Sustainability | GovernanceResponsible Sourcing of Minerals

Our Approach

Based on concerns that minerals mined in the Democratic Republic of the Congo (DRC) and adjoining countries serve as a source of funding for armed groups provisions on conflict minerals were incorporated in the US Dodd-Frank Wall Street Reform and Consumer Protection Act, which was enacted in July 2010, and its final rule was adopted in August 2012. The TDK Group Policy on Conflict Minerals was formulated in April 2013, to promote initiatives in full compliance with the Due Diligence Guidance of the Organization for Economic Cooperation and Development (OECD).

In recent years, the scope covered by the issue of responsible sourcing of minerals, etc. originating in conflict zones and high-risk areas has expanded, with the aim of controlling not only possible exacerbation of conflicts but also serious human rights abuses and pollution. Due to the special characteristics of TDK’s products (i.e., electronics components, etc.), the manufacturing of these products inevitably involves the use of various minerals, including tantalum, tin, tungsten, and gold.

With this in mind, in January 2019 we revised the “TDK Group Policy on Responsible Sourcing of Minerals.” The revised policy stipulates that TDK will work to promote responsible sourcing of minerals throughout the supply chain, in relation not only to conflict but also to risks and injustices relating to infringement of human rights, environmental destruction, etc. (including OECD Annex II risks)

Related link

Governance

One of the materiality (key issues) items that underpins the creation of value by TDK is the need to address environmental and social issues. A key topic identified in this area is to respect human rights, and this includes activities relating to the responsible sourcing of minerals.

We hold review meetings on a monthly basis to discuss and report on the progress made with these activities; this in turn is reported to the business planning function, which reports to the Board of Directors on an annual basis.

In terms of practical implementation, in order to manage risks and opportunities relating to minerals procurement, our headquarters procurement function is responsible for conducting an annual survey of suppliers, while our headquarters quality assurance function liaises with customers, and our sustainability promotion function monitors industry trends. Investigation and response systems have been established at each Group company.

Education and Awareness Raising

We provide training for team members (employees) newly assigned to the departments responsible for procurement to raise their awareness and help them to develop a more accurate understanding on the responsible sourcing of minerals. Training is also provided to relevant departments, such as the business divisions, as appropriate, and as needs dictate. TDK additionally participates as an organizing member in the Responsible Minerals Trade Working Group, which is convened annually by the Japan Electronics and Information Technology Industries Association (JEITA).

Strategy

In January 2019, we formulated the “TDK Group Policy on Responsible Sourcing of Minerals.” The Policy stipulates the promotion of responsible sourcing of minerals throughout the supply chain, both from conflict areas and those areas which may involve risks, such as the presence of human rights violations or environmental destruction, including OECD Annex II risks, or other injustices.

Under this policy, we will voluntarily and strategically promote initiatives for the responsible sourcing of minerals to enhance our corporate value, centered on the following five-stage framework in line with the OECD guidance^*1.

(1) Establishment of a robust corporate management system

• Formulate a policy on responsible sourcing of minerals
• Retain CMRT^*2 for a five-year period

(2) Identification and investigation of risks in the supply chain

• Survey suppliers using CMRT/EMRT^*3
• Declare TDK’s expectations (use of RMAP^*4-compliant smelters) to coincide with survey requests

(3) Establishment and implementation of strategies to address the identified risks

• Request the exclusion of any non-compliant smelters on lists

(4) Implementation of independent third-party audits of smelters’/refiners’ due diligence practices

• Encourage smelters to participate in RMAP through industry approaches (affiliated with RMI^*5/JEITA)

(5) Issuance of an annual report on supply chain due diligence

• Include annual report on activities on the company website

*1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

*2 Conflict Minerals Reporting Template

*3 Extended Minerals Reporting Template

*4 Responsible Minerals Assurance Process; A program that verifies compliance with responsible sourcing of minerals, using an independent third-party organization to evaluate smelters' and refiners' management systems and procurement practices.

*5 Responsible Minerals Initiative; An organization with a membership of over 400 companies and organizations worldwide, and which spearheads efforts relating to responsible mineral procurement

Risk Management

The TDK Group’s Global Common Regulations include a section on “responsible sourcing of minerals” in the regulations of the departments responsible for procurement of these minerals. We furthermore monitor whether these are reflected in the discrete regulations of our respective core subsidiaries.

Metrics and Goals

Goals and Achievements in FY March 2025

Initiatives