Responsible Mineral Sourcing

Responsible Minerals Sourcing

Policy for High Risk Minerals

Profits from the extraction and sale of minerals such as tin, tantalum, tungsten, and gold (3TG) in conflict-affected and high-risk areas such as the Democratic Republic of the Congo (DRC) and neighboring countries are a source of funding for armed groups and anti-government forces carrying out atrocities and human rights abuses. Furthermore, it has been pointed out that cobalt mines in the southern part of the DRC have become breeding grounds for child labor.

It is Epson’s corporate policy to avoid engaging in any form of human rights violations or environmental destruction. While sourcing minerals that originate in conflict-affected or high-risk areas, we will not tolerate any form of human rights violations or abuses. We will not engage in business relationships with any party involved in human rights abuses, nor will we support operations that result in the degradation of socioeconomic and environmental conditions.

Management of Epson recognizes that responsible sourcing of minerals is a societal issue that needs to be addressed. In order to confirm the responsible sourcing of minerals throughout the entire supply chain, we advocate the establishment of a survey system in the Principles of Corporate Behavior and further define the details of our efforts as "key sustainability themes".

Moreover, as a member of the Responsible Business Alliance (RBA) and the Responsible Minerals Initiative (RMI), we require our suppliers to adhere to this policy and expect them to require compliance within the supply chain.

We also ask them to understand and comply with the Epson Group Supplier Guidelines and the Epson Supplier Code of Conduct (RBA Code of Conduct).

Epson has direct material suppliers submit an agreement letter stating that they will comply with responsible mineral sourcing requirements.

Conflict Minerals Survey Program

Epson recognizes that the responsible sourcing of minerals is an important societal issue that it should address. To ascertain whether minerals are being sourced responsibly throughout the supply chain, Epson has established a survey system as stated in Principles of Corporate Behavior. The nature of actions to be taken is set forth in Key Sustainability Topics. Policies and results are discussed and reported at meetings of the Sustainability Strategy Council, a corporate management meeting that includes members of the board of directors.

Epson also established the Epson Group Responsible Minerals Survey Standard and is implementing a survey program across the entire Group in accordance with Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas issued by the Organization for Economic Co-operation and Development (OECD). Using the Conflict Minerals Reporting Template (CMRT) for 3TG and the Extended Minerals Reporting Template (EMRT) for other minerals, including cobalt and mica, provided by the RMI, we identify upstream smelters and refiners of conflict minerals (tin, tantalum, tungsten, gold, and cobalt) with the cooperation of direct material suppliers. We also check the country of origin by obtaining answers about the supply chain.

We ask our suppliers to source minerals only from conflict-free smelters (CFS) certified by RMI’s Responsible Minerals Assurance Program (RMAP). If suppliers indicate that they are unable to determine whether the source smelter is a CFS, Epson tries to avoid or mitigate risk by asking them to do additional checking or to source minerals from a different supplier.

Epson holds supplier conferences for CSR at our manufacturing sites around the world. We use these conferences as well as other opportunities to promote understanding of Epson policies, ask suppliers to improve survey accuracy, and share information about trends involving conflict minerals.
We also endeavor to educate suppliers about survey templates and foster understanding of the surveys. Epson will continue working with suppliers to make sure the minerals used in our products fulfill the standards set in our responsible minerals sourcing policy.

To responsibly source minerals used in Epson products, our program follows a five-step framework according to the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas issued by OECD.

STEP 1: Establish strong company management systems.
Epson establishes a Group-wide policy, implements a supply chain due diligence program, concludes written agreements with suppliers, and establishes a grievance mechanism.

STEP 2: Identify and assess risks in the supply chain.
Epson identifies and assesses risks in our supply chain by conducting surveys.

STEP 3: Design and implement a strategy to respond to identified risks.
Epson reports the results of risk assessments to the Chief Procurement Officer, discusses risk mitigation plans with tier 1 suppliers, and monitors their performance.

STEP 4: Carry out an independent third-party audit of the smelter/refiner due diligence practices.
Epson uses the results of the RMI's Responsible Minerals Assurance Program (RMAP) is assessments.

STEP 5: Report annually on supply chain due diligence.
Epson discloses its due diligence status on the company’s official Web site, in the annual integrated report, and in other media formats.

Survey Results

Epson conducts surveys using the reporting templates (CMRT and EMRT) provided by the Responsible Minerals Initiative (RMI). The CMRT and EMRT allow users to select one of three declaration scopes: (1) Company-wide, (2) Product (or List of Products), or (3) User-Defined. However, Epson asks that suppliers select Product and answer with respect to specific products that are delivered to Epson so that we can verify the smelter of the minerals included in parts and materials used in Epson products. We believe that conducting the survey in this way will enable us to identify where we should mitigate risk and will result in effective due diligence.

In 2022, Epson conducted a survey of 3TG and cobalt and received completed surveys from 99% of the suppliers of parts/materials containing 3TG and 97% of the suppliers of parts/materials containing cobalt. We analyzed suppliers’ answers and provided them with individual feedback based on the results within about a month or two. Suppliers with identified risks were asked to submit a corrective action plan and mitigate those risks.

Confirmed risks
•There are smelters that cannot be identified.
•Some smelters have not been certified as conforming to RMAP (including smelters in high-risk areas).

Risk management plan
•Explained and proposed possible risk mitigation measures to suppliers.
•Asked suppliers to submit a plan for addressing identified risks.

Tracking and monitoring of suppliers' risk mitigation efforts
•Meetings were held with individual suppliers to ascertain whether they have mitigated identified risks in their parts and supply chains.
•The results of surveys from suppliers who were asked to resubmit them were re-analyzed.

Concrete examples of risk mitigation
•We asked suppliers that were unable to identify smelters used for multiple minerals, including gold, to recheck whether they used a smelter that is not RMAP certified. As a result, it was found that no minerals from that smelter were used in parts delivered to Epson.
•We asked suppliers that sources tin in a procurement route that includes a smelter or smelters that is/are not RMAP certified to switch to a different source (or procurement route). We confirmed that the supplier made the change.

Epson is not required to report to the US authorities as we are not listed in the United States, but we do disclose identified smelter and refiner information (name, CID code, and country).

3TG Survey Results

  FY2020 FY2021 FY2022
Total Tin Tantalum Tungsten Gold
Number of identified smelters1 340 406 349 86 36 52 175
Number of CFS2 242 244 229 63 34 37 95

Supplier response rate

97% 99%

99%

 -  -  -  -

1 For information (name, country, etc.) on identified smelters, see "“List of the smelters and refiners identified in Seiko Epson’s Supply chain which were known by RMI"(PDF 298 KB)
2 Conflict-free smelters (CFS) certified by RMI's Responsible Minerals Assurance Program (RMAP).
  For detailed information on conflict minerals surveys for individual products, please contact your local Epson sales company.

Cobalt survey result

  FY2021 FY2022
Number of identified smelters 86 69
Number of CFS1 23 35

Supplier response rate

 98% 

97%

1 Conflict-free smelters (CFS) certified by RMI's Responsible Minerals Assurance Program (RMAP).
  For detailed information on conflict minerals surveys for individual products, please contact your local Epson sales company.

3TG survey results (for procured parts)

About 44% of the 80,000 parts and materials that were subject to the 2022 survey contained 3TG. We were able to determine that 65%(roughly 23,000 parts) of these were sourced from RMI-certified conformant smelters.

Information and education to suppliers

Epson believes that responsible sourcing of minerals is an important societal issue that needs to be addressed, and since supplier cooperation is essential for achieving this, Epson strives to inform and educate its suppliers.

Throughout the year, we provide the following tools and information to ensure that suppliers always have up-to-date and easily accessible information:
- Excel Check Tool to check a smelter’s or refiner’s RMAP certification information
- RMAP certification renewal information for smelters and refiners

In addition, we analyze the answers of suppliers who complete the surveys and provide them with detailed feedback on results, indicating what might have been missing and where risk avoidance or mitigation measures are needed.

The feedback, which is issued on each reporting template, is intended to clearly indicate where a supplier needs to exercise due diligence.

We also explain the reporting templates and provide individual support for completing them in response to requests from suppliers.

Third-Party Audit Results

Epson’s global manufacturing sites undergo RBA VAP audits. All sites that underwent a VAP audit between 2021 and 2022 were found to be in conformity with the RBA’s responsible sourcing of minerals (D7) criteria.

Manufacturing Site Country Main Products Manufactured
PT. Indonesia Epson Industry Indonesia Printers
PT. Epson Batam Indonesia Printers
Epson Engineering (Shenzhen) Ltd. China Printers
Projectors
Robots
Epson Precision (Philippines), Inc. Philippines Printers
Projectors
Epson Precision (Thailand) Ltd. Thailand Device products
Epson Precision Suzhou Co., Ltd. China Device products
Epson Precision Malaysia Sdn. Bhd. Malaysia Device products

Summary of the RBA Code of Conduct requirements for the responsible sourcing of minerals D7):
Participants shall adopt a policy and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, and gold in the products they manufacture to reasonably assure that they are sourced in a way consistent with the Organization for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas or an equivalent and recognized due diligence framework.

Partnerships with External Organizations

The conflict minerals problem is a global issue that we cannot solve alone. We are therefore participating in alliances and initiatives to address the issue of conflict minerals and to enhance conflict minerals surveys in global supply chains.

We support and actively participate in the programs of the Responsible Minerals Initiative (RMI), which was established to address responsible mineral sourcing issues, and of JEITA, a domestic Japanese industry association.

Domestic Japanese industry initiative
The Japan Electronics and Information Technology Industries Association (JEITA), Responsible Minerals Trade Working Group

Some of the activities of JEITA
- Collaborating with international initiatives such as RMI/GeSI
- Monitoring and sharing information on the regulatory situation in various countries and regions
- Educating and raising awareness among suppliers
- Pressuring smelters that are not RMI-certified to undergo for audits

Reporting to Mitigate Mineral Sourcing Risks

Epson complies with the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accepts reports from suppliers concerning mineral sourcing risks.


How to report:

  • For suppliers of domestic Japanese Epson Group companies: Link
  • For suppliers of Epson Group companies outside Japan: Use the reporting channel of that company. Link (PDF339kb)
    You may also use a comments/opinions box located in the Epson facility.

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