Code of conduct /Human Rights Policy

1. Toward a Sustainable Society

1. We will contribute to resolving social issues by promoting innovative solutions, accelerating collaborative creation with partners and stakeholders, and further integrating social and environmental responsibility into our business activities.
2. We will strive to develop technologies that contribute to social development and use them with due consideration of their impact on society.
3. We envision a low-carbon society, a resource efficient society, and a harmonized society with nature. To this end, we will endeavor to reduce CO₂ emissions, use water and other resources efficiently, and minimize impacts on natural capital throughout our value chain.
4. As a corporate citizen, we will make efforts to build rapport with communities and contribute to their development by working together to resolve social issues.

2. Sincere and Fair Business Activities

2.1 Fair Trading

1. To ensure fair and open competition, we will observe the fundamental rules of trade, including domestic and overseas competition laws and regulations, and act in compliance with legislation and sound corporate ethics.
2. We will have no relationship whatsoever with antisocial forces anywhere in the world, and resolutely reject involvement in improper or antisocial transactions.
3. We will not trade shares using undisclosed information regarding the group, affiliated companies, business partners, or customers that could affect the judgment of investors (insider information).
4. We strictly prohibit and will have no involvement in bribery and other corrupt business practices. We will neither give or receive gifts nor extend or accept invitations to business entertainment beyond socially accepted limits, as we recognize that such practices can foster corruption. When working with political entities, we will build and maintain sound and transparent relationships.
5. We will help maintain international peace and security through compliance with all applicable laws and regulations concerning import and export, and will operate appropriately according to our internal rules and policies.
6. We will comply with applicable laws, respect social cultures and practices, and act sincerely and fairly in countries and regions where we have operations. Furthermore, we will do so guided by international norms and standards even in areas where legislation is not adequately enforced.

2.2 Relationships with Suppliers

1. With a global vision, and mindful of the long-term perspective, we will find qualified suppliers and build fair and equal partnerships with them, working together to build mutual understanding and trust.
2. In selecting suppliers, we will thoroughly review the quality, reliability, delivery time, and price of the materials they provide as well as their business stability and technological capability. We will give due consideration to their adoption of social responsibility practices, including areas such as the abolition of unfair discrimination, the elimination of child labor and forced labor, and environmental conservation.
3. We will not accept any personal benefits from suppliers in procurement transactions.

2.3 Relationships with Customers

1. We will provide products and services that meet the needs and requirements of our customers, complying with relevant laws and standards and ensuring quality and safety by setting additional standards of our own where necessary.
2. We will communicate with customers sincerely, address defects and customer complaints quickly and in good faith, and strive to determine causes in order to eliminate them and prevent recurrence.

3. Respect for Human Rights

1. We will promote our understanding of internationally recognized human rights, and will respect and not infringe on the human rights of all those involved in our business activities.
2. We will implement human rights due diligence appropriate to the social circumstances of the countries and regions where we have operations and the nature of our businesses, products, and services there.
3. We will assess and prevent potential violations of human rights. In the event of such a violation, we will promptly take internal and external actions to correct and remedy the situation.
4. We will respect individual human rights in the recruitment and treatment of employees and during all other company activities. We will not engage in any acts that may impair individual dignity or discriminate on bases such as sex, sexual orientation, age, nationality, race, ethnicity, ideology, belief, religion, social status, family origin, disease, disability.
5. We will hire employees in compliance with the relevant laws and regulations in each country and region, and in accordance with international norms and standards. We will not use child labor that employs children below the minimum working age or forced labor that is against the will of employees.
6. We will strive to resolve issues through sincere and constructive discussion between management and employees, in compliance with the laws, regulations, and labor practices of each country and region, and in accordance with international norms and standards.

4. Building a Work Environment That Brings Out Employee Strengths

1. Prioritizing health and safety above all else, we will strive to ensure the safety of employees and the workplace. In addition, we will promote the physical and mental health of employees and their families.
2. We will support flexible work styles and respect diverse values, creating workplaces that provide employees with a sense of accomplishment and personal growth, and we will promote the sustainable growth of the organization and individuals.
3. We will invest in educational programs to help employees expand their capabilities and exercise their strengths. Supervisors will fairly and appropriately support, guide, and educate their employees to develop their abilities.

5. Information Management and Communication

1. We will promote the ethical handling of information, so as to ensure respect for human rights and security, through the proper management of personal information based on our Personal Information Protection Policy.
2. We will properly manage and protect confidential information related to our business activities in compliance with domestic and international laws and regulations as well as our internal rules and policies.
3. In order to maintain and expand our trusting relationship with the Energywith Group’s diverse stakeholders, we will disclose information openly and transparently, and respond to stakeholders responsibly through dialogue and other means of communication.

6. Protection of Intellectual Property and Brand

1. We will protect our own intellectual property, respect third-party intellectual property, and use both effectively for smooth business operations.
2. We will manage our own and third-party confidential information by importance and manage and handle it appropriately based on this ranking.
3. We will protect and enhance the value of the Energywith Brand, recognizing it as an important management asset.

7. Securing Corporate Assets

We will use all our corporate assets only for business activities and other appropriate purposes, and manage them properly to protect their value.

8. Crisis Management

We will make concerted efforts throughout the Energywith Group to secure employee safety and business continuity in case of disasters and threats such as earthquakes, tsunamis and floods, cyberattacks, and terrorism.

9. Responsibilities of Employees

Employees shall pledge to comply with the Codes of Conduct. If they become aware of any non-compliant activity, they shall immediately report to their manager or via the internal reporting system.

10. Responsibilities of Top Management

Top managers shall take the initiative in complying with the Codes of Conduct and make their best efforts to conduct business based on corporate ethics and the law. In the event of violation of the Codes of Conduct, top managers shall swiftly take corrective measures and actions to prevent the recurrence of similar incidents, while at the same time strictly disciplining themselves as well as those involved in the violation.

Scope of human rights policy

This policy applies to all officers and employees (including contract employees) working in the Energywith Group. We also expect all business partners, including our suppliers, to understand and support the content of this policy, and will continue to work to ensure that this policy is respected by them.

Commitment to respect for human rights

We are aware that the businesses of the Energywith Group and all business partners including suppliers, directly or indirectly affect human rights in each process of the value chain from product development to procurement, manufacturing, distribution, use, final consumption, and disposal.
The Energywith Group is committed to prohibiting all discrimination and harassment, providing a safe working environment and reducing excessive working hours, ensuring minimum wages, and respecting freedom of association and the right to collective bargaining. We also do not allow child labor, forced labor or human trafficking for the purpose of labor exploitation, especially in the field of supply chain management.

Support for international human rights principles

The Energywith Group supports internationally recognized human rights principles (“International Bill of Human Rights”, the International Labour Organization’s (ILO’s) “Declaration on Fundamental Principles and Rights at work”, “the Children’s Rights and Business Principles”, etc.) and make them our own standards.
In addition, as a UN Global Compact signatory company, we will respect human rights in all aspects of our business activities and strive to prevent and mitigate adverse impacts by operating our business in accordance with the “the Ten Principles of the UN Global Compact” and “the UN Guiding Principles on Business and Human Rights.”

Remediation

In the unlikely event that the operations, products and services of the Energywith Group and its business partners including suppliers, have an adverse impact on the human rights of our customers, local communities and other stakeholders, we will endeavor to provide for remediation through appropriate procedures.

Compliance with applicable laws and regulations

In making business decisions, the Energywith Group will comply with all applicable laws and regulations in each country and region in which it operates. In the unlikely event that the laws and regulations of the country or region differ or conflict with the internationally recognized human rights principles, or when faced with conflicting requirements, we will pursue ways to respect the internationally recognized human rights principles. In the context of stakeholders and circumstances where the Energywith Group cannot control decision-making, we will strive to exert influence so that this policy will be respected, and will continue to work to avoid complicity in human rights violations.

Governance

In order to fulfill our responsibility to respect human rights, the Energywith Group will maintain an internal system to steadily implement human rights due diligence initiatives based on this policy.
In addition, we will reflect this policy in relevant policies, procedures and operations so that it can be properly incorporated into our business activities.

Human rights due diligence

In accordance with the UN Guiding Principles on Business and Human Rights, the Energywith Group will establish a process to properly assess the impact of business decision-making and execution on human rights, identify, prevent and mitigate risks that cause or contribute to serious human rights violations, and strive to provide for remediation.
In addition, in order to verify whether the adverse impact on human rights is being dealt with, we will continuously track and evaluate the effectiveness of the response.

Grievance mechanism

The Energywith Group will establish grievance mechanisms both internally and externally with the aim of early detection of concerns, including adverse impacts on human rights, and the resolution of problems. The grievance mechanisms are available to all stakeholders such as employees, business partners including suppliers, and local communities. We will ensure the anonymity of the person making the report and the confidentiality of the content of the report. In addition, we will prohibit unfavorable treatment and retaliation against the whistleblowers, and will thoroughly protect them.

Stakeholder engagement

The Energywith Group recognizes that it is important to understand the adverse impacts on human rights from the perspective of those affected. Therefore, we will endeavor to utilize it in our efforts to respect human rights by continuously conducting dialogues and discussions with our stakeholders.

Information disclosure

The Energywith Group regularly discloses information on initiatives on respecting human rights and human rights due diligence taken based on this policy through its website and other means.

Dissemination / education

The Energywith Group will not only continue to provide appropriate education and training to all officers and employees (including contract employees) but also work on capability building necessary to put this policy into practice so that this policy will permeate the company. In addition, we will strive to respect human rights throughout the value chain by thoroughly communicating the contents of this policy to our business partners, including suppliers.

Human rights policy formulation process and review

This policy is informed by the advice of external experts who have expertise and practical experience in human rights and has been formulated based on internationally recognized human rights principles, “the Ten Principles of the UN Global Compact”, and “the UN Guiding Principles on Business and Human Rights” with the approval of the Board of Directors.
We will review this policy on a regular basis in light of changes in the social environment and dialogues and discussions with stakeholders, and strive to enhance efforts to respect human rights.