Compliance with The UK Modern Slavery Act 2015

Statement on the UK Modern Slavery Act 2024

1.

Introduction

This statement is published by our company on behalf of the group conducting business andmanaging supply chains in the UK, pursuant to Section 54 of the Modern Slavery Act enacted inthe UK on October 29, 2015. The purpose is to disclose our policies and the activities undertaken
to prevent international human rights violations, including slavery and human trafficking, within
our business and supply chains for the fiscal year 2024.

2.

About Optex Group Co., Ltd.

Since the establishment of Optex Co., Ltd. in 1979, we have aimed to be a group of companies
overflowing with entrepreneurial spirit. By transforming our actions and taking on the challengeof new business creation, we strive to build a society that is safe, secure, comfortable, and efficient.
We possess technological strengths in various niche markets, including a 40% global market sharein outdoor security sensors, 30% globally and 50% domestically in automatic door sensors, and aleading position in image-processing LED lighting. Our headquarters are located in Shiga
Prefecture, Japan, where we actively contribute to the community through environmental
education and supporting future athletes. We operate with approximately 2,100 employees across
41 subsidiaries, 1 affiliate and 95 domestic and overseas sites. Our consolidated revenue isapproximately 56.3 billion Japanese yen, with significant sales overseas. In the UK, we conductbusiness through Optex (Europe) Limited, Farsight Security Services Ltd., Raytec Limited, andGardasoft Vision Limited. For more detailed company and business information, please visit ourwebsite.
Company information | OPTEX GROUP CO., LTD.

3.

Policies and Initiatives on Preventing Slavery and Human Trafficking(1) Basic Policy
At our company, respecting the human rights of all individuals involved in our business activities
is essential for sustaining our business and fulfilling our social responsibilities. We havestrengthened our management system by transitioning to a holding company structure in 2017and have periodically revised the "Optex Group Code of Conduct" since it was clearly establishedin 2003. On July 12, 2024, we also published the "Optex Group Human Rights Policy," practicing
our commitment to human rights. This policy supports international norms such as the "UNGuiding Principles on Business and Human Rights" and the "International Bill of Human Rights,"
and applies to all employees and officers of the Optex Group and its subsidiaries. We also expect
our suppliers and business partners to understand and support this policy, and we continuously

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engage with them on this matter.
(2) Basic ApproachWith the basic stance of "continuously enhancing corporate value while earning the trust of all
stakeholders, including customers, business partners, shareholders, and the community," we haveestablished a system for regularly reviewing related policies and regulations. Not only do wepublish the "Optex Group Code of Conduct" and the "Optex Group Human Rights Policy" on ourwebsite, but we also disclose the Corporate Social Responsibility initiatives of each group company
there. Policies and regulations are also provided in English, ensuring that they are accessible to ouremployees and officers, including those in our overseas subsidiaries, on a regular basis.
Furthermore, we have established and properly operate an internal reporting system that allowsfor consultations on human rights violations, among other issues.

4.

Processes for Preventing Slavery and Human Trafficking in the Supply Chain(1) Supply Chain Policy
Our supply chain initiatives also focus on respecting basic human rights. We believe that theeffective prevention of slavery and human trafficking can only be achieved through cooperation
with our suppliers, and we emphasize sharing our philosophy with them.
(2) Supply Chain Approach
Our core business companies have established a "Responsible Minerals Policy" to prevent humanrights abuses, environmental destruction, and the exacerbation of armed conflicts through supply
chain surveys and collaboration with suppliers. Additionally, our main manufacturing companies
not only set a "Parts Procurement Policy" but also promote improvement activities with partner
factories through a program called "PROGRE3," visiting suppliers’ manufacturing sites, andconducting improvement guidance and exchange meetings on a regular basis, under the belief that"manufacturing is people development."

5.

Education

At the Optex Group Co., Ltd., the "Optex Group Code of Conduct" is available in both Englishand Japanese on the corporate website and intranet, ensuring that it is accessible at all times. It isalso communicated internally through company notices.

6.

Moving Forward

We aim to contribute to society through high-value-added business activities and ultimately gain
broad societal support. We will continue to focus on complying with laws, fostering high ethicalstandards, fully recognizing the importance of human rights issues, and engaging with and gaining
further understanding and cooperation from our supply chain partners as we conduct our business

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Compliance with The UK Modern Slavery Act 2015

activities.

This statement was approved by the Group Compliance Promotion Committee, consisting ofvarious companies within our group, on June 26, 2024, and by the Board of Directors of Optex
Group Co., Ltd. on July 12, 2024.

July 12, 2024

Tatsuya Nakajima
President and CEO,Optex Group Co., Ltd.

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