Home > Sustainability > Our Code of Conduct > Responsible Minerals Procurement Policy
TOHO ZINC group recognizes the risks that are stipulated in the AnnexⅡ of OECE Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (1. Direct or indirect support to non-state armed groups, 2. Serious abuses associated with the extraction, transport or trade of minerals, 3. Illegal conduct by public or private security forces, 4. Bribery and fraudulent misrepresentation of the origin of minerals, 5. Negligence in payment of taxes, fees and royalties due to governments), and shall not procure minerals with possible links to infringement of these risks in accordance with the Management Philosophy and the TOHO ZINC Group Code of Conduct (hereinafter trade concerning such minerals is defined as “High-Risk Trade”), and it shall not use those minerals as raw material.
In order to comply with this policy, TOHO ZINC shall carry out checks on companies supplying ore containing lead, zinc, and silver to TOHO ZINC group in accordance with the guidance set forth by LME (London Metal Exchange) (LME Policy on Responsible Sourcing of LME-Listed Brands) for lead and zinc, LBMA (London Bullion Market Association) (“LBMA Responsible Silver Guidance”) for silver.
Such checks involve identification and evaluation of the risks pertaining to illegal conduct, and confirmation that the procured ore is appropriate under TOHO ZINC group’s “Responsible Minerals Procurement Policy.”
Furthermore, TOHO ZINC group shall ensure objectivity concerning the management structure and implementation of its responsible minerals procurement by receiving periodic audits by an independent third party organization.
1. General Provisions
TOHO ZINC group shall refrain from direct or indirect involvement in or support of illegal conduct such as infringement of human rights, money laundering, supply of funds to terrorists, corruption, or aiding conflicts conducted organizationally and extensively in conflict-affected and high risk areas.
Furthermore, when procuring ore containing lead, zinc, and silver, TOHO ZINC group shall identify and evaluate the risks pertaining to such illegal conduct, and if deemed to be High-Risk Trade, mitigate the risks, or such trade shall immediately be suspended in case the risk mitigation can not be done.
TOHO ZINC group shall receive periodic audits of the management structure and implementation of its responsible minerals procurement by an independent third party organization.
2. Management structure and locus of responsibility
- The division/department in charge of procurement and management of mineral ore at TOHO ZINC group shall be Zinc and Lead Business Division and Mineral Resources Business Department of TOHO ZINC.
- A Compliance Officer shall be appointed in the division/department in charge of procurement and management of ore containing lead, zinc, and silver. Ore containing lead, zinc, and silver shall be supplied to refinery under the management structure for responsible minerals procurement.
3. Operation of the management system
(1) Risk evaluation of mineral supply chain
The supply chain for the ore containing lead, zinc, and silver is evaluated for the risks pertaining to illegal conduct. If risks are found in the evaluation, efforts shall be made to mitigate the risks, and if the trade is deemed to be High-Risk Trade, that trade shall immediately be suspended.
(2) Monitoring of trades
- Ore containing lead, zinc, and silver that is supplied to refinery shall be spot checked and weighed at the refinery. Integrity between the trade information obtained by Zinc and Lead Business Division and Mineral Resources Business Department, the division/department in charge of procurement and management of ore containing lead, zinc, and silver, shall also be checked.
After trades have been confirmed, the information of the procured ore containing lead, zinc, and silver shall be registered and managed in the TOHO ZINC’s management system. - In order to check whether the evaluations of the risks pertaining to illegal conduct are being properly implemented in the supply chain for ore containing lead, zinc, and silver, periodic management reviews shall be implemented.
(3) Education
TOHO ZINC group shall continuously carry out the necessary education and training to execute the Responsible Minerals Procurement Policy in the division/department in charge of procurement and management of ore containing zinc, lead and silver, the refinery, and the related divisions/departments.
(4) Management of records
TOHO ZINC group shall establish and maintain the records deemed necessary for the retention of information related to the implementation of the Responsible Minerals Procurement Policy and specify the retention period.
Established: April 20, 2020
Revised: Month day, March 25, 2022
LBMA Compliance Report & Assurance Report 2022 (1.4MB) 
Annual Report on Supply Chain Due Diligence for Zinc and Lead Minerals 2023 (69.7KB)
