Exeo Group Human Rights Policy

Exeo Group, Inc. and Group companies recognize, in accordance with our Group philosophy of "Cultivating Technological Capabilities, Seeking Affluence and Contributing to Society," that respect for human rights is an important corporate social responsibility for all aspects of our business activities. We will contribute to the realization of a sustainable society by fulfilling this responsibility.

In order to engage in efforts geared toward respect for human rights in this manner, we have established the Exeo Group Human Rights Policy based on the Guiding Principles on Business and Human Rights adopted by the United Nations Human Rights Council. We are dedicated to complying with this policy throughout our entire value chain.

Exeo Group Human Rights Policy

Applicable scope of Human Rights Policy

This policy applies to officers and employees (including contract and temporary employees) of all Group companies including overseas companies. We also request that the Group’s customers, suppliers, partner companies, and other business partners understand and support the policy.

Commitment to respecting human rights

As a company operating globally, the Group supports the following international covenants and treaties that have been adopted as common standards for all people and countries to achieve.

• Universal Declaration of Human Rights
• International Covenant on Economic, Social and Cultural Rights
• International Covenant on Civil and Political Rights
• Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• Children’s Rights and Business Principles

We also comply with the laws and regulations applicable to each country and region in which we conduct business activities. In case there is a conflict between internationally recognized human rights and the laws and regulations of each country or region, we will seek ways to respect international human rights principles while taking these local laws and regulations into consideration.

Efforts to address basic human rights issues

The Group engages in efforts to address the following basic human rights issues and thoroughly ensures that all our officers and employees comply with them.

(1)Diversity & inclusion

• We respect the human rights of all individuals. We do not tolerate working conditions or interpersonal language and behavior that discriminate on the basis of gender, age, nationality, race, ethnicity, beliefs, religion, social status, disability, pregnancy, childbirth, or the taking of leave for childcare or nursing care, nor do we tolerate any kind of harassment that may cause discomfort or disadvantage to a person or harm their dignity.
• We foster a corporate culture that recognizes diverse values regardless of gender, sexual orientation, or gender identity, and do not engage in language or behavior bound by preconceptions or stereotypes.
• Whether inside or outside the office, we do not tolerate unwanted sexual language or behavior (sexual harassment) or any other behavior that creates an environment of sexual discomfort in the workplace.
• We do not tolerate any kind of behavior that is beyond what is necessary and reasonable in the work context in which someone takes advantage of their superior position to cause mental distress, physical pain or worsen the work environment (power harassment) of not only officers or employees but also people at partner companies, job applicants, or others. To prevent this kind of behavior, we also strive to be vigilant of the language and behavior of other officers and employees.

(2)Promoting health and productivity management & improving work environments

• We thoroughly implement safety and health management systems to preemptively prevent occupational accidents, health problems, and construction accidents, and to create comfortable working environments.
• We promote the creation of comfortable work environments that reduce the fatigue and stress of officers and employees.
• We supervise to ensure that no inhumane practices arise such as long working hours, and promote the creation of comfortable work environments that reduce the fatigue and stress of officers and employees.
• We prohibit all forms of forced labor, human trafficking, and child labor, and work to correct and eradicate labor practices that violate human rights.
• We respect the right of workers to engage in union activities such as organizing and participating in labor unions and exercising the right to collective bargaining, and as a company we negotiate in good faith with their representatives.
• We comply with all wage-related laws and regulations and with labor standards, and strive to secure appropriate wage levels that guarantee a decent standard of living for employees and their families.

(3)Harmony with local communities

• When doing construction work, we sufficiently investigate impacts of the noise, vibration, and other disturbances on the living environment of the local residents, and when impacts are identified, we must obtain the approval of the local residents before starting construction.
• We do not allow our construction or security work to infringe on the rights of others or interfere with the legitimate activities of individuals or organizations.
• We protect the safety of people and vehicles passing by a work site and prevent accidents from happening.

(4)Protecting privacy

• We handle personal information with the utmost care under an appropriate management system and do not infringe on the privacy of individuals.

Governance

This policy is administered by the Sustainability Committee, which includes the CEO, and its initiatives are led by the Sustainability Promotion Office of the General Affairs Department.

We consider respect for human rights to be an important sustainability issue, and the Sustainability Committee regularly reports to the Board of Directors on the status of human rights due diligence efforts.

Efforts to respect human rights which are related to noteworthy human rights issues are reported to the Board of Directors to be discussed and monitored.

Human rights due diligence

The Group will respond appropriately if our business activities cause or contribute to any adverse impacts on human rights. We also strive to prevent or mitigate negative impacts on human rights which are directly linked to our businesses, products, or services through business relationships, even if they do not advance any negative impacts.

In order to fulfill our social responsibility to respect human rights, we will build and both regularly and continuously implement a human rights due diligence framework.

• Conduct impact assessment on human rights.
• Integrate assessment results into organizational functions and processes to prevent or mitigate potential impact.
• Monitor whether prevention and mitigation measures are being implemented effectively.
• Disclose results of impact assessments, response measures, and monitoring, and communicate with stakeholders accordingly.

In operating this system, we will revise and improve it as necessary based on the advice of external experts and organizations as we work toward ensuring an effective human rights due diligence process.

Corrections / remediation

We will establish a framework in the Group to provide a consultation service to remedy and correct any adverse human rights impacts that the Group has caused or contributed to. We will take into consideration the following items when establishing the consultation service.

• Users shall include not only officers and employees but all stakeholders, including external stakeholders, subcontractors, and their employees.
• All incidents related to responsible corporate behavior, as well as incidents related to laws, regulations and internal rules are subject to consultation.
• We will actively involve external experts.
• We will secure the anonymity and confidentiality of users and protect them from experiencing any disadvantages due to reporting an incident.
• We will incrementally develop the consultation service, including expanding the number of users and incidents that can be reported based on the reporting and consultation services at each company in the Group.

Disseminating, instilling, and educating about our Human Rights Policy

To establish this policy throughout our business activities, the Group regularly provides education to our officers and employees including information and training on issues related to human rights (including but not limited to topics such as harassment, forced labor, and child labor).

The Sustainability Promotion Office of the General Affairs Department repeatedly sends out messages about respecting human rights to officers and employees, informing them about our basic concept of respect for human rights and sharing examples of issues.

We also endeavor to instill understanding of this policy in our business partners and other parties associated with the Group's businesses, products, and services.

Dialogues with stakeholders and information disclosure

The Group continuously engages in dialogues and discussions with external experts and internal and external stakeholders on how to address any adverse impacts on human rights caused by our business activities.

We will periodically revise this policy based on changes in the external environment and the results of the aforementioned dialogues and discussions, and work to enhance our efforts to respect human rights. We will also regularly disclose our efforts to respect human rights based on this policy on our website and other media.

This policy was approved at a meeting of our Board of Directors in January 2024.

January 2024
Tetsuya Funabashi
President & CEO
Exeo Group, Inc.