1. Procurement policy:

  Global Procurement Basic Policy 1, Compliance with Laws, etc., and promote procurement activities that comply with all relevant laws and social norms. 2. FairnessFair trade is based on reasonable processes established to provide fair opportunity and competition. 3. The construction of partnership attaches importance to mutual understanding and trust with suppliers, and is committed to building a better partnership. 4. Caring for the environmentWe understand that protecting the global environment is a corporate social responsibility, and promote procurement activities that fully care for the environment.

2. Supplier selection:

Trends (information) of chemical substance regulations and their requirements
1 Is it necessary to manage chemical substances??
(Refer to Nikkei Ecology's April issue "Chemical Substances Attacking Companies" and Nikkei Electronics' March 3 issue "Green Challenge").
A) With the increasing environmental requirements and tightening regulations, it is necessary to control the purchase of finished products that "contain prohibited chemical substances".
B) If you cannot respond positively, it will be directly related to whether you can sell or not.
C) The consequences of this will have a significant impact on the operations and performance of each enterprise.
d) In Europe, the application of the RoHS directive has been since July 1, 2006Effective from the date of implementation. (The target substance is 3-B)
If the specified substance is contained, including the "in the library" at that time, It will all stop selling. To take into account the flow in the library, there are many places that start using it 1.5~2.0 in advance
(June 2004 or 2005End of March) Implementation.
All finished products (shipped to Europe) were abandoned by our company as of February 2004.
E) Regulations (European (EU) directives or Japanese law) are subject to changeIt is necessary to pay attention to their movements.
F) When it is time to correspond to previously designed products, "design changes" must be made.
2. A
) We hope that everyone will realize the necessity of conducting a new part chemical substance survey issued by our company.
1) Sample books and environmental surveys can be placed at the same level, and without them, they cannot be purchased.
2) The prohibition of chemical substances will become part of the sample book.
3) For steel plates, the material of the parts determined can be investigated according to the supplier's material composition table.
(However, there are post-processed ones (such as electroplating), In addition to the composition table, some data is required. For example, Cd pollution is also considered in the resin molding process, so only
the ingredient list is not enough. 4
) For packaging materials, it is necessary to comply with the "Packaging Directive (3-C) Refer to ", this directive has been implemented and it is necessary to correspond.
( Cd (cadmium), Pb (lead), Hg (mercury),The total of 4 heavy metals of Cr+6 (hexavalent chromium) is less than 100ppm).

B) Major trends (points for future review) 1)
Cadmium(CD): In particular, resins (cushioning materials such as molded products or styrofoam) and printing inks used in resins ( The part directly touched
by the person) is forbidden to contain cadmium.
2) Lead: Lead-free (solder) direction
3) Hexavalent chromium...Non-chromated direction
chromium plating: It is more likely to be replaced by "trivalent chromium plating".
Galvanized steel sheet (sheet metal processing material): The use of chromium-free materials tends to
be 3 Developments in the European Directive (Regulation) (Reference): This article is mainly related to item B, item C is related.
A) ELV Directive (End of Life Vehicle): 2003 7Implemented
on January 1) 4 heavy metals (Cd (cadmium) in scrap cars), Pb (lead), Hg (mercury), Cr+6 (hexavalent chromium) The limit is Pb· Hg·
Cr+6 stipulates that 0.1Wt% (weight %) or less (=1000ppm or lessCd<0.01 Wt% (below 100 ppm) 2)
Automotive side, there will definitely be requirements.

B) RoHS Directive (Restriction of the Use of Certain Hazardous Substances): Implemented on July 1, 2006.
1) Chemical substances are cadmium (Cd), lead (Pb), mercury (Hg) "Hexavalent chromium (Cr+6)" "PBB (polybvominated
biphenyls)" PBDE (polybvominated diphenyl ethers)" 6 substances.
2) There are also exceptions (excluded) uses. (Please refer to the "List
of Substances Excluded under RoHS" 3 in the "List of Substances Subject to Investigation" that has been commissioned for investigation.), but possibly with the ELV directive as standard. (3-A)-1) See) 4)
As for the implementation date, "First put the product on the shelf (i.e., the warehouse at that time will also be used as the corresponding objectis the most reliable method.

C) Packing Directive: Implemented.
1) The chemicals targeted are cadmium (Cd), lead (Pb), and mercury (Hg)."Hexavalent chromium (Cr+6)" 4 kinds.
2) The above four types contained in the "itself" and "printing ink" of the packaging material are 100ppm in totalHereinafter.
3) It is necessary to measure each part of the baling material (itself or the ink part).
4) Foam used as a cushioning material is also one of the targets.
D) WEEE Directive (Waste Electrical & Electronic Equipment): 2003Effective
February 13 1) This directive is not directly related to chemical substancesAs intelligence is for informational purposes only.
2) Promotion of waste electrical and electronic equipment: Promotion of necessary reuse.
3) This directive covers 8 categories of products, and CDs belonging to "3.IT communication equipment" are among our productsand audio equipment that falls under "4.AV Related Equipment"
may be targeted.
4) The manufacturer has an obligation, which refers to the "group that manufactures and sells with its own brand", "the group that sells with its own brand
", "the group that imports or exports professionally": and costs will certainly be incurred in the process of fulfilling the obligation.
5) By August 31, 2004, European countries will codify the WEEE Directive.
6) Application after 30 months after the effective date of the Directive. (2 and a half years later: August 2005).
4. Japanese law (reference): This article is mainly related to item A. (Note future revisions, etc.)
A) Censorship Act = Act
on the review of chemical substances and regulations on manufacturing, etcThe first specific chemical substance is prohibited from manufacturing other than licensed productsImports (de facto prohibited substances)
·The second specific chemical substance: manufacturingWhen importing, it is necessary to declare the intended annual quantity
Designated chemical substances (422 types): Manufacturing·When importing, it is necessary to declare the annual amount

of the previous year B) PRTR Act (Chemical Substance Management Promotion Act) = Measurement and management of the amount of specific chemical substances emitted into the environment, improvement of the law
PRTR = Pollutant Release and Transfer Register
·1st designated chemical substance = PRTR and MSDS (Article Safety Data Sheet = Material Safty Data Sheet) Objects
of both partiesDesignated chemical substance No. 2 = only the subject substance

of MSDS C) Ozone layer protection law = laws related to the protection of the ozone layer according to the provisions of specific substances (Flon, Halon, etc.)

D) Soil pollution prevention law: trichloroethylene, salted Methylene, etc

E) Air pollution prevention law: asbestos

F) Water pollution prevention method: dichromic acid

G) Highly toxic law: poison and violent substance prohibition law
<b1528 >H) Occupational Safety and Health Act: azo (AZO) compounds, asbestos Class I

) Fire Protection Act: gasoline, heavy oil, light oil, etc

K) Laws regulating household products containing harmful substances: formaldehyde, etc

3. Green Guarantee:

3.1: Overview of the RoHS Directive published by the European Union on February 13, 20032002/95/EC), ignited the spark of the green industrial revolution, the industry began to re-examine corporate social responsibility, but also began to re-examine those familiar processes and materials, environmental protection and RoHS, of course, has become a frequent word in the industry. In order not to be blocked from the entry threshold of commodity trading on July 1, 2006, the industry began to urgently mobilize to investigate the content of hazardous substances in materials, study alternative material solutions and alternative process conditions. At this time, enterprises have re-recognized the importance of "source flow guarantee". Shinano Silk Co., Ltd. of Japan and its subsidiaries Dongguan Shinano Motor Co., Ltd. and Hong Kong Shinano Co., Ltd. have also joined the environmental protection army of "green procurement" and "green manufacturing". At the end of 2003, the company began to promote "green procurement" activities and "reduction of hazardous substances" in response to customer requests Under the premise of thorough investigation, we will formulate a plan for the reduction of hazardous substances, promote the replacement of materials and processes in stages, and establish an internal management system. We have made due contributions to pollution prevention. At the same time, we also realize that environmental protection requires the joint efforts of the entire supply chain, and the strong cooperation of suppliers to truly achieve "source flow guarantee". Therefore, we formulated the [Green Procurement Technical Standard], and the company's production activities are implemented in accordance with this standard, and we invite suppliers to work with us for environmental protection. If the RoHS Directive only restricts 6 toxic and harmful substances, it can only be regarded as a spark, June 1, 2007The EU REACH law rules, which came into effect today, have once again caused a commotion in the industry. The REACH regulation has been expanded to cover all chemicals, and has completely changed the long-held concept of "safety without proof of toxicity" to "If there is no evidence to prove that it is safe, it is not safe", not only chemical manufacturers, but also finished product manufacturers will face the market risk of "no data, no market". In particular, in fact, the requirements of customers have exceeded the requirements of the above-mentioned RoHS directive and REACH regulation, because these two directives and regulations have awakened everyone's awareness of environmental protection and noticed the risk of violating environmental protection requirements, so they are responding to RoHSAt the same time, the requirements of the target market country/region are inventoried, and the environmental protection requirements such as the battery directive, cadmium directive, chemical review law and other environmental protection requirements of their own company are integrated into it, and the limit value is slightly tightened on the basis of considering the measurement error.

3.2: RoHS Directive Introduction The full name of the RoHS Directive (2002/95/EC) is [on the restriction of the use of certain hazardous substances in electrical and electronic equipment], translated as Chinese [restricting the use of certain hazardous substances in electrical and electronic equipment], the core content is to prohibit the intentional addition of lead, cadmium, mercury, hexavalent chromium, PBB, PBDE in eight categories of electronic and electrical productsThe content of the six toxic and hazardous substances, when present as impurities, must also be less than the specified limits (lead, mercury, hexavalent chromium, PBB, PBDE limit of 1000PPM, cadmium limit value100PPM。 Of course, because the current level of technology is temporarily irreplaceable or the benefits of use are greater than its harm, an exemption can be obtained after assessment. After several years of practice, the RoHS Directive was amended again on July 1, 2011 (2011/65/EUEffective July 21, 2011, the revision expands the scope from eight categories of electrical and electronic products to all electrical and electronic products, and clarifies the timing of phased integration of medical and surveillance equipment. As for the banned substances, the previous six substances were remarked, but it was proposed that the review would focus on hexabromocyclododecane (HBCDD), three phthalates (DEHP, BBP and DBP). ) and nanomaterials. Products that meet the requirements must bear the CE mark. The exempted items and timing were re-evaluated. At the same time, it strengthens the legal obligations of manufacturers and importers.

3.3 REACH Regulation Introduction To prevent and protect human health and the environment as the principle, for the purpose of controlling the danger of chemical substances, the European Union has formulated and promulgated REACH regulation, REACH is [Concerning the Registration, Evaluation, Authorization and Restriction of Chemicals] i.eRegulation on the Registration, Evaluation, Authorization and Restriction of Chemicals, 2007.6.1 came into force. The REACH regulation stipulates that those who have a registration obligation (generally a chemical manufacturer) must first register, submit safety data on chemical substances, and after assessment by the regulatory authorities, either license their use, or authorize their use, or directly restrict the use and content of certain substances, according to the hazard level. Since the enactment of the regulation, dozens of high-risk substances (SVHCs) have been issued (Annex 14) and selected as authorized substances. According to conservative estimates, the number of substances judged to be high-risk will reach 1,500. At the same time as the legislation was promulgated, substances deemed [inadequate control and unacceptable risk] were listed in Annex 17. Annex 17 sets out the conditions for the production, use and sale of such substances and the conditions for prohibition. For example: concentration, use, prohibition date, etc., but no tonnage requirements. In addition, the REACH regulation stipulates that from 2008.10.28, all articles with an SVHC content of more than 0.1% exported to the EU, must provide its customers with adequate information on safe use; It is also required to be provided free of charge to consumers within 45 days when requested by consumers. At a minimum, the name of the substance should be provided. From June 1, 2011, when exporting to the EU articles with SVHC content of more than 0.1% and total amount of more than 1t/a, it is necessary to report to the Chemicals Agency ( ECHA) circular.

3.4 The importance of system management Violation of RoHS directive, REACH regulation, will face market withdrawal, huge fines, prohibition of sales and even criminal liability. Therefore, we all hope that our products can meet the requirements stably for a long time, so as to reduce business risks and let customers use them with confidence. We all know that regular product testing can only be used as evidence that the product meets the requirements, and cannot be used as the basis for the long-term and stable compliance of the product. Of course, the frequency of chemical substances exceeding the standard is relatively low, but if it happens, the consequences will be very serious, and many companies may face the risk of bankruptcy. To this end, we hope to reduce the risk of occurrence through system management, without fine process management, there will be no perfect process results, in the company's procurement, production links, through the interlocking management loop, to ensure long-term stable supply of qualified products ability.

3.5 Risk management is the core of chemical substance management for suppliers. Only by establishing a systematic management method can we truly reduce risks. For this reason, suppliers are expected to conduct system management in accordance with the following requirements. (Can be integrated into other management systems) 1. The company's management attaches importance to it. Since the risk of non-conformities is very large and leads to management risks, it is necessary to attract the attention of the top management through the following matters: We will establish policies and targets for the management of chemical substances and review them regularly.
■Conduct regular internal audits to ensure that the management system is effectively implemented and maintained, and identify areas for improvement.
■During the management review, the status of the chemical substance management system is reported to the manager.
■Establish the company's chemical substance management standards and implement them at the company and suppliers. 2. Supplier management and procurement management ■ When selecting suppliers, it should be focused on whether the supplier has the ability to provide qualified products with chemical substances for a long time, and it should be noted that providing a guarantee letter is only a good wish or the basis for the division of responsibility after the occurrence of non-conformity, and cannot guarantee the long-term stable supply of qualified products. The annual test is only the monitoring of the product, which only means that the sample is qualified, and cannot be inferred that it can be qualified within one year. Therefore, you also need to pay attention to the management methods and management methods of your suppliers.
■Evaluation samples. When evaluating samples, the chemical content should be evaluated at the same time as the size.
■Based on the results of the risk assessment, we will conduct purchase inspections according to the planned frequency and quantity. If you do not have the ability to inspect incoming goods and can only test products once a year, then the evaluation and selection of suppliers, the ability to ensure that suppliers are more important. Because you rely on the management of the supplier.
■If you have a designated supplier, you must purchase from the designated supplier, but you must ensure that you purchase a qualified product.
■ Regularly evaluate the changes in the management level and management capabilities of your suppliers, as well as the effectiveness of the other party's system. 3. Pollution prevention ■ Identify processes that may cause cross-contamination and formulate management methods for pollution prevention.
■If complex chemical reactions occur in certain processes, or if the concentration of chemical substances changes, it is necessary to check whether the chemical substances exceed the standard.
■If your products or those of your suppliers use market-sourced raw materials or recycled materials, you need to pay attention to them. 4. Product monitoring and exception handling depending on ■You must be clear, on what basis can you determine that there is no problem with the product and determine the shipment? If you say that you are purchasing environmentally friendly products, how can you be sure that you are purchasing environmentally friendly products? How to determine engineering pollution?
■In the event of an abnormality, the method of identification, labeling, isolation, and disposal of abnormal products, as well as the process of investigating the cause and taking corrective measures.
■Management of measuring equipment and management of qualification of surveyors ■
System and process for reporting abnormalities to managers and customers5, 4M Change Management ■ 4M Change Application and Approval Process, it is important to note that the same material, different suppliers supply the risk is different, so if your materials, suppliers, processing technology need to be changed, you must be recognized by Shinano before you can import.
■In production and other links, the record of 4M change import should be recorded for traceability. 6. Education and training ■ Basic education on chemical substance management needs to be continuously carried out within the company ■Special positions require special education
, such as internal auditors, supplier audit managers, measurement personnel, abnormal handling personnel, etc7. Identification and management of regulations and customer requirements ■ The tracking path of environmental protection regulations should be clarified, and internal management requirements should be adjusted as regulations change.
■When the customer's request changes, the change needs should be evaluated and the response should be arranged.
■ Some requirements, such as REACH, upstream manufacturers should be ahead of customers, otherwise once the law enforcement is tightened, it will not be able to respond.
■Regulatory requirements and customer requirements, systems and processes transmitted to relevant departments.