CSR Report > Q & A > Business Partner Relations

CSR Report


Business Partner Relations

What is Nintendo's approach to business partner relations?

We place great importance on building strong relationships with all of our business partners. Through these relationships, we are able to offer the best products and services to our consumers.


What is the fabless production model?

Fabless is derived from "fabrication-less," meaning "without fabrication facilities." At Nintendo, we do not own the production factories that manufacture our products. All production processes are outsourced to external suppliers and production factories (production partners). We regularly visit our production partners' manufacturing sites to check the quality, safety, working conditions and efficiency of their production processes.


What is CSR procurement?

CSR procurement is the practice of requiring production partners to comply with not only environmental protection and safety rules (as specified in our Green Procurement Specifications) but also with certain social responsibility principles (as specified in the Nintendo CSR Procurement Guidelines).


How does Nintendo verify its production partners' performance on sustainability and ethical sourcing?

We share the Nintendo CSR Procurement Guidelines, which include specific requirements on sustainability, ethical sourcing and employee relations, with all of our production partners. We also ask our production partners to submit a Business Status Survey annually, which includes sections on their performance relating to sustainability and ethical sourcing.

Furthermore, we conduct on-site inspections at production sites based on Business Status Survey results, to confirm the compliance with our Guidelines. In addition to our own on-site inspections, we have incorporated an independent third-party monitoring process since fiscal year 2013 to increase transparency with our production partners and ensure our CSR Procurement Guidelines are being followed.

On-Site Inspections

FY 2008 7 companies (5 new)
FY 2009 14 companies (7 new)
FY 2010 13 companies (5 new)
FY 2011 9 companies (2 new)
FY 2012 13 companies (7 new)
FY 2013 11 companies (6 new)
FY 2014 14 companies (6 new)
FY 2015 16 companies (13 new)


What is Nintendo's approach on the Conflict Minerals issue?

Nintendo's Approach to Conflict Minerals

It has become a global concern that companies using minerals from conflict-affected regions could be playing a role in the conflicts by financing armed groups. In the U.S., Section 1502 of the Dodd-Frank Act, effective January 2013, requires companies listed in the U.S. disclose the use of any of the four conflict minerals (gold, tantalum, tin and tungsten) which are extracted from the Democratic Republic of the Congo or its adjoining countries and become a funding source for armed groups, are used in those companies’ products, and if so, those companies must disclose, among other matters, the measures taken to exercise due diligence on the sourcing of those minerals.

Although Nintendo is not subject to the law since we are not publicly listed in the U.S., Nintendo has an unequivocal policy banning the use of conflict minerals that support armed groups. As a result, Nintendo has carried out the following activities.

Nintendo's Progress

FY 2011   We revised the Nintendo CSR Procurement Guidelines (Ver.1), and incorporated and received consent on a provision on non-use of conflict minerals from each production partner. In addition, our Manufacturing Division explained the conflict minerals issue and Nintendo's policy on conflict minerals during on-site inspections.
FY 2012   Established an internal structure to address the conflict minerals issue and conducted a conflict minerals survey of all production partners to ascertain the progress made on their supply chain investigation and to understand whether policies on conflict minerals had been established.
FY 2013   Nintendo reorganized its internal structure and established a cross-functional conflict minerals team, consisting of members from legal, procurement and manufacturing to enhance Nintendo's approach on conflict minerals.
  We used the internationally recognized CFSI*1 Conflict Minerals Reporting Template to conduct our supply chain survey.
  Moreover, we reviewed all results to ensure there were no inconsistencies and no questions remained unanswered, carrying out follow-up requests with production partners when necessary. We also used the CFS (Conflict-Free Smelter)*2 list to verify smelters and refiners in our survey.
  We sent feedback to production partners regarding their individual survey results, and asked for their continued cooperation with Nintendo’s efforts based on our risk assessment of their status.
  In addition to conducting the supply chain survey, we worked with an external expert to interview our priority production partners and further examine both the progress made on their supply chain investigations and the challenges they currently faced.
FY 2014   Our cross-functional team continued to advance efforts regarding conflict minerals. We updated the Nintendo CSR Procurement Guidelines to include our conflict minerals policy and added language requiring production partners to cooperate with our supply chain survey, using a reporting template developed by CFSI, and to put into place a conflict minerals policy of their own. At the July 2014 Green Procurement briefing, we again used this time to explain Nintendo's policy on conflict minerals and to request that production partners to participate in our supply chain investigation.
  We achieved a 100 percent response rate to our fiscal year 2014 investigation, which used the CFSI Conflict Minerals Reporting Template, and as in the past, we reviewed all results and carried out follow-up requests when necessary.
  According to the results, Nintendo's supply chain consists of 355 smelters and refiners, including some that have not yet been identified by CFSI. We compared them against the list of smelters and refiners prepared by CFSI to ascertain the status of each mineral. As a result, from the smelters and refiners reported, 247 were on the CFSI Standard Smelter List, and among them 168 were certified as conflict free by CFSI.
  To promote further efficiency in our investigation, we carried out a risk assessment of our production partners' supply chain survey results and their overall importance to Nintendo's business. We also worked with an external CSR expert to interview selected production partners, to further examine the progress made on their supply chain investigations and the challenges they faced and their overall CSR initiatives.
  The results of our conflict minerals survey and interviews with suppliers have been reported to Nintendo's Executive Management Committee. Nintendo will continue to refrain from using any conflict minerals in our products, and we will further refine our conflict minerals investigation process.

FY 2015 Progress

To promote our initiatives according to the OECD Due Diligence Guidance for Conflict Minerals*3, we continued our cross-departmental efforts to investigate conflict minerals based on our conflict mineral investigation manual defining responsibility and authority, and investigation procedure.

Within the survey conducted in fiscal year 2015, which used the CFSI Conflict Minerals Reporting Template, we identified examples of the mistakes our production partners often made on the survey in the previous fiscal year, such as incorrect recording of smelter information, and asked our production partners to pay special attention to such issues. The response rate to the written surveys was again 100 percent.

We examined the responses in the same way as the past, and where there were clear contradictions, such as when a mineral is marked as not being in use, but a refiner is listed for that mineral, we asked all applicable production partners to review and resubmit their responses to ensure answers were consistent and correct.

According to our investigation, Nintendo's supply chain consists of 309 smelters and refiners (including some that could not be identified as smelters or refiners by CFSI). We compared these against the CFSI Standard Smelter list, to analyze how smelters and refiners are specified for each mineral. As a result, from the smelters and refiners reported, 294 were on the CFSI Standard Smelter List, and among them, 223 were certified as conflict-free by CFSI and 23 are on the Active list*4. The remaining CFSI standard smelters were not validated as CFS or engaged in the audit process, but as far as we have reviewed the provided information from production partners, our surveys revealed no evidence of conflict mineral use by those smelters either.

In addition to our survey activities, we have been conducting interviews with our productions partners since fiscal year 2013 with the belief that communicating directly with our production partners, and having an in-depth understanding of the framework and the procedures used in their supply chain investigation, can eventually lead to a higher level of involvement.

In fiscal year 2015, we selected production partners on the basis of risk assessments, taking into account their survey responses and the importance of the business relationship, and interviewed them on the status and challenges of their conflict minerals supply chain investigations, as well as their overall CSR initiatives.

The results of our surveys and interviews with production partners have been reported to the management of Nintendo Co., Ltd., who will use that information to define steps to further reduce the risk of using conflict minerals that support armed groups.

We will continue to advance our efforts on the issue of conflict minerals by continuing to communicate with our production partners, requiring them to set conflict minerals policies, use CFS smelters, and endeavor to reduce overall risks in our supply chain.

Number of Smelters and Refiners on the CFSI Standard Smelter List

  Gold Tantalum Tin Tungsten Total
Smelters and Refiners 124 46 81 43 294
Conflict-Free Smelters
(Including smelters and refiners on the Active list)
95 45 67 39 246

* Reference documents: The CFS list and Active list prepared by CFSI as of June 6th, 2016

* Smelters and refiners on the Active list have committed to undergo a Conflict-Free Smelter Program audit or are participating in one of the cross-recognized certification programs

*1 CFSI: Conflict-Free Sourcing Initiative
Founded by Electronic Industry Citizenship Coalition (www.eiccoalition.org) and Global e-Sustainability Initiative (www.gesi.org) in 2008 in order to develop tools and resources such as the Conflict Minerals Reporting Template.

*2 CFS: Conflict-Free Smelter
Smelters or refiners that have no relationship with the conflict in the Covered Countries and have been found to be compliant with the Conflict-Free Smelter program assessment protocols established by CFSI.

*3 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
This Guidance provides recommendations for responsible minerals supply chain management concerning conflict-affected or high-risk regions.

*4 Active List
The list of smelters and refiners that have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs


Page Top