Tokyu Fudosan Holdings Group Sustainable Procurement Policy Article Text

1） Legal compliance1) -1.

Total compliance with relevant laws and regulations
Comply with all applicable laws and regulations, including national and international laws,
maintain a complete understanding of regional social norms and corporate ethics, and act basedon sound judgement and a sense of responsibility.

2） Respect for human rights
2) -1.

Compliance with and respect for international human rights and labor standards
Promote international human rights and labor standards,* and conduct business activities in away that respects human rights.

* The International Bill of Human Rights (Universal Declaration of Human Rights, and the International
Covenant on Civil and Political Rights), ILO Declaration on Fundamental Principles and Rights at Work,UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational
Enterprises, etc.

2) -2.

No tolerance of discrimination
Discrimination based on nationality, race, religion, creed, gender, age, sexual orientation, gender
identity, disability, or other such characteristics is not permitted. Eliminate discrimination andensure fair employment and recruitment opportunities.

2) -3.

No tolerance of harassment
Never engage in any form of harassment, including sexual and power harassment, and no
demeaning remarks or actions are permitted in the workplace.

2) -4.

Respect for local residents
Respect the local cultures and customs of the locations in which it operates, as well as local
residents and communities.

2) -5.

Respect for minority rights
Respect the rights of vulnerable persons and minorities.

3） Ensuring a work environment based on safety, health and well-being3) -1.

Freedom of association, collective bargaining rights
Guarantee freedom of association and the right to collective bargaining, and work to solve issues
through labor-management dialogue in countries and territories where trade unions are notpermitted by law or practice.

3) -2.

No tolerance of forced labor

Eliminate and prevent all forms of forced labor.

3) -3.

No tolerance of child labor
Prohibit and work to prevent child labor.

3) -4.

Fair wages
Comply with relevant labor laws and regulations, and pay wages that exceed the local minimumwage.

3) -5.

Elimination of excessive working hours
Manage working hours properly and work to prevent illegally long hours.

3) -6.

Workplace health and safety measures
Conduct health and safety management based on relevant laws and regulations. Prevent
occupational accidents and establish safe working environments and conditions that are safe andsound from both the physical and mental perspectives. Take appropriate safety measures formachinery and equipment, such as establishing the necessary internal safety rules and inspecting
equipment. Provide workplace health and safety information and training in the employee’s nativeor working language.

3) -7.

Emergency preparedness
Implement safety measures to prepare for emergencies such as fire or earthquakes and ensure
personnel safety through regular disaster drills.

3) -8.

Prevention of occupational accidents and illness
Take appropriate measures to prevent occupational accidents and illness and take corrective
measures in the event of any incidents. In such cases, a process has been established foremployees to report hazards.

3) -9.

Industrial Hygiene measures
Manage hazardous organisms and chemicals properly and provide training and protective
equipment in cases when employees may come into contact with them.

3) -10. Measures for physically demanding work
Identify work that is physically demanding or that poses a health risk and take appropriate
measures to prevent injury and/or illness.

3) -11. Proper sanitary facilities, meals and housing
Ensure that employees have access to sanitary toilets and clean drinking water. Wherever foodand/or housing is provided, a safe and sanitary environment is maintained.

3) -12. Protection of foreign and migrant worker rights

Conduct appropriate labor management for foreign and migrant workers (including technicalinterns), based on relevant laws and regulations. Provide employment contracts and convey
working conditions in a language that each worker can understand and prevent any illegal or
improper actions such as withholding wages, requiring illegally long working hours, holding
worker passports, forcing a worker to return to their home country, collecting security deposits,etc.

4） Ensuring proper business ethics4) -1.

Preventing corruption
Do not engage in or facilitate any form of corruption, such as money laundering, bribery,embezzlement, or obstruction of justice.

4) -2.

Preventing contact with organized crime
Tolerate no contact with organized crime and firmly refuse any improper demands.

4) -3.

Ensuring fair trade practices
Comply with relevant antitrust and subcontracting laws. Do not use superior position to impose
unilateral conditions on business partners and do not hinder the business activities of competitors
by unfair means.

4) -4.

Appropriate response to conflicts of interest
Take appropriate measures to prevent conflicts of interest in all transactions, such as buying,selling and outsourcing.

4) -5.

Responsible political involvement
Maintain sound, standard relations with politicians and administrative officials in accordance withrelevant laws and regulations. Prohibit the provision of entertainment and gifts to politicians, aswell as to Japanese and foreign government officials and equivalent persons.

4) -6.

Protection of intellectual property rights
Protect intellectual property rights (patents, copyrights, design rights, etc.) from infringement bythird parties. Likewise, do not infringe on the intellectual property rights and trade secrets of thirdparties.

4) -7.

Maintaining confidential information and disclosureMaintain an awareness of information that needs to be disclosed and that which needs to be kept
confidential. Perform timely and appropriate information management in compliance with relevantlaws and regulations.

4) -8.

Compliance hotline and whistleblower protection
Maintain a compliance violation hotline to quickly identify and resolve compliance issues. Keepstrictly confidential all information concerning those who report or inquire about complianceviolation cases. Take appropriate measures to prevent hotline users from suffering
disadvantageous treatment, including internal retaliation, as a result.

5） Environmental measures5) -1.

Combatting climate change
In addition to renewable energy adoption, promote the efficient use of energy in businessactivities and throughout the life cycles of products and services. In this way, reduce the impactof greenhouse gas emissions on climate change.

5) -2.

Biodiversity protection
In material procurement and other business activities, reduce the impact on the surrounding
natural environment, biodiversity, and ecosystems. Do not use raw materials derived fromendangered species of animals and plants for which measures have not been taken to conserveresources and ensure reproduction.

5) -3.

Pollution prevention
Do not pollute the air, water, or soil, based on relevant environmental laws and regulations.
Manage chemical substances appropriately and work to prevent the emission of pollutants while
reducing the materials that cause them.

5) -4.

Effective use of resources
Work to use resources in business activities effectively and to reduce waste, based on relevant
environmental laws and regulations.

5) -5.

Proper water use
Ensure the appropriate management and efficient use of water resources and take measures toconserve water used in business activities and the production of raw materials.

5)-6.

Ensure appropriate use of forest resources
Comply with relevant laws and regulations in logging countries and territories and strive to procure
forest products produced in a sustainable manner, including recycled and certified wood. Support
the conservation of forests with high biodiversity and preservation value, while also respecting thecultures, traditions and economies of communities that coexist with forests.

6） Improving service and quality
6) -1.

Ensuring safety
Always consider the safety and security of customers in every aspect of product and service
planning, design, provision and after-sales service, to ensure customer health and safety.

6) -2.

Quality control and quality assurance systems
Establish quality management systems, comply with design and quality standards for products
and services and always strive to improve quality.

When procuring products, services, or raw materials, confirm that suppliers ensure animal welfare
and are not involved in armed conflicts or criminal activities.

6) -3.

Proper information disclosure for products and services
Explanations of the products and services comply with relevant laws and regulations, andimportant matters that may affect the decisions of consumers and end users must be describedto them in a way they can understand. In addition, do not use definitive predictions, make false
or excessive statements about products or services (such as misrepresentation), use ads thatare discriminatory or misleading, or release ads that may have an adverse effect on children.

7） Proper information management7）- 1. Proper information management
Establish and properly maintain information management systems to protect and prevent theunauthorized disclosure of information used in business activities, such as personal, privacyrelated, and confidential information.

8）

Business Continuity Planning8)-1.

Business Continuity Planning
Maintain business continuity plans (BCPs) to prepare for disasters or unforeseen emergencies.

9） Contributing to local communities
9)-1.

Contributing to local communities
Respect the local cultures and customs of the communities where it conducts business. Also seek
to gain an understanding of social issues in those communities through dialogue and strive toimplement business activities and social contribution activities that help solve those issues.

10） Extension of the Sustainable Procurement Policy10)-1.

Extension to business partners
Encourage companies in the supply chain to understand and share this Policy.

10)-2.

Cooperation for monitoring
Cooperate with any monitoring of the status of the activities based on this Policy.

3. Compliance Violation Reporting or Inquiries
If you are aware of any actual or possible violation of this Policy, please contact us using the inquiry form
below. Do not report anything that you know to be false, denigrating, or defamatory, and avoid any threats,or statements that would obstruct business, etc.
You may be required to cooperate in an investigation of the facts.
Anyone who reports a non-compliance issue, reports something by means of an inquiry, or who makes
an inquiry will be protected from any reprisals or other disadvantageous treatment by any members of theGroup and its entire supply chain.

＞ Link
https://www.tokyu-fudosan-hd.co.jp/english/inquiry/
Established January 6, 2020