TESS Group
Human Rights Policy

Introduction
As provided in the Code of Conduct of TESS Group*1 (“the Group”), the Company declares that it will “respect human rights and comply with laws, regulations and foreign and domestic rules, and will conduct highly ethical business activities through which it will support the sustainable development of society and realize the Group’s business philosophy of ‘Customer Focus, Customer Satisfaction.’” In this context, the Company has set forth the following matters.

Excerpts from Article 2 of the Code of Conduct of the TESS Group (the “TESS Group Code of Conduct”)

1. Legal Compliance
In all kinds of corporate activities, we will conduct sensible activities in compliance with laws and regulations and in conformity with social ethics.
2. Respect for Human Rights
We will respect each person’s human rights and will eliminate discrimination based on race, ethnicity, religion, nationality, social status, gender, age, or disability.
3. Response to Environmental Issues
We will conduct corporate activities helpful in building a low-carbon and circular society and will contribute to the establishment of a sustainable society that will achieve harmony between the environment and the economy.
4. Establishment of Employees’ Working Environment
We will respect the diversity, personality and individuality of employees, ensure fair treatment for them and prohibit harassing behaviors to create a safe and pleasant working environment which will allow each individual employee to demonstrate their ability and vitality.
5. Gaining the Trust of Customers
We will provide products and services that match the needs of customers and accurate information related thereto and will properly protect and manage customer and other information. In addition, we will take customer demands seriously and deal with them appropriately so as to gain their trust.
6. Mutual Development with Business Partners
We will build business relationships under fair rules and establish a trusting relationship through smooth communication with business partners and will seek to achieve mutual development.
7. Coexistence with Communities
To support the sound development of communities and comfortable, safe, and secure livelihoods, we will proactively incorporate communities’ opinions toward coexistence with communities.
8. Understanding and support from stakeholders
We will pursue fair and transparent corporate management to gain understanding and support from stakeholders.
9. Prohibition of Bribery
Any form of bribery is prohibited, including bribes, kickbacks and other illegal payments. We will maintain a sound relationship with business partners, sever any collusive ties, and conduct corporate activities in a fair and transparent manner.
10. Handling of Antisocial Forces
We will take a resolute attitude in dealing with antisocial forces and organizations which could pose a threat to social order and security and will cut off any and all relations with them.

The Company has established the TESS Group Human Rights Policy (the “Policy”) to further clarify the Group’s commitment to respecting human rights.
The Policy is applicable to all officers and employees*2 of the Group.

1. Respect and Support for International Norms and Legal Compliance
We will support and respect international norms on human rights*3. We will also promote human rights efforts as a signatory of the United Nations Global Compact. In case there arises any inconsistency between international norms on human rights and relevant laws and regulations of any country or region where we conduct business activities, we will seek measures to respect international norms to the maximum extent possible.
2. Respect for Human Rights across All Business Activities
We will respect the basic human rights, personality, individuality, and diversity of individuals and will prohibit all forms of discrimination, harassment, and unfair treatment, including employment management and treatment at the workplace based on race, nationality, ethnicity, gender, sexual orientation, gender identity, religion, age, sex, location, disability, physical characteristics, or other grounds. We will not accept child labor, forced labor or other forms of illegal labor and will not take part in any human rights violation. We will also strive to improve our working environment and establish decent working conditions.
3. Promotion of Diversity, Equity and Inclusion
We will aim to create a workplace where members with diverse attributes, values, experiences and other backgrounds coexist, recognize each other in a fair and impartial manner, fully demonstrate individual ability, truly feel their growth and self-fulfillment, and feel secure in their work.
4. Human Rights Due Diligence
Through the human rights due diligence framework, we will identify both direct and indirect negative impacts on human rights during business activities and will strive to prevent or mitigate such impact.
5. Relief and Correction
If any of our business activities is found to have caused, encouraged, or become involved in a negative impact on human rights, we will seek correction of or relief for such impact by appropriate means.
If there arises any issue concerning a human rights violation, we will set up a reporting and consultation center for all persons involved in our business activities to report such issue.
6. Dialogue and Discussion
We will identify stakeholders who are or may be subject to negative impacts on human rights during business activities and will continuously hold dialogues and discussions with such stakeholders in an effort to promote initiatives to respect human rights.
7. Promotional Structure
The Group has established the ESG Promotion Committee that will set forth and put into place various policies under the Policy and specific measures applicable across the company. Human rights due diligence will be led by the D&I Working Group, a subordinate specialist unit under the ESG Promotion Committee, and the Internal Audit Office.
8. Publicity and Permeation of and Education on the Human Rights Policy
We will provide appropriate education and training to officers and employees to ensure that the Policy will be well understood and effectively implemented through all of our business activities.
9. Information Disclosure
We will regularly disclose our human rights initiatives that are based on the Policy.
10. Responsible Department
The department responsible for the Policy is the Human Capital Strategy Division.

*1 The TESS Group includes the Company and its consolidated subsidiaries.

*2 All officers and employees include the Group’s officers, regular, contract and seconded employees, and part-time and temporary workers.

*3 International norms on human rights include the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, the Ten Principles of the UN Global Compact, and the UN Guiding Principles on Business and Human Rights.

Established on July 23, 2024
Kazuki Yamamoto
Representative Director and President,
TESS Holdings Co., Ltd.