CITIZEN Group Modern Slavery and Human Trafficking Statement for theFiscal Year Ended March 31, 2021
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 oursupply 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 business information 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 ofservices by our group companies: CITIZEN WATCHE UNITED KINGDOM, LTD.
and CITIZEN MACHINERY 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 were3,660 suppliers as of the end of the fiscal year ended March 31, 2021 (“Period”).
Approximately 63 percent of these suppliers are based in Japan, while themajority 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 andsupply chains
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
the Period, 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 and child labor”, this guideline sets out matters necessary for theCITIZEN Group to address social issues and anti-corruption problems such as
human rights, labor, and environment throughout the supply chain and to ensuresustainable development through responsible procurement in line with the Ten
Principles of the UN Global Compact.
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 sourceof funding for armed groups, contributing to conflict, human rights abuses andenvironmental destruction, is an important international issue. In January 2021,
we revised 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 ourpolicy of 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 andDevelopment (OECD).
The CITIZEN Group has also supported the 10 principles of the United NationsGlobal Compact since its joining in April 2005.
3. Due diligence process and risk assessment related to modern slavery andhuman trafficking
Within the CITIZEN Group, we conduct human rights and labor monitoring
surveys annually in accordance with the above “CITIZEN Group Human Rights
Policy” to ensure that child and forced labor practices are not occurring. During
the Period, we conducted audits on three group companies that had accepted
foreign technical trainees. For employees, we conduct stress checks and surveysof foreign employees, including technical interns, using a checklist on humanrights issues to investigate the risk of human rights violations in the workenvironment. In addition, the CITIZEN Group executives and employees canreport any actual or potential violation of our Code of Conduct to an internal orexternal compliance hotline if they become aware of such violation. The hotline isdesigned to protect whistleblowers by allowing anonymous reporting andprohibiting disadvantageous treatment of whistleblowers. The CITIZEN Group
strives for early detection and correction of human rights risks through themaintenance of various compliance hotlines.
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, 2021, we held briefings (including remote briefings) for 2,440
suppliers in Japan and overseas and conducted self-assessment surveys for 355
suppliers. Due to the impact of the new coronavirus pandemic, we adopted aremote fact-finding survey (known as “supplier audit”) and conducted it for eightsuppliers. We will continue to expand the scope of our self-assessment and fact-finding surveys, and request appropriate corrective measures in cases where there
is a risk of human rights violations by suppliers.
The CITIZEN Group implements responsible mineral procurement initiatives inconjunction with CSR procurement. Targets and results are reported at theCITIZEN Group Sustainable Procurement Committee, which meets twice a year,
and are linked to ongoing efforts and improvements aimed at realizing theCITIZEN Group Human Rights Policy.
We are also engaging with NGOs and experts to improve our Self-Assessment
Questionnaire (SAQ) for the self-assessment survey based on their opinions on
the CITIZEN Groupʼs human rights initiatives from a third-party perspective.
4. Training and capacity building related to modern slavery and human trafficking
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
Declaration of Human Rights were held at domestic Group companies and four
overseas companies. In addition, 6,065 domestic Group employees (96.0%
participation rate) took an e-learning course on "Business and Human Rights," andone overseas company also conducted the course. As for the web seminar on
sustainable procurement, 88.4% of all domestic employees participated in it.
The CITIZEN Group Sustainable Procurement Committee invited an outside
lecturer to hold a study session on due diligence in responsible mineralprocurement to deepen understanding of the tightening conflict mineralregulations and share future issues.
This statement was approved by the Board of Directors of CITIZEN WATCH CO.,LTD. on May 24, 2021.

May 24, 2021

Toshihiko Sato
President & CEO
CITIZEN WATCH CO., LTD.