Green Procurement Guidelines. January 30, 2018 Ver. 8.0 NAKAYO

Transcription

1 Green Procurement Guidelines January 30, 2018 Ver. 8.0 NAKAYO

2 <Table of Contents> 1. Purpose 2 2. Scope of Application 2 3. Investigation and Agreement of Environmental Conservation for Suppliers 2 Table 1 List of Surveys 3.1 Investigation of Suppliers Environmental Impact Assessment Investigation Related to Procured Products Request of Submitting the Application for Change of Product Condition of Purchased Product 4--6 Table 2. Chemical substances groups regulated by Nakayo / correspondence table Table 3. Level 1. Prohibited Substances Table 4. Level 2. Controlled substances 3.5 Conclusion of Memorandum on Chemicals Contained in Delivered Materials 7-8 Table5. Change in 4M that requires submitting "Application for Change of Production Condition of Purchased Product" Table 6. "Survey of Hazardous Chemical Substances" (water contamination, air pollution, odor nuisance and ozone layer destruction) 4. Attachments 4.3 Figure 1. Application for Change of Production Condition of Purchased Product and Description of entry method Figure 2. Non-Use Certificate, Entry instructions and Additional list for attachment Revision History 14 1

3 1. Purpose of Green Procurement The purpose of this guideline is to source eco-friendly parts and services from suppliers who are actively involved in environmental conservation. 2.Scope of Application These guidelines apply to all items and services procured by Nakayo, Inc. and delivered from suppliers, such as raw materials, parts, packing materials, partially-completed products, fully-completed products, equipment and tooling, secondary materials, writing materials, office and stationery supplies, office equipment, services and logistics. 3.Investigation and agreement of environmental conservation for suppliers To realize the purpose stated in the paragraph 1, Nakayo, Inc. requires suppliers to study and submit "Green Procurement Survey for Suppliers", "Survey of Hazardous Chemical Substances", "Application for Change of Production Condition of Purchased Product", "Hazardous Chemical Substances Inclusion Data (AIS and MSDS Plus)" and "Non-Inclusion Certificate" and to conclude "Memorandum on Chemicals Contained in Delivered Materials". Information on the status of the suppliers' environmental activities and the status of environmental load reduction of the procured products provided by suppliers is utilized to develop and design eco-friendly products to deliver environmentally-compatible products to customers, as well as to support environmental load-reducing activities as a part of the business activities of Nakayo, Inc. and suppliers. * Please download forms for each survey from Table 1. Table 1. List of Surveys Survey Category Scope Disclosure Category Frequency Required Documents Down load Others Changes of workers, machines and equipment, materials and parts and process/methods of manufacturing Required At the time of changing 4M Figure1"Application for Change of Production Condition of Purchased Product" fig1en.xls Survey of procured products Raw materials Packing materials Parts Partially-completed products Fully-completed products Required Note: At the time of accepting new parts Figure2"Non-Use Certificate of Prohibited Substance" chemsherpa-ai or chemsherpa-ci * (JAMP AIS or JAMP MSDS Plus) Until June 2018 fig2en.xls SHERPA/english/ ( om/english) Environmental impact assessment Production process (by manufacturing facility) Accordingly At the time of starting new transaction Table 6 "Survey of Hazardous Chemical Substances" t6en.doc *Note: To submit 'Chemical substance containing hazard data', please use chemsherpa -AI or chemsherpa -CI form. JAMP AIS or JAMP MSDS plus will be accepted until the end of June

4 3.1 Investigation of Suppliers As a condition for starting a new transaction, Nakayo, Inc. attaches importance to suppliers' "environmental conservation activities" and "status of the suppliers' environmental conservation for procured products" that we purchase from the suppliers. Our suppliers are encouraged to actively cooperate with us and satisfy the following guidelines. (1) Items related to environmental activities of suppliers Suppliers are kindly requested to participate in the investigation for the status of the environmental activities and submit the table 6 "Green Procurement Survey for Suppliers". i). Already obtained environmental certification such as ISO certification or other equivalent management system is in use. Verify the date of acquisition of ISO and certification authority. ii). Green Procurement is implemented. iii). If any of the external certifications such as ISO has not been obtained, the following shall be satisfied: Corporate philosophy and policy 1 Have a corporate policy regarding environmental protection. 2 Set environmental guidelines to ensure a continuous improvement and prevention of pollution. 3 The company's environmental policy commits to observe legal restrictions. 4 The company's environmental policy is known to all employees and available to any third party. Plan and organization 5 Assign specific organizations or persons to carry out relevant responsibilities toward the goal and target. 6 Have an implementation plan to achieve the goal and target. 7 Have a goal and target for environmental protection. Environment assessment / system * Control and assess the following items in an effort for improvement: 8 Reduce water contamination. 9 Reduce air pollution 10 Reduce noise and vibration 11 Treat waste properly and reduce the amount of waste disposal. 12 Reduce energy consumption (electricity, gas, fuel, etc.) 13 Prohibit the use of hazardous chemical substances prohibited by Nakayo in the production line. 14 Have a product assessment program. 15 Have a systematic plan for emergency. 16 Have any internal environment audit program. Provision of education, training, and information 17 Implement an environmental education program. 18 Implement training for personnel engaged in work that may significantly affect the environment and have a list of such personnel. 19 Provide information related to environmental protection. (2) Items related to the status of environmental load reduction of the procured products (raw materials, packing materials, parts, partially-completed products, fully-completed products) With regard to the products that Nakayo procures from suppliers, suppliers are requested to participate in the investigation concerning the environmental load reduction items and information of hazardous chemical substances contained in products (product mass, contained hazardous chemical substances and density, usage application and usage site). 3

5 3.2 Environmental Impact Assessment As a concept of Nakayo's environmental aspects and the environmental impact assessment, Nakayo considers that the input associated with the production activities of suppliers (input of energy and raw materials) and the output (unwanted materials such as waste materials and discharged water and discharge of usable materials such as products) as the environmental aspects, and Nakayo conducts an assessment of the environmental impact caused by these aspects. Suppliers are requested to fill in the table 6 "Hazardous Chemical Substances Inclusion Survey" as needed to investigate the usage of substances controlled by laws and regulations that have an impact on air pollution, water contamination, odor nuisance and ozone layer destruction. 3.3 Investigation Related to Procured Products (1) Investigation of chemical substances included in products For the procured production materials such as raw materials, parts, packing materials, partially-completed materials and fully-completed materials (including secondary materials such as paints and plating solution) which Nakayo adapts for the first time, suppliers are requested to investigate using chemsherpa-ai or chemsherpa-ci. Please break down to the level of raw materials for each part to submit the hazardous chemical substances inclusion data. ⅰ) Response to chemical substances subject to investigation and REACH ⅰ-1) Investigation of hazardous chemical substances Information on chemical substances contained in supplied products is controlled in accordance with two groups: Prohibited Substances and Controlled Substances (see Table 2). are voluntary controlled in accordance with the following groups. (2) Submission of Non-Inclusion Certificate As a warranty supporting the Hazardous Chemical Substances Inclusion data in chemsherpa AI Or chemsherpa -CI, suppliers are requested to submit Non-Inclusion Certificate (Table 2). 3.4 Request of Submitting the "Application for Change of Production Condition of Purchased Product Because changes in 4M shown in Table 5 such as a change of workers (Man), a change of machines and equipment (Machine), a change of materials and parts (Material) and a change of manufacturing process or method (Method) are considered to be an item of importance in quality control, the approval of customers is required to accept a change. Suppliers are required to submit an "Application for Change of Production Condition of Purchased Product" (Figure 1) to the representative of the Procurement Section of the Engineering Department no later than 6 months prior to the changing date. Table 2. Chemical substances groups regulated by Nakayo / correspondence table Group Controlled substances Main legal regulation Level 1 Prohibited substances group Level 2 Controlled substances group These chemical substances are prohibited for inclusion in supplied products. Under laws and regulations inside and outside Japan, those substances are basically prohibited for use in products (including packaging), but might be used in supplied products. Under laws and regulations inside and outside Japan, these are substances whose actual use must be known and for which appropriate management is required, or controlled substances whose recycling and proper disposal should be considered. This also includes substance groups whose inclusion in supplied products might be restricted according to usage. See Table 3 See Table 4 4

6 Table 3. Level 1. Prohibited Substances Chemical substance Legal limit Relevant regulations 1 Cadmium and its compounds *1 2 Hexavalent chromium compounds *1 3 Lead and its compounds *1 4 Mercury and its compounds *1 100ppm or less 100ppm or less (packaging materials) *5 1000ppm or less 100ppm or less (packaging materials) *5 1000ppm or less 100ppm or less (packaging materials) *5 1000ppm or less 100ppm or less (packaging materials) *5 RoHS directive (EU) Packaging directive (EU) RoHS directive (EU) Packaging directive (EU) RoHS directive (EU) Packaging directive (EU) RoHS directive (EU) Packaging directive (EU) 5 Polybrominated biphenyls (PBBs) 1000ppm or less RoHS directive (EU) 6 Polybrominated diphenyl ethers (PBDEs) 1000ppm or less RoHS directive (EU) 7 Tri-substituted organostannic compounds*2 Tributyltin compounds (TBT) Triphenyltin compounds (TPT) Bis (tributyltin) oxide (TBTO), etc. Intentional use is prohibited, however, 1000ppm or less as tin Japan Chemical Examination Law/Type 1 specified chemical substances REACH regulation (EU) 8 Polychlorinated biphenyls (PCBs) Intentional use is prohibited Japan Chemical Examination Law/Type 1 specified chemical substances POPs 9 Polychlorinated terphenyls *2 (PCTs) Intentional use is prohibited REACH regulation (EU) 10 Polychlorinated naphthalenes (with 2 or more chlorines) Intentional use is prohibited Japan Chemical Examination Law/Type 1 specified chemical substances 11 Short-chain chlorinated paraffins *2 *3 Intentional use is prohibited POPs REACH regulation (EU) 12 Asbestos *2 Intentional use is prohibited, however, 1000ppm or less REACH regulation (EU) 13 Ozone-layer-depleting substances (Class I) *4 Intentional use is prohibited 14 PFOS and its analogous compounds Intentional use is prohibited Montreal Protocol on Substances that Deplete the Ozone Layer Japan Chemical Examination Law/Type 1 specified chemical substances POPs 15 2-(2H-1,2,3-Benzotriazole-2-YL) -4,6-di-tert-Butylphenol Intentional use is prohibited Japan Chemical Examination Law/Type 1 specified chemical substances 16 Hexachlorobenzene Intentional use is prohibited Japan Chemical Examination Law/Type 1 specified chemical substances 17 Dimethyl fumarate (DMF) *2 0.1ppm or less REACH regulation (EU) 5

7 Table 4. Level 2. Controlled Substances Chemical substance or substance group name Chemical substance or substance group name Phthalic acid bis (2-ethylhexyl) (DEHP) (translation to Level 1 in Jan 2019) Benzyl butyl phthalate (BBP) (translation to Level 1 in Jan 2019) Dibutyl phthalate (DBP) (translation to Level 1 in Jan 2019) Diisobutyl phthalate (DIBP) (translation to Level 1 in Jan 2019) 16 Cobalt and its compounds *6 17 Azodyes and azocolourants which form specific amines 18 Formaldehyde 19 Benzene 5 Antimony and its compounds *6 20 Fluorine-based greenhouse gases 6 Arsenic and its compounds * Beryllium and its compounds * Nickel and its compounds *6 23 Polycyclic-aromatic hydrocarbons (PAHs) corresponding to REACH/restriction substance Perfluorooctanoic acid (PFOA) and individual salts and esters of PFOA Benzenamine, N-phenyl-, reaction products with styrene and 2,4,4-trimethylpentene (BNST) 9 Selenium and its compounds *6 24 REACH/restriction substances 10 Un-specific brominated flame retardants *7 25 REACH/authorization substances 11 Polyvinyl chlorides (PVCs) and its mixture, its copolymer 26 RECAH/SVHC 12 Phthalate esters other than No.1 - No.4 of this List 27 chemsherpa managed substance 13 Ozone-layer-depleting substances (Class II: HCFC) *8 14 Radioactive substances 15 Di-substituted organostannic compounds (DBT, DOT, etc.) 6

8 3.5 Conclusion of Memorandum on Chemicals Contained in Delivered Materials For the procured products that are considered as production materials, such as raw materials, parts, partially-completed products and fully-completed products, suppliers are requested to conclude the "Memorandum on Chemicals Contained in Delivered Materials" (Memorandum) from the perspective of quality management. Table 5. Change in 4M that requires submitting "Application for Change of Production Condition of Purchased Product" No. Types of change in 4M Description of the change 1 Worker (Man) 2 Machine and equipment (Machine) 3 Materials and parts (Material) 4 Manufacturing process or method (Method) (1) Change of supplier (parts supplier, material supplier, outsourcing) (2) Transfer of a manufacturing location to a different factory (from Japan to overseas) (3) Change of office organization at inspection dept. (1) Change of machine and equipment (2) Expansion of machine and equipment to something similar (3) Change of setup condition for machine and equipment (1) Change of material, parts measurement and structure (2) Change of specification, product name or designation to respond to the environment or other measures <e.g.> Changes to make a product lead-free or to correspond to RoHS guidelines. (3) Change of secondary materials (adhesive agent, implants, drugs, etc.) (4) Delivery of long term inventory (5) Change of packaging form and transportation method (1) Change of production method (changing from manual labor to mechanization, change of mold, etc.) (2) Change of processing conditions (changes in temperature, number of times, time, surface treatment, etc.) (3) Change of process management method (changes in standards, management items, etc.) (4) Change of work environment (Relocation of a factory, layout change, etc.) (5) Resumption of production (resumption after production stoppage or after taking measures for major incident, etc.) (6) Change of inspection method Note: For changes other than No.1 to 4, please contact the Procurement Section. 7

9 Date: Table 6 "Survey of Hazardous Chemical Substances" (water contamination, air pollution, odor nuisance and ozone layer destruction) Please enter "the estimated annual usage to the delivered amount" in the usage amount column, if it was used in the product manufacturing process for Nakayo in the past year. If the annual usage of the substance is less than 1 kg, enter "few" in the usage amount column. N O Substances controlled by the Water Quality Pollution Control Act Usage kg/ Year N O Substances controlled by the Air Pollution Control Act Usage kg / Year N O Substances controlled by the Offensive Odor Control Act Usage kg / Year N O Supplier Name: Responsible Person: Substances controlled by the Act for Protection of the Ozone Layer through Regulation of Designated Substances, etc. 1 Cadmium and its compound 1 Ammonia 1 Ammonia 1 Specified CFC CFC Cyanogen and its compound 2 Hydrogen fluoride 2 Methyl mercaptan (Chlorofluorocarbon) CFC Organic phosphorous compound 3 Hydrogen cyanide 3 Hydrogen sulfide Attachment A Group I CFC Lead and its compound 4 Carbon monoxide 4 Methyl sulfide CFC Hexavalent chromium compound 5 Formaldehyde 5 Methyl disulfide CFC Arsenic and its compound 6 Methanol 6 Trimethylamine 2 Specified halon Halon Mercury and its compound 7 Hydrogen sulfide 7 Acetaldehyde Attachment A Group II Halon Alkyl mercury compound 8 Phosphorus hydride 8 Propionaldehyde Halon PCB 9 Hydrogen chloride 9 N-butyl aldehyde 3 Other CFC CFC Trichloroethylene 10 Nitrogen dioxide 10 Isobutyraldehyde (Completely halogenated CFC Tetrachloroethylene 11 Acraldehyde 11 N-Valeraldehyde chlorofluorocarbon) CFC Attachment B Group I 12 Dichloromethane 12 Sulfur dioxide 12 Isobutanol CFC Carbon tetrachloride 13 Chlorine 13 Ethyl acetate CFC Dichloroethane 14 Carbon bisulfide 14 Methyl isobutyl ketone CFC Dichloroethylene 15 Benzene 15 Toluene CFC Cis Dichloroethene 16 Pyridine 16 Styrene CFC Trichloroethane 17 Phenol 17 Xylene CFC Trichloroethane 18 Sulfuric acid (incl. Sulfur 18 Propionic acid CFC trioxide) Dichloropropene 19 Silicon fluoride 19 N- Butyric acid 4 Carbon tetrachloride CCL4 20 Thiuram 20 Phosgene 20 N- Valeric acid Attachment B Group II 21 Simazine 21 Selenious anhydride 21 Isovaleric acid Trichloroethane (methyl C 2H 3CL 3 22 Thiobencarb 22 Chlorosulfuric acid 22 Isovaleraldehyde chloroform) Attachment B Group III 23 Benzene 23 Yellow phosphor 6 Alternative CFC HCFC Selenium and its compound 24 Phosphorus trioxide (Hydrochlorofluorocarbon) And other 39 types 25 Boron and its compound 25 Bromine Attachment C Group I 26 Fluorine and its compound 26 Nickel carbonyl 7 Hydrobromofluorocarbons 34 types 27 Ammonia, mmonium compound, nitrous acid compound and nitric acid compound 27 Phosphoric chloride 28 Mercaptan Attachment C Group II 8 Methyl bromide Attachment E Group I CH 3Br Usage kg / Year 9 Bromochloromethane Attachment C Group III CH 2BrCl 8

10 Distribution Date: Application for Change of Production Condition of Purchased Product Nakayo, Inc. Procurement Section of Engineering Dept. Submitted by (Company Name): *Procurement Section Control #: Stamp Purpose Name of Product *Target main model Fig. # Expected Implementation Date EDP Code Effective date of order by Nakayo: Details of the Change New Old Point to be checked Conflict with delivery specification, etc. Yes / No If Yes, specify the date of submission: Attachment of quality verification data Yes / No Expected date of submitting sample: Effect Internal Determination of Procurement Quality Assurance Preferred Procurement Section notice Section Manager Dept. date of Procurement Section for In Charge In Charge Manager Please circle one. In Charge Manager return Manager In Charge circulat ion Urgency Urgent Normal Determi nation of Quality Assuran ce Dept. *Action( s) to be taken and due date Yes A B Yes with some conditions Details <Internal> <Supplier> <Message to a supplier> No Note: If it is determined to be "No" or "Yes with some conditions",we do not accept delivery of the modified product until it is determined to be "Yes". (1) Quality related issue (2) Replacement of delivery spec *3 copies (3) Requalification of parts (4) Needs additional reliability data [Article] (1) Issuance of a design change r R equired / Not Required (2) Issuance of parts certification (4) Expected completion date of design verification: Due date (5) Expected completion date for requalification: Due dat (3) Price change Yes / No (6) Other Note: If (1) and (2) are applicable, the determination result shall be reported to the supplier immediately. (1) Replacement category: Mandatory : Voluntary (4) Submission of delivery spec *3 copies: Due date (2) Replacement control #: Or, replacement implementation date: Yes / No (3) Mixed use of lot: Possible / Not Possible (5) Change of EDP# (design) (6) Change of product name (design) (7) Hazardous Chemical Substances Inclusion Surve (8) Non-Inclusion Certificate (5) Submission of Hazardous Chemical Substances Inclusion Survey or Non-Inclusion Certificate: Due date (6) Sample for design verification: No. of pieces : Due date (7) Sample for parts verification: No. of pieces : Due date Return date of the application Date: Procurement Section In charge Manager Sections marked with * are filled by the Procurement Section. Shaded sections are filled by the company submitting this form. Sections enclosed with a double line are filled by the quality assurance dept. Style V Figure 1 9

11 Distribution Description of entry method Legend Pink colored call-outs for applicant, yellow ones for Nakayo Date: Application for Change of Production Condition of Purchased Product Nakayo, Inc. Procurement Section of Engineering Dept. *Procurement Section Control #: Submitted by (Company Name): If unknown, please contact the Nakayo's procurement representative. Stam p Purpo s e D e t a i l s o f t he C ha ng e Name of Product *Target main model Fill out by a procurement representative. Boxes in blue indicate changes from Ver. 10. Example of a case when it is Yes: New As in a spec change in packing, if the change is minor and there is no direct change to the quality property and it can be determined with a documentary examination. "Yes with some conditions" applies to the case when it becomes "Yes" after completing a requalification of parts or design change. In addition, if it falls under "Yes with some conditions", we do not accept delivery (replacement) of the modified product until it is determined to be "Yes". Fig. # Expected Implementation Date EDP Code Effective date of order by Nakayo: Old Be sure to clarify the department that filled by and add a prior confirmation item for a requalification of parts or design change. Point t o b e che cke d Ef f ec t Conflict with delivery specification, etc. Yes / No If Yes, specify the date of submission: Attachment of quality verification data Supporting documents that can prove that there is no issue caused by the change. Yes / No Expected date of submitting sample: Internal notice for cir cu la tio n De te rm in a tion o f Q u a lity A ssu ran ce De p t. *Action(s) to be taken and due date Procurement Section Determination of Procurement Quality Assurance Preferred Procurement Section In Charge In Charge Manager Please circle one. In Charge Manager date of Manager In Charge Urgency Normal Note: If it is determined to be "No" or Yes Yes with some No "Yes with some conditions", we do not accept delivery conditions of the modified product until it is determined to be "Yes". A B Details <Internal> <Supplier> <Message to a supplier> Urgent (1) Quality related issue Yes / No (2) Replacement of delivery spec *3 copies (3) Requalification of parts (4) Needs additional reliability data [Article] (5) Change of EDP# (design) (6) Change of product name (7) Hazardous Chemical Substances Inclusion Survey (8) Non-Inclusion Certificate (1) Issuance of a design change (2) Issuance of parts certificatio (3) Price change Yes / No (4) Expected completion date of design verification: Due date (5) Expected completion date for requalification: Due date (6) Other Note: If (1) and (2) are applicable, the determination result shall be reported to the supplier immediately. (1) Replacement category: Mandatory : Voluntary (4) Submission of delivery spec *3 copies: Due date (2) Replacement control #: Or, replacement implementation date: (5) Submission of Hazardous Chemical Substances Inclusion Survey or Non-Inclusion Certificate: Due date (3) Mixed use of lot: Possible / Not Possible (6) Sample for design verification: No. of pieces : Due date (7) Sam ple for parts verification: No. of pieces : Due date Return date of the application Date: Procurement Section In charge Manager Sections marked with * are filled by the Procurement Section. Shaded sections are filled by the company submitting this form. Sections enclosed with a double line are filled by the quality assurance dept. Style V

12 To: Nakayo,Inc. Date : Non-Use Certificate of Prohibited Substance Nakayo Business Partner Company name : Signature and seal of person in charge: Manufacturer Company name : Signature of person in charge: stamp Regarding the products in the following products list: we guarantee the followings. Prohibited chemicals shown Table-1and Table-2 aren't used intentionally. And the content (impurities) is below the threshold value which is specified by law(rohs etc) in Table-1and Table-2. In the case that the exemptions prescribed by RoHS, we show those exemptions in products list without guarantee but we guarantee that the exemption is applicable. Products list No. Supplier sproduct (part) number Nakay oproduct (EDP) number Nakay o product (part) name Manuf acturing plant *Attach a list if the space is insufficient Existence Exemption (*1) Substance group No.-The use which becomes exemption Part (*1)When application of the prohibited substance, you use correspond to the RoHS2 exclusion item, be sure to fill in the existence, Substance group No. -The use which becomes exemption in the ANNEXⅢ, ANNEXⅣand make it clear which part it is used in. (Example: Lead in the high melting temp. type solder=7(a)) Table-1 Prohibited chemicals No. Prohibited material Law thresholds No. Prohibited material Law thresholds 1 Cadmium and Cadmium Compounds 100ppm 10 Polychloronapthalenes (Cl=>3) Intentional use prohibited 2 Hexavalent Chromium Compounds 1000ppm 11 Short Chain Chlorinated Paraffins Intentional use prohibited 3 Lead and Lead Compounds 1000ppm 12 Hexabromocyclododecane (HBCD) and all major diastereoisomers Intentional use prohibited Lead and Lead Compounds (w ire coating) *1 300ppm 13 Asbestos Intentional use prohibited 4 Mercury and Mercury Compounds 1000ppm 14 Ozone Depleting Substances Intentional use prohibited 1~4 5 Lead, Cadmium, Mercury, Hexavalent Chromium(In the case of that articles (parts) are package or w rapping) *2 Tri-substituted Organostannic Compounds *3 *1: Apply to w ire coating. Total 100 ppm Intentional use prohibited and 1000ppm by weight of 15 Radioactive Substances Intentional use prohibited 16 PFOS and its Analogous Compounds Intentional use prohibited 6 Polybrominated Biphenyls (PBBs) 1000ppm 17 2-(2H-1,2,3-benzotriazole-2-yl)-4,6- di-tert-butylphenol Intentional use prohibited 7 Polybrominated Diphenyl ethers (PBDEs) 1000ppm 18 Hexachlorobenzene Intentional use prohibited 8 Polychlorinated Biphenyls (PCBs) Intentional use prohibited 19 Dimethylfumarate (DMF) 0.1ppm 9 Polychlorinated Terphenyls (PCTs) Intentional use prohibited 50ppm(equip ments) 20 Benzenamine, N-phenyl-, reaction products w ith styrene and 2,4,4- trimethylpentene (BNST) Intentional use prohibited The use as the additiv e f or rubber is allowed except tires. *2: Apply to the sum of lead, cadmium, mercury and the hexavalent chromium included in the package and w rapping of the products. *3: Tributyl Tin Oxide (TBTO), Tributyl Tins (TBTs), Triphenyl Tins (TPTs), and other Tri-substituted organostannic compounds Table-2 Prohibited chemicals No. Prohibited material Law thresholds 1 Bis(2-ethylhexyl)phthalate (DEHP) 1000ppm 2 Benzyl butyl phthalate (BBP) 1000ppm 3 Dibutyl phthalate (DBP) 1000ppm 4 Diisobutyl phthalate (DIBP) 1000ppm Contact details: depart. phone. name. . Figure 2 11 style PD

13 To: Nakayo,Inc. Date : Non-Use Certificate of Prohibited Substance Nakayo Business Partner Company name : Signature and seal of person in charge: Manufacturer Company name : Signature of person in charge: stamp Regarding the products in the following products list: we guarantee the followings. Please specify the business partner code and the business partner name that Prohibited chemicals shown Table-1and Table-2 aren't used intentionally. And the content (impurities) is below the concluded supplier contract (purchase of basic contract) with Nakayo. If you do threshold not mention value it, please which re-present. is specified by law(rohs etc) in Table-1and Table-2. In the case that the exemptions prescribed by RoHS, we show those exemptions in products list without guarantee but we guarantee that the exemption is applicable. Products list No. Supplier sproduct (part) number Nakay oproduct (EDP) number Nakay o product (part) name Manuf acturing plant *Attach a list if the space is insufficient Existence Exemption (*1) Substance group No.-The use which becomes exemption Part (*1)When application of the prohibited substance, you use correspond to the RoHS2 exclusion item, be sure to fill in the existence, Substance group No. -The use which becomes exemption in the ANNEXⅢ, ANNEXⅣand make it clear which part it is used in. (Example: Lead in the high melting temp. type solder=7(a)) Table-1 Prohibited chemicals No. Prohibited material Law thresholds No. Prohibited material Law thresholds 1 Cadmium and Cadmium Compounds 100ppm 10 Polychloronapthalenes (Cl=>3) Intentional use prohibited 2 Hexavalent Chromium Compounds 1000ppm 11 Short Chain Chlorinated Paraffins Intentional use prohibited Hexabromocyclododecane (HBCD) Lead and Lead Compounds 1000ppm 12 Intentional use prohibited and all major diastereoisomers 3 Lead and Lead Compounds (w ire 300ppm 13 Asbestos coating) *1 Intentional use prohibited 4 Mercury and Mercury Compounds 1000ppm 14 Ozone Depleting Substances Intentional use prohibited 1~4 5 If the number of lines is insufficient (can not be filled in) please indicate on separate sheet producuts list and present it. Lead, Cadmium, Mercury, Hexavalent Chromium(In the case of that articles (parts) are package or w rapping) *2 Tri-substituted Organostannic Compounds *3 *1: Apply to w ire coating. Total 100 ppm Intentional use prohibited and 1000ppm by weight of 15 Radioactive Substances Intentional use prohibited 16 PFOS and its Analogous Compounds Intentional use prohibited 6 Polybrominated Biphenyls (PBBs) 1000ppm 17 2-(2H-1,2,3-benzotriazole-2-yl)-4,6- di-tert-butylphenol Intentional use prohibited 7 Polybrominated Diphenyl ethers (PBDEs) 1000ppm 18 Hexachlorobenzene Intentional use prohibited 8 Polychlorinated Biphenyls (PCBs) Intentional use prohibited 19 Dimethylfumarate (DMF) 0.1ppm 9 Polychlorinated Terphenyls (PCTs) Intentional use prohibited 50ppm(equip ments) 20 Benzenamine, N-phenyl-, reaction products w ith styrene and 2,4,4- trimethylpentene (BNST) Intentional use prohibited The use as the additive for rubber is allowed except tires. *2: Apply to the sum of lead, cadmium, mercury and the hexavalent chromium included in the package and w rapping of the products. *3: Tributyl Tin Oxide (TBTO), Tributyl Tins (TBTs), Triphenyl Tins (TPTs), and other Tri-substituted organostannic compounds Table-2 Prohibited chemicals No. Prohibited material Law thresholds 1 Bis(2-ethylhexyl)phthalate (DEHP) 1000ppm 2 Benzyl butyl phthalate (BBP) 1000ppm 3 Dibutyl phthalate (DBP) 1000ppm 4 Diisobutyl phthalate (DIBP) 1000ppm Contact details: depart. phone. name. . Figure 2 12 style PD

14 Products list No. Supplier sproduct (part) number Nakay product (EDP) number Nakayo product (part) name Manuf acturing plant Existence Exemption (*1) Substance group No.-The use which becomes exemption Part 13

15 Revision History of the Green Procurement Guidelines of NAKAYO, Inc. Ver. Date of Issue Location Page Reasons/Description First version Table 1: List of 3 Change the t6en-v6.2.xls Surveys Change of trade name Nakayo Telecommunications,Inc., Nakayo, Inc Table1: List of Surveys 2 chemsherpa -AI or chemsherpa- CI added 3.3(1) 4 Table4.Level2. Controlled Substances 6 14