Daiwabo Group Human Rights Policy

1. Basic stance on human rights

The Daiwabo Group* herein sets forth the “Daiwabo Group Human Rights Policy” (hereinafter referred to as the Policy) under the Daiwabo Group Charter of Corporate Behavior. We will respect the human rights of all people and not practice any form of discrimination. The Group will respect international codes of behavior, such as the Universal Declaration of Human Rights, and will act with a high sense of ethics toward the creation of a sustainable society.
*“The Daiwabo Group” refers collectively to Daiwabo Holdings Co., Ltd., and its consolidated subsidiaries.

2. Scope of Application

The Policy applies to all officers and employees of the Group, including contract and temporary employees.
We ensure that the Policy is communicated to all employees to convey our fundamental approach to respecting human rights.
We also continuously engage with business partners who are directly involved in the businesses, products or services of the Group to support the Policy and adopt a similar policy to advance respect for human rights in cooperation with the partners. 

3.Compliance with International Norms

The Daiwabo Group understands the following international principles and standards as the minimum principles and standards to be observed with respect to human rights and endorses them.

- International Bill of Human Rights (Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and International Covenant on Economic, Social and Cultural Rights)

- ILO Declaration on Fundamental Principles and Rights at Work

- UN Guiding Principles on Business and Human Rights

- Ten Principles of the United Nations Global Compact

- Children’s Rights and Business Principles

4.Promotion system

In the Daiwabo Group, the President of the Company will appoint an officer responsible for the execution of the Policy and shall be responsible for supervising the compliance and execution of the Policy.

5.Governance

In the Daiwabo Group, efforts to respect human rights are discussed by the ESG Promotion Committee and reported to the Board of Directors.
The establishment and revisions of the Human Rights Policy are resolved at the Board of Directors after deliberation at the ESG Promotion Committee.

6.Commitment to Human Rights Issues related to Corporate Activities

The Daiwabo Group will support and respect ten conventions in five core labor standards fields of the ILO Declaration on Fundamental Principles and Rights at Work.
- Elimination of Any Form of Discrimination
The Daiwabo Group will respect the diversity of individuals and all fundamental human rights. Based on laws and regulations, the Group will not be complicit in any human rights violations nor discriminate against any people based on gender, age, nationality, race, ethnicity, ideology, creed, religion, social status, employment format, marital status, pregnancy status, family origin, sexual orientation or gender identity, physical characteristics, disease, disability, etc.

- Workplace Environment
Based on laws and regulations, the Group provides a healthy and safe work environment free from physical and mental harassment, including corporal punishment, violence, threats, discrimination, and sexual harassment. We protect the rights of young workers, ensure equal pay for equal work, guarantee minimum wages, manage appropriate working hours, reduce excessive working hours, respect freedom of association and the right to collective bargaining, protect privacy and freedom of expression, and respect the rights of children. The Group does not tolerate any form of forced labor, child labor, or human trafficking.

7.Human Rights Due Diligence

The Daiwabo Group will establish a mechanism of human rights due diligence to grasp negative impacts on human rights and their risks, and to prevent and mitigate such impacts.

8. Remedial Measures

If it becomes clear that the Group’s business activities have caused negative impacts on human rights, we will engage in remedy through dialogue and appropriate procedures in accordance with international codes of conduct.

9. Education and Awareness

The Daiwabo Group will provide appropriate education for all officers and employees (including contract and temporary employees) to ensure that the Policy is incorporated into and implemented in all business activities and will work to raise their awareness of human rights.

10.Dialogue and Discussion

The Daiwabo Group will engage in sincere dialogue and discussion with relevant stakeholders to understand and address the impact of its business activities on human rights from the perspective of affected people.

11.Disclosure of the Policy and Reporting on Human Rights Initiatives

The Daiwabo Group will disclose the progress of its efforts to address negative impacts on human rights through methods including the website and integrated report of the Company.

Established: July 1, 2024
Revised: December 24, 2025
Daiwabo Holdings Co., Ltd.
Representative Director, President and Chief Executive Officer
Chair of ESG Promotion Committee
Yukihiro Nishimura

Individual Policy

Human Rights Response to Advanced Technologies

The Daiwabo Group recognizes that the rapid spread of diverse services utilizing the Internet and ICT (Information and Communication Technology), as well as emerging technologies such as AI (Artificial Intelligence), brings significant convenience to society while also posing potential human rights issues, including defamation, privacy violations, and discrimination. As a company driving technological innovation, we are committed to respecting human rights and ensuring that technology is used ethically and fairly.

Promotion system

The Daiwabo Group has established the ESG Promotion Committee, chaired by the Representative Director and President, and positioned respect for human rights as one of the key materiality themes. The Committee deliberates, makes decisions on, and reviews related issues, and important matters are reported to and, where necessary, submitted to the Board of Directors. Human rights initiatives are overseen by the ESG Promotion Dept. as the coordinating function, working in collaboration with the human resources department, the legal compliance department, and related departments of operating companies to assess the current situation, examine countermeasures, and implement actions.

 

Human rights due diligence

The Daiwabo Group, in response to the growing social importance of human rights, established its Human Rights Policy in July 2024 and has been promoting human rights due diligence based on this policy. We conduct awareness surveys among employees of our group companies to identify human rights risks and utilize our internal reporting system (Helpline) to receive reports, consultations, and suggestions related to human rights issues, thereby supporting risk response and prevention. For suppliers, we work to identify risks and ensure respect for human rights through responses to the CSR Procurement Self-Assessment Questionnaire (SAQ) based on the Group CSR Procurement Guidelines.
Through our human rights due diligence framework, we strive to protect the human rights of stakeholders and promote sustainable business activities. Under the responsibility of senior management, we will continue to assess the impact of our business activities and supply chain on human rights, prevent and remedy adverse impacts, monitor and evaluate effectiveness, and disclose information externally.

Human Rights Impact Assessment and Response

To identify potential human rights risks that may arise within the business value chain of the Daiwabo Group, we conducted an assessment based on international human rights standards such as the International Bill of Human Rights, the Ten Principles of the United Nations Global Compact, and the ILO Declaration on Fundamental Principles and Rights at Work, as well as advice from external experts. We identified human rights issues that could be associated with our business activities and carried out employee awareness surveys and supplier CSR procurement surveys. Risk assessment was conducted by comprehensively assessing the scale of potential human rights violations, the possibility of remediation, the scope of impact, and the likelihood of occurrence. Based on this assessment, we determined the level of impact on human rights and identified priority issues requiring action. As a result, we confirmed common issues shared by the Daiwabo Group and its suppliers. Measures to prevent and mitigate these risks are being implemented as shown in the table below.

Prevention and Remediation of Negative Impacts

If it becomes evident that the Daiwabo Group has caused or contributed to negative impacts on human rights, or that such impacts are directly linked to our business activities, we will respect the rights of affected individuals and work to provide remediation through sincere dialogue with stakeholders and appropriate procedures.

 

Although no serious human rights violations have been identified as a result of our human rights due diligence, we are implementing the following measures to prevent and address potential risks:
- Thorough dissemination of the Group Human Rights Policy
- Disclosure to all employees of responses to low-severity findings to enhance employee satisfaction
- Initiatives to improve awareness and trust in the Helpline

Human Rights Education

Respect for human rights is essential for ensuring appropriate consideration for all stakeholders involved in corporate activities. Achieving this requires every employee to have a correct understanding and a strong awareness of human rights.
In 2024, the Group established our Human Rights Policy and enhanced our annual compliance education program by incorporating content aimed at deepening understanding of key human rights risks that companies should address in relation to “Business and Human Rights.”
Furthermore, we introduced training programs designed not only to develop subordinates but also to foster growth among managers themselves. These programs include practical modules to strengthen the ability to appropriately handle harassment reports and related cases, thereby promoting a company-wide culture of respect for human rights. 

Education Achievements in FY2024

  • Managers: Comprehensive study on “Improving Workplace Environment” and “Skills and Qualities of a Trusted Leader”
  • New Managers / Section Chiefs: “Harassment Prevention Education”

Awareness Initiatives

We are committed to reducing human rights risks by implementing measures such as proactive reporting and discussions by senior management with all managers, sharing the outcomes company-wide, and enhancing training programs focused on respect for human rights.

Awareness Achievements

  • Reported the status of human rights initiatives and survey results at the all-managers meeting
  • Published the results on the company intranet and shared them with all employees

Labor-Management Relations Initiatives

The group strives to build a sound and trusting relationship with employees by engaging in dialogue with labor unions and employee representatives, while respecting the rights of each individual employee.

 

  • Industrial Machinery Business: Maintains a labor union and has long conducted healthy labor-management negotiations, including explanations of business and production conditions. Wage level adjustments in response to rising prices are also addressed through labor-management discussions.
  • Daiwabo Holdings / IT Infrastructure Distribution Business: Although no labor union is in place, we ensure explanations and obtain consent from all employees when making significant changes to work rules or employment conditions. For revisions to personnel systems, employee representatives are elected, and changes are implemented following proper labor-management consultations in compliance with legal requirements.

Monitoring

In the Group, we not only analyze annual SAQ (Self-Assessment Questionnaire) results for both suppliers and our own operations, but also regularly review the progress of issue-specific measures in ESG Promotion Meeting and Committee. We continuously monitor and confirm actions taken to address potential negative impacts. Through this ongoing monitoring and improvement proposals, we strive to reduce human rights risks and enhance human rights awareness across the entire Group.

External Information Disclosure

In line with the Daiwabo Group Human Rights Policy, the Group places great importance on demonstrating a high level of transparency and accountability to all stakeholders regarding our efforts to respect human rights. To this end, we actively disclose information on the human rights due diligence process and its outcomes through our corporate website and the annually published Integrated Report. By doing so, we aim to create an environment where rights holders can fully understand our initiatives and engage with us with confidence.

Remediation Measures

The Group has established a system that allows individuals who believe their rights have been violated, or are at risk of violation, to seek remedies with confidence. Employees can report or consult on any legally questionable acts or inappropriate incidents through the “Daiwabo Helpline.” In addition, stakeholders other than employees can submit opinions or inquiries related to human rights via the “Sustainability and Human Rights Contact” page permanently available on our corporate website.
All submissions are investigated as necessary, and if any human rights violation is confirmed, we promptly provide relief to the affected party, correct the issue, and implement measures to prevent recurrence. Furthermore, personal information and consultation details are strictly managed and will never be disclosed externally without the consent of the individual.

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