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 as a key part of fulfilling our social responsibilities. This includes 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, we became the first Japanese refiner to receive the Code of Practices (COP) certification from the Responsible Jewellery Council (RJC)*. In July 2021,
the company also obtained the Chain of Custody (COC)
certification for its processing and distribution management. While adhering to the RJC’s strict standards
for ethics, human rights, society, and the environment, as
well as for due diligence and traceability, the company is
committed to fulfilling its responsibilities as a member of the
precious metals supply chain, including gold and platinum.
*A non-profit organization that promotes transaction transparency and
responsible corporate behavior in the jewelry industry, targeting companies
that handle precious metals and diamonds, from mining to retail.
Responsible Precious Metals Management System
In the precious metals supply chain, we have established a
Responsible Precious Metals Management Policy and formed
the Responsible Precious Metals Management Committee
(RPM Committee) to oversee our domestic Group
companies. Under the leadership of the Chief Compliance
Officer, appointed by the President and CEO, the RPM
Committee is responsible for making key decisions, including
formulating and revising policies, developing management
systems, monitoring implementation, educating employees,
and reporting to senior management.
We evaluate transactions that adversely impact
our precious metals supply chain as high-risk. The RPM
Committee discusses these transactions, and additional due
diligence is conducted as necessary to further strengthen the
management system.
Responsible Precious Metals Management