Human Rights

Human Rights Policy of Mitsui Kinzoku Group

Providing society with useful materials by refining underground resources into nonferrous metals: this is the starting point of Mitsui Kinzoku Group. Throughout the businesses, however, there is the potential for a major impact on the environment and on local residents. The Mitsui Kinzoku Group is determined to respect the human rights of all those who are affected by our business activities and to contribute to the creation of a sustainable society through the use of our knowledge and technology as well as valuable commodities.

［Basic Principle and Position of the Policy］

Mitsui Kinzoku Group has established the Human Rights Policy (“the Policy”), considering the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights), Declaration on Fundamental Principles and Rights at Work (International Labor Organization; ILO), and United Nations Global Compact. Based on this Policy, the Group is taking steps to respect human rights. The Policy also declares our efforts to respect human rights based on Mitsui Kinzoku’s Management Philosophy, Corporate Slogan and Code of Conduct, and complements Mitsui Kinzoku Group’s Basic CSR Policies.

［Scope of Application］

This Policy applies to all our business offices, plants, laboratories and subsidiaries worldwide. In addition, we will encourage business partners, including suppliers and sales partners, to support human rights and prevent infringements of rights, and cooperatively promote respect for human rights.

［Responsibility for Respecting Human Rights］

We will fulfill our responsibility for respecting human rights by preventing infringements of human rights and addressing any adverse impacts on human rights caused by our business activities, In the case where a business partner, such as a supplier or a sales partner, has had adverse impacts on human rights, we will encourage them not to infringe upon human rights.

［Dialogue and Consultation with Stakeholders］

In terms of human rights issues related to business activities, we will make use of independent external expertise and hold a dialogue and consultation with the involved stakeholders.

［Human Rights Due Diligence］

To fulfill our responsibility for respecting human rights, we will establish a framework of human rights due diligence and implement it on an ongoing basis. Human rights due diligence is a continuous process conducted to preliminarily identify any adverse impact on human rights in society that could potentially be caused by our company, and then to mitigate or prevent it.

［Remedy］

Should it be revealed that we were involved, directly or indirectly, in any action with adverse impacts on human rights, we will work on correcting it through appropriate procedures.

［Information Disclosure and Education］

We will release reports on our human rights initiatives based on the Policy on Mitsui Kinzoku Group’s website, CSR report, and other means. In addition, we will provide appropriate education to ensure the effectiveness of the Policy.

Mitsui Kinzoku Group Human Rights Standards

Mitsui Kinzoku Group conducts human rights due diligence and approaches human rights issues following internationally recognized guidelines and the ICMM Principles, with particular reference to the Responsible Business Alliance (RBA) Code of Conduct.

Mitsui Kinzoku Group recognizes that there are human rights risks in our businesses and supply chain, particularly mining-specific human rights risks and human rights risks in the mineral supply chain. We identify workers^ⅰ of our own sites^ⅱ, workers of our business partners including suppliers, and residents of local communities as the prioritized stakeholders who could potentially be affected in our businesses and supply chain. We also identify major risks through risk assessment conducted in relation to labor, health and safety, the environment, and ethics, and define our approach to the major risks as our “Human Rights Standards.”

1. Management System
   We establish and maintain a human rights management system.
   • The management system includes regular trainings for promoting understanding and raising awareness of the human rights policy and human rights across the entire group, and keeping appropriate records of human rights matters.
2. Freely Chosen Employment
   We do not use forced labor.
   • Workers retain and manage their own legal documents including passports, other government-issued identification documents, and travel documents, and are not required to hand over the original documents.
   • Workers are not required to pay any type of fees or bonds in relation to employment.
   • Employment agreements are executed in the native language of workers or in a language that workers can understand, and no unfair changes are made.
3. Prohibition against Child Labor and Protection of Young Workers
   We do not use child labor.
   We protect the rights of young workers and student workers, and manage them appropriately in accordance with applicable laws and regulations.
   • We strictly check the age of workers using documents issued by official organizations. We do not employ workers who have not reached the highest age of either 15 years, the legal minimum age for employment, or the age for completing compulsory education in that country.
   • We do not require young workers under the age of 18 to perform work that is likely to jeopardize their health or safety, including night shifts and overtime.
4. Working Hours
   With regard to working hours and day off, we comply with applicable local laws and support international guidelines.
5. Wages and Benefits
   With regard to wages and benefits, we comply with applicable local laws and support international guidelines.
   • We manage the wages paid to workers so that they never fall below the minimum wages.
   • With regard to overtime work, we pay workers at legal pay rates greater than regular hourly rates.
   • We do not reduce wages illegally or unjustly as a disciplinary measure.
6. Humane Treatment
   We prohibit the inhumane treatment, including any type of abuse or harassment.
   • We prohibit any type of harassment such as sexual harassment^ⅲ, sexual abuse, corporal punishment, mental or physical coercion, and verbal abuse.
   • We take appropriate measures against harassers/abusers and against those who make false accusations.
7. Non-Discrimination
   We prohibit unlawful discrimination.
   • We do not engage in discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status in hiring and employment practices such as application for employment, wages, benefits, promotions, rewards, job assignments, discipline, termination and access to training.
   • We provide workers with reasonable accommodation for religious practices.
   • Except when specified by laws and regulations or to ensure individual safety or workplace safety, workers do not be subjected to pregnancy testing or other medical testing (such as for type B hepatitis or HIV), and the test results do not be used in a discriminatory way.
8. Freedom of Association
   With regard to freedom of association and collective bargaining, we comply with applicable local laws and regulations and support global standards.
   • We respect the right to form or participate in organizations such as labor unions and worker committees.
   • Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of interference, discrimination, reprisal, intimidation or harassment.
9. Protection of Identity and Non-Retaliation
   We maintain a grievance mechanism enabling internal and external stakeholders to raise any concerns they may have.
   • We ensure the confidentiality and anonymity of whistleblowers.
   • We maintain a process that ensures whistleblowers are able to raise any concerns they may have without fear of retaliation.
10. Suppliers ^ⅳ
    At each of our sites, we select suppliers in accordance with the Mitsui Kinzoku Group Procurement Policy and conduct supplier due diligence on a continual basis.
11. Local Communities
    We respect the human rights, interests, cultures, customs, and values of local communities including indigenous people, affected by our businesses.

    ⅰ All personnel working in our facilities or offices, regardless of their employment type
    ⅱ All sites including our own mine
    ⅲ Giving disadvantage in the working condition of a worker by reason of the worker’s responses to verbal or physical conduct of a sexual nature or harming the working environment of the worker by such conducts
    ⅳ Including third-party employment agencies