Inherited
ULVAC-StyleULVAC’s Strategy

Respect for Human Rights and Responsible
Conduct in the Value Chain
Human Rights
Approach to Human Rights

Human Rights Initiatives
We respect the United Nations Guiding Principles on Business and Human Rights as well as the international
norms and standards set forth in the International Bill of Human Rights (Universal Declaration of Human Rights andInternational Covenants on Human Rights) and the ILO Declaration on Fundamental Principles and Rights at Work.
We respect human rights in accordance with the Ten Principles of the UN Global Compact and other guidelines of theinternational community and industry guidelines.

Key Human Rights Issues
The ULVAC Human Rights Policy covers “prohibition ofdiscrimination/harassment,” “employment autonomy,”“product safety, workplace health and safety, andemployee health,” “freedom of association,” and “ensuring
appropriate working conditions.”
The Corporate Code of Conduct also prohibits any
form of discriminatory treatment. In accordance with
the Corporate Code of Conduct and the Basic Policy for
Human Resources Development, we are striving to create
workplaces offering job satisfaction.
P.67 Compliance

For detailsP.41 Human Resources

About ULVACULVAC’s VisionCorporateGovernance

ULVAC’s Strategy

Financial Data/
Corporate Information

Employee Health
ULVAC has concluded labor agreements with labor unions and promised to sincerely work together with them toadhere to these agreements in order to establish and develop labor-management relations based on mutual faith andtrust. Furthermore, we engage in close dialogue with labor unions on management plans and measures, in addition tolabor conditions.
From the perspective of work-life balance, we are conducting a review of working hours that includes thoroughovertime management and productivity improvement initiatives.
Health and Productivity Management
For details
P.44

We believe that consideration for human rights is an important management issue in the context of further global
business development. At ULVAC, we respect human rights in every aspect of business activities and are promoting
initiatives in accordance with international guidelines and norms. ULVAC has established the Corporate Code ofConduct as guidelines for all officers and employees to keep in mind so as to ensure their work does not infringe
human rights. In response to recent changes in awareness and issues regarding human rights in the international
community, ULVAC has formulated the ULVAC Human Rights Policy based on international norms and will strengthen
initiatives in accordance with those norms. This policy is the most authoritative statement of the regulations governing
the ULVAC Group companies concerning human rights and it applies to all officers and employees of all Groupcompanies. In addition, we strive to ensure that this policy is endorsed and put into practice not only by the Group
companies but also by our business partners.

For details

Message to OurReaders“Requests to Our Business Partners” states ULVAC’s
requests to business partners concerning human rights.
We conduct a questionnaire survey of business partners
and confirm whether employment autonomy is maintained.

Prohibition of Discrimination/Harassment
ULVAC does not and will not discriminate on the basis of race,skin color, age, sex, sexual orientation, gender identity and gender
expression, ethnicity or national origin, disability, pregnancy, religion,
political party, union membership, military service, protected genetic
information, marital status, or on any other basis. Inhumane treatment,including any form of harassment will not be tolerated. We ensure
equal opportunities and fairness in hiring, placement, training,compensation, and promotion.

Employment Autonomy
No form of child labor, forced labor, debt labor, human trafficking, orprison labor will be tolerated. All work is voluntary, and we will ensurethat employees are able to request termination of their employment
in accordance with the standards set forth by the relevant laws andregulations of each country and region.
Product Safety, Workplace Health and Safety, and Employee Health
We will take steps to ensure that ULVAC Group products and services
do not endanger the lives or health of those who manufacture, provide,or use them, and we will comply with the laws and regulations
concerning health and safety as established in the countries andregions where we operate. We will strive to manufacture and provide
safe products and to maintain a safe, secure, and healthy work
environment.

Freedom of Association
We respect the right to freely form and join labor unions and to participate
in collective bargaining and peaceful assembly. We will also create anenvironment in which workers have opportunities to engage in dialogue
with management regarding working conditions and management
practices without fear of discrimination, retaliation, intimidation, orharassment.

Supply Chain Initiatives
We endeavor to comply with the RBA Code of Conduct, which is a CSR promotion group focused on the electronics
industry. In addition to implementing, evaluating and correcting self-evaluations and thoroughly managing labor
hours at major production bases, we request business partners to work with us on these initiatives. We conductedquestionnaire surveys mainly of major business partners and have incorporated the questionnaire items into theevaluation at the time of periodic renewal. Furthermore, we have established a policy on the handling of conflictminerals and conduct due diligence.
For details
P.47 Procurement

Due Diligence on Human Rights
We have incorporated international norms into the ULVAC Human Rights Policy and have established human rights
due diligence processes according to the procedures corresponding to the international norms. We are making aneffort to further strengthen relief mechanisms by recognizing, preventing, and addressing possible negative effects ofbusiness activities on human rights.

Education
We educate all officers and employees about human rights and compliance so that they are well-informed and able toact appropriately.

Remedies and Corrections
We will establish a system (a mechanism for filing grievances) through which any infringement on human rights
caused by or associated with our business activities can be reported. If we are made aware of a violation of humanrights through this system, we will promptly investigate and take appropriate measures to remedy and correct thesituation after fully confirming the facts.
ULVAC has adopted a whistleblowing system operated via the Manager of the Internal Auditing Department for
which independence is secured. The Compliance Committee will implement appropriate measures with adequate
consideration for confidentiality, anonymity and protection of whistleblowers, and strive to promptly resolve issues
and prevent their recurrence.
For details
P.67 ComplianceGroup’s Issues with Significant Impact on Human Rights and Relations with Stakeholders
Business-related human rights issues/stakeholders

Quality Assurance and Product Safety Initiatives
Our top priority is to ensure the quality and functions related to “health and safety” of ULVAC products, which are theresult of sound business activities, at the customer's side.
For details

Ensuring Appropriate Working Conditions
We respect the right of employees to live a healthy
lifestyle, and we will comply with applicable laws andregulations regarding working hours and the use ofbreaks, holidays, and vacation time in the conduct ofour business.

Website >> Sustainability > Quality Assurance and Product Safety

Workplace Health and Safety
In the execution of development, manufacturing, transport, installation, maintenance and other business processes,
everyone in the ULVAC Group, from senior management to line workers, is encouraged to seize the initiative incontinuously undertaking improvements placing the highest priority on safety, striving to maintain and improve thesafety of everyone involved and ensure a healthy working environment.
For details
P.48 Occupational Safety and Health

Employees

Businesspartners

Customers

Localcommunity
residents

Forced labor and child labor
Violations of workers’ rights (e.g., the right to collective bargaining anddecent working conditions)Occupational health and safety
Discrimination and harassment
Invasion of privacy
Restrictions on freedom of expression
Human suffering due to misuse of products and promotion of discrimination
Complicity in conflicts and inhumane acts (e.g., conflict minerals)
Violations of local residents’ livelihoods and cultures (indigenous peoples’rights, right to water resources/access to medical care, etc.)

45

ULVAC VALUE REPORT 2023

ULVAC VALUE REPORT 2023

46

ULVAC’s Strategy

Respect for Human Rights and Responsible
Conduct in the Value Chain

Responsible Procurement Management
Suppliers are our important partners for manufacturing. ULVAC is committed to responsible procurement
throughout the supply chain, in cooperation with business partners, taking human rights, labor, and theenvironment into consideration.

Procurement Policy
The ULVAC Group has established the Basic Procurement Policy. We observe the policy and are promoting CSR
procurement in cooperation with our business partners. Furthermore, “Requests to Our Business Partners” states
our requests to business partners in areas such as the environment, human rights, labor and compliance as wellas compliance with the RBA*1 Code of Conduct. With regard to promoting CSR procurement, we had conducted aquestionnaire survey with reference to the RBA Code ofConduct covering 610 suppliers by FY 2022. As a result,
Promoting CSR
we confirmed that there were no incidences of child labor,
procurement
forced labor, inhumane treatment, fraud or bribery, which
PromotingCompliancegreenwith laws andare particularly emphasized in the RBA Code of Conduct,procurement
regulations
Basicand the handling of conflict minerals. We plan to expand
Procurement
the scope of this CSR questionnaire survey to cover
PolicyMaintaining
Promoting
ULVAC Group companies in Japan in FY 2023 and overseas
and promoting
globalfair and freeprocurement Sound, goodGroup companies in FY 2025.
competition
relationships
Furthermore, we revised the basic transaction
with business
partners andagreement in April 2020 and explicitly mentioned
affiliates
Purchasing Code of Conduct
understanding the content of “Requests to Our Business
Website >> Sustainability > Procurement
For details
Partners” and its observance.

Purchasing Code of Conduct
We established the Purchasing Code of Conduct, a set of principles emphasizing compliance for employees engaged
in procurement, in 2019 with the aim of maintaining sound, good relationships with business partners. In-house
education such as case studies on the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors
is provided twice a year for employees engaged in ULVAC, Inc.’s procurement and that of Group companies in Japan.

Communication with Business Partners
We had been holding operations briefing meetings once a year as a forum for our president to directly explain tobusiness partners matters such as the business environment and ULVAC’s business results and supplier meetings
three times a year for the person in charge of procurement to communicate production plans in a timely manner.
We cancelled these meetings in view of the COVID-19 pandemic, but launched and started operating a membershipbased website in FY 2020. We will strive to build closer relationships with business partners by resuming face-toface meetings, in view of the abatement of the COVID-19 pandemic. Moreover, we will hold seminars for business
partners on specific social issues (environment, human rights, etc.) to promote swift responses to those issues.

Responsible Minerals Procurement
Conflict minerals are minerals, such as 3TGs*2 and cobalt, that are sourced from conflict-affected and high-risk areas(CAHRAs) and whose extraction and sale directly or indirectly serve as sources of funding for armed groups or areroot causes of serious human rights abuses and poor working conditions. ULVAC, Inc. does not purchase 3TGs,cobalt, or other raw materials that are derived from these conflict minerals.
In particular, we manufacture and sell sputtering targets and various tantalum wrought products in the materials
business. We conduct due diligence in accordance with the guidance of OECD and RMI*3 through conflict minerals
surveys covering raw materials suppliers in order to ensure transparency of transactions.
*1 Responsible Business Alliance. CSR promotion group focused on the electronics industry in global supply chains*2 Tantalum, tin, tungsten, and gold
*3 Responsible Minerals Initiative. An organization that inspects smelters and refiners handling 3TGs to certify that they are not using conflict minerals

47

ULVAC VALUE REPORT 2023

InheritedULVAC-Style

Message to Our
Readers

About ULVACULVAC’s Vision

ULVAC’s Strategy

CorporateGovernance

Financial Data/
Corporate Information

Green Procurement Initiatives
We revised the Green Procurement Standards in August 2020 and request suppliers to share information on chemical
substances in commercial components used for products through the chemSHERPA*. In FY 2021, we conductedactivities with a focus on creating an internal structure, implementing systems, and penetration of the Green
Procurement Standards among business partners. Since FY 2022, a cross-departmental team for management ofchemical substances contained in products established within the company has been organizing and managing
information collected from our business partners.
* Scheme for enabling sharing of information on chemical substances contained in products throughout the supply chain

Occupational Safety and Health
The ULVAC Group has made “Safety First” the fundamental philosophy of business management. By operating
our Occupational Safety and Health Management System (OSHMS) focused on risk assessment, we endeavor toensure safety of the products and services used by our customers and create dynamic workplaces where Groupemployees can work in good physical and mental health.

Approach to Occupational Safety and HealthIn the execution of development, manufacturing, transport, installation, maintenance and other business processes,
everyone in the ULVAC Group, from senior management to line workers, is encouraged to seize the initiative incontinuously undertaking improvements placing the highest priority on safety, striving to maintain and improve thesafety of everyone involved and ensure a healthy working environment.

Implementation of Safety and Health Activities
To ensure the safety and good health of its customersand employees, the ULVAC Group holds meetings ofthe Global Safety Committee, twice a year and all Group
companies promote safety and health activities in an
integrated manner. Furthermore, we have established anetwork of the safety personnel in each Group company
and promptly share, discuss or implement safety
information such as revisions of laws and effective
accident prevention measures.
Each Group company operates the OSHMS anddeclares safety based on management reviews
conducted by the president and other executives.
To ensure safety, every employee is engaged in
occupational safety and health activities through riskassessments etc. We identify hazardous risks at thetime of work planning and implement measures before
commencement of work. The positive impact of thestrengthening of safety measures is apparent in thetrend of the frequency ratio of occupational accidents.
We hold monthly meetings of the Safety andHealth Committee at each business site, whererepresentatives from the company and the labor union
work together to discuss workplace safety and healthof employees. We also hold Safety and Health Council
meetings twice a year to share a variety of information
on safety and health activities in an effort to prevent
accidents in unison with our contractors.
ULVAC Group Safety Management
SystemPresident and CEOULVAC, Inc.

Global Safety
Committee

ULVAC Group Basic Policy on Occupational Safetyand Health Management System (OSHMS)
1. Compliance with the code/regulations, andimplementation of risk assessment
Comply with Codes of Occupational Safety & HealthManagement and Rules according to ULVAC’s
OSHMS, and conduct Risk Assessment in order toperform Occupational Safety & Health Management
activities with the help of all the employees.
2. Assure safety of ULVAC’s productsComply with ULVAC’s standard for safety design andperform risk assessment of our products, in orderto deliver our safe products and services to ourcustomers.
3. Planned education about Occupational Safety &Health & Product Safety
For all the employees and contractor’s employees,
perform Occupational Safety & Health training basedon ULVAC Safety Management system, while offeringscheduled Product Safety training for our users.
4. Promotion of mental health care
Promote mental health care to achieve a healthy,
vigorous workplace environment.
5. Global expansion of ULVAC GroupThrough the Safety & Health promotion activities of
the Global Safety Committee, we will strive to createa safe, secure and appropriate working environment
for the whole ULVAC Group, and contribute toprosperity of our businesses.

Frequency ratio of occupational accidents at the ULVAC Group
Group as a whole

Companies in Japan

1.50

Companies inSouth Korea

1.00

Companies in Taiwan
Companies in China
Companies inSoutheast Asia
Companies in Europe
and North America

1.00

0.88

Japan

0.83

0.50

China

South Korea

Taiwan

0.54

0.59

2021

20220201820192020(FY)* This graph shows the rate of occupational accidents for each fiscal year, with thevalue for FY 2018 (as of June 2019) as 1.00. We have maintained a low frequency
ratio of accidents by preventing accidents through various safety activities.

ULVAC VALUE REPORT 202348