Human Rights Policy

purpose

The purpose of this policy is to protect partners from violations of various laws and regulations and prevent the occurrence of fraudulent and unfair acts by establishing rules regarding consideration for human rights in business activities that the Company's officers and employees (hereinafter referred to as "partners") should comply with.

Human Rights Policy

We will respect human rights in all aspects of our business activities and contribute to the development of a sustainable society.

We support and respect international norms related to human rights, including the United Nations International Bill of Human Rights, the Guiding Principles on Business and Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work.

We will comply with the laws and regulations applicable to each country and region in which we conduct business activities, and promote initiatives to respect human rights.

Elimination of Discrimination in Employment and Occupation

As a member of the GMO Internet Group, the "Spirit Venture Declaration" states that "we will eliminate all discrimination based on race, nationality, gender, educational background, language, and religion. We will respect diversity and strive to achieve equal opportunities.

We do not tolerate any kind of discrimination or harassment, including gender identity, sexual orientation, age, disability, disease, etc.

Prohibition of forced labor and effective abolition of child labor

We will prohibit all forms of forced labor, effectively abolish child labor, and conduct business activities that comply with regulations.

Compliance with laws and regulations and working conditions related to working hours and wages

We will comply with laws and regulations and working conditions regarding working hours and wages in each country and region in which we conduct business activities.

In terms of working hours, we will reduce total working hours and take measures to reduce overwork to prevent health problems among our partners.

In terms of wages, we will provide opportunities for dialogue with our partners as necessary and strive to ensure fair working conditions.

Maintaining and promoting a safe work environment and health

We will comply with laws, regulations, and regulations related to safety and health in each country and region in which we conduct business activities.

We have established an organizational structure specializing in health maintenance and promotion, and support our partners in living healthy and active lives through a wide range of programs such as "food," "healing," "excitement," and "medicine."

Freedom of Association and Right to Collective Bargaining

We respect freedom of association and the right to collective bargaining as the rights of our partners.

Employee representatives are elected by a vote of confidence through a candidacy system.

We maintain smooth labor-management relations and build a rewarding work environment for all partners by concluding labor-management agreements, reviewing internal regulations such as employment rules, implementing health committees, and conducting occupational accident prevention activities, led by employee representatives elected at each site nationwide.

Understanding and dissemination of human rights policies and conducting in-house training

We will provide appropriate in-house education and training to all partners so that this policy is established throughout our corporate activities, understood, and effectively implemented.

Establishment of a correspondence desk

We will establish appropriate response points to prevent human rights violations from occurring, and if human rights violations become apparent, we will work to remedy them through appropriate procedures.

Consultations and reports will be handled by External Director, external lawyers, and specialized staff, and a system will be established to ensure the confidentiality and anonymity of the consulting and whistleblowers, conduct fair and objective investigations, and respond appropriately.

Establishment of a system of dialogue and consultation

We will consult with relevant stakeholders, including suppliers and business partners, on responses to potential and actual impacts on human rights.

The person in charge of human rights issues shall be the Corporate Support Division Director, who supervises efforts to address human rights issues and determines policies and responds to human rights issues.

Purpose

This policy sets forth the rules that officers and employees (hereinafter referred to as "partners") of the Company must comply with regarding respect for human rights in business activities. The objective is to protect partners from violations of laws and regulations, and to prevent the occurrence of fraudulent or unjust acts.

Human Rights Policy

Respect for human rights shall be ensured in all aspects of business activities, thereby contributing to the development of a sustainable society.

International human rights norms, including the United Nations "International Bill of Human Rights," the "Guiding Principles on Business and Human Rights," and the "ILO Declaration on Fundamental Principles and Rights at Work," are supported and respected.

Laws and regulations applicable in each country and region of business operations shall be complied with, and initiatives to respect human rights shall be promoted.

Elimination of Discrimination in Employment and Occupation

As a member of the GMO Internet Group, the Company upholds the "Venture Spirit Declaration" as its code of conduct, which states: "Eliminate any kind of prejudice on the grounds of race, nationality, gender, educational background, language, religion, or any other factors. Value people for their ability and merits." The Company respects diversity and strives to realize equal opportunities.
Discrimination or harassment based on gender identity, sexual orientation, age, disability, illness, or any other attribute is not tolerated.

Prohibition of Forced Labor and Effective Elimination of Child Labor

All forms of forced labor are strictly prohibited. Effective elimination of child labor is pursued, and business activities are conducted in compliance with applicable laws and regulations.

Compliance with Labor Laws and Conditions Regarding Working Hours and Wages

Labor laws and conditions regarding working hours and wages in the respective countries and regions of operation are complied with.

Measures are implemented to reduce total working hours and prevent excessive workloads in order to safeguard partners' health.

Dialogue opportunities with partners are established as necessary to ensure fair working conditions, including appropriate compensation.

Safe Workplace Environment and Health Maintenance and Promotion

Laws, regulations, and internal rules related to safety and hygiene in each country and region of operation are strictly observed.

A dedicated organizational framework is established to support health maintenance and enhancement, providing a wide range of programs focusing on "Diet," "Healing," "Movement," and "Medicine" to promote partners' well-being and vitality.

Freedom of Association and Right to Collective Bargaining

The Company respects the right of partners to freedom of association and collective bargaining.

Employee representatives are elected through a candidacy and vote-based system.

By centering activities around employee representatives selected at offices nationwide, the Company maintains sound labor-management relations and fosters a rewarding workplace through activities such as concluding labor agreements, revising work rules, convening hygiene committees, and preventing workplace accidents.

Understanding, Dissemination, and Internal Training on the Human Rights Policy

To ensure thorough understanding, effective implementation, and integration of this policy into corporate activities, appropriate internal education and training programs are conducted for all partners.

Establishment of a Contact Point

A dedicated contact point is established to prevent human rights violations. In the event a violation is identified, remedial actions are taken through appropriate procedures.

Consultations and reports are handled by outside directors, external legal counsel, and specialized staff. Confidentiality and anonymity of the whistleblower or inquirer are strictly protected, and fair, objective investigations are conducted with appropriate measures taken accordingly.

Establishment of a Dialogue and Consultation System

Dialogue is conducted with relevant stakeholders, including suppliers and business partners, concerning actual and potential human rights impacts.

The General Manager of the Corporate Support Division shall be appointed as the officer in charge of human rights issues, overseeing the supervision of initiatives, determination of policy, and response regarding human rights challenges.