Procurement Policy

The ULVAC Group has established the Basic Procurement Policy, and we are promoting CSR procurement.
Furthermore, "Requests to Our Suppliers" states our requests to suppliers in areas such as the environment, human rights, labor and compliance as well as compliance with the RBA^*1 Code of Conduct. With regard to promoting CSR procurement, we had conducted a questionnaire survey with reference to the RBA Code of Conduct covering 1,100 suppliers by FY 2023. As a result, we confirmed that there were no incidences of child labor, forced labor, inhumane treatment, fraud or bribery, which are particularly emphasized in the RBA Code of Conduct, and the handling of conflict minerals.
In March 2024, in accordance with the RBA Code of Conduct, we established the ULVAC Group Supplier Code of Conduct. We have distributed it to our suppliers in Japan, requesting that they make every effort to comply.
In FY 2024, we have expanded the scope of the survey and are conducting it primarily with our key suppliers.
We plan to implement the survey at ULVAC's domestic and overseas group companies starting from FY 2025 onward.

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

Basic Procurement 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 decency.
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 enforces strict security measures with regard to individuals who share in or gain unfair enrichment 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 procurement

1. We optimize our components procurement 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 different countries to procure superior components, technologies, and services.

5. Promoting green procurement

1. ULVAC recognizes that protecting the global environment is one of the momentous challenges posed to all humankind. In all its business operations, we contribute the technologies that we have developed or will develop on behalf of environmental conservation for the development of an affluent society on a more livable Earth.
2. We promote environmentally-conscious procurement by developing green procurement standards.

6. Promoting CSR procurement

1. In our procurement process, we emphasize not only quality, technology, price, and delivery time, but also CSR throughout the entire supply chain.
2. To encourage all of our business partners to pursue CSR-friendly procurement, we have formulated a message entitled "Requests to our business partners."

Executive General Manager
Production HQ
ULVAC, Inc.

Purchasing Code of Conduct

We established the Purchasing Code of Conduct, a set of principles emphasizing compliance for employees engaged in procurement, 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 Payment of Subcontract Proceeds, Etc. to Subcontractors is provided twice a year for employees engaged in ULVAC, Inc.'s procurement and that of Group companies in Japan.
Purchasing Code of Conduct

Responsible Minerals Procurement

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 ensure transparency of transactions, we conduct surveys of conflict minerals covering raw materials suppliers and promote procurement from conformant smelters and refiners. We also conduct due diligence 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 components of the products of the Components Business Division and Equipment Business Division. Therefore, we strive to improve the accuracy of the survey by conducting product risk assessments and briefing sessions for suppliers, referring to information obtained through various organizations and experts.

*2 Tantalum, tin, tungsten, and gold.
*3 Responsible Minerals Initiative. An organization that inspects smelters and refiners handling 3TGs to certify that they are not using conflict minerals.

Establishment of a Management System for Responsible Minerals Procurement

To date, our Materials Business Division has been leading the efforts in promoting conflict minerals investigations. In FY2023, we have established a new "Task Force Team for Responsible Minerals Procurement Management " under the Sustainability Promotion Committee to expand the scope of responsible minerals sourcing management across the company, with an emphasis on respect for human rights and ethical conduct.
Through this initiative, we aim to develop a company-wide procurement policy, strengthen traceability of conflict minerals, and ensure that the supply chain is well informed.

Survey Results in the Materials Business Division for FY2024

The results of the survey for raw materials (3TGs^*2 and cobalt) in the field of materials in FY2024 are as follows.

※Scroll through the Table

Percentage of Survey Forms（CMRT^＊4, EMRT^＊5etc.）Collected	100%
Target Mineral	Gold	Tantalum	Tin	Tungsten	Cobalt	Total
Number of Smelters/Refiners	1	7	4	5	2	19
Conformant Smelter^＊6Certified Rate	100%	100%	100%	100%	100%	100%

*4. CMRT：Conflict Minerals Reporting Template

*5. EMRT：Extended 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 procurement activities for the fulfillment of our responsibilities from not only by our own Group alone, but also by our entire supply chain. In 2013, as a part of this effort, we posted a message entitled "Requests to our business partners" on our website, which lists specific requests we make to our business partners in areas including the environment, human rights, labor affairs, and compliance.