The ARE Holdings Group is engaged in the global procurement of materials for recovering precious metals, which are essential for manufacturing products such as electronics, auto parts, and jewelry. We have established a management system that complies with guidance issued by relevant international organizations. As a member of the precious metals supply chain, we promote Responsible Precious Metals Management. This is a key part of fulfilling our social responsibilities, which include compliance with laws and respect for international norms, human and labor rights, health and safety, environmental preservation, fair trade, and ethics.
Responsible Sourcing of Minerals
The Dodd-Frank Act was passed in the United States in 2010 out of concern that mineral resources were being used as sources of funding for armed groups causing conflicts and human rights abuses. This act regulates the use of conflict minerals from the Democratic Republic of the Congo and nine surrounding countries. Companies that are publicly listed in the U.S. and which procure tin, tantalum, tungsten, and gold (called 3TG) are required to carry out due diligence, determine the country of origin, and report on the use of any conflict minerals.
The Organization for Economic Co-operation and Development (OECD) has issued Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). This OECD Guidance sets out a five-step framework for companies: (1) establish strong company management systems; (2) identify and assess risks in the supply chain; (3) design and implement a strategy to respond to identified risks; (4) carry out independent third-party audits; and (5) report annually on supply chain due diligence.
The Conflict Minerals Regulation also came into effect in the European Union in January 2021. This regulation applies to importers of materials containing 3TG into the EU from conflict and high-risk areas, and they are now required to carry out due diligence in their supply chain. As a result, responsible sourcing of minerals is expanding globally.
Responsible Precious Metals Management
Refiners who meet criteria in areas such as quality of products, assaying, and responsible sourcing, and which have passed testing procedures, are accredited by the London Bullion Market Association (LBMA) for gold and silver or the London Platinum and Palladium Market (LPPM) for platinum and palladium as Good Delivery refiners. ASAHI METALFINE has received Good Delivery accreditation for gold, silver, platinum, and palladium, while Asahi Refining (USA and Canada) has received the same for gold and silver. These accreditations ensure that the companies are trusted by customers in the global market.
To maintain Good Delivery accreditations, in addition to regular quality and technical testing, Good Delivery refiners are required to be audited annually by a third party for the LBMA Responsible Gold and Silver Guidance (called LBMA Guidance), and the LPPM Responsible Platinum and Palladium Guidance (LPPM Guidance) in compliance with OECD Guidance.
In addition to avoiding conflict minerals, human rights abuses, money laundering, financing terrorism, and fraudulent transactions, the LBMA Guidance also now requires refiners to fulfill their social responsibilities for sustainability and the environment.
ASAHI METALFINE and Asahi Refining (USA and Canada) are also accredited by the Responsible Minerals Initiative (RMI) as conflict-free gold refiners that comply with the Responsible Minerals Assurance Process (RMAP).
In July 2019, ASAHI METALFINE (known as Asahi Pretec at that time) became the first Japanese refiner to obtain the Code of Practices (COP) certification from the Responsible Jewellery Council (RJC)*. In July 2021, the Company further obtained Chain of Custody (COC) certification, also from the RJC. Our operations meet the RJC’s rigorous standards for ethics, human rights, social responsibility and environmental practices. Additionally, the Company has successfully implemented to uphold these high standards and fulfill our responsibilities as a committed participant in the precious metals supply chain, particularly in the areas of refining and processing.
Note: An international nonprofit organization that promotes the ethical, socially responsible, and environmentally conscious handling of diamonds, gold, platinum, and other precious metals in the jewelry industry, from mining to retail.
Responsible Precious Metals Management System
We have established the Responsible Precious Metals (RPM) committee, chaired by the President, who is the Chief Executive Officer for RPM, to manage RPM operations across our domestic group companies. This committee is responsible for the adoption and revision of policies, decision-making on important measures, development of management systems, monitoring implementation, employee training, and reporting to senior management. Under the direction of the Compliance Officer, these responsibilities ensure our Responsible Precious Metals Management Policy is upheld.
We consider any transaction that adversely impacts our precious metals supply chain to be high risk. All risky transactions are evaluated by the RPM Committee and additional due diligence is carried out, if necessary, to improve our management systems.
Responsible Precious Metals Management