Self-assessment grades A: Target achieved B: Target mostly achieved C: Target not achieved

In an effort to reinforce our organizational responsiveness with regard to CSR priorities throughout the global supply chain, we inform suppliers of the CSR Procurement Guidelines for the Procurement & Logistics Division and make efforts such as entering into agreements that incorporate the guidelines following mutual verification and consensus regarding the details with suppliers. The guidelines apply to all raw materials (excluding copper ores) and equipment. They consist of a Basic Procurement Policy, our top-level policy setting out requirements to which we must adhere in terms of fair trade, respect for human rights, legal compliance, ethical procurement, occupational hygiene, environmental protection, and information security, and in addition to these items, we require our suppliers to comply with other requirements stated in our CSR Procurement Standards, including fair business practices, the development of work environments, working hours, freedom of association, responsible raw material procurement, quality and safety of products, Protection of intellectual property, disclosure of information, and protection of whistleblowers.

In addition, to ensure the effectiveness of the initiatives of our suppliers, we began to audit new supplier audits and regularly evaluate existing suppliers in April 2016, and we began to conduct on-site audits as necessary.

■New supplier audits
Before starting transactions with new suppliers, we comprehensively audit the new supplier based on its responses on the Supplier Self-Check Sheet below and confirm that specific criteria have been met.

■Regular evaluations of existing suppliers
We select important suppliers, focusing on suppliers of key items, and regularly evaluate them based on the Supplier Self-Check Sheet as we do during audits of new suppliers. We provide the results of the regular evaluations individually to suppliers as feedback. We comprehensively examine the contents of evaluations, and where necessary, request improvements to address items which received poor evaluations.

■Supplier Self-Check Sheet Operations
Before auditing a new supplier or the regular evaluation of an existing supplier, we request that the suppliers that will be audited conduct self-evaluations using the Supplier Self-Check Sheet. This self-check sheet includes items regarding quality, price, supply capacity, and technological capabilities, which are common evaluation items. In the fiscal year ended March 2024, we added items related to CSR, human rights, and ESG to the self-check sheet. Using this form, we confirm the policies, systems, initiatives, and existence of corrective mechanisms regarding about 13 items in total.

■Initiatives regarding human rights due diligence

• Initiatives implemented by the Procurement & Logistics Division 

  By regularly evaluating existing suppliers, we also identify and assess human rights risks in the supply chain, with a focus on key suppliers. Where corrective actions are deemed necessary, we request improvements regarding the matter in question and monitor the status of improvements on an ongoing basis. We request that tier one suppliers not only do the supplier self-check but also have their suppliers do it, facilitating risk assessments of tier two suppliers as much as possible.
  In addition, during the fiscal year ended March 2025 and the fiscal year ending March 2026, we are also conducting human rights risk assessments of suppliers other than key suppliers (270 companies identified based on transaction track records and industry-specific risks) using the Supplier Self-Check Sheet. In the fiscal year ended March 2025, we requested that 140 companies do the self-check. This is about half of the identified suppliers other than key suppliers. We plan to request that the remaining 130 companies do the self-check in the fiscal year ending March 2026.
  As a result of the assessment of the human rights risks regarding each supplier, a total of 22 companies were identified as suppliers at high risk in the fiscal year ended March 2025. We provided feedback to these suppliers individually and requested improvements as part of our human rights due diligence activities. We have confirmed that all of the suppliers have made or are making improvements. We will continue to encourage our suppliers to make improvements in our efforts to improve the entire supplier chain.

  For new suppliers, we include the specific results of human rights risk assessments in the requirements for starting to transact business with us. For suppliers with low evaluation scores, we indicate policies for handling these issues and take appropriate actions, such as the continuous monitoring of these suppliers.  
   

• Initiatives implemented by divisions other than the Procurement & Logistics Division 
  In the fiscal year ended March 2025, we expanded the scope of our human rights due diligence activities to include suppliers providing services on the premises of our sites and in other places and those to which we outsource the processing of our products (hereafter, “suppliers of services, etc.”).
  In the fiscal year ended March 2025, we conducted human rights risk assessments of approx. 270 target suppliers of services, etc. using the Supplier Self-Check Sheet. As a result of the assessments, four suppliers at high risk were identified. We continuously followed up with them to facilitate the implementation of improvements. 
  We also informed target suppliers of services, etc. of the CSR Procurement Guidelines used by the Procurement & Logistics Division and requested that they comply with the Procurement Standards.

Participation in an international initiative
The Procurement & Logistics Division participates in the Supply Chain Subcommittee of the United Nations Global Compact (Global Compact Network Japan) as a member of the committee and appropriately promotes the identification of trends in society and issues that we face, as well as initiatives and monitoring activities to solve issues that have been identified.

The Metals business consists of three areas of business; mining, smelting and refining, and resource circulation. In the mining sector, we invest in overseas copper mines in order to contribute to procuring a steady supply of copper concentrate. In the smelting and refining sector, we manufacture and sell high quality products, thanks to the Mitsubishi Process, which combines high efficiency with exceptionally low environmental impact. Making the most of the smelting process, we have also established a recycling system for efficiently recovering and recycling valuable metals from E-Scrap and other sources. We also provide precious metal bullion products and services under the brand “Mitsubishi Gold,” including our accumulation plan service called “MY GOLD PARTNER” for gold, silver and platinum for individual customers. In the resource circulation sector, we work on a joint basis with partner companies in the operation of recycling plants for waste products such as home appliances and automobiles, while also coordinating with the smelting and refining sector in an effort to expand resource circulation model.

Naoshima Smelter & Refinery of Mitsubishi Materials Corporation and Onahama Smelter & Refinery of its Group company Onahama Smelting & Refining Co., Ltd. have been assessed under the Copper Mark Assurance Framework and awarded The Copper Mark as of October 4, 2024.
The Copper Mark is a framework developed in 2019 to demonstrate the copper industry's "responsible production" and contribution to the SDGs advocated by the United Nations. The Copper Mark is the leading assurance framework to promote responsible practices across the copper, molybdenum, nickel and zinc value chains. The Copper Mark works with companies and organizations throughout these metals' value chains to enable them to better understand and meet the increasing demands for independently verified responsible practices, and to contribute positively to sustainable development.
We started the procedure for participation in the Copper Mark Assurance Framework in December 2023 and have now achieved the award after an audit by an independent third-party organization. The Group has established key material issues in its Medium-term Management Strategy FY2031 and promoted various initiatives for "contribution to the global environment," "sustainable supply chain management," and "respect for human rights." Attaining The Copper Mark certification is an objective recognition of the steady results of these efforts.
The Group set "For people, society and the earth, circulating resources for a sustainable future" as "Our Commitment." Going forward, we aim to realize Our Commitment by taking full advantage of our copper smelters & refineries.

Advanced Products Company (APC) operates two businesses in an integrated manner - the Copper & Copper Alloy business and the Electronic Materials & Components business - since they are very similar in terms of market needs and technology development. Taking advantage of our unique technologies, we offer various products in the markets of next-generation vehicles, semiconductor manufacturing, electronics, industrial equipment, robots, and infrastructure, which are our focus market domains.
We supply a wide range of products for semiconductor manufacturing and electronics market as well as automotive industry; oxygen-free copper and advanced copper alloys, lead frames and various other copper products that are essential to handle high current, high voltage and high capacity data communication required to next generation vehicles; solar heat-ray shielding paints that are used mainly for automotive windows to save energy; electronic components such as thermistor sensors; processed silicon products and sealing products for semiconductor manufacturing equipment. In addition, we supply superconducting wires (used for magnetic resonance imaging (MRI) scanners and scientific research), high-performance alloy wires, ECO BRASS® and GloBrass® (an environmentally friendly, lead-free superior machinability brass), and others for the market of industrial equipment, robotics, and infrastructure.
In this way, APC contributes widely to the development of society, like a popularization of new mobility services, by providing high value-added products in response to mega trends.

We supply cutting tools and cemented carbide tools such as civil construction tools, mining tools and wear- resistant tools that are essential for processing metal parts. We operate manufacturing and sales facilities worldwide, in the U.S., Europe, China, and other parts of Asia. By providing high value-added products and services that cater to customer needs, underpinned by high levels of technical expertise and reliability, we support manufacturing across various fields. Our share of the market in Japan is large. Tungsten, which is the main material of cemented carbide, is a rare metal and there are procurement risks related to this mineral resource. We are therefore focused on the collection and recycling of used cemented carbide tools. In the fiscal year ended March 2025, we achieved a tungsten recycling rate of 58.6%. In 2025, H.C. Starck Holdings (Germany) GmbH (H.C. Starck), which engages in the production, sale, and recycling of tungsten raw materials, joined the Group, and we are continuing to strengthen our supply chain.

In the Renewable Energy business, we contribute to the building of a decarbonized society by providing a stable supply of renewable energy, including geothermal, hydroelectric, solar and wind power.

We have developed former mining sites for utilization as tourist roadways.
In the Cement business, we have established a wide-ranging business structure, from mining limestone, the main raw material in cement, through to cement plants, transportation, sales, ready-mixed concrete plants, and construction companies, etc. With this structure, we contribute to the development of social infrastructure and undertake global activities via production and sales facilities in Japan and other countries. We also supply high quality products such as low-heat cement, ultra-high strength concrete cement, and non-shrink grout, in addition to regular Portland cement and other general-purpose products. Furthermore, we actively take in difficult-to-treat waste products at our cement plants, and detoxify them using a high-temperature burning process at approx. 1,450ºC. Effectively reusing resources like this enables us to contribute to the establishment of a recycling-oriented society.

Of all the base metals, copper in particular is used for a wide range of purposes. While there are risks such as short-term metal prices and exchange rate fluctuations, demand is forecast to continue growing over the long term, not least due to infrastructure development in emerging economies.
However, as copper-producing regions around the world are limited and competition for the resource is intensifying, promising production regions are becoming increasingly rare. Recently, policies to protect national resources in resource-holding countries and anti-development campaigns due to growing environmental awareness are on the rise. In addition, newly developed mines require mining at higher elevations and to greater depths, while the quality is lower and also contains more impurities. This has made securing clean copper concentrates a more important challenge than ever.

Since the closure of our domestic Akenobe Mine in 1987, we have been reliant on imports from overseas mines for copper concentrates*, the main raw material used in our products. To reduce the environmental impact caused by mine development and ensure the sustainable development of local communities, when investing in overseas mines we emphasize not only legal and regulatory compliance but a "Social License to Operate" approach, and endeavor to minimize the ecological impact caused by the mines in which we invest. Depending on our level of investment, we also assign personnel to mines in other countries, and provide support to ensure that mines are developed sustainably in the best interests of the environment and the local community.
At the Mantoverde Mine, one of the mines in which we invest, we aim to continually achieve our target of zero accidents involving employees based on our belief that all occupational illnesses are preventable, and all accidents are opportunities for improvement. We strive to strengthen our efforts in this regard through commendations and training provided to employees and contractors.
To learn more about our biodiversity initiatives for overseas mines, see the section on Biodiversity Initiatives (Disclosure in Accordance with TNFD).

The efficient recycling of resources is becoming increasingly important, in terms of securing stable supplies of metal resources and enabling the sustainable development of society as a whole. In particular, waste electrical and electronic equipment (WEEE), such as televisions, computers and cellular phones contain large quantities of valuable metals such as precious metals and rare metals. These “urban mines”^* are also being thrust into the spotlight because they enable highly efficient extraction (recycling) of resources with minimal impact on the environment and local communities compared to natural mines.
In addition to the smelting and refining technologies that our Group has built up over more than a century, for nonferrous metals, we have a wealth of technologies and expertise in recycling, and continue to actively work on recycling, particularly E-Scrap (mainly printed circuit boards and other recyclable materials picked out from dismantled and crushed WEEE).
Alongside our high-level operational expertise and “the Mitsubishi Process,” a unique continuous copper smelting and converting process developed exclusively by Mitsubishi Materials, we have established a global collection network, and are constantly working to improve and reinforce acceptance and processing capacity, as well as services such as our online E-Scrap trading platform “MEX. ” Our E-Scrap information network includes recyclers from more than 60 countries around the world. In February 2018 we newly established MM Metal Recycling B.V., which handles the intake, inspection and sampling of E-Scrap in the Netherlands. In September 2024, we established Mitsubishi Materials Europe B.V. as the base overseeing our recycling business in Europe. We are responding to the expansion of the E-Scrap market with a focus on Europe which leads the world in terms of environmental policy.

In recent years, we have been disposing of large quantities of electric and electronic devices that have outlived their useful lifespan as WEEE. These devices still have potential value as urban mines. However, there are concerns that they could also cause environmental contamination from lead, mercury or other harmful substances if they are processed inappropriately. To address this issue, in 2003 the European Union (EU) introduced a directive to limit volumes, and promote the reuse and recycling of WEEE.
Within the EU, a certification scheme is being put in place for companies throughout the recycling chain, to encourage them to handle WEEE in an appropriate manner. In fall 2016, we became the first company in Japan to obtain certification under the Standard on End-Processing of WEEE Fractions (E-Scrap) at the Naoshima Smelter & Refinery and Onahama Smelter & Refinery (Onahama Smelting & Refining Co. Ltd.). In addition, both the Naoshima Smelter & Refinery and the Onahama Smelter & Refinery have been certified as recycling operators pursuant to the provisions of Article 15 of the Basel Act.
Revised annexes to the Bael Convention came into force in January 2025, and all transboundary movements of WEEE became subject to the Prior Informed Consent Procedure (PIC). In Europe, waste transportation regulations were revised in 2024, and this is one of developments that are resulting in transboundary movements of recycled resources being strictly controlled and the increasing promotion of the local production and local consumption of these resources. The Group will continue to build on the technologies and knowledge developed so far and leverage the strong networks it has developed with suppliers in Japan and overseas to respond appropriately to changing laws, regulations, and other rules while communicating closely with customers. The Group will continue to contribute to the sustainable development of society as a leading company in responsible E-Scrap recycling.

We procure copper concentrate, a raw material for copper products, primarily from the overseas mines in which we invest, to ensure a stable supply to domestic smelters and refineries both in Japan and overseas. While this places us in the position of a non-operator not directly involved in mine management, as a company engaged in global procurement activities, we hope to fulfill our sustainable development responsibilities.
We place importance on dialog with indigenous peoples and members of local communities. For example, we assign specific staff members to participate in the advisory committees of mines in which we have a certain scale of interests.
Moreover, our Metals Company requires the mining companies to comply with Sustainability Investment Guideline and CSR procurement standards before we invest in them. We also check the status of compliance with those standards, for example through regular questionnaire surveys, and as necessary seek to understand and improve the situation. We also regard environmental preservation and respect for human rights as important matters to consider in management of the global supply chain and have incorporated these considerations into our business processes.

The United States’ Dodd-Frank Wall Street Reform and Consumer Protection Act requires all companies listed in the US to disclose whether their products contain “conflict minerals,” defined as gold, tin, tantalum and tungsten, along with details of reasonable survey on producing countries and the survey results, in an effort to prevent minerals mined in the Democratic Republic of Congo (DRC) or its neighboring countries from being used to fund the activities of armed groups responsible for human rights violations and other acts of violence. Recently, the scope of conflict minerals has been expanded, particularly in EU countries, with consideration also being given to cobalt and silver from a broader perspective of responsible mineral procurement. In tandem with this trend, the OECD, SEC, and organizations such as RMI^*1, LBMA^*2, and LME^*3 have formulated guidance related to the issue of conflict minerals (responsible mineral procurement management).
As a responsible business operator smelting gold, silver, copper, lead and tin, we have instituted initiatives such as conducting efficient surveys of the suppliers of these metals based on due diligence standards stipulated in each standard to respond to these global requirements, and we have formulated and disclosed our Responsible Minerals Sourcing Policy.

Contact the Responsible Minerals Control Hotline if you identify any act in violation of the provisions of our Responsible Minerals Control Policy.

The Metals Company has pledged its support for a campaign to ensure a transparent flow of funds related to mineral resources, as promoted by the Extractive Industries Transparency Initiative (EITI)^*1 since June 2011. We began preparations for tackling the issue of conflict minerals in 2012, obtained certification in August 2013 for our compliance with the London Bullion Market Association (LBMA)^*2 gold guidance on avoiding use of conflict minerals and have had this certification renewed every year since. We have also begun operations and obtained certification with regard to silver.
Since February 2014, we have received annual certification of our conformance with the RMI^*3 of RMAP^*4 regarding tin.

The company had previously outsourced the smelting and refining of platinum and palladium to one of our Group companies, Materials Eco-Refining Co., Ltd., and since April 1, 2025, Onahama Smelting and Refining Co., Ltd., has taken over this business. On this occasion, Onahama Smelting and Refining Co., Ltd., established "Responsible Minerals Sourcing Policy for Platinum, Palladium" in April 2025. Since the raw materials for platinum and palladium are sourced not only from our precious metals refinery at Naoshima Smelter and Refinery, but also from outside the Group, Onahama Smelting and Refining Co., Ltd., has implemented a system to manage risks in the raw materials supply chain related to human rights abuses, terrorist financing, money laundering, illegal trade, etc. in accordance with the Responsible Platinum/Palladium Guidance of the London Platinum and Palladium Market (LPPM). And in July 2025, as a result of an assurance audit by a third-party organization, Onahama Smelting and Refining Co., Ltd., was awarded LPPM Good Delivery certification.

Copper cathodes and Lead Ingots which Metals Company manufactures are registered with LME (London Metal Exchange). In line with LME’s initiative to introduce “LME Policy on Responsible Sourcing of LME-Listed Brands”, Metals Company has set out its Responsible Minerals Sourcing Policy for Copper and Lead as below and will implement responsible sourcing measures to comply with LME’s requirements.

The company had previously outsourced the smelting and refining of platinum and palladium to one of our Group companies, Materials Eco-Refining Co., Ltd., and since April 1, 2025, Onahama Smelting and Refining Co., Ltd., has taken over this business. On this occasion, Onahama Smelting and Refining Co., Ltd., established "Responsible Minerals Sourcing Policy for Platinum, Palladium" in April 2025. Since the raw materials for platinum and palladium are sourced not only from our precious metals refinery at Naoshima Smelter and Refinery, but also from outside the Group, Onahama Smelting and Refining Co., Ltd., has implemented a system to manage risks in the raw materials supply chain related to human rights abuses, terrorist financing, money laundering, illegal trade, etc. in accordance with the Responsible Platinum/Palladium Guidance of the London Platinum and Palladium Market (LPPM). And in July 2025, as a result of an assurance audit by a third-party organization, Onahama Smelting and Refining Co., Ltd., was awarded LPPM Good Delivery certification.

In June 2021, Japan New Metals Co., Ltd., a Group company whose operations include tungsten smelting and refining, revised the existing Conflict Mineral Management Policy to the Responsible Mineral Procurement Management Policy, which has expanded its scope of control to a wider range of areas and minerals. As a company smelting and refining tungsten in Japan, Japan New Metals Co., Ltd. carries out management to ensure that raw materials put into the smelting and refining process are ones conforming to the Responsible Mineral Procurement Guidelines. The company also carries out the similar management for raw materials purchased from external tungsten smelting and refining companies. Furthermore, in November 2021, the company acquired the Responsible Minerals Assurance Process (RMAP) conformance certification, which was updated from the CFS Certification.