Responsible Minerals Procurement Policy

1. SUBLIME aims to realize a sustainable and responsible supply chain, and comply with all applicable laws and 　regulations while giving due consideration to human rights, the environment, ethics, etc.

2. In procuring mineral raw materials such as mica, we shall promote CSR activities with the understanding and cooperation of our supply chain to avoid risks (*) such as child labor and other human rights violations, financing of terrorists, money laundering, illicit transactions, and involvement in conflicts in high risk areas, so that our customers can use our products wiith confidence.

　（*）For risks, we follow the OECD Due Diligence Guidance Annex Ⅱ for Responsible Supply Chains of Minerals from
　　　　Conflict and High Risk Areas.
　　　　　--- Human rights violations related to mineral mining, transportation and trading
　　　　　--- Direct or indirect support for non-governmental armed groups
　　　　　--- Direct or indirect support for public or private security forces committing illegal

                       activities
　　　　　--- Bribery and misrepresentation of mineral origin
　　　　　--- Money laundering
　　　　　--- Unpaid government taxes, fees, and mining rights fees

Specific initiatives to achieve responsible mineral procurement include:

(a) Establishment of control systems
With regard to the procurement of raw materials such as mica, we will establish a system for conducting risk assessment (due diligence) of the raw materials procured and the supplier

(b) Identifying high-risk raw material procurement
Identify high-risk areas in accordance with guidance from the OECD and other organizations, and determine transactions suspected of involvement in risks such as human rights violations, financing of terrorism, money laundering, illicit transactions, and complicity in conflicts as high-risk procurements。

(c) Assessment of raw materials and suppliers
If the risk assessment of raw materials or suppliers determines that the risk is high, cooperate with suppliers in consultation to mitigate the risk. If risk mitigation is not possible, immediately discontinue the transaction

(d) Monitoring and record keeping of transactions
We monitor incoming raw materials for consistency with information obtained from suppliers, and maintain their records appropriately.

(e) Implementation of training
We will continuously educate and train our personnel involved in the procurement of raw materials to ensure responsible mineral procurement. We will also communicate our approach to raw material procurement to our suppliers and educate them to engage in responsible mineral procurement throughout the supply chain.

(f) Third-party audits
We arrange for an independent third-party audit on the responsible supply chain management system and implementation status on a regular basis. We also conduct regular audits of our suppliers, either by us or by an independent third party.

(g) Annual Reporting
Report the details of due diligence conducted on raw materials and suppliers on an annual basis in the Company's CSR report.