ITOCHU Group Human Rights Policy

The ITOCHU Group has adopted the "ITOCHU Group Human Rights Policy" (hereinafter "the Policy"), drafted based on our Corporate Mission, Code of Ethical Conduct, and The Basic Policy on Promotion of Sustainability. This Policy iterates our commitment to respect the human rights of our stakeholders and address negative impacts that may arise from our business activities.

1. Policy Scope and Our Expectations Toward Business Partners

This Policy applies to all worldwide executives and employees of the ITOCHU Group, including contractors and temporary employees. The ITOCHU Group also expects business partners and other relevant stakeholders to comply with this Policy.

2. Endorsement of International Agreement

The ITOCHU Group supports international agreements on human rights, including the Universal Declaration of Human Rights, the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, and the United Nations Global Compact, which we have been a signatory to since 2009. We will also implement measures aligning to the United Nations Guiding Principles on Business and Human Rights.

3. Legal Compliance and Respect for Internationally Recognized Human Rights

The ITOCHU Group will comply with the laws and regulations in the respective countries and regions where we perform our business activities in addition to Japan. If there is a contradiction between internationally recognized human rights and the laws and ordinances of a country or region, we will pursue a method to maximize respect for international human rights principles.

4. Management Approach

The ITOCHU Group will build structures to realize this Policy. The Sustainability Officer will bear the responsibility to oversee the compliance and implementation situation of this Policy.

5. Human Rights Due Diligence

Based on the United Nations Guiding Principles on Business and Human Rights, the ITOCHU Group will implement human rights due diligence in order to identify, prevent and mitigate negative impacts on human rights and fulfill our commitment to accountability.

6. Remedy and Rectification

If the business activities of the ITOCHU Group induce a negative impact on human rights or if involvement in such becomes clear, we will strive to remedy and rectify that through appropriate procedures and dialogue.

7. Dialogue and Consultations

The ITOCHU Group will leverage external human rights expertise in its implementation of human rights due diligence and will engage in dialogues and consultations with our stakeholders – especially those potentially subject to adverse impacts from our business activities.

8. Education and Awareness

The ITOCHU Group will provide appropriate education to all executives and employees (including contractors and temporary employees) and strive to raise human rights awareness in order to incorporate and implement this Policy in our business activities.

9. Communication on this Policy and Our Relevant Initiatives

This Policy will be approved by senior executive in charge of sustainability and be reported to our Board of Directors and we will widely publish it to the public. We will also report on our human rights initiatives based on this Policy on the ITOCHU website and in our ESG Report.

Sustainability Action Guidelines for Supply Chains

ITOCHU Europe PLC adopted the "Sustainability Action Guidelines for Supply Chains" to clarify and communicate the sustainability concerns we expect our suppliers to address. We will take the necessary measures to communicate and cooperate with our suppliers to ensure responsible management of the following items.
Suppliers shall comply as follows;

1. Abuse and Harassment
   Respect the human rights of all of employees and not engage in inhumane treatment, including discrimination, harassment, abuse and corporal punishment.
2. Forced Labor and Child Labor
   Prohibit forced labor or child labor including the employment of children under the minimum working age.
3. Discrimination
   Prohibit employment discrimination based on characteristics including but not limited to gender, race, and religion.
4. Suitable Remuneration
   Comply with statutory minimum wages, strive to exceed living wages, and not unjustly reduce wages.
5. Freedom of Association and Collective Bargaining
   Respect the freedom of association and right to collective bargaining of employees and ensure that labor-management discussions on working conditions and environment are held, as appropriate.
6. Working Hours
   Comply with statutory working hour restrictions. Properly manage employees’ working hours, provide holidays and paid leave as necessary and strictly prohibit excessive overtime work.
7. Safe and Healthy Working Environments
   Take necessary measures to provide a safe, hygienic and healthy working environment to employees.
8. Environment
   Consider potential and existing impacts on local communities and the environment with regards to business activities – such as impacts on nearby biodiverse habitats or pollution of the local ecosystem. Take the necessary measures to reduce consumption of energy, water and other natural resources, as well as emissions of greenhouse gases and waste.
9. Anti-Corruption
   Comply with all applicable local and international laws and regulations. Ensure compliance with fair business practices and anti-corruption, including prevention of conflicts of interest and anti-competitiveness.
10. Information Disclosure
    Disclose information on all items listed above in a timely and appropriate manner.