The Marubeni-Itochu Steel Group Human Rights Policy
The Marubeni-Itochu Steel Group (“the MISI Group”) holds as our corporate vision: “Tocreate a better world through the individual and collective growth of our stakeholders.”
We recognize our responsibility to respect the human rights of all people to work towardbuilding a society to which we aspire. In order to fulfill this responsibility, we have adopted
the MISI Group Human Rights Policy (the “Policy”) that is based on the United Nations
Guiding Principles on Business and Human Rights and will promote human rights initiatives.
Scope of Application
The Policy applies to all directors, officers and employees (including contract and temporaryworkers) of the MISI Group. We also expect that our business partners and other relevant
parties understand and honor the Policy.
Our Basic Philosophy toward Human Rights
The MISI Group values and respects the international standards relating to human rights,
such as the United Nations International Bill of Human Rights, the International Labour
Organization (ILO) Declaration of Fundamental Principles and Rights at Work, theOrganisation for Economic Co-operation and Development (OECD) Guidelines forMultinational Enterprises, the Ten Principles of the United Nations Global Compact.
The MISI Group is committed to complying with the laws and regulations of the countries
and regions where we conduct business. In the event that the laws and regulations of suchcountry and/or region are inconsistent with the internationally recognized standards ofhuman rights, we will seek to find a way to uphold our Policy and internationally recognized
standards of human rights.
Our Framework for Promoting Human Rights
The MISI Group put in place a framework for implementing the Policy. The Managing
Executive Officer in charge of Sustainability is responsible for overseeing theimplementation of and compliance with the Policy.
Respect for Human Rights in Conducting Our Business
The MISI Group will fulfill our responsibility to respect human rights in the conduct of ouroverall business by not violating human rights, and in the event that there is a negative
impact with respect to human rights, by seeking to take appropriate remedial measures.
Forced labor and child labor will not be permitted, proper consideration will be given to legally
employed workers who are minors and all forms of discrimination, harassment andinhumane acts are banned. In addition, proper labor practices, including ensuring
appropriate working hours, wages and benefits, will be encouraged, and the right to freedomof association and collective bargaining will be respected.
Human Rights Due Diligence
The MISI Group, in accordance with the United Nations Guiding Principles on Business andHuman Rights, will conduct human rights due diligence in order to fulfill our responsibility toidentify, prevent and mitigate matters that have a negative impact on human rights.
Grievance Mechanism and Remediation
In the event that it becomes apparent that our business activities have had, have a potential

of having, or was implicated in having, a negative impact on human rights, the MISI Groupwill seek to implement corrective actions and remediate through appropriate measures. Inaddition, we will implement and appropriately operate a grievance mechanism to enableissues to be reported and to provide access to remedy.
Dialogue and Engagement
As part of the implementation of the Policy, the MISI Group will work together withindependent external human rights experts, and taking into consideration their expertise andadvice, will discuss and engage in good faith with relevant stakeholders.
Education and Building Awareness
The MISI Group will take measures to educate and build awareness in all directors, officers
and employees (including contract and temporary workers) to ensure that the Policy will beincorporated into and implemented throughout its business activities.
Information Disclosure
The MISI Group will report on the status and results of the human rights initiatives
undertaken in connection with our Policy through our official corporate website or oursustainability reports.
The Policy has been approved by our company’s Management Committee and reported onto the Board of Directors.
November 27, 2023
Makoto Ishitani
President and CEO
Marubeni-Itochu Steel Inc.