Exhibit 1.01
Canon Inc.
Conflict Minerals Report
For the Period from January 1, 2021 to December 31, 2021
This Conflict Minerals Report for the period from January 1, 2021 to December 31, 2021, is presented as an exhibit to the Specialized Disclosure Report on Form SD, to comply with Rule 13p-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 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 Form 20-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 Rule 13p-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, 2021 to December 31, 2021 (“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, 2021, Canon Inc. had 329 consolidated subsidiaries, of which 55 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, 56 companies of the Canon Group, including Canon Inc. and those 55 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 Printing Business Unit, the Imaging Business Unit, the Medical Business Unit and the Industrial and Others Business Unit.
The Printing Business Unit includes office MFDs, laser printers, and inkjet printers for personal and office use as well as production print products for print professionals. The Imaging Business Unit includes digital cameras as well as lenses and various related accessories. It also includes compact photo printers, network cameras, digital cinema cameras, and broadcast HDTV lenses. The Medical Business Unit includes Computed tomography (CT), Magnetic resonance imaging (MRI), ultrasound, X-ray systems, and clinical laboratory systems, as well as digital radiography (DR) systems and ophthalmic equipment. The Industrial and Others Business Unit includes semiconductor lithography equipment, flat panel display (FPD) lithography equipment, organic light-emitting diode (OLED) panel manufacturing equipment.
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. Many of the first-tier suppliers also have to rely on information from their upstream suppliers.
| 3. | Basic principles regarding response to conflict minerals |
Canon Inc. established the “Basic Approach of the Canon Group Regarding Conflict Minerals” in September 2012. Canon Inc. expanded the scope of covered minerals and risks in 2020 and updated the policy as the “Canon Group Basic Policy on Responsible Minerals Sourcing”. 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 Responsible Minerals Sourcing (“Working Group”). |
| - | As stated above, Canon Inc. established the “Canon Group Basic Policy on Responsible Minerals Sourcing”. |
| - | Canon established the “Guidelines for Responsible Minerals Sourcing” that clarified the responsible divisions and the framework for handling responsible minerals sourcing issues as well as the survey process, for the persons involved in the Canon Group. |
| - | In July 2021, Canon Inc. summoned the persons in charge of responsible minerals sourcing for Canon Group’s domestic subsidiaries that manufacture or contract to manufacture products and held a meeting to share the results of the 2020 minerals survey and discuss Canon’s policies for the survey of 2021. Moreover, for the persons in charge of responsible minerals sourcing matters for overseas subsidiaries, Canon Inc. shared information by e-mail and web conference. |
| - | Canon created and distributed the Responsible Minerals Sourcing 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 “Canon Group Basic Policy on Responsible Minerals Sourcing” and their agreement to take an action for appropriate measures should any significant risks associated with mineral sourcing be found in the supply chain. |
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| - | Using its 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. |
| - | 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 provided the documents and videos related to the responsible minerals sourcing for suppliers in supply chains in the electrical and electronics industry. Step 3 below provides details of the industry initiatives on responsible minerals sourcing that Canon Inc. participates in. |
| - | As an early-warning risk-awareness system specified in the OECD Guidance, Canon Inc. established a grievance mechanism — “Contact Point for Reporting Concerns Regarding Conflict Mineral Issues” (renamed in 2020 “Procedure for the Submission of Concerns Regarding Minerals Risk”) — on its official website in 2015. No reports from employees, suppliers, or other stakeholders were received by the contact point in 2021. |
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 2021. (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 Revision 6.1 (“CMRT”). The CMRT is published by the Responsible Minerals Initiative (“RMI”), one of the programs of the Responsible Business Alliance (“RBA”). Canon requested the 3,202 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. |
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| - | 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. Suppliers who reported 3TG smelters were requested to fill in Canon’s own “Smelter Risk Check Form” and if they reported any smelters that did not meet the conformant or active smelters in the RMI’s audit program, they were also asked to submit the estimated schedule to mitigate the risks on such non-conformant or non-active smelters. |
| - | Canon requested replies from the first-tier suppliers who did not respond by the closing date of the response. |
| - | 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 April 28, 2022, Canon had received responses from 92 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). |
| - | As a new initiative during the reporting period, Canon sent a letter in September 2021 to request the first-tier suppliers not to use the SORs designated by Canon’s customers as high-risk SORs and non-conformant SORs under the RMAP in order to strengthen risk management. Further, Canon analyzed the responses of the “Smelter Risk Check Form” from the first-tier suppliers. Among the first-tier suppliers who had not been taking action to address risks, Canon approached those that Canon considered might carry particular risk and requested them to take measures to mitigate risks. |
| c. | Step 3: Design and implement a strategy to respond to identified risks |
| - | The head of the Working Group reported the progress of responsible minerals sourcing activities to the representative director in charge. |
| - | Moreover, the Working Group reported in November 2021 on its progress to relevant directors and executive officers of Canon Inc. as well as the presidents of the relevant domestic and overseas subsidiaries by distributing the explanatory material. |
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| - | Canon Inc. is a key member of JEITA’s RMTWG. The RMTWG is allied with the RMI, which plays the leading role in the response to responsible minerals sourcing. Canon Inc. has held the role of co-chair of the RMTWG since 2013. Canon Inc. has also served as team leader of the RMTWG’s Smelter Support Team since 2015. |
| - | 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. |
| - | 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. |
| 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, 2022, 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. |
| - | Since 2011, Canon Inc. has been reporting its activities in response to responsible minerals sourcing in its annually published Sustainability Report. |
| 5. | Survey results for the 2021 calendar year |
Result of RCOI and due diligence
| - | Canon conducted the RCOI on 3,202 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. |
| - | 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 website of the RMI provides information of the auditing status under the RMAP. |
http://www.responsiblemineralsinitiative.org/
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| - | As of January 13, 2022, 239 SORs in Canon supply chain were identified as RMAP conformant and 20 SORs were identified as Active in the RMAP through our review. The remaining 78 SORs were neither RMAP conformant nor Active in the RMAP. Appendices 1-1, 1-2 and 1-3 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. |
| - | Appendix 1-4 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 2022 onwards.
| - | Canon will continue promoting verification operations of high-risk first-tier suppliers in accordance with Canon’s Guidelines for Responsible Minerals Sourcing. |
| - | Canon Inc. will continue its participation at JEITA’s RMTWG, CFSWG and RMI, and support activities to reduce risks in entire supply chains. |
The EU Conflict Minerals Regulation (Regulation (EU) 2017/821) came into operation in January 2021. The EU Conflict Minerals Regulation does not limit due diligence to covered countries in Africa. In response, the CMRT, the industry standard reporting template for conflict minerals, was revised in May 2020 as Revision 6.01 and new Question 4: “Do any of the smelters in your supply chain source the 3TG from conflict-affected and high-risk areas?” was added to the template. Although Canon is not subject to the EU Conflict Minerals Regulation, Canon has conducted due diligence not only in the covered countries stipulated in the Dodd-Frank Act but also in the “conflict-affected and high-risk areas” stipulated in the OECD Guidance by using the CMRT as revised since the 2020 survey.
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| 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. |
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 SORs that are believed to be in Canon’s supply chain who were RMAP conformant as of January 13, 2022. (The notation of SOR names and locations is in accordance with the information provided by RMI.) |
Metal
| SORs
| Country/Regions
| ||
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
|
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 Gold Smelting Co., Ltd.
|
CHINA
| ||
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
CHINA
| ||
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
CHINA
| ||
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
CHINA
| ||
Gold
|
SAFINA A.S.
|
CZECHIA
| ||
Gold
|
SAAMP
|
FRANCE
| ||
Gold
|
Allgemeine Gold-und Silberscheideanstalt A.G.
|
GERMANY
| ||
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 Germany GmbH Co. KG
|
GERMANY
| ||
Gold
|
SAXONIA Edelmetalle GmbH
|
GERMANY
| ||
Gold
|
WIELAND Edelmetalle GmbH
|
GERMANY
| ||
Gold
|
Bangalore Refinery
|
INDIA
| ||
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
INDIA
| ||
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Gold
| PT Aneka Tambang (Persero) Tbk
| INDONESIA
| ||
| Gold | 8853 S.p.A. | ITALY | ||
| 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 | Chugai Mining | JAPAN | ||
| Gold | Dowa | JAPAN | ||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||
| Gold | Eco-System Recycling Co., Ltd. West Plant | 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 | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | Torecom | KOREA, REPUBLIC OF | ||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||
| Gold | REMONDIS PMR B.V. | NETHERLANDS | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
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| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
| Gold | Metal Concentrators SA (Pty) Ltd. | 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 | ||
| 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 Refinery DMCC | 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 | ||
| Gold | Navoi Mining and Metallurgical Combinat | 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 | ||
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| 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 | ||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | ||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
| Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | CHINA | ||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tantalum | NPM Silmet AS | ESTONIA | ||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||
| Tantalum | TANIOBIS GmbH | GERMANY | ||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
| Tantalum | Global Advanced Metals Aizu | JAPAN | ||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | ||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
| Tantalum | KEMET de Mexico | MEXICO | ||
| Tantalum | Meta Materials | NORTH MACEDONIA, REPUBLIC OF | ||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||
| Tantalum | TANIOBIS 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 | 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 Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | ||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||
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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 Kai Meng Industry and Trade LLC | CHINA | ||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||
Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | ||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||
Tin | PT Artha Cipta Langgeng | INDONESIA | ||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
Tin | PT Babel Surya Alam Lestari | INDONESIA | ||
Tin | PT Bangka Serumpun | INDONESIA | ||
Tin | PT Menara Cipta Mulia | INDONESIA | ||
Tin | PT Mitra Stania Prima | INDONESIA | ||
Tin | PT Prima Timah Utama | INDONESIA | ||
Tin | PT Rajawali Rimba Perkasa | INDONESIA | ||
Tin | PT Rajehan Ariq | INDONESIA | ||
Tin | PT Refined Bangka Tin | INDONESIA | ||
Tin | PT Stanindo Inti Perkasa | INDONESIA | ||
Tin | PT Timah Tbk Kundur | INDONESIA | ||
Tin | PT Timah Tbk Mentok | INDONESIA | ||
Tin | PT Tinindo Inter Nusa | INDONESIA | ||
Tin | Dowa | JAPAN | ||
Tin | Mitsubishi Materials Corporation | JAPAN | ||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||
Tin | Minsur | PERU | ||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
Tin | Fenix Metals | POLAND | ||
Tin | Luna Smelter, Ltd. | RWANDA | ||
Tin | Metallo Spain S.L.U. | SPAIN | ||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
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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 | ||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||
Tungsten | ACL Metais Eireli | BRAZIL | ||
Tungsten | Cronimet Brasil Ltda | BRAZIL | ||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | ||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||
Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Haichuang 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 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 Tonggu Non-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 | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||
Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||
Tungsten | A.L.M.T. Corp. | JAPAN | ||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||
Tungsten | JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION | ||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
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Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
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 | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||
Tungsten | Masan High-Tech Materials | VIET NAM | ||
| 2. | List of SORs that are believed to be in Canon’s supply chain who were RMAP Active as of January 13, 2022. (The notation of SOR names and locations is in accordance with the information provided by RMI.) |
| Metal | SORs | Country/Region | ||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | ||
| Gold | WEEEREFINING | FRANCE | ||
| Gold | Augmont Enterprises Private Limited | INDIA | ||
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||
| Gold | Alexy Metals | UNITED STATES OF AMERICA | ||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | ||
| Tin | Estanho de Rondonia S.A. | BRAZIL | ||
| Tin | Super Ligas | BRAZIL | ||
| Tin | Yunnan Tin Company Limited | CHINA | ||
| Tin | CV Venus Inti Perkasa | INDONESIA | ||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | ||
| Tin | PT Timah Nusantara | INDONESIA | ||
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | ||
| Tin | CRM Synergies | SPAIN | ||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||
| Tungsten | GEM Co., Ltd. | CHINA | ||
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | ||
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | ||
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| 3. | List of SORs that are believed to be in Canon’s supply chain who were neither RMAP conformant nor RMAP Active as of January 13, 2022. (The notation of SOR names and locations is in accordance with the information provided by RMI.) |
Metal
|
SORs
|
Country/Region
| ||
| Gold | Industrial Refining Company | BELGIUM | ||
| Gold | Value Trading | BELGIUM | ||
| Gold | Daye Non-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 | Hunan Guiyang yinxing Nonferrous Smelting 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 Humon Smelting Co., Ltd. | CHINA | ||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | ||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||
| Gold | Gold Coast Refinery | GHANA | ||
| Gold | CGR Metalloys Pvt Ltd. | INDIA | ||
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | ||
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | ||
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | ||
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | ||
| Gold | JALAN & Company | INDIA | ||
| Gold | Kundan Care Products Ltd. | INDIA | ||
| Gold | MD Overseas | INDIA | ||
| Gold | Sai Refinery | INDIA | ||
| Gold | Shirpur Gold Refinery Ltd. | INDIA | ||
| Gold | Sovereign Metals | INDIA | ||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||
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| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||
| Gold | TSK Pretech | KOREA, REPUBLIC OF | ||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||
| Gold | Modeltech Sdn Bhd | MALAYSIA | ||
| Gold | Sellem Industries Ltd. | MAURITANIA | ||
| Gold | Caridad | MEXICO | ||
| Gold | Morris and Watson | NEW ZEALAND | ||
| Gold | K.A. Rasmussen | NORWAY | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | ||
| Gold | AU Traders and Refiners | SOUTH AFRICA | ||
| Gold | Sudan Gold Refinery | SUDAN | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
| Gold | African Gold Refinery* | UGANDA | ||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | ||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | ||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||
| Tin | Precious Minerals and Smelting Limited | INDIA | ||
| Tin | CV Ayi Jaya | INDONESIA | ||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | ||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | ||
| Tin | Modeltech Sdn Bhd | MALAYSIA | ||
| 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 Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
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| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | ||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | ||
| Tungsten | Artek LLC | RUSSIAN FEDERATION | ||
| * | On March 17, 2022, the U.S. Department of the Treasury added this gold refinery in Uganda to the OFAC’s Specially Designated Nationals (SDN) List. The Canon Group has no direct business with the refinery. Through our due diligence examination, we identified our first-tier suppliers who reported utilizing the Ugandan refinery in their supply chain. We will continue to confirm if the refinery actually exists on our supply chain and eliminate it once it is found. |
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| 4. | Examples of the countries and regions of origin from which the SORs listed in Appendix 1-1, 1-2 and 1-3 are believed to have sourced 3TG |
| Andorra | France | |
| Argentina | Gambia | |
| Armenia | Georgia | |
| Australia | Germany | |
| Austria | Ghana | |
| Azerbaijan | Greece | |
| Bahamas | Guatemala | |
| Belgium | Guinea | |
| Bolivia | Guyana | |
| Botswana | Honduras | |
| Brazil | Hungary | |
| Bulgaria | Iceland | |
| Burkina Faso | India | |
| Burundi | Indonesia | |
| Cameroon | Ireland | |
| Canada | Israel | |
| Chile | Italy | |
| China | Japan | |
| Colombia | Jordan | |
| Cote d’Ivoire | Kazakhstan | |
| Croatia | Kenya | |
| Cyprus | Korea, Republic of | |
| Czech Republic | Laos | |
| Democratic Republic of the Congo | Latvia | |
| Dominican Republic | Lebanon | |
| Ecuador | Liberia | |
| Egypt | Libya | |
| El Salvador | Liechtenstein | |
| Estonia | Lithuania | |
| Ethiopia | Luanda | |
| Fiji | Luxembourg | |
| Finland | Madagascar | |
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| Malaysia | Senegal | |
| Mali | Serbia | |
| Malta | Sierra Leone | |
| Mauritania | Singapore | |
| Mauritius | Slovakia | |
| Mexico | Slovenia | |
| Mongolia | Solomon Islands | |
| Morocco | South Africa | |
| Mozambique | Spain | |
| Myanmar | Sudan | |
| Namibia | Suriname | |
| Netherlands | Sweden | |
| New Caledonia | Switzerland | |
| New Zealand | Taiwan | |
| Nicaragua | Tajikistan | |
| Niger | Tanzania | |
| Nigeria | Thailand | |
| Norway | Togo | |
| Pakistan | Trinidad and Tobago | |
| Panama | Tunisia | |
| Papua New Guinea | Turkey | |
| Peru | Uganda | |
| Philippines | United Arab Emirates | |
| Poland | United Kingdom | |
| Portugal | United States of America | |
| Puerto Rico | Uruguay | |
| Russian Federation | Uzbekistan | |
| Rwanda | Viet Nam | |
| San Marino | Zambia | |
| Saudi Arabia | ||
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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, 2021, that the design of Canon Inc.’s (the “Company”) due diligence framework is in conformity with the criteria set forth in the Organisation of Economic Co-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, 2021, 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, 2021, 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, 2021, is consistent, in all material respects, with the due diligence process that the Company undertook. |
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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/ Kazuhiko Saito
Kazuhiko Saito, Partner, Representative Director
KPMG AZSA Sustainability Co., Ltd.
Tokyo, Japan
May 27, 2022
Notes to the Reader of Independent Assurance Report:
This is a copy of the Independent Assurance Report and the original copies are kept separately by the Company and KPMG AZSA Sustainability Co., Ltd.
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