By respecting the human rights of all individuals involved in the Punch Group and its supply chain, we will help to realize a fair and just society.

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Main initiatives Targets
Establishment of a human rights policy 2022 Establish Human Rights Policy for Punch Group
2023 Establish Sustainable Procurement Policy for Punch Group
Establish Sustainable Procurement Guideline for Punch Group
2024 Launch activities to inform suppliers of the Punch Group's Human Rights Policy, Sustainable Procurement Policy, and Sustainable Procurement Guideline, and ensure compliance with them
Implementation of human rights due diligence 2023 Implement human rights due diligence (non-consolidated basis)
Education and training 2024 Conduct training on business and human rights for employees (non-consolidated basis)
Conduct training on human rights due diligence for management (non-consolidated basis)

Human Rights Policy for Punch Group

Human Rights Policy for Punch Group

We, Punch Group, carry on business activities in order to contribute to "global craftmanship", with a corporate vision, "we aim to become the leading brand in the mold and die components industry and achieve high profitability by leveraging our competitive advantage as a comprehensive manufacturing and sales company". On the understanding that we might give some influences to Human Rights directly or indirectly through our business activities, we hereby establish "Human Rights Policy", so as to express that we will protect Human Rights of all the people involved in our business.

In order to enhance effectiveness of the Policy, we will show our "Punch Spirits" handed over to us from our founder - "Challenge", "Imaginative & Innovative" and "Open & Honest", and promise to try our very best to realize the world where no one will be left behind through the solution of every human rights issues.

1.Basic Concept

We respect the international Human Rights standards such as "International Bill of Human Rights" ("Universal Declaration of Human Rights" and "International Covenants on Human Rights"), "ILO Declaration on Fundamental Principles and Rights at Work" etc. We also support the 10 principles of UN Global Compact and the UN Guiding Principles on Business and Human Rights and carry on the business activities in accordance with those principles.

2.Scope of the Policy

This policy applies to all officers and employees including temporary employees, contract employees, dispatched employees and part-time employees in Punch Group (Punch Industry Co., Ltd. and its subsidiaries). In addition, we ensure that all the business partners and the suppliers of Punch Group are informed of the Policy and approach them to understand and approve it.

3.Legal Compliance

In principle, we ensure compliance with applicable laws where we operate. However, in the event of conflicts between those laws and international human rights standards, we seek the way to make them harmonize by setting the international human rights standards as a superordinate concept.

4.Governance and Organization

In order to promote the activities for the respect of human rights, we set up "Sustainability Committee" chaired by CEO and "Task Force on Respect of Human Rights" under the Committee. The Committee is required to report the activities on the respect of human rights regularly to Executive Board Meeting and Board of Directors' meeting in order to establish proper surveillance system.

5.Human Rights Due Diligence

We set up the system on Human Rights Due Diligence and conduct it regularly in order to specify, evaluate, prevent and mitigate any adverse impacts on human rights caused by our business activities.

6.Corrective and Remedial measures

In the event that any adverse impacts on human rights are caused or contributed by our business, we will take corrective measures promptly and proceed to the remedial action adequately for people suffering from disadvantage caused by adverse human rights impacts.

7.Education and Training

We provide all officers and employees with adequate education and training so as for us to ensure that the spirit of the Policy take root in each Group companies and enhance its effectiveness.

8.Stakeholder Engagement

We verify our activities on the respect of human rights and strive for further improvement through the engagement with the stakeholders who have various viewpoints with regards to the respect of human rights.

9.Disclosure

We disclose the status of the efforts and the progress with regards to the respects on human rights appropriately, including the occurrence of adverse impacts and the countermeasures against them.

December 13, 2022

Sustainable Procurement Guideline for Punch Group

Sustainable Procurement Guideline for Punch Group

In accordance with the Sustainable Procurement Policy, the Punch Group shall endeavor to comply with the following guidelines as standards for Punch Group procurement.

1.Compliance with laws and regulations and respect for international norms

Compliance with Laws and Regulations
We shall not engage in any activities that conflict with the laws and regulations set forth in the countries and regions in which we operate.
Fair and equitable transactions
We will comply with antitrust laws and other relevant laws and regulations in the countries and regions in which we operate, and promote transactions based on fair and equitable competition.

2.Respect for Human Rights, Labor Environment, and Health and Safety

Respect for Human Rights and Labor Environment
We will comply with the laws and regulations of the countries and regions in which we operate, and will observe the legal and regulatory limits on employee working hours, with the International Labor Organization (ILO) as the standard and SDG Goal 8, Decent Work.
Appropriate wages and benefits
Pay appropriate wages and benefits to employees in accordance with the laws and regulations of the countries and regions in which we operate, including minimum wages, overtime pay, and other benefits such as allowances and wage deductions.
Human resource development, including diversity of human resources
Ensure diversity of human resources at companies, etc., and develop an internal environment for human resource development, including promotion of women's empowerment. Identify and assess risks to occupational health and safety, and ensure the health and safety of employees. In particular, we will give appropriate consideration to female employees who are pregnant or breastfeeding, employees with disabilities, and elderly employees. In addition, machinery and equipment used by employees and facilities provided (dormitories, cafeterias, restrooms, etc.) shall be evaluated to determine whether any safety risks exist and appropriate safety measures shall be taken.
Prohibition of Harassment
Inhumane acts in the workplace, including all forms of harassment (sexual harassment, power harassment, etc.), abuse, and coercion, shall not be tolerated.
Prohibition of discrimination
Discrimination on the basis of individuality (race, disability, gender, gender identity, religion, age, ethnicity, nationality, marriage, etc.) protected by law shall be prohibited in employment and treatment (hiring, promotion, compensation, right to education, job assignments, wages, benefits, disciplinary actions, termination, retirement, etc.).
Prohibition of forced and compulsory labor
In accordance with the International Labor Organization (ILO) standards and in accordance with the laws and regulations of the countries and regions in which we operate, we prohibit the use of bonded, forced, or inhumane prison labor, and do not use slavery or human trafficking labor. We respect that employees are not forced to work and are free to leave their jobs or terminate their employment relationships.
Prohibition of Child Labor
In accordance with the International Labor Organization (ILO) and in compliance with the laws and regulations of the countries and regions in which we operate, we will prohibit labor by children under the minimum working age.
Response to Conflict Minerals
We will strive to conduct responsible procurement activities to avoid procurement of materials and products containing tungsten, tantalum, tin, and gold (3TG), which are conflict minerals related to support for armed groups, serious human rights abuses, and environmental destruction in conflict and high-risk areas, etc.

3.Promotion of activity for environmental conservation

Reduction of greenhouse gas emissions
We will set our own targets for greenhouse gas emissions and engage in continuous activities to reduce greenhouse gas emissions through improvement of energy efficiency and introduction of renewable energy in production, development, logistics, offices, etc.
Waste Reduction
We will engage in environmental preservation activities such as proper disposal of waste and reduction of environmental burdens by promoting the 3Rs: reduce, reuse, and recycle.
Control of Chemical Substances Contained in Products
In accordance with the laws and regulations of the countries and regions in which we operate, we will identify hazardous substances, comply with laws and regulations, and properly manage chemical substances related to our business activities.
Biodiversity Conservation
We will consider the impact of our business activities on biodiversity and minimize adverse effects.

4.Maintenance of ethical policy

Prevention of corruption
We do not engage in corrupt practices of any kind, including bribery, corruption, extortion, and embezzlement.
Prohibition of Inappropriate Entertainment and Gifts
We do not accept or give inappropriate entertainment or gifts to or from customers or suppliers.

5.Security of quality and safety

Provision of high quality products and services
We will provide high-quality products, goods, and services that meet quality standards and various safety standards with customers, as well as safety laws and regulations of the countries and regions where we operate.
Establishment of a system to ensure quality
We will establish a quality management system, implement measures in accordance with our quality policy, and continuously improve quality assurance through the PDCA cycle. 6. Protection of Intellectual Property Respect intellectual property rights, transfer technology and know-how in a manner that protects intellectual property rights, and protect intellectual information.

6.Protection of Intellectual Property

Respect intellectual property rights, transfer technology and know-how in a manner that protects intellectual property rights, and protect intellectual information.

7.Control of information security

Network security management
We shall take protective measures against threats on computer networks and strictly manage them so as not to cause damage to the company or others.
Management of personal and confidential information
All personal and confidential information of customers, suppliers, third parties, employees, etc. shall be obtained in a legitimate manner in compliance with relevant laws and regulations, and shall be properly managed and protected.
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Please understand that these guidelines will be reviewed and revised from time to time in accordance with the changing demands of the international community, and that they do not cover all of the requests we make of our suppliers.

Enacted April 2023

Sustainability