Human Rights & Supply Chain Management

Basic Approach on Respect for Human Rights

Mitsubishi Corporation RtM Japan believes that respect for human rights is fundamental to conducting of businesses.
Our Code of Conduct stipulates : respect for human rights ; prohibition of discrimination ; prohibition of harassment; learning the culture, customs, and history of each country and region, and having a proper understanding and recognition of human rights issues; not supporting forced labor, child labor, or other inhumane treatment at our business partners or in our supply chain; and striking a balance between work and life. Mitsubishi Corporation RtM Supply Chain CSR Guidelines also sets forth: prohibition of forced labor, prohibition of child labor, prohibition of discrimination, and prohibition of inhumane treatment.
Moreover, after reorganizing and clarifying our approach on respect for human rights and to promote efforts to do so, we formulated the following Human Rights Policy in November 2024, which has been approved by the Board of Directors.

Human Rights Policy

Our commitment to respect human rights
We believe that respect for human rights is fundamental to our business across the world. In an increasingly complex business environment, we face various human rights challenges. We believe that respecting and promoting human rights are directly linked to the sustainability of our business activities. Since our founding, we, as a subsidiary 100% owned by Mitsubishi Corporation, have been promoting fair and sound business activities based on our corporate philosophy, the Three Corporate Principles. The Three Corporate Principles guide us in striving to enrich society, both materially and spiritually, while contributing towards the preservation of the global environment. We believe respect for human rights relates deeply rooted in our philosophy. Based on these beliefs, we have established this Human Rights Policy (hereafter “this Policy”), which represents our commitment to respect human rights throughout our business activities.
Scope of application
This Policy applies to all persons working for Mitsubishi Corporation RtM Japan Ltd.
Outreach to business partners
We recognize the importance of respecting human rights not only within our own business activities but also throughout our value chain. We will work together with our business partners, including our suppliers, to respect human rights in line with this Policy.
Support and respect for international norms
We support international norms on human rights, including the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights), the Declaration on the Fundamental Principles and Rights at Work of the International Labour Organization (ILO), the United Nations Guiding Principles on Business and Human Rights.
We comply with the local laws and regulations of the countries and regions in which we operate. In cases where there is a conflict between internationally recognized human rights principles and the laws and regulations of the country or region in which we operate, we will seek ways to honor the international principles.
Human Rights Due Diligence
We conduct human rights due diligence to identify, prevent and mitigate adverse impacts on human rights and engage with affected stakeholders where relevant. We pay special attention to vulnerable or marginalized individuals and strive to identify actual or potential adverse human rights impacts that our business activities have caused or contributed to.
Human rights issues related to business activities
We recognize the following as major human rights issues related to our business activities and will work to address them.
1. Prohibition of discrimination
  We prohibit any discrimination based on race, ethnicity, creed, religion, gender, gender identity, sexual orientation, nationality, age, origin, mental or physical disability, illness, or any other grounds.
2. Prohibition of inhumane treatment
  We do not tolerate any forms of inhumane treatment including mental or physical abuse and harassment.
3. Providing a safe and healthy working environment
  We provide our employees with a safe, and healthy working environment.
4. Respect for freedom of association and right to collective bargaining
  We respect the right of employees to organize and to bargain collectively as a means to facilitate dialogue among employees and management regarding, but not limited to, working conditions and wage levels.
5. Securing appropriate working hours and wages
  We properly manage our employees’ working hours. We compensate our employees at least the statutory minimum wage, and endeavor to pay at least the living wage.
6. Prohibition of all forms of forced labor
  We employ all of our employees at their free will and prohibit the use of forced labor.
7. Prohibition of all forms of child labor
  We do not employ children under the minimum working age and prohibit any forms of work that impairs their physical and mental development.
8. Rights of indigenous peoples and local communities
  We respect the rights of indigenous and local people as defined by the laws and international arrangements of the countries and regions in which we operate. We will take measures that our business operation will not cause or contribute to cause threat to the rights of indigenous and local people.
9. Environment
  Acknowledging the adverse impact of environmental destruction on human rights, we take measures to protect the global environment within our business activities. This includes addressing climate change and preserving and restoring natural capital, notably biodiversity.
10. Diversity, Equity & Inclusion
  We aim to foster an inclusive society where individuals with diverse values and personalities are respected and have equal opportunities to participate and contribute.
Remedy
When we identify that our business activities have caused or contributed to adverse human rights impacts, we will remediate such impacts through legitimate processes.
In case if adverse impacts were directly linked to our operations, products, or services by a business relationship, we will endeavor to correct and remedy the situation by using our leverage.
Grievance mechanism
We recognize that establishing a grievance mechanism, which consists of a series of processes to address internal and external stakeholder grievances, is crucial to identifying adverse human rights impacts concerning our operations and value chain. We will establish and operate grievance mechanisms to enable individuals and groups to show concerns about adverse human rights impacts caused by our business activities and seek remedies.
Education and capacity building
We will provide the necessary training and capacity building to ensure that our officers, employees, suppliers, and other business partners understand the importance of respecting human rights and put it into practice.
Information disclosure
We ensure transparency by regularly and appropriately disclosing information on our human rights efforts and their progress.
Stakeholder engagement
We engage with relevant stakeholders through sincere and constructive dialogue to understand, improve and address human rights issues.
Governance and management system
Our human rights efforts are overseen by the Officer Responsible for Sustainability and CSR. Following deliberations by the Management Committee, these efforts and practices are put forward or reported to the Board of Directors.

Established on November 8, 2024

Human Rights Due Diligence

We are a general trading company operating as a 100% subsidiary of Mitsubishi Corporation, and our main business is trading in various types of metal resources. Our activities related to human rights due diligence are positioned as part of the human rights and environmental due diligence for trading operations of the Mitsubishi Corporation Group.

We also recognize respect for human rights through supply chain management as one of our key issues for sustainability (materiality).

Procurement activities that take human rights into account are an essential step for realizing responsible corporate conduct by our company, and we present our stance toward achieving that in our Sustainable Procurement Policy.

We present specific requirements to our suppliers, including respect for human rights, in our Sustainable Procurement Guidelines, confirm the compliance situation through our Sustainable Procurement Survey, and conduct on-site investigations of business partners as necessary.

Grievance Mechanism

Sustainable Procurement Policy

We have established our Sustainable Procurement Policy as our company’s approach to realizing sustainable procurement and supply, respect for human rights throughout the supply chain, environmental conservation, and other objectives. In accordance with this policy, we will work to realize sustainable procurement that considers human rights, environmental aspects, and other factors in the supply chain.
As a trading company positioned in the middle of the supply chain, we believe our mission is to procure products that take into account human rights and the environment, and to accurately convey information about products. We also work together with everyone in the supply chain on the management of chemical substances contained in products, from the perspectives of environmental impact reduction, quality, legal and regulatory compliance, and other factors.

In our procurement activities, we comply with the following principles:

Legal and regulatory compliance and respect for international norms
We comply with laws and regulations of each country and region, and conduct activities that respect international conduct norms.
Human rights and labor
We comply with relevant laws and regulations, consult international human rights standards and our company’s human rights policy, and not only strive to respect the human rights of our own workers but also encourage similar efforts from our business partners.
Safety and health
We comply with relevant laws and regulations, consult related international standards, and aim to minimize work-related injuries and physical and mental illnesses of workers in our company and throughout the supply chain, and strive to establish safe, hygienic, and healthy work environments.
Environment
We place the highest priority on ensuring the health and safety of people in related regions, and engage in green procurement to minimize adverse effects on local communities, ecosystems, the environment, and natural resources.
Fair trade and ethics
Throughout the entire supply chain, we comply with relevant domestic and international laws and regulations, and conduct procurement activities based on high ethical standards.
Responsible mineral procurement
To prevent complicity in and support of risks related to human rights, the environment, and other objectives via mineral procurement in conflict-affected and high-risk areas, we comply with relevant laws and regulations and work toward responsible mineral procurement throughout the supply chain in accordance with international standards (*), etc.
* OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, etc.
Quality and safety
We aim to ensure the safety and quality of products and services throughout the supply chain and we provide accurate information.
Information security
We prevent leakage of confidential information and personal information, as well as unauthorized acquisition and use of information throughout the supply chain, and work to strengthen information security.
Business continuity planning
We aim to establish appropriate plans and systems in advance throughout the supply chain to ensure we can fulfill our supply responsibilities when large-scale natural disasters, terrorism, riots, infectious diseases, accidents, and other incidents occur.
To comply with each of the above matters, we take action on the following matters throughout the supply chain:
Development of management systems
We develop management systems and work to identify, prevent, and mitigate negative impacts on human rights and the environment in the supply chain.
Supplier management
We communicate requirements for items 1–9 above to suppliers, confirm the compliance situation, and encourage improvement through engagement.
Access to remedies
We establish and operate consultation desks available to internal and external stakeholders, including suppliers.
Corrective action
If our business, products, or services are directly involved in negative impacts on human rights due to business relationships, we work toward corrective action through the exercise of influence.
Reporting
We will communicate with stakeholders regarding our efforts and progress on this policy.

Established on April 1, 2025

Toward Responsible Mineral Procurement

Our company works to prevent complicity in and support of risks related to human rights and the environment via procurement of minerals such as 3TG (tantalum, tungsten, tin, gold) and others that are produced in the Democratic Republic of the Congo (DRC) and its surrounding countries, and conflict-affected and high-risk areas (CAHRAs) for which risks related to human rights and the environment are of concern.
We comply with relevant laws and regulations and, in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, we will identify and assess risks within the supply chain, take measures against identified risks, and report the results of our efforts.

Based on the content of our company’s Sustainable Procurement Policy, we present specific requirements to our suppliers in our Sustainable Procurement Guidelines. We ask that you do self-assessment of the implementation status of specific requirements through responses to our Sustainable Procurement Survey.
We would also appreciate your cooperation with conflict mineral surveys using formats provided by RMI, confirmation of the acquisition status of industry certifications by suppliers of target commodities, and other necessary steps.

Requirements for Suppliers

Based on the above Sustainable Procurement Policy, we have established specific requirements for our business partners as Requirements for Suppliers.
Also,in order to help us monitor your engagement with the stated requirements, we kindly request your cooperation in completing a self-assessment by responding to our Sustainable Procurement Survey. Depending on the response results, we may conduct detailed confirmation of the response content, make requests and provide support for improvement of your efforts, and take other measures.
Through confirmation and response to the Requirements for Suppliers, and Sustainable Procurement Survey, we expect your agreement, understanding, and implementation of the items specified in our Sustainable Procurement Policy.

* If necessary, please also respond by submitting a Certificate of Non-Use of Chemical Substances in Products, providing additional documentation regarding chemical substances in products, accepting Environmental Quality Assurance System Audits of business partners to whom our company delivers products, and taking other relevant action.

Legal compliance and respect for international norms
We comply with laws and regulations of each country and region, conduct activities that respect international conduct norms, and encourage similar efforts for the supply chain.
Human rights and labor To respect the human rights of workers in our company and our supply chain, we comply with relevant laws and regulations, consult international human rights standards, and encourage not only efforts for our own workers but also similar efforts from business partners.
1. Prohibition of forced labor All workers shall be employed of their own free will and no form of forced labor or debt bondage shall be tolerated.
2. Prohibition of child labor and consideration for young workers
  1. Young workers under 18 years of age (including students) must not be engaged in work that may harm their health, safety, morals, or right to education, etc.
  2. Labor by children who do not meet the minimum working age is prohibited.
3. Working hours and leave
  We comply in this area by monitoring the number of working hours, holidays, and paid leave days granted, as stipulated by laws, regulations, local ordinances, and other administrative agencies in the region where workers are employed, and by appropriately managing workers’ working hours and leave.
4. Appropriate wages and allowances
  We comply with all legal regulations applicable to compensation paid to workers, and pay compensation appropriately at designated times while providing detailed statements written in a language workers can understand.
5. Prohibition of inhumane treatment
  We establish workplace environments that prevent the occurrence of inhumane treatment such as discrimination, mental or physical abuse, coercion, and harassment, as well as any acts that could potentially lead to such treatment.
6. Prohibition of discrimination
  We do not discriminate against workers based on characteristics unrelated to job requirements in hiring, employment, and compensation.
7. Diversity, Equity & Inclusion
  We establish workplace environments where all individuals with diverse values and individuality are respected and can participate fairly and actively.
8. Freedom of association and right to collective bargaining
  While complying with local laws and regulations, we respect workers’ right to organize as a means of realizing labor-management discussions on issues such as working environment and wage levels.
Safety and health
We comply with relevant laws and regulations, consult related international standards, and establish a safe, sanitary, and healthy working environment that minimizes work-related injuries and physical and mental illnesses for workers in our company and supply chain.
1. Occupational safety
  We develop an occupational safety and health management system, identify and evaluate potential risks of disasters, accidents, and health hazards that may occur during work including their likelihood of occurrence, and ensure safety through appropriate design, and technical and management measures.
2. Industrial accidents and occupational diseases
  We identify, evaluate, record, and report the status of industrial accidents and occupational diseases, implement appropriate countermeasures and corrective actions, and make environmental improvements to promote workers’ return to the workplace.
3. Safety assurance initiatives We implement the following initiatives for safety assurance:
  - We clearly post safety and health-related information within facilities or display it at locations where workers can confirm and access it.
  - We provide education and training on appropriate safety and health information regarding various occupational hazards that workers may face, using language and methods that workers can understand.
  - We develop a system for workers to provide feedback on their safety-related opinions.
4. Worker health management
  We provide appropriate health management for all employees.
5. Facility safety and health
  We appropriately ensure the safety and health of facilities provided for workers’ daily life (dormitories, cafeterias, restrooms, etc.).
Environment
To minimize adverse impacts on local communities, ecosystems, the environment, and natural resources in the supply chain, we place top priority on ensuring the health and safety of people in relevant regions, comply with related laws and regulations, consult related international standards, and realize green procurement by promoting similar initiatives not only within our company but also among business partners.
1. Environmental permits and reporting
  We obtain necessary permits and approvals for business operations and conduct registration and reporting in accordance with laws and regulations at each business location.
2. Environmental management system
  We establish and operate a management system to mitigate negative impacts on the environment and achieve conservation.
3. Energy consumption and reduction of greenhouse gas emissions
  We strive to improve energy efficiency and engage in continuous activities to reduce energy consumption and greenhouse gas emissions.
4. Management of air, soil, and water resources, and pollution
  We comply with related laws and regulations, establish appropriate measures for air, soil, water resources, and river pollution, and manage and work to reduce emissions of harmful substances.
5. Effective resource utilization and waste management
  Through compliance with laws and regulations and appropriate management, we engage in management to ensure responsible disposal and promote the 3Rs: reduce, reuse, and recycle.
6. Chemical substance management
  For materials such as chemical substances handled in business activities, we comply with laws and regulations, and reliably carry out appropriate handling, management, etc.
7. Management of chemical substances contained in products
  We comply with all laws, regulations, and customer requirements regarding the prohibition and restriction of use of specific substances contained in products, and we strive to identify whether raw materials, parts, and other items that are procured, manufactured, sold, or distributed contain substances harmful to people or the environment.
8. Biodiversity
  We consider the impact of business activities on local communities and ecosystems, and promote plans and initiatives aimed at biodiversity conservation.
Fair trade and ethics
We comply with laws and regulations in all countries where we conduct business, and with management themselves serving as role models, all employees conduct business with high ethical standards.
1. Corruption prevention
  We strive to engage in fair transactions and prevent all forms of corrupt practices and improper granting of benefits.
2. Respect for intellectual property
  We respect intellectual property, take appropriate measures for protection, and confirm protection status.
3. Fair business conduct
  We conduct fair business activities, competition, advertising, and product/service labeling.
4. Indigenous peoples and local communities
  To respect the rights and cultures of indigenous peoples and local residents as stipulated in the laws and international agreements of the countries and regions where we conduct business activities, we prevent business activities from causing or facilitating infringement of rights such as land seizures.
Responsible mineral procurement
To prevent complicity in and support of risks related to human rights, the environment, and other objectives via mineral procurement in conflict-affected and high-risk area, we comply with relevant laws and regulations and work toward responsible mineral procurement throughout the supply chain in accordance with international standards (*), etc.
* OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, etc.
Quality and safety
To ensure the safety and quality of products and services, we consult international standards and other provisions, and aim to ensure safety and quality of products and services throughout the entire supply chain.
1. Quality management
  1. To ensure the safety and quality of products and services, we consult international standards and other provisions, and aim to ensure safety and quality of products and services throughout the entire supply chain.
  2. We implement the following initiatives for quality control of products and services:
    - Development of quality management systems
      We comply with all laws and regulations related to product and service quality and develop management systems to comply with our own quality standards and customer requirements.
    - Development of systems enabling reporting to customers
      We establish and implement systems enabling immediate reporting to customers when problems occur regarding product and service quality.
    - Confirmation of usage and distribution purposes
      We strive to confirm whether the usage and distribution purposes of manufacturing and services are appropriate.
2. We provide accurate and non-misleading information about product and service specifications and quality, and substances contained in materials and parts used in products.
Information security
We consult international standards and other provisions, prevent leakage of confidential information and personal information, unauthorized information acquisition and use, and strengthen information security.
1. Strengthening information security
  1. We conduct management to prevent harm to ourselves and others by taking defense measures against threats such as cyberattacks and establishing plans for rapid recovery when cyberattacks occur.
  2. We implement the following initiatives to protect personal information and prevent leakage of confidential information:
    - Appropriate management and protection of personal information
      We comply with related laws and regulations and appropriately manage and protect personal information of all parties we conduct business with, including suppliers, customers, consumers, and employees.
    - Appropriate collection, storage, processing, transfer, and sharing of personal information
      When collecting, storing, processing, transferring, and sharing personal information, we comply with laws and regulatory requirements regarding personal information protection and information security, and stay within the scope of usage purposes and retention periods voluntarily consented to by the subjects.
    - Appropriate management and protection of confidential information
      We appropriately manage and protect confidential information received not only from our company but also from customers and third parties.
Business continuity plan
We consult international standards and other provisions to identify and evaluate risks that may interfere with business continuity, and formulate a business continuity plan (BCP) that summarizes the careful examination of impacts on business, necessary proactive countermeasures for the medium to long term, and the status of such initiatives.
Development of management systems
We develop management systems for compliance with items 1–9 above.
1. Corporate commitment
  Formulation, publication, and sharing of related policies
2. Person in charge
  We appoint a person in charge and regularly review the situation
3. Formulation of goals and implementation plans for improvement
  Formulation of goals and implementation plans for improving initiatives
4. Education and training
  We conduct education and training as necessary for improving initiatives
5. Documentation and records
  We prepare and maintain documents and records regarding initiatives
Supplier management
To realize responsible procurement, we communicate the requirements of items 1–9 above to suppliers and develop a process to confirm suppliers’ compliance status, referring to the OECD Due Diligence Guidance for Responsible Business Conduct and other guidelines.
Access to remedies
We develop a system that allows internal and external stakeholders to report/consult on misconduct in our company and our supply chain while having their identity protected and without suffering disadvantages such as retaliation.
Remediation
We provide remediation when our company’s or business partners’ operations, products, or services are involved in negative impacts on supply chain sustainability.
Reporting
We provide timely and appropriate information disclosure to stakeholders regarding information disclosure stipulated by laws and regulations, etc., and initiatives for addressing those requirements, and we connect this to continuous improvement through communication.

Grievance Mechanism

As part of human rights and environmental due diligence in the Mitsubishi Corporation Group’s trading business, we accept consultations from internal and external stakeholders, using the grievance mechanism established and operated by Mitsubishi Corporation, our parent company, for cases that have negative impacts on human rights and the environment, or are of concern for potentially having negative impacts, through our business activities and business relationships.

Grievance Mechanism (from the Mitsubishi Corporation Corporate Website)