Form SD CANON INC

JAPAN

(State or other jurisdiction of

incorporation or organization)

(Commission

File Number)

                     (IRS Employer

                 Identification No.)

30-2, Shimomaruko 3-chome, Ohta-ku, Tokyo 146-8501, Japan

(Address of principle executive offices)

                (Zip code)

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2020 to December 31, 2020.

Introduction (Background to the disclosure of the Conflict Minerals Report)

Application of Conflict Minerals Report on Canon and products subject to disclosure

Basic principles regarding response to conflict minerals

RCOI and Due Diligence

Step 1: Establish strong company management systems

In order to respond to the conflict minerals situation, Canon established a cross-functional Conflict Minerals Response Project Team (“Project Team”) in its headquarters under the direction of a representative director in charge (Executive Vice President & CFO) in December 2010. Moreover, Canon designated a person in charge of conflict minerals in each of its group companies that manufacture or contract to manufacture products. The Project Team currently operates as the Working Group on Responsible Minerals Sourcing (“Working Group”).

As stated above, Canon Inc. renewed the “Canon Group Basic Policy on Responsible Minerals Sourcing”.

Canon established the “Guidelines for Responsible Minerals Sourcing” that clarified the responsible divisions and the framework for handling responsible minerals sourcing issues as well as the survey process, for the persons involved in the Canon Group.

In July 2020, Canon Inc. summoned the persons in charge of responsible minerals sourcing for Canon Group’s domestic subsidiaries that manufacture or contract to manufacture products and held a meeting to share the results of the 2019 minerals survey and discuss Canon’s policies for the survey of 2020. Moreover, for the persons in charge of responsible minerals sourcing matters for overseas subsidiaries, Canon Inc. shared information by e-mail and web conference.

Canon created and distributed the Responsible Minerals Sourcing Survey Manual to the first-tier suppliers.

Canon requested the first-tier suppliers to sign and submit written confirmation (“Certificate of Consent”) of their agreement and cooperation with Canon’s “Canon Group Basic Policy on Responsible Minerals Sourcing” and their agreement to take an action for appropriate measures should any significant risks associated with mineral sourcing be found in the supply chain.

Using its Minerals Information Management System, Canon Inc. linked survey responses to product information, conducted product-level assessments, and stored the assessment results in a database, except for such products as handled by newly joined subsidiaries. Internal rules require that data records be retained for at least five years.

Canon Inc. is a member of the Responsible Minerals Trade Working Group (“RMTWG”) of the Japan Electronics and Information Technology Industries Association (“JEITA”). As part of its initiatives, the RMTWG provided the documents and videos related to the responsible minerals sourcing for suppliers in supply chains in the electrical and electronics industry. Step 3 below provides details of the industry initiatives on responsible minerals sourcing that Canon Inc. participates in.

As an early-warning risk-awareness system specified in the OECD Guidance, Canon Inc. established a grievance mechanism — “Contact Point for Reporting Concerns Regarding Conflict Mineral Issues” (renamed in 2020 “Procedure for the Submission of Concerns Regarding Minerals Risk”) — on its official website in 2015. No reports from employees, suppliers, or other stakeholders were received by the contact point in 2020.

Step 2: Identify and assess risks in the supply chain

Canon designed a framework to identify each of the parts and materials used in the products that it manufactured or contracted to manufacture. Canon used its production and shipping management system, which includes bills of materials for products and also used its procurement system, to identify parts and materials required in products planned for production and shipping between January and the end of December 2020. (Canon Group companies not using such system made use of a similar method to identify parts and materials.) Canon then carried out the RCOI on the first-tier suppliers handling the identified parts and materials.

For the RCOI, Canon used the RMI Conflict Minerals Reporting Template Revision 6.01 (“CMRT”). The CMRT is published by the Responsible Minerals Initiative (“RMI”), one of the programs of the Responsible Business Alliance (“RBA”). Canon requested the 3,032 first-tier suppliers that were identified as possibly using 3TG to report their status of 3TG using the CMRT. Suppliers that were not using 3TG for their parts and materials had the option of reporting their status through an alternative method, instead of using the CMRT.

In addition to the RCOI described above, Canon conducted due diligence examinations of first-tier suppliers that reported the use of 3TG originating from covered countries. Suppliers who reported 3TG smelters were requested to fill in Canon’s own “Smelter Risk Check Form” and if they reported any smelters that did not meet the conformant or active smelters in the RMI’s audit program, they were also asked to submit the estimated schedule to mitigate the risks on such non-conformant or non-active smelters.

Canon requested replies from the first-tier suppliers who did not respond by the closing date of the response.

Canon Inc. verified the replies submitted by first-tier suppliers (for any incomplete answers or errors) using a proprietary reply-processing tool. When necessary, Canon requested resubmissions from first-tier suppliers.

As of April 19, 2021, Canon had received responses from 94 percent of all first-tier suppliers surveyed.

Canon compared the smelters or refiners (“SORs”) identified through the RCOI against the list of the SORs which have been validated to be conformant to the Responsible Minerals Assurance Process (“RMAP”), the audit program of the RMI, as published by the RMI. The RMI implements cross recognition with the London Bullion Market Association (LBMA) and the Responsible Jewellery Council (RJC).

Step 3: Design and implement a strategy to respond to identified risks

The head of the Working Group reported the progress of responsible minerals sourcing activities to the representative director in charge.

Moreover, the Working Group reported in November 2020 on its progress to relevant directors and executive officers of Canon Inc. as well as the presidents of the relevant domestic and overseas subsidiaries by distributing the explanatory material.

Canon Inc. is a key member of JEITA’s RMTWG. The RMTWG is allied with the RMI, which plays the leading role in the response to responsible minerals sourcing. Canon Inc. has held the role of co-chair of the RMTWG since 2013.

Canon Inc. has also served as team leader of the RMTWG’s Smelter Support Team since 2015. In this capacity, Canon Inc., along with the other companies in the RMTWG, played an active role to encourage the SORs to join the RMI’s RMAP.

Canon Inc. participates in the Japan Conflict-Free Sourcing Working Group (CFSWG), a joint initiative by JEITA’s RMTWG and major Japanese automobile manufacturers, and serves as the CFSWG vice-chair.

In addition to the above activities, Canon Inc. has been a member of the RMI since April 2015. Its membership code is “CNON.” Canon Inc. assists RMI activities as a corporate member of the RMI.

Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices

As a RMI member, Canon Inc. supports audits under the RMAP carried out by the RMI on SORs.

Step 5: Report annually on supply chain due diligence

In accordance with the Dodd-Frank Act and the SEC’s final rules, on or before May 31, 2021, Canon Inc. plans to file a Form SD and Conflict Minerals Report (this report) with the SEC, and plans to publish the same information on its official website.

Canon Inc. has been reporting its activities in response to responsible minerals sourcing in its Annual Report and Sustainability Report since 2011.

Survey results for the 2020 calendar year

Result of RCOI and due diligence

Canon conducted the RCOI on 3,032 first-tier suppliers that possibly use 3TG. Canon conducted further due diligence on first-tier suppliers which reported the use of 3TG from the covered countries.

In cases where 3TG originating from covered countries were used, Canon received some responses indicating the minerals in question had been sourced from SORs that are conformant with the RMAP.

Within the scope of the responses, there was nothing to clearly suggest that the Canon Group’s purchasing of parts and materials contributed to funding armed groups.

Result of SORs survey

Canon analyzed the information on the SORs mentioned in the responses from the supply chain through the RCOI, with reference to the RMI’s SOR information. The RMI classifies SORs based on the auditing status. The website of the RMI provides information of the auditing status under the RMAP.

233 SORs in Canon supply chain were identified as RMAP conformant and 9 SORs were identified as Active in the RMAP. The remaining 69 SORs were neither RMAP conformant nor Active in the RMAP. Appendix 1-1, 1-2 and 1-3 provide lists of these SORs.

Canon was unable to determine whether the remaining entities reported by the first-tier suppliers as SORs were truly SORs.

Due to inadequate information from its supply chains, Canon was unable to determine the country or region of origin of many 3TG used in Canon Group products.

Appendix 1-4 lists examples of 3TG countries and regions of origin first-tier suppliers reported to Canon through CMRT responses.

Based on the results of the RCOI and due diligence mentioned above, Canon was unable to determine whether the 3TG used for the products of the Canon Group financed or benefitted armed groups in the covered countries.

Efforts to determine the mine or location of origin of 3TG with the greatest possible specificity and risk mitigation

Canon will continue promoting verification operations of high-risk first-tier suppliers in accordance with Canon’s Guidelines for Responsible Minerals Sourcing.

Canon Inc. will continue its participation at JEITA’s RMTWG, CFSWG and RMI, and support activities to reduce risks in entire supply chains.

Independent monitoring

KPMG AZSA Sustainability Co., Ltd. conducted an independent private sector audit of this report. The audit assessed whether the due diligence framework Canon designed conforms to the OECD Guidance’s due diligence framework and whether the due diligence description in this report is consistent with the actual measures Canon undertook. The independent assurance report is attached in Appendix 2.

List of the SORs identified in Canon’s supply chain which are RMAP conformant (As of February 2, 2021)

Metal    

SORs

Country/Region

Gold

L’Orfebre S.A.

ANDORRA

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

Gold

Marsam Metals

BRAZIL

Gold

Asahi Refining Canada Ltd.

CANADA

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

Gold

Royal Canadian Mint

CANADA

Gold

Planta Recuperadora de Metales SpA

CHILE

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

Gold

Jiangxi Copper Co., Ltd.

CHINA

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

Gold

Shandong Gold Smelting Co., Ltd.

CHINA

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

Gold

SAFINA A.S.

CZECHIA

Gold

SAAMP

FRANCE

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

Gold

Aurubis AG

GERMANY

Gold

C. Hafner GmbH + Co. KG

GERMANY

List of the SORs identified in Canon’s supply chain which are Active in RMAP (As of February 2, 2021)

Metal    

SORs

Country/Region

List of the SORs identified in Canon’s supply chain which are neither RMAP conformant nor Active in RMAP (As of February 2, 2021)

Metal    

SORs

Country/Region

Examples of the countries and regions of origin from which the SORs listed in Appendix 1-1, 1-2 and 1-3 are believed to have sourced 3TG

management’s assertion, included in section 4 of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2020, that the design of Canon Inc.’s (the “Company”) due diligence framework is in conformity with the criteria set forth in the Organisation of Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition 2016 (“OECD Due Diligence Guidance”), and

whether the Company’s description of the due diligence measures it performed, as set forth in section 4 of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2020, is consistent, in all material respects, with the due diligence process that the Company undertook.

The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance;

The completeness of the Company’s description of the due diligence measures performed;

The suitability of the design or operating effectiveness of the Company’s due diligence process;

Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance;

The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or

The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products.

the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2020, as set forth in section 4 of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and

the Company’s description of the due diligence measures it performed as set forth in section 4 of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2020, is consistent, in all material respects, with the due diligence process that the Company undertook.