Respect for Human Rights

Respect for Human Rights

The Company has established the Hulic Human Rights Policy, by applying "Guiding Principles on Business and Human Rights (UNGPs)" of the United Nation, which proclaims respect for human rights so that all employees can maximize their abilities and contribute to the realization of a society full of peace of mind and trust. In our Human Rights Policy, we declare that we prohibit any acts of discrimination and harassment, as well as any discrimination against any person on the ground of his or her beliefs, religion, age, sex, sexual orientation, race, nationality, origin, physical or mental disorder, etc. We also prohibit any act, including sexual harassment or abuse of authority, to inflict emotional distress on any person through language or behavior that damages his or her character or dignity. Respect for human rights encompasses all fundamental human rights found in the Constitution, Labor Standards Act, and Universal Declaration of Human Rights, as well as human rights related to equal employment, prohibition of forced labor and child labor, freedom of association, and collective bargaining stipulated in the ILO's international labor standards.
We regularly post the information on the theme of human rights to all Group Companies, using our intranet. In FY2024, we posted a notice on the theme of "The Company and Human Rights".

Communicating the Hulic Human Rights Policy and Labor Standards to All Employees

We communicate the Hulic Human Rights Policy and labor standards, including employment regulations and labor contracts, to all employees^* through in-house intranet, maintenance of the list of regulations, compliance training and in other ways to ensure understanding and full assimilation.

• *All employees are engaged in business in Japan.

Implementation of Human Rights Due Diligence

Based on the Hulic Human Rights Policy, Hulic engages in human rights due diligence to prevent negative impacts on human rights through our business activities.

The Company conducts dialogue with internal and external parties through human rights risk assessment questionnaires and feedback. In 2023 and 2024, the Company conducted external human rights risk assessments with multiple construction companies.

Regarding grievance mechanisms, the Company has established contact points where both internal and external parties can report and consult on human rights-related issues.

Based on information from human rights risk assessments and grievance mechanisms, the Company evaluates the effectiveness of initiatives, review priority issues, and evaluate the effectiveness of prevention and mitigation measures that have been formulated to date. In 2024, the status of efforts to address human rights risks was concluded to be appropriate.

If it is determined that negative impacts on human rights is being caused, the Company will formulate preventive and mitigation measures, as well as disclose necessary information and conduct follow-up investigations.

Human Rights Due Diligence Process

Management of Risks regarding Labor and Human Rights Issues

Based on "The Hulic Human Rights Policy," we thoroughly manage risks related to labor and human rights issues. We have a policy that prohibits any form of human rights violation such as child labor and forced labor. We conduct regular employment management audits to ensure compliance with laws, as well as provide compliance training for employees. In addition, the department in charge of the matter assesses the situation for risk management, reports and makes recommendations through the Risk Management Committee, and the Board of Directors regularly review the risk management. Through these efforts, the situations threatening freedom of association, collective bargaining rights, child labor, forced labor, security practices, and the rights of indigenous peoples are not occurred.

Furthermore, in the human rights due diligence process, we recognize labor issues as a critical human rights issue.

Specifically, the following actions are implemented:

• Risk Assessment for New Businesses
  When investing in new projects, we conduct due diligence on the management structure of the companies targeted for M&A, etc. The due diligence includes human resources management and internal regulations, to identify and assess human rights risks including labor issues.
• Risk Assessment for Existing Businesses
  We regularly evaluate the status of human resources and labor affairs to continuously monitor the operation of existing businesses and manage labor-related risks associated with human rights.
• Supply Chain Risk Management
  We send human rights due diligence questionnaires to some suppliers to confirm the working conditions and occupational health and safety situations of their employees and manage risks across the entire supply chain.
• Education and Awareness Activities
  To manage human rights and labor issues appropriately, we focus on internal education and information dissemination. Training sessions on preventing power harassment, etc. are conducted by external instructors for executives and general managers to enhance their awareness of human rights issues. In addition, we utilize the company intranet to promote " The Hulic Human Rights Policy" and display messages related to " Harassment " for all group companies, and promote awareness activities among all employees.

Hulic Group
Basic Policy on Customer Harassment

The Hulic Group is committed to sincerely and respectfully addressing the opinions and requests of our customers. At the same time, we take a firm stance to protect our employees against acts that constitute abuse by customers (what is called “Customer Harassment” in Japan), and will respond to such acts in an organized manner, including consulting with law enforcement and legal professionals.

(1) Definition of Customer Harassment

Based on materials such as the Corporate Manual on Measures against Customer Harassment published by Japan’s Ministry of Health, Labour and Welfare in February 2022, we define Customer Harassment as complaints or statements made by customers, facility users, or other stakeholders, where the means or manner of pursuing a request is inappropriate in light of the nature of the request, and where such conduct harms the employee’s working environment. Examples of such harassment are listed below. Note that this list is not exhaustive.

Examples of Customer Harassment:

• Physical attacks such as assault and battery
• Psychological attacks such as threats, slander, defamation, insults, or abusive language
• Demands for excessive apologies, including kneeling to apologize
• Intimidating behavior such as shouting threats or using abusive language
• Persistent or relentless behavior
• Unreasonable or excessive demands, including those unrelated to products or services
• Demands for financial compensation, apologies, or other requests without reasonable cause
• Occupying an employee’s time for extended periods, such as by refusing to leave or making repeated phone calls
• Attacking, making demands of, or stalking an individual employee
• Discriminatory behavior
• Sexually inappropriate behavior
• Posting content that damages the reputation of the company or its employees, or discloses personal information about employees, including on social media

(2) Response to Customer Harassment

• We strive to build better relationships through calm and constructive dialogue aimed at reaching a reasonable solution.
• If we determine that a customer’s behavior constitutes Customer Harassment, we will take firm action to protect our employees and may, if necessary, refuse to provide products or services.
• If a case is deemed particularly malicious, we will respond firmly and appropriately, including by consulting law enforcement or external professionals such as lawyers.

(3) Initiatives by the Hulic Group

• We provide training on how to recognize and respond to Customer Harassment.
• We have established a dedicated consultation point for issues relating to Customer Harassment.
• We have established a system to respond to incidents of Customer Harassment.
• We are committed to supporting employees affected by such Customer Harassment and working to prevent its recurrence.
• To ensure an appropriate response, we work in cooperation with law enforcement and external professionals such as lawyers.

(4) A Request to Our Customers

At the Hulic Group, we aim to build strong, trusting relationships with our customers by listening to their needs and continuously improving our services. However, if a customer engages in behavior that constitutes Customer Harassment, we will respond firmly in accordance with this policy. We kindly ask for your understanding and cooperation in this matter. Going forward, we will continue our efforts to foster even better relationships with our customers.