Policies and Basic Approach

In keeping with the spirit of love (ai) and respect (kei) advocated by its founder, the Inabata Group has always conducted its business based on respect for people. In recent years, respect for human rights in business has increased in importance worldwide. To fulfill our responsibilities as a company with a strong global network, we have formulated the Inabata Group Human Rights Policy in March 2022 to advance the spirit of respect for people. In December 2024, we revised the Policy in light of factors such as social expectations, various guidelines, and the results of human rights due diligence. Both the establishment and revision of the Policy were approved by resolutions of the Board of Directors.
We fulfill our responsibility to promote human rights in our business activities by respecting the human rights of stakeholders affected by our activities and by addressing the negative impacts on human rights caused by our business activities.

Inabata Group Human Rights Policy

The Inabata Group has a corporate mission of respecting people and contributing to the development of society in the spirit of love (ai) and respect (kei). The values we hold most dear are the spirit of love (ai) and respect (kei), which have been passed down as the IK values since the group’s founding. We realize that people are our true business partners, and we have cherished the attitude of respecting people for over 130 years. As we expand our business globally, there are an increasing number of situations in which diverse cultures and values intersect. This makes our attitude of respecting people even more important. We recognize that protecting the dignity and rights of all people is an important responsibility of a corporation. The Inabata Group is working to promote human rights initiatives throughout our entire group. As a guideline for fulfilling this responsibility, we hereby establish the Inabata Group Human Rights Policy (hereinafter, “the Policy”) based on the United Nations Guiding Principles on Business and Human Rights and the Inabata Group Sustainability Basic Policy and Code of Conduct. We have positioned the Policy as the highest level policy of all documents and rules related to human rights efforts in our business activities. The Inabata Group recognizes that all activities in value chains in all business segments can directly or indirectly impact human rights. We will continue to promote efforts to respect human rights in our business processes. It is difficult to ascertain all of the ways in which the products and services we provide are used. However, as society continues to change, we will work toward fostering more responsible and beneficial applications. Respect for human rights is a fundamental premise for expanding our business domain worldwide and developing together with global society. The Inabata Group fulfills our responsibilities as a member of the international community.

1. Scope of Application

All officers and employees of the Inabata Group (including employees working on a fixed-term contract and temporary employees) are directly protected and are expected to act in accordance with the Policy. We also expect our business partners and other related parties to support the Policy and encourage them to respect human rights.

2. Support for and Respect of International Norms / Compliance with Laws and Regulations

We have declared our support for the Ten Principles of the UN Global Compact in four areas: human rights, labor, environment, and anti-corruption. We support and respect international norms regarding human rights, such as the International Bill of Human Rights^＊1, the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work^＊2, the Convention on the Rights of the Child. Furthermore, we promote initiatives for respecting human rights based on the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. We also comply with the laws and regulations of the relevant countries and regions in our business activities. Where internationally recognized human rights and national law are in conflict, we will seek ways to respect internationally recognized human rights principles to the greatest extent possible.

• *1 The International Bill of Human Rights is a collective term for three documents: the Universal Declaration of Human Rights and its codified covenants; namely, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights. The International Bill of Human Rights is currently considered the basic framework for the protection of human rights as recognized internationally.
• *2 The ILO Declaration on Fundamental Principles and Rights at Work sets out five areas as minimum standards to be observed in the workplace (core labor standards): freedom of association and the effective recognition of the right to collective bargaining, the elimination of all forms of forced or compulsory labor, the effective abolition of child labor, the elimination of discrimination in respect of employment and occupation, and a safe and healthy working environment.

3. Governance

The Board of Directors oversees compliance with and implementation of the Human Rights Policy. Important decisions regarding human rights are made based on reports from the Sustainability Committee and the Human Rights Affairs Committee. The Sustainability Committee, chaired by the President, formulates human rights policies, strategies and plans, and monitors the progress of plans and goals. The Human Rights Affairs Committee, chaired by the officer in charge of the Human Resources Office, provides education to deepen knowledge and understanding of human rights among employees. In addition, the Sustainability Promotion Department and the Human Resources Office take the lead in promoting human rights practices while cooperating with related divisions and group companies both in Japan and overseas.

4. Human Rights Due Diligence

Based on the United Nations Guiding Principles on Business and Human Rights, the Inabata Group will establish a system of human rights due diligence, including in our supply chain, and will continually work to identify, evaluate, and prevent or mitigate any negative effects on human rights that may result from our business activities. We also evaluate the effectiveness of these efforts and use the evaluation results to continually improve our efforts for respecting human rights.

5. Remedies and Corrections

The Inabata Group will establish appropriate and effective grievance mechanisms for use by internal and external stakeholders to raise concerns about our business activities. If it becomes clear that we have caused or contributed to an adverse impact on human rights, we will undertake remedies and corrections through appropriate procedures. Furthermore, for cases in which we are directly linked to adverse impact on human rights, we will endeavor to prevent or mitigate the impact by, for example, working together with other companies that caused or contributed to the impact.

6. Education and Awareness-Raising Activities

The Inabata Group provides appropriate education to all officers and employees of our group and works to raise awareness of human rights so that the Policy is understood and effectively implemented. We also share the Policy with our business partners and relevant stakeholders to promote the understanding and consideration of the policy.

7. Information Disclosure

The Inabata Group reports on our initiatives to respect human rights through communication channels such as our website and integrated report.

8. Dialogue with Stakeholders

The Inabata Group seeks to build trust by engaging in sincere dialogue and discussion with relevant stakeholders and external experts in all processes related to respecting human rights, including human rights due diligence.

Established in March 2022 Revised in December 2024

President and CEO

• Appendix : Basic Stance on Human Rights Issues Recognized as Salient by the Inabata Group

Targets

In the Sustainability Medium-term Plan 2026, we set strategies, KPIs, and targets.

Structure

As clearly stated in the Inabata Group Human Rights Policy, the Board of Directors oversees compliance with and implementation of the Human Rights Policy. Important decisions regarding human rights are made on the basis of reports from the Sustainability Committee and the Human Rights Affairs Committee.
The Sustainability Committee, chaired by the president, formulates human rights policies, strategies, and plans, and monitors the progress of plans and goals.
The Human Rights Affairs Committee, chaired by the officer in charge of the Human Resources Office, provides education to deepen knowledge and understanding of human rights among employees.
In addition, the Sustainability Promotion Department and the Human Resources Office take the lead in promoting human rights practices while cooperating with related divisions and Group companies both in Japan and overseas.

Human Rights Due Diligence (HRDD)

Based on the United Nations Guiding Principles on Business and Human Rights, the Inabata Group conducts HRDD to respect the human rights of people who may be affected by the Group's business activities.
An overview of the HRDD initiatives undertaken by the Group is shown in the figure below. We are advancing HRDD initiatives under the three categories of HRDD for Inabata and Group companies, HRDD for the supply chain, and foundations for HRDD.
First, we believe it is important to identify human rights risks both at Inabata and Group companies and work to foster a culture of respect for human rights. This is to protect the human rights of our employees, which are our greatest asset, and to ensure that our own awareness of human rights has a significant impact within the Group and in our supply chain. Accordingly, we have conducted an HRDD Digital Survey targeting our employees.
In addition, because the Group handles a wide range of products and solutions, its supply chain spreads across the world and involves a variety of stakeholders. For this reason, we are addressing issues related to HRDD in the supply chain using two approaches: one that thoroughly examines the supply chain up to upstream companies by identifying risks in business activities, and another that covers direct business partners, where influence can be more effectively exerted through HRDD targeting business partners (new and existing).

FY2024 activity results and FY2025 activity plan

(1) HRDD Digital Survey

In June 2023, we carried out the HRDD Digital Survey with the assistance of external experts such as SDG Partners, Inc.
This survey quantitatively measures the level of internal human rights risk based on the 25 types of human rights risks identified in "Responses to 'Business and Human Rights' Now Required of Companies" (published by the Ministry of Justice; see figure below), as well as psychological safety and unconscious bias, which are among the underlying causes of such risks. The survey used a sampling method targeting 166 of the Company’s employees.

The results of this survey overlap with issues previously recognized by the Company, such as harassment and awareness of the internal whistleblowing system, reaffirming our recognition of these challenges. Therefore, while building on the initiatives currently in place, we will further advance our efforts by incorporating the perspective of human rights.
Moreover, as these results are merely a snapshot, we plan to expand the scope to include the entire Group and monitor changes over time, as outlined in the strategies and goals of our Sustainability Medium-term Plan 2026.

Assessment items, criteria, methods, results, and response in the HRDD Digital Survey

(2) Identification of Risks in Businesses

In FY2023, we identified risks in businesses with the help of outside experts. We collected data on products we handled and interviewed sales division employees to identify the state of the Group’s businesses. Using a dual axis of products and regions, we analyzed the potential human rights risks for each business with reference to international guidelines and indicators.
The survey results revealed significant differences across businesses. It showed that many businesses face challenges due to complex supply chains, which make information gathering difficult and prevent a comprehensive assessment of human rights risks, such as those related to raw materials used in semi-finished products in the Information & Electronics sector. Meanwhile, the inability to obtain information itself is also a significant risk.
Accordingly, we will continue to investigate and develop systems for collecting information in these areas.
Conversely, in the food business and the wood-based construction materials business, it was found that information on the origin and processing stages is available, and interactions with suppliers for quality control are relatively frequent. In these businesses, risk assessments based on severity and likelihood led to the identification of agricultural and marine products from regions such as Southeast Asia as potential candidates for future HRDD.
Through interviews with employees of sales divisions and desktop research, it was confirmed that these products are being managed appropriately, and that efforts related to human rights by suppliers and producers, including handling certified products, are underway. Building on this, as outlined in the strategies and goals of our Sustainability Medium-term Plan 2026, we aimed to establish a model case for the HRDD cycle. As part of this process, we carried out an on-site investigation in FY2024 of the shrimp business in Vietnam, which was assessed as having potential human rights risks.

On-Site Assessment in Vietnam

As part of supply chain DD, we conducted an on-site assessment of the shrimp business in Vietnam’s food sector together with SDG Partners, Inc., an external expert on human rights.

●Preliminary desk research and information gathering

During the preliminary desk research, we identified potential human rights risks in Vietnam’s shrimp business by reviewing surveys from the United Nations, expert organizations, and reports from other companies. The risks deemed high were then selected as the focus for the on-site assessment.
In addition, we gathered information on these human rights risks by consulting with the International Labor Organization (ILO) and the International Organization for Migration (IOM) on the situation in Vietnam.

●On-site assessment

On March 24 and 25, 2025, representatives from the Inabata Group and external experts visited the shrimp supplier in Soc Trang Province, Vietnam. We visited the shrimp processing plant and farms, held interviews with management, and spoke with employees, resulting in the following findings.

●Conclusion and future outlook

The labor conditions, occupational health and safety measures, and employee development initiatives were found to be at a level comparable to those in Japan. At present, no serious human rights risks requiring immediate corrective action were identified. However, human rights risks are not entirely absent in the local industry, and changes in external conditions, such as fluctuations in the company’s production, could increase these risks. Therefore, monitoring will continue going forward. The results of this assessment and our improvement recommendations have been submitted to the supplier in the form of a feedback letter from our company.
Furthermore, this series of investigations has provided a model case for the HRDD process, and we are considering expanding it to other businesses within the Inabata Group.

Please refer to the following report for details of the on-site assessment.

• Human Rights Due Diligence: Vietnam On-site Assessment Report (Japanese only)

(3) HRDD for Business Partners (new and existing): Introduction of a Screening System

A screening system was introduced in FY2023 as part of HRDD for business partners (new and existing) to address not only human rights risks but also compliance, environmental, and social risks.
We monitor the supply chain risks of both existing and new business partners on a daily basis. These risks include human rights, labor, bribery, corruption, and the environment. The identified risks are evaluated by the relevant departments on a monthly basis. At present, we have not identified any business partners as posing significant risks. In FY2025, the Group will consider measures such as establishing an internal framework for responding when business partners posing significant risks are identified.
Going forward, in addition to system-based screening and monitoring, we will also consider conducting direct surveys of suppliers.

Consultation Services

We have a counseling desk in place as the point of contact for employees with issues related to harassment, evaluations, human relations, and other problems in the workplace. We have also set up a compliance hotline as the point of contact for employees with issues involving transgressions of laws and regulations, all types of misconduct, severe violations of human rights, serious harassment, and so forth.

These two consultation services—namely, internal whistleblowing system—can be used by any Group executive and employee regardless of their employment status, including fixed-term contract employees and temporary agency workers. Under the system, employees handling whistleblowing reports are obliged to keep the identity of the whistleblower confidential. It is also prohibited to seek to identify whistleblowers, or to put whistleblowers or anyone cooperating with an investigation at a disadvantage. These and other rules allow employees and other personnel to safely provide information without fear of being at a disadvantage. We seek to keep employees informed by posting information about the consultation services on the corporate intranet portal, and by including the information in training sessions.

• Governance：Compliance/Anti-corruption

We have set up a point of contact for the general public and our stakeholders on the Inabata corporate website. Their opinions and suggestions are utilized primarily to improve customer satisfaction, promote stakeholder understanding, and prevent risk.

• Contact

Human Rights Training

Every year, we hold human rights training at joint training sessions for all employees (officers, regular employees, fixed-term contract employees, and temporary agency workers). In 2025, we conducted training on the revision of the Human Rights Policy and establishment of the Sustainable Supply Chain Policy, as well as on the internal whistleblowing system. More than 80% of employees completed the training.
We have also created an e-learning program that imparts the knowledge and ways of thinking needed to prevent harassment in the workplace and teaches criteria for determining what constitutes harassment. There are videos for all employees and managers on the intranet portal that can be viewed at any time. This facilitates learning by repeatedly watching, understanding, practicing, and reviewing.
We also bring in external experts to conduct sexual harassment training for staff in managerial positions. The training is designed to prevent harassment within departments and provides appropriate guidance, such as approaches to ensure that there are no cases of sexual harassment in the workplace. The training also addresses the current situation where perceptions of what constitutes sexual harassment have changed due to changes over time and generational differences.
Content on business and human rights was published in Inaho, the internal newsletter issued in Japanese and English for employees worldwide. The information includes case studies to enable employees to learn about human rights issues that should be considered in business activities.

Collaboration with External Parties

Inabata participates in the following subcommittees related to human rights at the Global Compact Network Japan:

• Human rights due diligence subcommittee
• Human rights education subcommittee

By taking part in these subcommittees, we study best practices in due diligence and other matters to prevent human rights violation. What we learn is linked to our efforts to respect human rights.
Furthermore, we participate in the Corporate Federation for Dowa and Human Rights Issue, Osaka, as a corporate member, and in the Osaka City Corporate Human Rights Promotion Council as a member of the steering committee.

• Sustainability at the Inabata Group：Participation in Initiatives

We continuously participate in the 'Business and Human Rights Academy' organized by UNDP. This academy offers lectures by domestic and international experts on human rights, as well as group work sessions conducted by participating companies.

●UNDP | Business and Human Rights Academy