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)
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Governance
The nature of the various sustainability-related areas that TDK needs to address both internally and externally (including human capital, climate change, human rights) means that they cannot be addressed individually by specified units; rather, they need to be tackled using an integrated, company-wide framework. With this in mind, in April 2025 we established a Sustainability Committee, comprising cross-functional members from multiple units across TDK, under the Executive Committee Meeting (ECM), which is composed of executive officers. The Sustainability Committee identifies sustainability-related risks and opportunities, defines the TDK Group’s key issues, monitors progress, makes adjustments in response to changes in the internal and external environment, and responds to the introduction of new sustainability-related regulations, with the aim of aligning the sustainability of the TDK Group (i.e., the ability to grow corporate value over the long term) with the sustainability of society as a whole.
Framework for Implementation of Human Rights Measures
One of the Key Issues(Materiality) items that underpins the creation of value by TDK is implementing solutions to social and environmental 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 corporate 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.
Strategy
To give TDK’s products (such as electronic components) the properties they need, it is essential to use various minerals, including tantalum, tin, tungsten, and gold. However, these resources are largely concentrated in conflict-affected and high-risk areas, giving rise to risks such as funding armed groups, human rights violations, and environmental destruction.
Recognizing the need to exclude minerals associated with risks such as human rights violations from our supply chain, in January 2019 we formulated the “TDK Group Policy on Responsible Sourcing of Minerals,” and since then we have been working to implement this Policy. Including our earlier efforts, we have been undertaking activities in this area for over 10 years, working to promote responsible sourcing of minerals throughout the supply chain—encompassing both upstream and downstream companies—addressing not only conflict-related issues but also issues related to minerals associated with human rights violations, environmental destruction, and other misconduct, including OECD Annex II risks. In addition, as our supply chain is multi-layered and extends throughout the world, given that it would be difficult for TDK to implement related initiatives effectively on its own, we participate in numerous industry organizations, and through these we continue to engage in activities that leverage the collective influence of the industry as a whole.
Risk Management
TDK implements risk management based on the five-step framework for achieving risk management goals that is specified in the OECD Due Diligence Guidance*1
(1) Establishment of a robust corporate management system
- Formulate a policy on responsible sourcing of minerals
- Formulate common global rules
- Establish clear, documented management procedures
- Put in place the necessary organizational structures
- 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
- Implement template collection and risk assessment
(3) Establishment and implementation of strategies to address the identified risks
- If non-compliant smelters are included in lists, request that certified smelters be used instead
(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 and in the company’s Sustainability Report
*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 Identification Process
Implementation of surveys in Group companies and promotion of conflict-free sourcing
TDK has been conducting initiatives for risk identification measures in accordance with the OECD’s Due Diligence Guidance. To guarantee the rationality of replies, surveys use the CMRT issued by the RMI to check whether products contain the so-called 3TG conflict minerals (tin, tantalum, tungsten, and gold) and identify smelters. After the retrieval of CMRT surveys, TDK compares them with the RMI’s Smelters List and evaluates the risk of conflict minerals included in production materials being used as funding for armed groups and the risk of human rights violations, including child labor.
In FY March 2026, surveys were implemented at Group companies, and the ratio of suppliers confirmed to be conflict-free was 91.1%, achieving our target.
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Cobalt / Mica Survey
We have been proceeding with the identification of cobalt smelters and mica processors using the Extended Minerals Reporting Template (EMRT) issued by RMI since December 2021. In addition with regard to cobalt smelters, we request that cobalt be sourced from RMAP-compliant smelters.
Starting from 2025, we have been expanding the scope of the minerals covered by our surveys.
■Correction Process
Response to identified risks
When we request a survey of suppliers, we clarify to them our policy that they use RMI-conformant smelters, that appear on RMI's Conformant Facilities Lists. In the survey process, if a risk is discovered, TDK requests the supplier to remove the smelter concerned from the supply chain. The status of this response is confirmed in the following year's survey, in an ongoing process.
Metrics and Goals
Goals and Achievements in FY March 2026
| FY March 2026 Goals | Achievements |
|---|---|
| A ratio of at least 90% of suppliers whose procurement of conflict minerals (3TG: tantalum, tin, tungsten, and gold) is confirmed as being from RMAP-compliant smelters | 91.1% |
Evaluations and Future Activities
In FY March 2026 as in past years, we requested that suppliers continue to make procurements from RMAP-compliant smelters. We requested maximum efforts from suppliers whose compliance we could not confirm. For 3TG, the share of suppliers confirmed as procuring from RMAP-compliant smelters was 91.1%. For FY March 2027, we have set “a ratio of at least 90% of suppliers whose procurement of conflict minerals (3TG) is confirmed as being from RMAP-compliant smelters” as a common KPI for the TDK Group and will become more proactive in promoting Group-wide efforts, specifically those to make continued requests to suppliers while responding to inquiries from customers in a precise and timely manner. Furthermore, since collaboration with industrial organizations is essential to solve the expanding problem of responsible sourcing of minerals, we will continue to participate in such industrial discussions.
| FY March 2027 Goals |
|---|
| A ratio of at least 90% of suppliers whose procurement of conflict minerals (3TG) is confirmed as being from RMAP-compliant smelters |
Initiatives
In order to solve problems relating to responsible mineral procurement, efforts are necessary in the entire supply chain. TDK has participated in the RMI since February 2020 and in the JEITA's Responsible Minerals Trade Working Group ever since its founding.
TDK took part in the following activities in FY March 2026:
- Participated in the activities of the Responsible Minerals Trade Working Group’s Education and PR Team. A responsible minerals sourcing survey presentation was held, both in person and online, with the aim of helping representatives of secondary suppliers (and below) to develop awareness of responsible minerals sourcing issues and understand the survey methods used. TDK staff gave talks to explain the background to the event, and also took part as panelists. In addition, TDK personnel provided advice in the individual consultation sessions that followed the presentation, and collaborated on the organizing of the event.
- TDK has participated in the Conflict-free Sourcing Working Group together with automotive manufacturers, providing feedback on the survey manual and related tools.
- TDK has participated in the Smelter Support Team, and has contacted smelter that are not yet participating in RMAP to encourage them to undergo RMAP assessment.
- As a leader of the Responsible Minerals Trade Working Group’s Communication Team, TDK has offered its views regarding the format for the reporting template, has undertaken follow-up on developments regarding the revision of the IPC-1755 Responsible Sourcing of Minerals Data Exchange Standard, and has undertaken collation of views within JEITA. In addition, in line with the above developments, TDK has organized study sessions aimed at strengthening member companies’ response measures.
- TDK has held meetings to exchange views with upstream suppliers.
- TDK has held numerous meetings to exchange views with representatives of the RBA (and of the RMI) and with other stakeholders involved with responsible sourcing of minerals.
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).
