles regarding response to conflict minerals |
Canon Inc. established the “Basic Approach of the Canon Group Regarding Conflict Minerals” in September 2012. This has been published on Canon Inc.’s official website and applied to the entire Canon Group.
URL: https://global.canon/en/csr/conflict/policy.html
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| 4. | RCOI and Due Diligence |
The design of Canon’s RCOI and due diligence measures is in conformity with the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (third edition)” (“OECD Guidance”). Canon took the steps described below in accordance with the five steps laid out in the OECD Guidance.
| a. | Step 1: Establish strong company management systems |
| - | In order to respond to the conflict minerals situation, Canon established a cross-functional Conflict Minerals Response Project Team (“Project Team”) in its headquarters under the direction of a representative director in charge (Executive Vice President & CFO) in December 2010. Moreover, Canon designated a person in charge of conflict minerals in each of its group companies that manufacture or contract to manufacture products. The Project Team currently operates as the Working Group on Conflict Minerals (“Working Group”). |
| - | As stated above, Canon Inc. established the “Basic Approach of the Canon Group Regarding Conflict Minerals” in September 2012. |
| - | In March 2016, Canon established the “Guidelines for Compliance with Conflict Minerals Regulation” that clarified the responsible divisions and the framework for handling conflict minerals issues as well as the survey process, for the persons involved in the Canon Group. |
| - | In July 2018, Canon Inc. summoned the persons in charge of conflict minerals for Canon Group’s domestic subsidiaries that manufacture or contract to manufacture products and held a meeting to share the result of the 2017 conflict minerals survey and discuss Canon’s policies for the survey of 2018. Moreover, for the persons in charge of conflict minerals matters for overseas subsidiaries, Canon Inc. shared information bye-mail, video and telephone conference. |
| - | Canon created and distributed the Conflict Minerals Survey Manual to the first-tier suppliers. |
| - | Canon requested the first-tier suppliers to sign and submit written confirmation (“Certificate of Consent”) of their agreement and cooperation with Canon’s “Basic Approach of the Canon Group Regarding Conflict Minerals” and their agreement to consult with the Canon Group concerning appropriate measures should any affiliation with armed groups be discovered in the supply chain. |
| - | Using its Conflict Minerals Information Management System, Canon Inc. linked survey responses to product information, conducted product-level assessments, and stored the assessment results in a database, except for such products as handled by newly joined subsidiaries. Internal rules require that data records be retained for at least five years. |
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| - | Canon Inc. is a member of the Responsible Minerals Trade Working Group (“RMTWG”) of the Japan Electronics and Information Technology Industries Association (“JEITA”). As part of its initiatives, the RMTWG held conflict minerals inquiry briefings for suppliers in supply chains in the electrical and electronics industry. Step 3 below provides details of the industry initiatives on conflict minerals that Canon Inc. participates in. |
| - | As an early-warning risk-awareness system for conflict minerals specified in the OECD Guidance, Canon Inc. established a grievance mechanism — “Contact Point for Reporting Concerns Regarding Conflict Mineral Issues” — on its official website in 2015. No reports from employees, suppliers, or other stakeholders were received by the contact point in 2018. |
URL: https://global.canon/en/contact/conflict/conflict-form-e.html
| b. | Step 2: Identify and assess risks in the supply chain |
| - | Canon designed a framework to identify each of the parts and materials used in the products that it manufactured or contracted to manufacture. Canon used its production and shipping management system, which includes bills of materials for products and also used its procurement system, to identify parts and materials required in products planned for production and shipping between January and the end of December 2018. (Canon Group companies not using such system made use of a similar method to identify parts and materials.) Canon then carried out the RCOI on the first-tier suppliers handling the identified parts and materials. |
| - | For the RCOI, Canon used the RMI Conflict Minerals Reporting Template (“CMRT”). The CMRT is published by the Responsible Minerals Initiative (“RMI”), one of the programs of the Responsible Business Alliance (“RBA”). Canon requested the 3,515 first-tier suppliers that were identified as possibly using 3TG to report their status of 3TG using the CMRT. Suppliers that were not using 3TG for their parts and materials had the option of reporting their status through an alternative method, instead of using the CMRT. |
| - | In addition to the RCOI described above, Canon conducted due diligence examinations of first-tier suppliers that reported the use of 3TG originating from covered countries. |
| - | Canon requested replies from the first-tier suppliers who did not respond by the closing date of the response. |
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| - | Canon Inc. verified the replies submitted by first-tier suppliers (for any incomplete answers or errors) using a proprietary reply-processing tool. When necessary, Canon requested resubmissions from first-tier suppliers. |
| - | As of the end of March, 2019, Canon had received responses from 90 percent of all first-tier suppliers surveyed. |
| - | Canon compared the smelters or refiners (“SORs”) identified through the RCOI against the list of the SORs which have been validated to be conformant to the Responsible Minerals Assurance Process (“RMAP”), the audit program of the RMI, as published by the RMI. The RMI implements cross recognition with the London Bullion Market Association (LBMA) and the Responsible Jewellery Council (RJC). |
| c. | Step 3: Design and implement a strategy to respond to identified risks |
| - | The head of the Working Group reported the progress of conflict minerals response activities to the representative director in charge. |
| - | Moreover, the Working Group reported in October 2018 on its progress to relevant directors and executive officers of Canon Inc. as well as the presidents of the relevant domestic and overseas subsidiaries. |
| - | Canon Inc. is a key member of JEITA’s RMTWG. The RMTWG is allied with the RMI, which play the leading role in the response to conflict minerals. Canon Inc. has held the role ofco-chair of the RMTWG since 2013. |
| - | Canon Inc. has also served as team leader of the RMTWG’s Smelter Support Team since 2015. In this capacity, Canon Inc., along with the other companies in the RMTWG, played an active role in sending letters to SORs encouraging them to join the RMI’s RMAP or to check if the SORs haveso-called Annex II risks of the OECD Guidance or the U.S. sanction risks based on the U.S. Office of Foreign Assets Control (OFAC). |
| - | Canon Inc. participates in the Japan Conflict-Free Sourcing Working Group (CFSWG), a joint initiative by JEITA’s RMTWG and major Japanese automobile manufacturers, and serves as the CFSWG vice-chair. The CFSWG met twice in 2018 and early 2019 to examine creating conditions to better facilitate conflict minerals surveys by supply chains in the electrical and electronics industry and the automobile industry. |
| - | In addition to the above activities, Canon Inc. has been a member of the RMI since April 2015. Its membership code is “CNON.” Canon Inc. assists RMI activities as a corporate member of the RMI. |
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| d. | Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices |
| - | As a RMI member, Canon Inc. supports audits under the RMAP carried out by the RMI on SORs. |
| e. | Step 5: Report annually on supply chain due diligence |
| - | In accordance with the Dodd-Frank Act and the SEC’s final rules, on or before May 31, 2019, Canon Inc. plans to file a Form SD and Conflict Minerals Report (this report) with the SEC, and plans to publish the same information on its official website. |
| - | Canon Inc. has been reporting its activities in response to conflict minerals in its Annual Report and Sustainability Report since 2011. |
| 5. | Survey results for the 2018 calendar year |
| a. | Result of RCOI and due diligence |
| - | Canon conducted the RCOI on 3,515 first-tier suppliers that possibly use 3TG. Canon conducted further due diligence on first-tier suppliers which reported the use of 3TG from the covered countries. |
| - | In cases where 3TG originating from covered countries were used, Canon received some responses indicating the minerals in question had been sourced from SORs that are conformant with the RMAP. |
| - | Within the scope of the responses, there was nothing to clearly suggest that the Canon Group’s purchasing of parts and materials contributed to funding armed groups. |
| b. | Result of SORs survey |
| - | Canon analyzed the information on the SORs mentioned in the responses from the supply chain through the RCOI, with reference to the RMI’s SOR information. The RMI classifies SORs based on the auditing status. The SORs that have undergone assessment through the RMAP or industry equivalent program and have been validated to be in conformance with the protocols are defined as RMAP conformant. The SORs with are-audit in progress are still considered to be RMAP conformant. The SORs are identified as Active in the RMAP once they submit signed Agreement for the Exchange of Confidential Information (AECI), Auditee Agreement, and have submitted a Due Diligence Checklist. |
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| - | 252 SORs in Canon supply chain were identified as RMAP conformant and 6 SORs were identified as Active in the RMAP. The remaining 64 SORs were neither RMAP conformant nor Active in the RMAP. Appendix1-1,1-2 and1-3 provide lists of these SORs. |
| - | Canon was unable to determine whether the remaining entities reported by the first-tier suppliers as SORs were truly SORs. |
| - | Due to inadequate information from its supply chains, Canon was unable to determine the country or region of origin of many 3TG used in Canon Group products. |
| - | Appendix1-4 lists examples of 3TG countries and regions of origin first-tier suppliers reported to Canon through CMRT responses. |
| - | Based on the results of the RCOI and due diligence mentioned above, Canon was unable to determine whether the 3TG used for the products of the Canon Group financed or benefitted armed groups in the covered countries. |
| 6. | Efforts to determine the mine or location of origin of 3TG with the greatest possible specificity and risk mitigation |
The following efforts to determine the mine or location of origin of 3TG with the greatest possible specificity are planned to be implemented from 2019 onwards.
| - | Canon will continue promoting verification operations of high-risk first-tier suppliers in accordance with the Canon’s Guidelines for Compliance with Conflict Minerals Regulation. |
| - | Canon Inc. will continue its participation at JEITA’s RMTWG, CFSWG and RMI, and support activities to make entire supply chains conflict free. |
| 7. | Independent monitoring |
| - | KPMG AZSA Sustainability Co., Ltd. conducted an independent private sector audit of this report. The audit assessed whether the due diligence framework Canon designed conforms to the OECD Guidance’s due diligence framework and whether the due diligence description in this report is consistent with the actual measures Canon undertook. The independent assurance report is attached in Appendix 2. |
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Forward-Looking Statements
This report contains not only past and present facts about Canon, but also future forecasts based on plans, prospects, management policies and strategies as of the publication date. These future forecasts are assumptions or estimations based on information available at the time the report was prepared. Due to a range of variables, however, the results or circumstances of our future business activities may vary from the forecasts contained herein.
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Appendix 1.
| 1. | List of the SORs identified in Canon’s supply chain which are RMAP conformant (As of March 15, 2019) |
Metal
| SoRs
| Country/Region
| ||
Gold
|
L’Orfebre S.A.
|
ANDORRA
| ||
Gold
|
Western Australian Mint (T/a The Perth Mint)
|
AUSTRALIA
| ||
Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
AUSTRIA
| ||
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
BELGIUM
| ||
Gold
|
AngloGold Ashanti Corrego do Sitio Mineracao
|
BRAZIL
| ||
Gold
|
Marsam Metals
|
BRAZIL
| ||
Gold
|
Umicore Brasil Ltda.
|
BRAZIL
| ||
Gold
|
Asahi Refining Canada Ltd.
|
CANADA
| ||
Gold
|
CCR Refinery - Glencore Canada Corporation
|
CANADA
| ||
Gold
|
Royal Canadian Mint
|
CANADA
| ||
Gold
|
Planta Recuperadora de Metales SpA
|
CHILE
| ||
Gold
|
Gold Refinery of Zijin Mining Group Co., Ltd.
|
CHINA
| ||
Gold
|
Heraeus Metals Hong Kong Ltd.
|
CHINA
| ||
Gold
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
|
CHINA
| ||
Gold
|
Jiangxi Copper Co., Ltd.
|
CHINA
| ||
Gold
|
Metalor Technologies (Hong Kong) Ltd.
|
CHINA
| ||
Gold
|
Metalor Technologies (Suzhou) Ltd.
|
CHINA
| ||
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
CHINA
| ||
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
CHINA
| ||
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd.
|
CHINA
| ||
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
CHINA
| ||
Gold
|
SAAMP
|
FRANCE
| ||
Gold
|
AllgemeineGold-und Silberscheideanstalt A.G.
|
GERMANY
| ||
9
Gold
|
Aurubis AG
|
GERMANY
| ||
Gold
|
C. Hafner GmbH + Co. KG
|
GERMANY
| ||
Gold
|
DODUCO Contacts and Refining GmbH
|
GERMANY
| ||
Gold
|
Heimerle + Meule GmbH
|
GERMANY
| ||
Gold
|
Heraeus Precious Metals GmbH & Co. KG
|
GERMANY
| ||
Gold
|
SAXONIA Edelmetalle GmbH
|
GERMANY
| ||
Gold
|
WIELAND Edelmetalle GmbH
|
GERMANY
| ||
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
INDIA
| ||
Gold
|
PT Aneka Tambang (Persero) Tbk
|
INDONESIA
| ||
Gold
|
Chimet S.p.A.
|
ITALY
| ||
Gold
|
Italpreziosi
|
ITALY
| ||
Gold
|
Safimet S.p.A
|
ITALY
| ||
Gold
|
T.C.A S.p.A
|
ITALY
| ||
Gold
|
Aida Chemical Industries Co., Ltd.
|
JAPAN
| ||
Gold
|
Asahi Pretec Corp.
|
JAPAN
| ||
Gold
|
Asaka Riken Co., Ltd.
|
JAPAN
| ||
Gold
|
Dowa
|
JAPAN
| ||
Gold
|
Eco-System Recycling Co., Ltd.
|
JAPAN
| ||
Gold
|
Ishifuku Metal Industry Co., Ltd.
|
JAPAN
| ||
Gold
|
Japan Mint
|
JAPAN
| ||
Gold
|
JX Nippon Mining & Metals Co., Ltd.
|
JAPAN
| ||
Gold
|
Kojima Chemicals Co., Ltd.
|
JAPAN
| ||
Gold
|
Matsuda Sangyo Co., Ltd.
|
JAPAN
| ||
Gold
|
Mitsubishi Materials Corporation
|
JAPAN
| ||
Gold
|
Mitsui Mining and Smelting Co., Ltd.
|
JAPAN
| ||
Gold
|
Nihon Material Co., Ltd.
|
JAPAN
| ||
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
JAPAN
| ||
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
JAPAN
| ||
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
JAPAN
| ||
Gold
|
Tokuriki Honten Co., Ltd.
|
JAPAN
| ||
Gold
|
Yamakin Co., Ltd.
|
JAPAN
| ||
Gold
|
Yokohama Metal Co., Ltd.
|
JAPAN
| ||
Gold
|
Kazzinc
|
KAZAKHSTAN
| ||
Gold
|
Daejin Indus Co., Ltd.
|
KOREA, REPUBLIC OF
| ||
Gold
|
DSC (Do Sung Corporation)
|
KOREA, REPUBLIC OF
| ||
10
Gold
|
HeeSung Metal Ltd.
|
KOREA, REPUBLIC OF
| ||
Gold
|
Korea Zinc Co., Ltd.
|
KOREA, REPUBLIC OF
| ||
Gold
|
LS-NIKKO Copper Inc.
|
KOREA, REPUBLIC OF
| ||
Gold
|
Samduck Precious Metals
|
KOREA, REPUBLIC OF
| ||
Gold
|
SungEel HiMetal Co., Ltd.
|
KOREA, REPUBLIC OF
| ||
Gold
|
Torecom
|
KOREA, REPUBLIC OF
| ||
Gold
|
DS PRETECH Co., Ltd.
|
KOREA, REPUBLIC OF
| ||
Gold
|
Kyrgyzaltyn JSC
|
KYRGYZSTAN
| ||
Gold
|
MetalurgicaMet-Mex Penoles S.A. De C.V.
|
MEXICO
| ||
Gold
|
Remondis Argentia B.V.
|
NETHERLANDS
| ||
Gold
|
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
|
PHILIPPINES
| ||
Gold
|
JSC Uralelectromed
|
RUSSIAN FEDERATION
| ||
Gold
|
Moscow Special Alloys Processing Plant
|
RUSSIAN FEDERATION
| ||
Gold
|
OJSC “The Gulidov KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet)
|
RUSSIAN FEDERATION
| ||
Gold
|
OJSC Novosibirsk Refinery
|
RUSSIAN FEDERATION
| ||
Gold
|
Prioksky Plant ofNon-Ferrous Metals
|
RUSSIAN FEDERATION
| ||
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
RUSSIAN FEDERATION
| ||
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.
|
SINGAPORE
| ||
Gold
|
AU Traders and Refiners
|
SOUTH AFRICA
| ||
Gold
|
Rand Refinery (Pty) Ltd.
|
SOUTH AFRICA
| ||
Gold
|
SEMPSA Joyeria Plateria S.A.
|
SPAIN
| ||
Gold
|
Boliden AB
|
SWEDEN
| ||
Gold
|
Argor-Heraeus S.A.
|
SWITZERLAND
| ||
Gold
|
Cendres + Metaux S.A.
|
SWITZERLAND
| ||
Gold
|
Metalor Technologies S.A.
|
SWITZERLAND
| ||
Gold
|
PAMP S.A.
|
SWITZERLAND
| ||
Gold
|
PX Precinox S.A.
|
SWITZERLAND
| ||
Gold
|
Valcambi S.A.
|
SWITZERLAND
| ||
11
Gold
|
Singway Technology Co., Ltd.
|
TAIWAN, PROVINCE OF CHINA
| ||
Gold
|
Solar Applied Materials Technology Corp.
|
TAIWAN, PROVINCE OF CHINA
| ||
Gold
|
Umicore Precious Metals Thailand
|
THAILAND
| ||
Gold
|
Istanbul Gold Refinery
|
TURKEY
| ||
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.S.
|
TURKEY
| ||
Gold
|
Al Etihad Gold LLC
|
UNITED ARAB EMIRATES
| ||
Gold
|
Emirates Gold DMCC
|
UNITED ARAB EMIRATES
| ||
Gold
|
Advanced Chemical Company
|
UNITED STATES OF AMERICA
| ||
Gold
|
Asahi Refining USA Inc.
|
UNITED STATES OF AMERICA
| ||
Gold
|
Geib Refining Corporation
|
UNITED STATES OF AMERICA
| ||
Gold
|
Kennecott Utah Copper LLC
|
UNITED STATES OF AMERICA
| ||
Gold
|
Materion
|
UNITED STATES OF AMERICA
| ||
Gold
|
Metalor USA Refining Corporation
|
UNITED STATES OF AMERICA
| ||
Gold
|
United Precious Metal Refining, Inc.
|
UNITED STATES OF AMERICA
| ||
Gold
|
Almalyk Mining and Metallurgical Complex (AMMC)
|
UZBEKISTAN
| ||
Tantalum
|
LSM Brasil S.A.
|
BRAZIL
| ||
Tantalum
|
Mineracao Taboca S.A.
|
BRAZIL
| ||
Tantalum
|
Resind Industria e Comercio Ltda.
|
BRAZIL
| ||
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.
|
CHINA
| ||
Tantalum
|
F&X Electro-Materials Ltd.
|
CHINA
| ||
Tantalum
|
FIR Metals & Resource Ltd.
|
CHINA
| ||
Tantalum
|
Guangdong Rising RareMetals-EO Materials Ltd.
|
CHINA
| ||
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd.
|
CHINA
| ||
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
CHINA
| ||
Tantalum
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
|
CHINA
| ||
Tantalum
|
Jiangxi Tuohong New Raw Material
|
CHINA
| ||
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
CHINA
| ||
Tantalum
|
Jiujiang Tanbre Co., Ltd.
|
CHINA
| ||
Tantalum
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
|
CHINA
| ||
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
CHINA
| ||
12
Tantalum
|
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
|
CHINA
| ||
Tantalum
|
XinXing HaoRong Electronic Material Co., Ltd.
|
CHINA
| ||
Tantalum
|
Jiujiang Janny New Material Co., Ltd.
|
CHINA
| ||
Tantalum
|
NPM Silmet AS
|
ESTONIA
| ||
Tantalum
|
H.C. Starck Hermsdorf GmbH
|
GERMANY
| ||
Tantalum
|
H.C. Starck Smelting GmbH & Co. KG
|
GERMANY
| ||
Tantalum
|
H.C. Starck Tantalum and Niobium GmbH
|
GERMANY
| ||
Tantalum
|
Metallurgical Products India Pvt., Ltd.
|
INDIA
| ||
Tantalum
|
Global Advanced Metals Aizu
|
JAPAN
| ||
Tantalum
|
H.C. Starck Ltd.
|
JAPAN
| ||
Tantalum
|
Mitsui Mining and Smelting Co., Ltd.
|
JAPAN
| ||
Tantalum
|
Taki Chemical Co., Ltd.
|
JAPAN
| ||
Tantalum
|
Asaka Riken Co., Ltd.
|
JAPAN
| ||
Tantalum
|
Ulba Metallurgical Plant JSC
|
KAZAKHSTAN
| ||
Tantalum
|
Power Resources Ltd.
|
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
| ||
Tantalum
|
KEMET Blue Metals
|
MEXICO
| ||
Tantalum
|
Solikamsk Magnesium Works OAO
|
RUSSIAN FEDERATION
| ||
Tantalum
|
H.C. Starck Co., Ltd.
|
THAILAND
| ||
Tantalum
|
D Block Metals, LLC
|
UNITED STATES OF AMERICA
| ||
Tantalum
|
Exotech Inc.
|
UNITED STATES OF AMERICA
| ||
Tantalum
|
Global Advanced Metals Boyertown
|
UNITED STATES OF AMERICA
| ||
Tantalum
|
H.C. Starck Inc.
|
UNITED STATES OF AMERICA
| ||
Tantalum
|
KEMET Blue Powder
|
UNITED STATES OF AMERICA
| ||
Tantalum
|
QuantumClean
|
UNITED STATES OF AMERICA
| ||
Tantalum
|
Telex Metals
|
UNITED STATES OF AMERICA
| ||
Tin
|
Metallo Belgium N.V.
|
BELGIUM
| ||
Tin
|
EM Vinto
|
BOLIVIA (PLURINATIONAL STATE OF)
| ||
Tin
|
Operaciones Metalurgical S.A.
|
BOLIVIA (PLURINATIONAL STATE OF)
| ||
13
Tin
|
Magnu’s Minerais Metais e Ligas Ltda.
|
BRAZIL
| ||
Tin
|
Melt Metais e Ligas S.A.
|
BRAZIL
| ||
Tin
|
Mineracao Taboca S.A.
|
BRAZIL
| ||
Tin
|
Resind Industria e Comercio Ltda.
|
BRAZIL
| ||
Tin
|
Soft Metais Ltda.
|
BRAZIL
| ||
Tin
|
White Solder Metalurgia e Mineracao Ltda.
|
BRAZIL
| ||
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
CHINA
| ||
Tin
|
Chifeng Dajingzi Tin Industry Co., Ltd.
|
CHINA
| ||
Tin
|
China Tin Group Co., Ltd.
|
CHINA
| ||
Tin
|
Gejiu Fengming Metallurgy Chemical Plant
|
CHINA
| ||
Tin
|
Gejiu Jinye Mineral Company
|
CHINA
| ||
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
CHINA
| ||
Tin
|
GejiuNon-Ferrous Metal Processing Co., Ltd.
|
CHINA
| ||
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
CHINA
| ||
Tin
|
Guangdong HanheNon-Ferrous Metal Co., Ltd.
|
CHINA
| ||
Tin
|
Guanyang Guida Nonferrous Metal Smelting Plant
|
CHINA
| ||
Tin
|
HuiChang Hill Tin Industry Co., Ltd.
|
CHINA
| ||
Tin
|
Huichang Jinshunda Tin Co., Ltd.
|
CHINA
| ||
Tin
|
Jiangxi New Nanshan Technology Ltd.
|
CHINA
| ||
Tin
|
Yunnan ChengfengNon-ferrous Metals Co., Ltd.
|
CHINA
| ||
Tin
|
Yunnan Tin Company Limited
|
CHINA
| ||
Tin
|
CV Ayi Jaya
|
INDONESIA
| ||
Tin
|
CV Dua Sekawan
|
INDONESIA
| ||
Tin
|
CV Gita Pesona
|
INDONESIA
| ||
Tin
|
CV Tiga Sekawan
|
INDONESIA
| ||
Tin
|
CV United Smelting
|
INDONESIA
| ||
Tin
|
CV Venus Inti Perkasa
|
INDONESIA
| ||
Tin
|
PT Aries Kencana Sejahtera
|
INDONESIA
| ||
Tin
|
PT Artha Cipta Langgeng
|
INDONESIA
| ||
Tin
|
PT ATD Makmur Mandiri Jaya
|
INDONESIA
| ||
Tin
|
PT Babel Inti Perkasa
|
INDONESIA
| ||
14
Tin
|
PT Bangka Prima Tin
|
INDONESIA
| ||
Tin
|
PT Bangka Serumpun
|
INDONESIA
| ||
Tin
|
PT Bangka Tin Industry
|
INDONESIA
| ||
Tin
|
PT Belitung Industri Sejahtera
|
INDONESIA
| ||
Tin
|
PT Bukit Timah
|
INDONESIA
| ||
Tin
|
PT DS Jaya Abadi
|
INDONESIA
| ||
Tin
|
PT Inti Stania Prima
|
INDONESIA
| ||
Tin
|
PT Karimun Mining
|
INDONESIA
| ||
Tin
|
PT Kijang Jaya Mandiri
|
INDONESIA
| ||
Tin
|
PT Lautan Harmonis Sejahtera
|
INDONESIA
| ||
Tin
|
PT Menara Cipta Mulia
|
INDONESIA
| ||
Tin
|
PT Mitra Stania Prima
|
INDONESIA
| ||
Tin
|
PT Panca Mega Persada
|
INDONESIA
| ||
Tin
|
PT Premium Tin Indonesia
|
INDONESIA
| ||
Tin
|
PT Prima Timah Utama
|
INDONESIA
| ||
Tin
|
PT Refined Bangka Tin
|
INDONESIA
| ||
Tin
|
PT Sariwiguna Binasentosa
|
INDONESIA
| ||
Tin
|
PT Stanindo Inti Perkasa
|
INDONESIA
| ||
Tin
|
PT Sukses Inti Makmur
|
INDONESIA
| ||
Tin
|
PT Sumber Jaya Indah
|
INDONESIA
| ||
Tin
|
PT Timah (Persero) Tbk Kundur
|
INDONESIA
| ||
Tin
|
PT Timah (Persero) Tbk Mentok
|
INDONESIA
| ||
Tin
|
PT Tinindo Inter Nusa
|
INDONESIA
| ||
Tin
|
PT Tommy Utama
|
INDONESIA
| ||
Tin
|
Dowa
|
JAPAN
| ||
Tin
|
Mitsubishi Materials Corporation
|
JAPAN
| ||
Tin
|
Malaysia Smelting Corporation (MSC)
|
MALAYSIA
| ||
Tin
|
Modeltech Sdn Bhd
|
MALAYSIA
| ||
Tin
|
Minsur
|
PERU
| ||
Tin
|
O.M. Manufacturing Philippines, Inc.
|
PHILIPPINES
| ||
Tin
|
Fenix Metals
|
POLAND
| ||
Tin
|
Metallo Spain S.L.U.
|
SPAIN
| ||
Tin
|
Rui Da Hung
|
TAIWAN, PROVINCE OF CHINA
| ||
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
THAILAND
| ||
15
Tin
|
Thaisarco
|
THAILAND
| ||
Tin
|
Alpha
|
UNITED STATES OF AMERICA
| ||
Tin
|
Metallic Resources, Inc.
|
UNITED STATES OF AMERICA
| ||
Tin
|
Tin Technology & Refining
|
UNITED STATES OF AMERICA
| ||
Tungsten
|
Wolfram Bergbau und Hutten AG
|
AUSTRIA
| ||
Tungsten
|
ACL Metais Eireli
|
BRAZIL
| ||
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
CHINA
| ||
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
CHINA
| ||
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
CHINA
| ||
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
CHINA
| ||
Tungsten
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
|
CHINA
| ||
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
South-East Nonferrous Metal Company Limited of Hengyang City
|
CHINA
| ||
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
CHINA
|
16
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
|
CHINA
| ||
Tungsten
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Ganzhou Haichuang Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
H.C. Starck Smelting GmbH & Co. KG
|
GERMANY
| ||
Tungsten
|
H.C. Starck Tungsten GmbH
|
GERMANY
| ||
Tungsten
|
A.L.M.T. TUNGSTEN Corp.
|
JAPAN
| ||
Tungsten
|
Japan New Metals Co., Ltd.
|
JAPAN
| ||
Tungsten
|
Woltech Korea Co., Ltd.
|
KOREA, REPUBLIC OF
| ||
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
PHILIPPINES
| ||
Tungsten
|
Hydrometallurg, JSC
|
RUSSIAN FEDERATION
| ||
Tungsten
|
Moliren Ltd.
|
RUSSIAN FEDERATION
| ||
Tungsten
|
Unecha Refractory metals plant
|
RUSSIAN FEDERATION
| ||
Tungsten
|
Global Tungsten & Powders Corp.
|
UNITED STATES OF AMERICA
| ||
Tungsten
|
Kennametal Fallon
|
UNITED STATES OF AMERICA
| ||
Tungsten
|
Kennametal Huntsville
|
UNITED STATES OF AMERICA
| ||
Tungsten
|
Niagara Refining LLC
|
UNITED STATES OF AMERICA
| ||
Tungsten
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
|
VIET NAM
| ||
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
VIET NAM
| ||
| 2. | List of the SORs identified in Canon’s supply chain which are Active in RMAP (As of March 15, 2019) |
Metal
|
SoRs
|
Country/Region
| ||
Gold
|
Bangalore Refinery
|
INDIA
| ||
Gold
|
Chugai Mining
|
JAPAN
| ||
Gold
|
NH Recytech Company
|
KOREA, REPUBLIC OF
| ||
Gold
|
KGHM Polska Miedz Spolka Akcyjna
|
POLAND
| ||
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
CHINA
| ||
Tungsten
|
Hunan Litian Tungsten Industry Co., Ltd
|
CHINA
| ||
17
| 3. | List of the SORs identified in Canon’s supply chain which are neither RMAP conformant nor Active in RMAP (As of March 15, 2019) |
Metal
|
SoRs
|
Country/Region
| ||
Gold
|
Morris and Watson Gold Coast
|
AUSTRALIA
| ||
Gold
|
Tony Goetz NV
|
BELGIUM
| ||
Gold
|
DayeNon-Ferrous Metals Mining Ltd.
|
CHINA
| ||
Gold
|
Great Wall Precious Metals Co., Ltd. of CBPM
|
CHINA
| ||
Gold
|
Guangdong Jinding Gold Limited
|
CHINA
| ||
Gold
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
|
CHINA
| ||
Gold
|
Hangzhou Fuchunjiang Smelting Co., Ltd.
|
CHINA
| ||
Gold
|
Hunan Chenzhou Mining Co., Ltd.
|
CHINA
| ||
Gold
|
Lingbao Gold Co., Ltd.
|
CHINA
| ||
Gold
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
|
CHINA
| ||
Gold
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
|
CHINA
| ||
Gold
|
Penglai Penggang Gold Industry Co., Ltd.
|
CHINA
| ||
Gold
|
Refinery of Seemine Gold Co., Ltd.
|
CHINA
| ||
Gold
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
|
CHINA
| ||
Gold
|
Tongling Nonferrous Metals Group Co., Ltd.
|
CHINA
| ||
Gold
|
Yunnan Copper Industry Co., Ltd.
|
CHINA
| ||
Gold
|
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
|
CHINA
| ||
Gold
|
SAFINA A.S.
|
CZECH REPUBLIC
| ||
Gold
|
Degussa Sonne / Mond Goldhandel GmbH
|
GERMANY
| ||
Gold
|
GCC Gujrat Gold Centre Pvt. Ltd.
|
INDIA
| ||
Gold
|
Sai Refinery
|
INDIA
| ||
Gold
|
Kazakhmys Smelting LLC
|
KAZAKHSTAN
| ||
Gold
|
TOOTau-Ken-Altyn
|
KAZAKHSTAN
| ||
Gold
|
HwaSeong CJ CO., LTD.
|
KOREA, REPUBLIC OF
| ||
Gold
|
Samwon Metals Corp.
|
KOREA, REPUBLIC OF
| ||
Gold
|
State Research Institute Center for Physical Sciences and Technology
|
LITHUANIA
| ||
18
Gold
|
Modeltech Sdn Bhd
|
MALAYSIA
| ||
Gold
|
Caridad
|
MEXICO
| ||
Gold
|
Schone Edelmetaal B.V.
|
NETHERLANDS
| ||
Gold
|
Morris and Watson
|
NEW ZEALAND
| ||
Gold
|
JSC EkaterinburgNon-Ferrous Metal Processing Plant
|
RUSSIAN FEDERATION
| ||
Gold
|
Kyshtym Copper-Electrolytic Plant ZAO
|
RUSSIAN FEDERATION
| ||
Gold
|
L’azurde Company For Jewelry
|
SAUDI ARABIA
| ||
Gold
|
Sudan Gold Refinery
|
SUDAN
| ||
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
|
TURKEY
| ||
Gold
|
African Gold Refinery
|
UGANDA
| ||
Gold
|
Kaloti Precious Metals
|
UNITED ARAB EMIRATES
| ||
Gold
|
Republic Metals Corporation
|
UNITED STATES OF AMERICA
| ||
Gold
|
Sabin Metal Corp.
|
UNITED STATES OF AMERICA
| ||
Gold
|
Abington Reldan Metals, LLC
|
UNITED STATES OF AMERICA
| ||
Gold
|
Pease & Curren
|
UNITED STATES OF AMERICA
| ||
Gold
|
Elemetal Refining, LLC
|
UNITED STATES OF AMERICA
| ||
Gold
|
QG Refining, LLC
|
UNITED STATES OF AMERICA
| ||
Gold
|
Navoi Mining and Metallurgical Combinat
|
UZBEKISTAN
| ||
Gold
|
Universal Precious Metals Refining Zambia
|
ZAMBIA
| ||
Gold
|
Fidelity Printers and Refiners Ltd.
|
ZIMBABWE
| ||
Tantalum
|
Yichun Jin Yang Rare Metal Co., Ltd.
|
CHINA
| ||
Tantalum
|
Duoluoshan
|
CHINA
| ||
Tin
|
Estanho de Rondonia S.A.
|
BRAZIL
| ||
Tin
|
Super Ligas
|
BRAZIL
| ||
Tin
|
Jiangxi Ketai Advanced Material Co., Ltd.
|
CHINA
| ||
Tin
|
CNMC (Guangxi) PGMA Co., Ltd.
|
CHINA
| ||
Tin
|
PT Eunindo Usaha Mandiri
|
INDONESIA
| ||
Tin
|
Pongpipat Company Limited
|
MYANMAR
| ||
Tin
|
An Vinh Joint Stock Mineral Processing Company
|
VIET NAM
| ||
Tin
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
|
VIET NAM
| ||
Tin
|
Nghe TinhNon-Ferrous Metals Joint Stock Company
|
VIET NAM
| ||
19
Tin
|
Tuyen QuangNon-Ferrous Metals Joint Stock Company
|
VIET NAM
| ||
Tungsten
|
Ganzhou Yatai Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangxi Minmetals Gao’anNon-ferrous Metals Co., Ltd.
|
CHINA
| ||
Tungsten
|
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
|
CHINA
| ||
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
VIET NAM
| ||
Tungsten
|
Vietnam Youngsun Tungsten Industry Co., Ltd.
|
VIET NAM
| ||
20
| 4. | Examples of the countries and regions of origin from which the SORs listed in Appendix1-1,1-2 and1-3 are believed to have sourced 3TG |
Albania | Guinea | |
Andorra | Guyana | |
Angola | Hungary | |
Argentina | India | |
Armenia | Indonesia | |
Australia | Ireland | |
Austria | Israel | |
Azerbaijan | Italy | |
Belarus | Japan | |
Belgium | Jersey (Bailiwick of Jersey) | |
Bermuda | Kazakhstan | |
Bolivia | Kenya | |
Brazil | Korea, Republic of | |
Bulgaria | Kyrgyz Republic | |
Burkina Faso | Laos | |
Burundi | Liberia | |
Cambodia | Luxembourg | |
Canada | Madagascar | |
Central African Republic | Malaysia | |
Chile | Mali | |
China | Mauritania | |
Colombia | Mexico | |
Cote d’Ivoire | Mongolia | |
Czech Republic | Morocco | |
Democratic Republic of the Congo | Mozambique | |
Djibouti | Myanmar | |
Dominican Republic | Namibia | |
Ecuador | Netherlands | |
Egypt | New Zealand | |
Estonia | Niger | |
Ethiopia | Nigeria | |
France | Panama | |
Germany | Papua New Guinea | |
Ghana | Peru | |
21
Philippines | Switzerland | |
Poland | Taiwan | |
Portugal | Tajikistan | |
Republic of the Congo | Tanzania | |
Russian Federation | Thailand | |
Rwanda | Turkey | |
Saudi Arabia | Uganda | |
Sierra Leone | United Arab Emirates | |
Singapore | United Kingdom | |
Slovakia | United States of America | |
South Africa | Uzbekistan | |
Spain | Viet Nam | |
Suriname | Zambia | |
Sweden | Zimbabwe | |
22
Appendix 2.
INDEPENDENT ASSURANCE REPORT
To the Board of Directors and Stockholders of Canon Inc.
We have undertaken a reasonable assurance engagement of:
| ● | management’s assertion, included in section 4 of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, that the design of Canon Inc.’s (the “Company”) due diligence framework is in conformity with the criteria set forth in the Organisation of EconomicCo-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition 2016 (“OECD Due Diligence Guidance”), and |
| ● | whether the Company’s description of the due diligence measures it performed, as set forth in section 4 of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is consistent, in all material respects, with the due diligence process that the Company undertook. |
Management is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on the procedures we have performed.
Our reasonable assurance engagement was conducted in accordance with ‘International Standard on Assurance Engagements (ISAE) 3000, Assurance Engagements other than Audits or Reviews of Historical Financial Information’, issued by the International Auditing and Assurance Standards Board, and the standards applicable to performance audits contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Our reasonable assurance engagement was not conducted for the purpose of evaluating:
| ● | The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance; |
| ● | The completeness of the Company’s description of the due diligence measures performed; |
| ● | The suitability of the design or operating effectiveness of the Company’s due diligence process; |
| ● | Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance; |
| ● | The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or |
| ● | The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products. |
Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than section 4.
In our opinion,
| ● | the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2018, as set forth in section 4 of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and |
| ● | the Company’s description of the due diligence measures it performed as set forth in section 4 of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is consistent, in all material respects, with the due diligence process that the Company undertook. |
23
We have complied with the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants, which includes independence and other requirements founded on fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behavior. In accordance with International Standard on Quality Control 1, we maintain a comprehensive system of quality control including documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.
/s/ KPMG AZSA Sustainability Co., Ltd.
KPMG AZSA Sustainability Co., Ltd., Tokyo
May 30, 2019
24
