RESPONSIBLE PRECIOUS METALS MANAGEMENT POLICY

Axvircle Co., Ltd. (hereinafter referred to as ‘the Company’) shall, in its trading of precious metals (gold, silver, platinum, and palladium), the Company shall, in accordance with the Axvircle Code of Conduct, avoid transactions with regions involved in human rights abuses, money laundering, and other illicit activities. It should prohibit the financing of conflicts and terrorism. Furthermore, based on the guidance established by the LBMA(※1) and LPPM(※2), the Company shall promote the management of precious metals within its supply chain as outlined below.

The Company shall appoint an overall officer responsible for precious metals management. A management framework shall be established under the appointed management officer to promote responsible precious metals management.

Based on the ‘Guidelines for Respecting Human Rights in Responsible Supply Chains’ established by Japan's Ministry of Economy, Trade and Industry in September 2022, we will identify and assess risks of human rights violations within our supply chain regarding ‘adverse impacts (identification and assessment of human rights violation risks)’ (※4).

We will provide necessary education and training to employees involved in responsible precious metals management.

We shall undergo regular audits by independent third-party organizations regarding the structure and operational status of our responsible precious metals management system.

(※1) London Bullion Market Association
(※2) London Platinum and Palladium Market
(※3) LBMA Responsible Gold Guidance, LBMA Responsible Silver Guidance, LPPM Responsible Platinum and Palladium Guidance
(※4) These guidelines were established based on the UN Guiding Principles, the OECD Guidelines for Multinational Enterprises, and the ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy, among others.

Established: June 2024
Axvircle Co., Ltd.
President and Representative Director
Yuto Kamijo