CITIZEN Group Modern Slavery and Human Trafficking Statement for theFiscal Year Ended March 31, 2022 (Proposal)
This statement is made pursuant to the United Kingdom Modern Slavery Act of 2015.
The CITIZEN Group (CITIZEN WATCH CO., LTD. and its group companies)
endeavors to ensure that there are no violations of human rights nor complicity inthe violation of human rights in any way in our own business operations or our
supply chains. We hereby provide this disclosure statement regarding our activities
to prevent and tackle modern slavery and human trafficking.

1. Organizational structure, businesses and supply chains
The CITIZEN Group has been engaged in the manufacturing and sales of products
in various business fields, such as Watches, Machine Tools, Devices & Components
and Electronic Products, based on the compact precision technology which CITIZEN
has developed since its establishment in 1918. Details of our corporate and businessinformation can be found on the “About Us” page of the CITIZEN WATCHʼs website.
Our business activities in the UK consist of sales of products and provision of services
by our group companies: CITIZEN WATCHE UNITED KINGDOM, LTD. and CITIZENMACHINERY UK LTD.
Materials, parts and some finished products used for production by the CITIZEN
Group are purchased from external suppliers in and outside of Japan. There wereabout 3,700 suppliers as of the end of the fiscal year ended March 31, 2022(“Period”). Approximately 63 percent of these suppliers are based in Japan, while
the majority of our overseas suppliers are located in China, the Philippines, Thailand,
Vietnam and Malaysia.
2. Policies related to modern slavery and human trafficking in operations and supplychains
The CITIZEN Group revised the CITIZEN Group Code of Conduct in October 2016.
This Code of Conduct presents our basic stance on social responsibility and serves

as the standard for conduct and decision-making by each individual who works forthe Group. We have reinforced sections related to human rights by addressing“ Respect for Human Rights” and “Responsible, Sustainable Procurement” andclarifying our stance against forced labor and child labor not only with respect tothe CITIZEN Group, but also our suppliers and business partners. In addition, in thePeriod, we formulated the CITIZEN Group Human Rights Policy to define ourresponsibilities in respecting human rights.
As for our supply chains, we revised the CITIZEN Group CSR Procurement Guideline(established in April 2017) in April 2020 and requested our procurement partners
to comply with it. In addition to prohibiting “forced labor, inhumane treatment andchild labor”, this guideline sets out matters necessary for the CITIZEN Group toaddress social issues and anti-corruption problems such as human rights, labor, andenvironment throughout the supply chain and to ensure sustainable development
through responsible procurement in line with the Ten Principles of the UN GlobalCompact.
The CITIZEN Group recognizes that the use of minerals (tantalum, tin, tungsten,gold, and cobalt) originating from conflict and high-risk areas (CAHRAs), such as
the Democratic Republic of the Congo and its neighboring countries, as a source offunding for armed groups, contributing to conflict, human rights abuses andenvironmental destruction, is an important international issue. In January 2021, werevised the CITIZEN Group Conflict Minerals Policy to the CITIZEN Group
Responsible Mineral Procurement Policy in response to the adoption of the EU
Conflict Minerals Regulation in 2021. Conflict minerals, when mined, traded,handled, or exported, may contribute to human rights abuses, such as child laborand forced labor, environmental degradation, conflicts, terrorist financing, money
laundering, corruption, and other risks, or may help illicit financing. Under our policyof not using these minerals, we are conducting surveys in line with the Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict and High Risk
Areas, issued by the Organization for Economic Cooperation and Development(OECD).
The CITIZEN Group has also supported the 10 principles of the United Nations
Global Compact since its joining in April 2005.

3. Due diligence process and risk assessment related to modern slavery and humantrafficking
Within the CITIZEN Group, we conduct human rights and labor monitoring surveys
annually in accordance with the above “CITIZEN Group Human Rights Policy” toensure that child and forced labor practices are not occurring. In the fiscal year
ending March 31, 2022, we surveyed for negative impacts on human rights involvedin our business operations, in order to practice human rights due diligence. A humanrights risk survey was conducted at 14 domestic and 41 overseas companies, using
the Human Rights Due Diligence Questionnaire, which was developed with reference
to the ILO Declaration and the UN Global Compact. The results of the questionnaire
showed that there were no significant human rights risks both in Japan and overseas.
In addition, an audit was conducted at all three companies in the Citizen Group
where foreign technical intern trainees are enrolled. As a result, no typical behaviors
or situations were identified, such as passport storage by the company, illegal long
working hours, or any other problems.
In addition, we checked for human rights risks in the supply chain, covering primaryand secondary suppliers in the watch business. As a result, potential risks wereidentified regarding the labor environment of suppliers of conflict minerals and raw
materials. We will consider ways to minimize these risks.
In addition, the CITIZEN Group executives and employees can report any actual or
potential violation of our Code of Conduct to an internal or external compliancehotline if they become aware of such violation. The hotline is designed to protectwhistleblowers by allowing anonymous reporting and prohibiting disadvantageous
treatment of whistleblowers. The CITIZEN Group strives for early detection andcorrection of human rights risks through the maintenance of various compliancehotlines.
With regard to the supply chain, we are working to eliminate risks in the supply
chain, including modern slavery and human trafficking, by requesting suppliers tocomply with the CITIZEN Group CSR Procurement Guideline. In the fiscal year
ended March 31, 2022, briefing sessions for suppliers (including remote sessions)were held for about 1,900 suppliers in Japan and overseas, while a self-assessment
survey was carried out for 657 suppliers. Due to the impact of the new coronavirus

pandemic, we conducted a fact-finding survey (supplier audit) in a remote format
for 67 companies.
We will continue to expand the scope of our self-assessment and factfinding surveys,
and request appropriate corrective measures in cases where there is a risk of humanrights violations by suppliers.
The CITIZEN Group implements responsible mineral procurement initiatives inconjunction with CSR procurement. Targets and results are reported at the CITIZEN
Group Sustainable Procurement Committee, which meets twice a year, and arelinked to ongoing efforts and improvements aimed at realizing the CITIZEN Group
Human Rights Policy.
4. Training and capacity building related to modern slavery and human traffic
To deepen understanding of the importance of human rights and how it ties into
our business, we designated December as “CITIZEN Group Human Rights Month”,
starting in the year ended March 31, 2019. Panel displays on the CITIZEN Group
Human Rights Policy and the contents of all 30 articles of the Universal Declarationof Human Rights were held at domestic Group companies and three overseas
companies. In addition, 6,220 domestic Group employees (99.0% participationrate) took an e-learning course on "Business and Human Rights," while threeoverseas companies provided a similar course.
For the purpose of deepening understanding of risks related to sustainableprocurement, the CITIZEN Group Sustainable Procurement Committee held a study
session on human rights issues involving the supply chain, with an outside lecturer.
In the study session, participants learned the basics of "internationally recognizedhuman rights" and understood the importance of being aware of the perspectivesof rights holders in identifying outstanding human rights issues for companies, asrequired by the Guiding Principles on Business and Human Rights. In addition,
training on the contents of the Anti-Corruption Policy was provided at a briefing
session for business partners in China.
This statement was approved by the Board of Directors of CITIZEN WATCH CO.,LTD. on June 17, 2022.

June 17, 2022

President & CEO
CITIZEN WATCH CO., LTD.