A.L.M.T. Corp.

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Conflict Minerals Control Policy

A.L.M.T. Corp. (hereinafter referred to as "the company") will comply with the Organization for Economic Co-operation and Development "Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict Areas and High Risk Areas, 3rd Edition (OECD Guidance). The company also recognize and actively support international efforts to investigate, monitor and mitigate activities that contribute to illegal armed groups, human rights abuses or financial misconduct in the Tungsten supply chain.

1. Management System and Responsibility

Among the four conflict minerals, the company smelts tungsten alone. Furthermore, all raw tungsten materials are procured by our Procurement Department and then supplied to our factory under the control of the company. Our factory does not procure any raw tungsten material independently.

In order to promote conflict mineral management, the company appoints a compliance officer who is tasked with organizing related sections and departments to establish a management system.

2.Criteria for Raw Material Procurement from High Risk Countries

Minerals that may pose a risk of harm listed in Annex II of the OECD Guidance are considered "conflict minerals". Tungsten-containing materials should only be purchased from sources that have been identified as non-conflict minerals.

3.Due Diligence of Raw Material Supplier

The company carry out the following due diligence and risk assessment to all of the supplier of tungsten raw materials.

  • Carry out due diligence with relevant suppliers and encourage suppliers to do likewise in accordance with the OECD Due Diligence Guidance and the Responsible Business Alliance's Responsible Mineral Guarantee Process (RMAP).
  • Expect our suppliers to provide due diligence information that to ensure not contributing to illegal armed groups, human rights abuses, or financial misconduct under OECD Guidance Annex II as to materials including tungsten in whole supply chain.
  • Aim to establish long-term relationships with direct suppliers.
  • Consider ways to build and support to improve the supplier’s conflict mineral policy.
  • Suspend or discontinue business with the supplier whose risk mitigation attempts have failed.
  • Immediately discontinue engagement with the supplier that could cause serious human rights abuses.
  • Conduct assessment of annual RMAP to ensure conflict-free conditions and continually improve the due diligence management system for conflict minerals.
  • The company promises transparency in the implementation of this policy by providing progress reports to Customer, relevant stakeholders, and the general public (if necessary).

4.Monitoring of Purchased Raw Material

Any raw material purchased by the company is supplied to our smelters. The smelters physically check the material for all accepted lots, compare it with the information presented by the seller which is then provided by the Material Department beforehand and finally report the result of the comparison to the Head Office.


The compliance officer provides opportunities of education and training to the Material Department, our smelters and to other related sections and departments at any point in time and depending on the situation where such education and training are considered to be necessary.

6.Audit by Third Party Organization

For the purpose of verifying the suitability of the control system and its enforcement, the company undergoes an audit conducted by an independent third-party organization on a periodic basis.

7.Retention of Records

The administrative officer defines the types of documents that need to be retained regarding the conflict mineral management and decides the limit of retention time for the purpose of control.

Compliance Officer
 Appointed by Compliance Committee
Person Subject to Control
Administrative officer in Material Department: General Manager of the Department
Administrative officer in smelters: Director of Powder Alloy Division
Control Item
Due diligence of raw material recipients
Business procedures for comparison of records between receipt and shipping
Retention of Records

Established on November 28, 2014
Revised on August 27, 2021