Responsible Mineral ProcurementSupply Chain Management


Responsible Mineral Procurement

The considerations for responsible minerals procurement are heightened lately, following the enactment of The US Dodd-Frank Wall Street Reform and Consumer Protection Act in July 2010. Especially the concern regarding conflict minerals (tin, tantalum, tungsten, and gold commonly known as "3TG") that are mined from the Democratic Republic of the Congo and surrounding areas and used by an armed group or anti-government force as a source of funds.
According to the Article 1502 of The Securities and Exchange Commission (SEC), companies listed on securities exchanges in the US are required to investigate/report usage conditions regarding conflict minerals that are mined from the Democratic Republic of the Congo and surrounding areas that are used by an armed group or anti-government force as a source of funds. With the EU Conflict Minerals Regulation coming into effect in 2021, the need for and importance of responsible mineral procurement will become increasingly important. As we enter a new phase, ROHM Group is committed to responsible mineral procurement throughout the supply chain, not only with regard to conflicts, but also with regard to risks such as human rights violations and environmental destruction, including OECD Annex II risks, as well as tin, tantalum, tungsten, gold, cobalt, mica, and other minerals that may be involved in illegal activities.


  • 1. We do not use conflict minerals illegally mined in the DRC and adjoining countries as raw materials for our products.
  • 2. In conflict and high-risk areas (CAHRAs), we will establish a management system based on the "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict and High-Risk Areas (OECD Guidance)*1" of the Organization for Economic Cooperation and Development (OECD), and will implement measures to avoid procuring from suppliers with risks such as human rights abuses, environmental destruction, and conflict.
  • 3. In the unlikely event that we discover the use of conflict minerals as a source of funding for armed groups, we will promptly inform our customers and take corrective measures.
  • 1. OECD Due Diligence Guidance :OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

We also request that our suppliers understand ROHM Group's policy and make efforts to comply with them.

Promotion System

The executive officer chairs the Supply Chain Management System Committee of the EHSS General Committee, which formulates targets, implements measures, and conducts evaluations under the theme of creating an appropriate procurement environment for the entire ROHM Group.
Responsible mineral procurement is led by the Supplier Management G in the Supplier Management Subcommittee, a subordinate organization of the Supply Chain Management System, and its activities are based on the ROHM Group's standard "ROHM Group Procedures for Responsible Mineral Procurement.
Every year, we analyze the results obtained through CMRT*2 and EMRT*3 surveys to identify risks and take corrective actions. We also report the progress and results to the supply chain management system every three months.
In addition, as a member of the "Smelter Support Team" of the JEITA*4 Responsible Mineral Procurement Study Group, ROHM sends a letter to smelters requesting their participation in RMAP*5 audits.

  • 2. CMRT:Conflict Minerals Reporting Template

  • 3. EMRT:Extended Minerals Reporting Template

  • 4. JEITA:Japan Electronics and Information Technology Industries Association

  • 5. RMAP:Responsible Minerals Assurance Process(Program to certify smelters by RMI)

Targets and Achievements

The following are our achievements in FY2022 and our targets for FY2023 toward the realization of responsible mineral procurement.
In cooperation and trust with our suppliers, we will continue to conduct mineral procurement surveys and engage in two-way communication with suppliers to understand their procurement status and share information.

Target for FY2022 FY2022Actual Target for FY2023
  • 1. Deploy the management system established in FY2021 to all group companies.
The management system was deployed to all domestic group companies. Deploy the responsible mineral procurement management system to overseas group companies for faster and more accurate procurement activities.
  • 2. Audit at least two suppliers that use tin, tantalum, tungsten, and gold to better understand the status of suppliers and enhance information disclosure.
  • ・Conducted audits of two suppliers conducted to understand their activities and shared information on the policies.
  • ・One supplier was requested to improve its procedures and agreed to do so
Audit at least two suppliers that use tin, tantalum, tungsten, and gold to better understand the status of suppliers and enhance information disclosure.

Responsible Mineral Procurement Survey

To ensure that customers can use ROHM products with peace of mind, the Supply Chain Management Headquarters plays a central role in conducting the following assessment processes in accordance with OECD Due Diligence Guidance.

Mineral Procurement Survey Process

STEP1 : Construction of a Management System
  • ・ROHM uses the Sustainability Guidebook, an in-house educational material on sustainability, and our website to inform people both inside and outside the company about ROHM Group's Responsible Mineral Procurement Policy.
  • ・ROHM provides education on responsible mineral procurement to procurement division staff in charge of surveys, in an effort to increase their knowledge, understanding, and motivation regarding the initiatives.
  • ・ROHM has established a system for surveying and assessing the risk of 3TG, cobalt, and mica contained in its products in cooperation with related departments in Japan and overseas in accordance with the group standards.
  • ・ROHM seeks the support of the suppliers for ROHM Group's responsible mineral procurement activities and asking for their cooperation in submitting consent forms.
  • ・ROHM appropriately manages and stores information on survey results in accordance with internal rules.
  • ・ROHM requests the suppliers to do business with RMAP-certified smelters at the time of survey request.
  • ・ROHM requests the suppliers to comply with ROHM Group's Responsible Mineral Procurement Policy and to sign an agreement. ROHM requests the suppliers to comply with ROHM Group's Responsible Mineral Procurement Policy and to sign an agreement.
STEP2 : Identifying and Assessing Risks in the Supply Chain
  • ・Selecting from parts and materials purchased annually those that need to be surveyed, we conduct surveys for suppliers using CMRT and EMRT provided by RMI.
  • ・ROHM collects and processes the data provided by the suppliers and identifies the supply chain down to the smelter level. We also ask suppliers to disclose the country of origin of the mines they use during the survey so that we can identify all countries of origin.
  • ・For smelters, ROHM confirms participation and completion of third-party audits such as the latest RMAP.
  • ・Conducting a risk assessment and identify risks within the supply chain.
STEP3 : Develop Strategies and Implement Measures to Address Identified Risks
  • ・To ensure continuous risk mitigation, ROHM establishes a Responsible Mineral Procurement Survey Plan every year, updates the latest information, and conducts due diligence as necessary.
  • ・For smelters that have not yet completed third-party audits such as RMAP, ROHM works with the suppliers to request third-party audits.
  • ・If a smelter is identified by a customer as a concern, ROHM confirms the issues raised, informs the customer of the nature of the risk, and discusses appropriate measures (e.g., re-inspection of the smelter) with the customer.
  • ・In the event that a relationship with armed forces or human rights violations becomes clear, we will promptly discuss with our business partners to suspend transactions.
STEP4 : Conducting an Audit of the Smelter's Due Diligence Status by an Independent Third Party
  • ・As a member of the JEITA Responsible Mineral Procurement Study Group and Smelter & Refinery Support Team, ROHM works directly with smelters to request third-party audits.
  • ・ROHM reviews RMI and smelter websites to confirm their participation and schedule for audits.
STEP5 : Annual Report on Supply Chain Due Diligence
  • ・ROHM's responsible mineral procurement initiatives will be disclosed annually on our website.

3TG Survey Results

In FY2022, ROHM Group continued to conducting a survey of the parts and materials it purchases. We carefully examined the responses, and for suppliers who used smelters that were not RMAP-certified or who responded at the company level, we requested a re-survey and due diligence in order to improve their responses' reliability.

  • ・Suppliers surveyed : 98 companies
  • ・Suppliers who provided survey responses : 98 companies, 100%
  • ・Specified smelters : 211 companies for all minerals (Of these, 206 have obtained RMAP certification for RMI)

3TG Survey Results (FY2022)

Gold Tantalum Tin Tungsten Total
All Smelters 99 35 39 38 211
Number of CFS*6 Certified Smelters 98 34 39 35 206
CFS*6 Certification Rate 99% 97% 100% 92% 98%
  • 6. CFS:Conflict Free Smelter ROHM defines a CFS as a smelter certified by the Responsible Minerals Assurance Program (RMAP) of the Responsible Minerals Initiative (RMI).

To date, our investigations have not confirmed the use of conflict minerals as a source of funding for armed groups.
In FY2022, the CFS rate was 98%, the same as the previous year, and alternative sources are being investigated for the remaining 2% of minerals that are not in the CFS.
In the unlikely event that the use of conflict minerals as a source of funding for armed groups is found in ROHM Group products in the future, we will take corrective measures as promptly as possible.

Cobalt and Mica Procurement

Cobalt is used in lithium-ion batteries, which are essential for electric vehicles, cell phones, and laptop computers, while mica is widely used for components in the fields of home appliances and next-generation energy. In the Democratic Republic of Congo (DRC), the world's largest producer of cobalt, and in India, where mica is mined, unsafe working conditions and child labor risks have emerged in recent years.

ROHM Group SCM Guidelines stipulate a labor and ethics policy that includes the prohibition of all forms of forced labor and child labor, and based on this policy, ROHM promotes responsible mineral procurement for minerals that it deems to be a risk. With regard to cobalt and mica, which have become a social issue as mentioned above, ROHM has determined that it is necessary to take immediate action and is conducting investigations using EMRT provided by RMI to ascertain the content of cobalt and mica, investigate the country of origin, and identify the smelter. ROHM will continue the same activities in the future, as we regard it as our mission to increase "transparency" in the responsible mineral supply chain.

Results of Cobalt Survey

  • ・Suppliers surveyed : 24 companies
  • ・Suppliers providing survey responses : 24 companies, 100%
  • ・Cobalt smelters identified: 83 companies

Cooperation with Industry Groups

ROHM is a member of the JEITA Responsible Mineral Procurement Study Group, which was established in 2012 with the aim of collaborating with industry and establishing researindustrial ch methods for responsible mineral procurement.
Every year, we participate in responsible mineral surveys held by the Responsible Mineral Procurement Study Group, and work to penetrate the industry supply chain. In order to respond to growing international demand, we are promoting responsible procurement activities through industrial activities, such as encouraging smelters that have not received RMAP (Refinery Audit Protocol) certification to undergo RMAP audits.

Cooperation with Industrial Associations

[ Voice of the Person in Charge ]

Expanding ROHM’s Advanced Initiatives Throughout the Supply Chain

ROHM has participated in the Responsible Minerals Trade Working Group (Japan Electronics and Information Technology Industries Association) since its inception to study effective measures. In addition, ROHM has been actively involved in RBA audits voluntarily for more than 10 years. As part of our responsibility as a company that respects human rights, we have been actively working to expand this initiative throughout our supply chain through such means as holding individual consultation meetings. We will continue to hold individual consultation meetings to help our suppliers resolve any questions they may have and to strengthen their initiatives. We will also conduct ongoing due diligence to ensure that all of our suppliers' smelters undergo the RMAP certification system promoted by RMI and obtain certification as compliant smelters. ROHM will continue to enhance the quality of our management by complying with laws and regulations regarding responsible mineral procurement, which is an important social issue, and build a supply chain that society and our customers can trust and rely on.

Caiyun Jiang Group Leader Procurement Department SCM Division
Caiyun Jiang
Group Leader
Procurement Department SCM Division



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