Human Rights and Labor

1. Prohibition of Forced Labor

• ・Forced labor in any form, including but not limited to involuntary or exploitative prison labor, slavery, or human trafficking, bonded labor, or debt bondage is prohibited. This includes transporting, harboring, recruiting, transferring or receiving people by means of threat, force, coercion, abduction or fraud for the purpose of providing labor or services.
• ・Employees’ employment must be voluntarily, and as stipulated in the Company’s employment policy, if an employee requests leave or resigns in accordance with the policy, the Company will not impede or penalize them.
• ・The Company appropriately maintains employment-related documents of all employees including those who terminated, and will retain them securely in accordance with applicable laws and regulations.
• ・It is the employees’ responsibility to keep their own ID cards, passports, and work permits with them. The Company will not store them for the employees.
• ・Regardless of the terms of employment, the Company responsibly manages the employment process to avoid unfair treatment, such as making employees pay employment-related fees, substituting or changing contract terms that are less favorable than those offered before formal employment contract was signed, or concluding a contract using an employment contract written in a language that the employee do not understand.
• ・The Company does not impose unreasonable restrictions on employees’ movement in and out of company provided facilities.

2. Prohibition of Child Labor

• ・The age of the employee must be verified by an appropriate mechanisms to prevent the hiring of those who have not completed compulsory education or do not meet the minimum employable age stipulated by the government.
• ・If there are employees under the age of 18, they will not be required to work late at night, overtime, or in any other job that poses a risk of adverse health effects, or to work in locations where danger is inherent.
• ・When accepting student workers as interns, etc., the Company will manage them according to applicable laws and regulations, and provide necessary support and training to protect the rights and safety of the students.
• ・If it is discovered that any employee is below the minimum age, appropriate measures will be taken against that person in accordance with the law and by considering the audit standards of the Responsible Business Alliance (RBA).

3. Working Hours

• ・The Company manages employee work hours in accordance with the Labor Standards Act and aims to maintain and improve a healthy and cultured lifestyle. Even during busy periods, we will keep overtime and holiday work to a minimum, and work will be conducted within the limits set by the Article 36 Agreement.
• ・Except in emergencies or extraordinary circumstances, the total weekly work hours must be less than 60 hours with no more than 6 consecutive days of work.
• ・Overtime work is carried out at the request of the Company and with the employees’ agreement.

4. Wages and Benefits

• ・The Company complies with all applicable wage laws, including statutory minimum wages, premium pay for overtime work, and legally mandated benefits.
• ・Regardless of the employee’s employment term, the same work and qualifications ensure equal pay and access to benefits.
• ・Unlawful wage reductions are prohibited. Additionally, there will be no deductions or withholdings of wages as disciplinary action.
• ・Employees receive a pay statement at the end of each pay period that clearly states the basis for calculating wages.

5. Prohibition of Discrimination and Harassment / Humane Treatment

• ・The Company prohibits abuse, corporal punishment, violence, harassment, coercion, bullying, public humiliation, and other inhumane treatment of the employees.
• ・The Company is committed to a workplace free of harassment and unlawful discrimination. There shall be no type of discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity, or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training.
• ・If an employee makes requests based on religious practices or a disability, the Company will provide a reasonable accommodation.
• ・The Company does not administer pregnancy tests or other medical or physical tests to job applicants or employees that could be used for a discriminatory purpose.

6. Freedom of Association and Collective Bargaining

• ・The Labor Relations Committee, acting as representatives of the employees, strives to improve the working conditions and working environment for employees through dialogue and negotiations with the Company and share them with employees.
• ・The Company respects the right of employees to form or join organizations of their own volition, to participate in peaceful assembly, and to refrain from such activities. The Company will not retaliate against, intimidate or unfairly appraise employees’ work performance based on their participation in collective bargaining or the content of their opinions.

Health and Safety

1. Occupational Health and Safety

• ・The Company will evaluate workplace health and safety risks to prevent accidents by eliminating hazardous situations, substituting work processes, providing Personal Protective Equipment (PPE) free of charge, and taking preventive measures.
• ・The Company shall consider gender-friendly measures to eliminate potential hazards to female employees who are expecting or taking care of small children. Appropriate measures will be taken to accommodate their specific needs.

2. Emergency Preparedness

• ・In preparation for emergencies due to natural disasters such as earthquakes, fire, and floods, the Company established disaster prevention systems that include identifying and assessing risks, notifying and educating employees, creating response plans and procedures and installing necessary equipment and providing supplies.
• ・Disaster prevention drills should be conducted at least once a year, and appropriate fire extinguishing equipment and emergency equipment must be regularly inspected and maintained. Evacuation routes and emergency exits should be secured, and emergency contact information and recovery plans should be confirmed.
• ・Evacuation routes and evacuation shelters will be posted at visible places in the facility.
• ・To prevent the spread of infectious diseases, the Company will take measures to block the infection routes and create an environment that will prevent infection. In addition, if an employee becomes infected, the Company will prevent the spread of infection by suspending them from coming to work during the recovery period.

3. Prevention of Occupational Injuries and Illnesses

• ・Establish and implement a system to prevent, manage, track and report occupational injuries and illnesses and to take appropriate countermeasures and corrective actions.
• ・Should a hazardous nonstationary emergency occurs, employees will be not allowed to work in that area until the hazard has been eliminated or mitigated.

4. Industrial Hygiene

• ・The Company is committed to continually improving the work environment by identifying, evaluating, and effectively managing exposure to chemicals, biological and physical hazards in the workplace.
• ・The Company will provide those employees who work in environments requiring protection from potential exposure with appropriate PPE free of charge, and train them in the proper use of such equipment.
• ・Periodic medical checks shall be conducted as follows:
   General health checks: once a year
   Lifestyle-related disease checks: twice a year
   Specialized health exams: twice a year

5. Physically Demanding Work

• ・The Company will identify and evaluate ergonomic risks including long-term repetitive work and physically demanding work such as lifting heavy objects, and taking measures to reduce physical strain by implementing procedures such as providing additional rest period if frequency of rest is not sufficiently meeting the need.

6. Machine Safeguarding

• ・When introducing production equipment and other facilities, the Company identifies and assesses potential hazards and provide training on operational risks, including those that may arise during use. The Company also implements protective measures such as safety devices, interlocks, and physical barriers to prevent accidents and reduce the risk of personal injury.
• ・In accordance with relevant laws and regulations regarding the safety of machinery and equipment, the Company will implement documented safety management procedures. The operators will be sufficiently trained in their use/operation.
• ・The Company identifies and evaluates hazards in routine operations at the production and other facilities, and non-routine operations such as maintenance and cleaning, and take measures to address the source of specific hazard.

7. Sanitation, Food and Housing

• ・The Company facilities such as worker dormitories, dining halls, and bathrooms must be maintained as safe, clean, and comfortable space.
• ・In dining halls and dormitories, there will be access to clean drinking water, and all foods served are prepared and stored in a safe and sanitary manner.
• ・The dormitories will provide secure personal space, properly working emergency exits/ventilation, bathing facilities, lighting and air conditioning.

8. Health and Safety Communication

• ・The Company routinely provides the employees with Appropriate workplace health and safety information and delivers regular training on any identified hazards in the workplace in a language they understand.
• ・For chemicals used in the workplace, SDS (Safety Data Sheet) which contains information regarding hazards, handling and emergency response procedures are posted where employees can quickly find or stored in a specific place.
• ・The Company provides employees with health information related to their individual attributes in an easily accessible format.
• ・The Company establishes a mechanism for employees to raise health and safety related concerns or suggestions.

9. Prohibition of Drugs and Other Substances in the Workplace

• ・The use, sale, and possession of illegal drugs or any other controlled substances (excluding drugs prescribed to an individual by a physician for medical use) are strictly prohibited within the Company premises.
• ・Possession and storage of alcoholic beverages for the purpose of consumption in the workplace is prohibited. (Excludes temporary storage as gifts, use at Company events, or possession.)
• ・Workers are prohibited from being under the influence of alcohol, illegal drugs, illicit drugs, and/or over-the-counter drugs while working.
• ・To prevent drug allergies and overdoses, the Company prohibits the transfer of personal medications (including prescription drugs) in the workplace.

Environment

1. Environmental Permits and Reporting

• ・In accordance with laws and regulations, obtain licenses and permits from the government when required, and manage operations and reports accordingly.

2. Pollution Prevention and Effective Use of Resources

• ・By continually improving production processes and promoting reduce, reuse, and recycle, the Company strives to make effective use of resources and reduce waste, and aims to prevent resource waste and environmental pollution.

3. Hazardous Substances

• ・Chemicals, wastes and other materials that are hazardous to humans or the environment will be identified, labeled, and managed to ensure their safe handling, transportation, storage, use, recycling or reuse and disposal.
• ・All hazardous wastes are properly collected, transported, and disposed of, and are logged in the Waste Management Data Sheet to be retained.

4. Waste

• ・The Company establishes and operates a system for recycling which includes proper classification, management, reduction, and disposal of waste.
• ・All hazardous wastes are properly collected, transported, and disposed of, and are logged in the Waste Management Data Sheet to be retained.
• ・Specially controlled waste will be responsibly managed from discharge to disposal in accordance with the applicable laws and regulations.

5. Emission to the atmosphere

• ・The Company establishes a system to measure the usage of Volatile Organic Compounds (VOCs), aerosols, corrosive substances, ozone depleting substances, combustion by-products, etc. in each workplace, and maintain a management system to prevent air pollution through emissions.
• ・Ozone-depleting substances will be managed in accordance with the Montreal Protocol and applicable regulations.

6. Restrictions on Substances Used

• ・The Company complies with all applicable laws, regulations, and customer requirements related to the prohibition, restriction, and reporting of substances used in product manufacturing.

7. Water Management

• ・The Company strive to conserve water by managing water usage as well as discharge status.
• ・The Company complies with applicable laws and regulations and strive to identify specific contamination risks and manage the risks to prevent contaminated water from entering storm drains or public water supplies.

8. Energy Consumption and Greenhouse Gas Emissions

• ・The Company develops energy conservation programs and establishes quantitative targets for greenhouse gas (GHG) reduction, adopts climate change countermeasures applicable to our business activities and publish the achieved results.
• ・The Company publishes data on greenhouse gas (GHG) emissions of Scope 1, 2 and main categories of Scope 3.

Fair Trade and Ethics

1. Business Integrity

• ・The Company prohibits all forms of corruption, extortion, and embezzlement, as well as any falsification of documents, in order to uphold the highest standards of integrity in all business dealings.

2. No Improper Advantage

• ・The Company prohibits all forms of bribery, collusion, money launderings and other improper acts aimed at obtaining undue benefits to prevent corruption.
• ・Transactions involving potential conflicts of interest will be appropriately managed, and will be addressed through deliberations based on the corporate governance rules and systems.
• ・The Company complies with relevant domestic and International laws and regulations, including Japan's Unfair Competition Prevention Act and the United States Foreign Corrupt Practices Act (FCPA), and prohibits bribery of public officials and government officials or their equivalents.

3. Disclosure of Information

• ・The Company makes disclosures as required by law which include information such as business activities, organizational structure or financial standing.
• ・Information disclosed will be as accurate as possible within the scope of what is available at the time when it is acquired, and disclosure will take place in a timely and appropriate manner.
• ・The Company prohibits falsification of statements or data.

4. Respecting Intellectual Property

• ・The Company protects its intellectual property rights as well as those of customers and business partners.
• ・The Company respects intellectual property rights, and conducts business activities that involve sales and transfer of technical information in a manner that protects intellectual property.

5. Fair Business Activities

• ・The Company competes fairly and freely, and conducts business activities honestly and fairly.
• ・The Company will not engage in any relationship with anti‑social forces or organizations that threaten social order, public safety, or the integrity of corporate activities.

6. Protection of Anonymity and Prohibition of Retaliation

• ・The Company established and communicated a system to protect the confidentiality of information related to reports of violations of laws and regulations as well as the anonymity of whistleblowers. The Company strictly prohibits any form of reprisal against whistleblowers.

7. Responsible Mining Activities (Mineral Procurement)

• ・The Company prohibits business transactions with individuals or organizations that contribute to conflict, terrorism, child labor, and other human rights violations, and source and use minerals that comply with RMI (Responsible Minerals Initiative) regulations.
• ・The target minerals undergo due diligence within a framework aligned with the Organization for Economic Cooperation Development (OECD)’s “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected And High-Risk Areas,” and the Company promotes procurement of conflict-free minerals.

8. Protection of Privacy

• ・The Company complies with applicable laws and regulations and effectively manage and protect the personal information of all stakeholders with whom the Company does business, including those of customers, suppliers and employees.

9. Export Control

• ・The Company complies with applicable laws and internal regulations, and by regularly scheduled audits in order to conduct proper export controls.

10. Respect for Local Communities

• ・The Company conducts business activities in accordance with relevant international standards, respecting the culture and customs of each region, taking into consideration for the human rights and health of residents and shared resources such as land and water.

Product Quality and Safety

1. Ensuring Product Safety

• ・The Company ensures its products meet the safety standards set forth in applicable laws and regulations. The Company designs and manufactures the products to ensure sufficient product safety, and market the products as a responsible manufacturer.

2. Quality Management

• ・The Company complies with applicable laws and regulations regarding product and service quality, internal quality standards as well as customer requirements.

3. Providing Information on Products and Services

• ・The Company prohibits false representations and data tampering, and provides customers with accurate information about its products and services.

Information Security

1. Securing Computer and Network

• ・The Company takes appropriate cybersecurity measures to protect computer networks from unauthorized access, and manages to prevent any potential damage to the Company and business partners.
• ・The Company performs risk management to prevent information or data breaches by implementing effective protective mechanisms to safeguard information assets.

2. Preventing Information Leaks

• ・The Company is committed to effectively managing and protecting its confidential information as well as those received from businesses partners or third parties.

3. Use of Social Media

• ・All employees will be trained in the use of social media in accordance with the guidelines set forth by the Company.

Business Continuity Planning

1. Developing a Business Continuity Plan

• ・Anticipating the occurrence of emergencies such as natural disasters, the Company conducts risk assessments in order to minimize potential damage, and develops a plan to swiftly restore business operations.

Social Contributions

1. Social Contributions

• ・The Company is committed to contributing to the development of culture and education through involvement with local communities.
• ・The Company is committed to cooperating for events held by the local communities.

2. Biodiversity

• ・Engage in activities that protect nature and the environment as well as those that aim to maintain and protect biodiversity.

Management Systems (Human Rights and Labor / Health and Safety / Environment / Fair Trade and Ethics)

1. Responsibility and Commitment

• ・The various company approved policies will be made accessible to employees in a language that can be shared by all employees.
• ・The Company’s management team clarifies the scope of their responsibilities and the people in charge of operations, and regularly review the management status.

2. Risk Management

• ・The Company establishes a process to identify, monitor and recognize applicable legal matters as well as customer requirements.
• ・The Company complies with laws and regulations related to Its business and establishes a management framework for appropriately overseeing risks in labor, health, and safety as well as the environment and ethics.

3. Improvement Objectives

• ・The Company will establish clearly defined goals, and implement plans to enhance our social, environmental, and health and safety performance, and will drive continuous improvement through regular evaluations.

4. Training

• ・The Company develops training programs for managers and employees to ensure effective implementation of our policies, procedures, and improvement objectives, and to support compliance with all applicable legal and regulatory requirements.

5. Communication

• ・The Company will establish processes to ensure that clear and accurate information about our policies, initiatives, expectations, and performance is communicated appropriately to employees, suppliers, and customers.

6. Grievance Mechanism

• ・The Company ensures two-way communication with employees and stakeholders, and promotes continuous improvement based on the feedback it receives.
• ・The Company provides a safe environment in which employees and stakeholders can raise concerns or complaints without fear of retaliation or retribution.

7. Assessment and Corrective actions

• ・The Company will conduct regular self‑assessments to ensure compliance with legal requirements the provisions of the principle, and customer contractual obligations related to social and environmental responsibility.
• ・The Company will establish processes to promptly and appropriately correct non‑conformities identified through internal and external assessments, inspections, investigations, and reviews.

8. Documentation and Records

• ・To comply with regulations, meet internal requirements, and protect privacy, the Company will create and maintain documents and records with appropriate confidentiality.