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As one of the main businesses of listed corporation Mitsui Mining and Smelting Co., Ltd. (“Mitsui Kinzoku”), and as the most advanced member of the Mitsui Kinzoku Group in terms of globalization, Mitsui Kinzoku ACT has established a compliance framework on par with those of listed companies.

Policy on Compliance Initiatives

Mitsui Kinzoku ACT recognizes that compliance is the most important thing in earning the trust of all of its stakeholders and expanding its business activities on a global scale, and is endeavoring the thoroughly ensure compliance with laws and regulations, corporate ethics, social norms and rules such as internal regulations, as well as the further enhancement of the systems that support such compliance.

Code of Conduct

All Officers and employees of Mitsui Kinzoku ACT share the values and code of conduct set forth in the Standard of Conduct formulated by Mitsui Kinzoku ACT, and operate with these standards serving as the guide for their conduct.

1. Social mission of the Mitsui Kinzoku Group
We shall contribute to society by providing valuable products.
2. Self-Awareness and Social Responsibility as a Member of the Mitsui Kinzoku Group
We shall always be mindful of our role as a member of the Mitsui Kinzoku Group and act with dignity and responsibility, while positively conducting social contribution activities by facilitating communication with all stakeholders.
3. Compliance
We shall comply with domestic and international laws and regulations as well as our company’s regulations and shall act with good sense and dignity as a member of society.
4. Fair Business Activities
We shall conduct appropriate business activities based on free and fair competition.
We shall also maintain healthy and transparent relationships with political parties and factions, the government, and business partners, shall not be involved in inappropriate behavior.
5. Elimination of Anti-Social Forces
We shall respond to anti-social forces and organizations in a decisive manner, and never form or foster relationships with them.
6. Proactive Information Disclosure and Thorough Information Management
We shall proactively and fairly disclose corporate information and comprehensively protect and manage confidential information, including personal and customer information.
7. Contribution to the Natural Environment
We shall address environmental issues to help realize a sustainable society.
8. Provision of Comfortable Work Environment
We shall provide a safe and comfortable work environment that respects the human rights, personalities, and uniqueness of our employees, while providing a place where a diverse range of human resources can play an active role.
9. Leadership of Senior Management
Top management shall recognize that it is their responsibility to realize the spirit of this code, and act on their own responsibility while demonstrating leadership.

Internal Reporting System

To deal with potential risks concerning compliance, we utilize an internal reporting system which Mitsui Kinzoku has deployed across the entire corporate group, as well as Mitsui Kinzoku ACT's own system and work to quickly deal with acts that may violates laws, regulations or the standards of conduct and impede the development and growth of the company.

Education, Training and Other Initiatives

As examples of compliance promotion activities, the following initiatives are being carried out.
- Implementation of compliance training
- Awareness-raising activities such as the affixing of posters, distribution of booklets and dissemination of information over the company intranet
- Inspections of the state of implementation of safety and environmental measures at all business locations including overseas by a dedicated department