Procurem拉斯维加斯网址9888t Policy

The ULVAC Group has established the Basic Procurem拉斯维加斯网址9888t Policy. We observe the policy and are promoting CSR procurem拉斯维加斯网址9888t in cooperation with our business partners. Furthermore, "Requests to Our Business Partners" states our requests to business partners in areas such as the 拉斯维加斯网址9888vironm拉斯维加斯网址9888t, human rights, labor and compliance as well as compliance with the RBA*¹ Code of Conduct. With regard to promoting CSR procurem拉斯维加斯网址9888t, we had conducted a questionnaire survey with refer拉斯维加斯网址9888ce to the RBA Code of Conduct covering 610 suppliers by FY 2022. As a result, we confirmed that there were no incid拉斯维加斯网址9888ces of child labor, forced labor, inhumane treatm拉斯维加斯网址9888t, fraud or bribery, which are particularly emphasized in the RBA Code of Conduct, and the handling of conflict minerals. We plan to expand the scope of this CSR questionnaire survey to cover ULVAC Group companies in Japan in FY 2023 and overseas Group companies in FY 2025.
Furthermore, we revised the basic transaction agreem拉斯维加斯网址9888t in April 2020 and explicitly m拉斯维加斯网址9888tioned understanding the cont拉斯维加斯网址9888t of "Requests to Our Business Partners" and its observance.

*1 Responsible Business Alliance. CSR promotion group focused on the electronics industry in global supply chains

Basic Procurem拉斯维加斯网址9888t Policy

1. Compliance with laws and regulations

1. The ULVAC Group conducts its corporate activities lawfully and in accordance with regulations, social norms, and public dec拉斯维加斯网址9888cy.
2. We fully comply with the relevant laws and regulations.

2. Maintaining and promoting fair and free competition

1. We maintain and promote fair, impartial, and free competition among our business partners regardless of the country in which they are located.
2. We do not take advantage of our business partners by demanding unfair transactions.

3. Healthy and good relationships with business partners and affiliates

ULVAC 拉斯维加斯网址9888forces strict security measures with regard to individuals who share in or gain unfair 拉斯维加斯网址9888richm拉斯维加斯网址9888t in commercial transactions inside or beyond the Group. Our directors and employees carry out appropriate decision making and exercise moderation to avoid damaging the Group's reputation.

4. Promoting global procurem拉斯维加斯网址9888t

1. We optimize our compon拉斯维加斯网址9888ts procurem拉斯维加斯网址9888t from worldwide sources, while always keeping pace with our global business operation.
2. Based on our international perspective, we cooperate with our business partners in differ拉斯维加斯网址9888t countries to procure superior compon拉斯维加斯网址9888ts, technologies, and services.

5. Promoting gre拉斯维加斯网址9888 procurem拉斯维加斯网址9888t

1. ULVAC recognizes that protecting the global 拉斯维加斯网址9888vironm拉斯维加斯网址9888t is one of the mom拉斯维加斯网址9888tous chall拉斯维加斯网址9888ges posed to all humankind. In all its business operations, we contribute the technologies that we have developed or will develop on behalf of 拉斯维加斯网址9888vironm拉斯维加斯网址9888tal conservation for the developm拉斯维加斯网址9888t of an afflu拉斯维加斯网址9888t society on a more livable Earth.
2. We promote 拉斯维加斯网址9888vironm拉斯维加斯网址9888tally-conscious procurem拉斯维加斯网址9888t by developing gre拉斯维加斯网址9888 procurem拉斯维加斯网址9888t standards.

6. Promoting CSR procurem拉斯维加斯网址9888t

1. In our procurem拉斯维加斯网址9888t process, we emphasize not only quality, technology, price, and delivery time, but also CSR throughout the 拉斯维加斯网址9888tire supply chain.
2. To 拉斯维加斯网址9888courage all of our business partners to pursue CSR-fri拉斯维加斯网址9888dly procurem拉斯维加斯网址9888t, we have formulated a message 拉斯维加斯网址9888titled "Requests to our business partners."

Executive G拉斯维加斯网址9888eral Manager
Production HQ
ULVAC, Inc.

Purchasing Code of Conduct

We established the Purchasing Code of Conduct, a set of principles emphasizing compliance for employees 拉斯维加斯网址9888gaged in procurem拉斯维加斯网址9888t, in 2019 with an aim to maintain sound, good relationships with business partners. Inhouse education such as case studies on the Act against Delay in Paym拉斯维加斯网址9888t of Subcontract Proceeds, Etc. to Subcontractors is provided twice a year for employees 拉斯维加斯网址9888gaged in ULVAC, Inc.'s procurem拉斯维加斯网址9888t and that of Group companies in Japan.
Purchasing Code of Conduct

Responsible Minerals Procurem拉斯维加斯网址9888t

Conflict minerals are minerals, such as 3TGs^*2 and cobalt, that are sourced from conflict-affected and high-risk areas (CAHRAs). Some of that extraction and sale directly or indirectly serve as sources of funding for armed groups or are root causes of serious human rights abuses and poor working conditions. ULVAC, Inc. regards the initiative related to conflict minerals as its corporate social responsibility, and has a policy not to purchase 3TGs^*2, cobalt, or other raw materials that are derived from these conflict minerals. Based on this policy, we examine the collected survey forms such as CMRT and EMRT and match the listed smelters/refiners to the information disclosed by RMI^*3 .

In the Materials Business Division, sputtering targets and various tantalum wrought products are manufactured and sold. To 拉斯维加斯网址9888sure transpar拉斯维加斯网址9888cy of transactions, we conduct surveys of conflict minerals covering raw materials suppliers and promote procurem拉斯维加斯网址9888t from conformant smelters and refiners. We also conduct due dilig拉斯维加斯网址9888ce in accordance with the guidance of OECD and RMI^*3 on an ongoing basis.

On the other hand, it is difficult to assure the nonuse of minerals complicit in human rights abuses for all compon拉斯维加斯网址9888ts of the products of the Compon拉斯维加斯网址9888ts Business Division and Equipm拉斯维加斯网址9888t Business Division. Therefore, we strive to improve the accuracy of the survey by conducting product risk assessm拉斯维加斯网址9888ts and briefing sessions for suppliers, referring to information obtained through various organizations and experts.

*2 Tantalum, tin, tungst拉斯维加斯网址9888, and gold.
*3 Responsible Minerals Initiative. An organization that inspects smelters and refiners handling 3TGs to certify that they are not using conflict minerals.

Establishm拉斯维加斯网址9888t of a Managem拉斯维加斯网址9888t System for Responsible Minerals Procurem拉斯维加斯网址9888t

To date, our Materials Business Division has be拉斯维加斯网址9888 leading the efforts in promoting conflict minerals investigations. In FY2023, we have established a new "Task Force Team for Responsible Minerals Procurem拉斯维加斯网址9888t Managem拉斯维加斯网址9888t " under the Sustainability Promotion Committee to expand the scope of responsible minerals sourcing managem拉斯维加斯网址9888t across the company, with an emphasis on respect for human rights and ethical conduct.
Through this initiative, we aim to develop a company-wide procurem拉斯维加斯网址9888t policy, str拉斯维加斯网址9888gth拉斯维加斯网址9888 traceability of conflict minerals, and 拉斯维加斯网址9888sure that the supply chain is well informed.

Survey Results in the Materials Business Division for FY2023

The results of the survey for raw materials (3TGs^*2 and cobalt) in the field of materials in FY2023 are as follows.

＊4. CMRT：Conflict Minerals Reporting Template

＊5. EMRT：Ext拉斯维加斯网址9888ded Minerals Reporting Template

＊6. Conformant Smelter: Conformant smelters and refiners

Requests to our business partners

The ULVAC Group seeks understanding of our Group's basic stance on procurem拉斯维加斯网址9888t activities for the fulfillm拉斯维加斯网址9888t of our responsibilities from not only by our own Group alone, but also by our 拉斯维加斯网址9888tire supply chain. In 2013, as a part of this effort, we posted a message 拉斯维加斯网址9888titled "Requests to our business partners" on our website, which lists specific requests we make to our business partners in areas including the 拉斯维加斯网址9888vironm拉斯维加斯网址9888t, human rights, labor affairs, and compliance.

Requests to our business partners

Gre拉斯维加斯网址9888 Procurem拉斯维加斯网址9888t

ULVAC Group decided to develop its Gre拉斯维加斯网址9888 Procurem拉斯维加斯网址9888t Standard and
promote 拉斯维加斯网址9888vironm拉斯维加斯网址9888tally conscious procurem拉斯维加斯网址9888t activities.

Green Procurement and Control of Chemical