Kaga Electronics (the “Company”) has established environmental policies and practices management that benefits the environment. We promote green procurement as an important part of this. These Green Procurement Guidelines (the “Guidelines”) set out green procurement standards, which constitute Kaga Electronics’ basic stance on green procurement. The Guidelines’ purpose is to ensure compliance with environmental laws and regulations and mitigate environmental impact by clearly and concretely defining what we ask of our suppliers of components, materials, units, products, secondary materials, and more (“supplies”).
The Company considers our basic principle of green procurement to be the procurement of supplies with a small environmental impact from suppliers that actively promote environmental conservation.
[1 Priority Procurement]
As part of the initiatives we are promoting under management that benefits the environment, the Company has obtained ISO 14001 certification and puts it into practice. When procuring supplies, we prioritize suppliers who actively implement initiatives for environmental conservation.
The Company’s Management Standards for Chemical Substances in Products
[1 Scope of Application]
The Guidelines apply to all components and materials (components, materials, units, products (including OEM/ODM products), and secondary materials) procured by the Company for use in electric and electronic products. Additionally, in the case of supplies outside of electric and electronic products (toys, medical devices, automotive products, etc.), cases when separate standards are presented by clients of the Company, etc., the Company may request measures that correspond to management standards that differ from the content of the Guidelines.
[2 Substances Prohibited from Use in Supplies (Prohibited Substances)]
Prohibited substances are substances whose use is prohibited, in principle. The Company’s prohibited substances are equivalent to the standards of International Standard IEC 62474 (*1), and consist of chemical substances whose use is prohibited or restricted under laws and regulations in Japan and overseas. We have presented our standards for the management of prohibited substances in Appendix 1 of the “Standard for the Management of Chemical Substances (Version 3.0)” (the “Standards”), so please ensure that supplies to the Company satisfy the management standards set forth in Appendix 1; provided, however, that the use of substances stipulated in the “RoHS Directive of the EU (2011/65/EU)” is possible for applications where it is stipulated that the directive does not apply. (See Appendix 5 of the Standards.) In cases where there are separate requirements from clients of the Company, etc., the Company may request measures that correspond to management standards that differ from the content of the Guidelines.
[3 Substances for which Information Concerning their Content in Supplies is to be Reported (Substances Subject to Content Reporting)]
The intentional use of substances subject to content reporting is not restricted, but in cases when they are contained in concentrations that exceed standard values, the parts that use these substances and the amount contained should be ascertained, and they should also be appropriately managed from the perspective of considerations when products are recycled and the environmental impact at the time of disposal. We have indicated the minimum substances subject to reporting in Appendix 2 of the Standards. If substances subject to reporting are contained in supplies, please report content information, such as the amount contained, parts that use substances, etc., in a “chemSHERPA – AI File” (*2), etc.
In order to promote green procurement, Kaga Electronics requests the following from suppliers, who are our business partners: (1) “Submission of receipts, etc., and conclusion of agreements to the effect that suppliers will comply with the Guidelines,” (2) “Creation and assessment of systems for managing chemical substances in products by suppliers,” (3) “Conclusion of agreements to ensure the environmental quality of supplies,” and (4) “Submission of documents related to information on chemical substances in supplies.” We request that our suppliers understand and cooperate with the intent of these requests. In cases where there are separate requirements from clients of the Company, the Company may request measures that correspond to requirements from clients.
[1 Submission of Receipts, etc., and Conclusion of Agreements to the Effect that Suppliers will Comply with the Guidelines]
The Company requests the submission of receipts, etc., after receiving the Guidelines of the Company, to confirm the agreement to comply with the content of the Guidelines. In order to ensure the environmental quality of items procured, the Company may also request the conclusion of agreements, memoranda, statements of agreement, etc., concerning chemical substances in products. (This content may also be included in basic agreements, business agreements, etc.) When there are separate clauses related to chemical substances in products, the separate specifications shall be prioritized. The Company shall take due care with regard to the confidentiality of information submitted.
[2 Creation and Assessment of Systems for Managing Chemical Substances in Products]
The Company requires that suppliers create systems for managing chemical substances in products. In order to confirm the creation of these systems, the Company performs assessments of suppliers’ systems for managing chemical substances in products. In principle, the Company requests that the management of chemical substances in products supplied conforms with the “Guidelines for the Management of Chemicals in Products” issued by JAMP (*4). The Company assesses management systems based on the results of self-audits conducted by suppliers or audits conducted by the Company, using materials such as the “Guidelines for the Management of Chemicals in Products (Edition 4.0) Annex Check Sheet (Version 4.01)” issued by JAMP.
[3 Submission of Documents Related to Information on Chemical Substances in Supplies]
The Company requests that suppliers survey the chemical substances in supplies and submit the following documents: ○ Documents whose submission is required: ・ Statement proving the non-use of prohibited substances; ・ Information on chemical substances in products (submitted via chemSHERPA – AI File, etc.); in principle, the Company requests that suppliers provide information concerning all chemical substances content. ○ Documents whose submission may be required depending on the type of supplies and necessity: ・ ICP analysis data (substances restricted under the RoHS Directive); ・ MSDS, MSDS plus, component tables, mill sheets; ・ Other, documents required by the Company’s clients, etc.
[4 Acceptance Management]
When accepting supplies, please confirm and record that the supplies satisfy the management standards of the Company. It is also important to clarify the method of confirmation at the time of acceptance. (Evaluation method, recording method for evaluation results, identification management method, etc.)
[5 Shipping Management]
Before shipping supplies, please check that the standards for managing chemical substances in the products to be shipped have been satisfied, and record the results of this check. As part of the acceptance and manufacturing process, please reconfirm that all predetermined checks have been performed, and manage product warehouses to ensure there are no mistaken shipments or contamination.
[6 Change Management]
If there are any changes to the following information on chemical substances in supplies, please immediately notify the Company, and make the changes after first acquiring information concerning chemical substances in products and checking compliance with management standards, submitting this information to the Company, and obtaining permission from the Company in advance. (1) Changes to the raw materials or components used; (2) Changes to the suppliers of raw materials or components used; (3) Changes to manufacturing locations or contracted manufacturers; (4) Changes to manufacturing methods; and (5) Other changes that may impact the information on chemical substances content.
[7 Management of Non-conformance]
In the event of any non-conformance in the information on chemical substances in supplies, the Company requests that suppliers promptly notify the Company and related parties, clarify any non-conforming lots, suspend shipments and prevent distribution of these lots, and perform the following management of non-conforming items: (1) Immediately notify the Company of any non-conformities; (2) Identify, separate, suspend shipments, and prevent distribution of non-conforming items (including lot tracing); (3) Assess non-conforming items and formulate measures for rectification; (4) Formulate measures to prevent similar incidents in advance; and (5) Submit and retain related records (reports).
[8 Traceability]
In order to perform management in a way that ensures the following items, etc., can be traced from products shipped, please create records, such as lot management record slips and production record slips, and manage the history of products. (1) Constituent components and information on chemical substances in those products; (2) Manufacturing dates and manufacturing lot numbers; and (3) Manufacturing plants and contracted external parties.
[9 Document and Record Management]
Please systematically manage requirements from the Company related to the management of chemical substances content, as well as information on chemical substances content and management records obtained from suppliers, by organizing related files or electronic media and creating lists of documents. In principle, please retain the latest version of requirements from the Company, and ensure that they are available for viewing by related departments, through their distribution, the internal intranet, etc. The retention period for documents is 10 years.
* Under the revised RoHS Directive (Directive 2011/65/EU), documents shall be retained for 10 years.