Pigeon Group Human Rights Policy
We, the Pigeon Group1, conduct business around the world in pursuit of our Purpose: “Wewant to make the world more baby-friendly by furthering our commitment to understanding andaddressing babiesʼ unique needs.” In accordance with our Corporate Philosophy, “Love,” and ourCredo, “Only love can beget love,” respect for human rights is the foundation of our businessactivities. “Respect for human rights” is stipulated in our Corporate Ethics Guidelines, whichconstitute our fundamental policy on compliance to ensure we adhere to the highest ethicalstandards and integrity in our business activities, as well as our CSR Procurement Policy andGuidelines, which are based on our Corporate Ethics Guidelines and govern our conduct withrespect to business partners in the course of procurement activities.
The Pigeon Group Human Rights Policy (“the Human Rights Policy”) clearly defines ourcommitment to respecting human rights as stipulated by our Corporate Ethics Guidelines, anddescribes the concrete ways we implement that commitment.

Scope of the Human Rights Policy
The Human Rights Policy applies to all officers and employees2 of the Pigeon Group. We also
expect our suppliers and other business partners to uphold and act in accordance with the HumanRights Policy along with our CSR Procurement Guidelines.
All provisions of the Pigeon Group, including provisions set out in employment regulations,shall be interpreted and enacted in accordance with both our Corporate Ethics Guidelines and theHuman Rights Policy.

Our Commitment to Respecting Human Rights
We are committed to respecting the internationally recognized human rights of stakeholders
affected by our operations, products, and services throughout our value chains, including humanrights as set out in the Universal Declaration of Human Rights, the International Covenant on Civiland Political Rights, and the International Covenant on Economic, Social and Cultural Rights; thecore labor standards3 recognized by the International Labour Organization (ILO)ʼs Declaration on

1“The Pigeon Group” refers to Pigeon Corporation and its subsidiaries

2

Employees include fixed-term contract employees, part-time employees, temporary (casual) employees, andworkers/persons dispatched by staffing agencies.
3The ILOʼs core labor standards are freedom of association and effective recognition of the right to collective

bargaining; elimination of all forms of forced or compulsory labor; effective abolition of child labor; elimination ofdiscrimination in respect of employment and occupation; and a safe and healthy working environment.

Fundamental Principles and Rights at Work; and the human rights set out in the UN General
Assemblyʼs resolution recognizing the human right to a clean, healthy, and sustainable environment.
As a signatory to the UN Global Compact, we will continue our efforts to realize the Ten
Principles of the United Nations Global Compact.
We comply with all applicable laws and regulations and respect internationally recognizedhuman rights wherever we operate. When faced with conflicting requirements, we will seek ways tohonor the principles of internationally recognized human rights to the greatest extent possible in thecircumstances.

Implementing Our Commitment
We implement our commitment to respecting human rights in ways that accord with the United
Nations Guiding Principles on Business and Human Rights in order to avoid causing or contributing
to adverse human rights impacts through our own business activities, and address such impacts
when they occur. We seek to prevent or mitigate adverse human rights impacts that are directly
linked to our operations, products, or services by our business relationships, even if we have notcontributed to those impacts.

Human Rights Governance
Our Board of Directors makes decisions on matters that are central to honoring our commitment tohuman rights and promotes human rights initiatives accordingly. These human rights initiatives arecarried out under the supervision of the Human Rights Owner appointed by the Chair of the Risk
Management Committee, with regular progress reports from the Chair of the Risk Management
Committee to the Board of Directors. The Board of Directors carries out monitoring and othernecessary matters relating to compliance with the Human Rights Policy and human rights due
diligence.

Human rights due diligence
We carry out human rights due diligence, including steps to: identify and assess any actual or
potential adverse human rights impacts with which we may be involved either through our own
activities or as a result of our business relationships; integrate the findings from our impact
assessments across relevant internal functions and processes, and take action to prevent andmitigate adverse impact; track and verify the effectiveness of our responses; and communicate how
impacts are addressed.
Where it is necessary to prioritize actions to address actual and potential adverse human rights
impacts, we strive to first seek to prevent and mitigate those that are most severe or where delayed
response would make them irremediable.

Remedy
Where we identify that we have caused or contributed to adverse impacts, we are committed toprovide for or cooperate in remediation through legitimate processes.
Where adverse impacts have occurred that we have not caused or contributed to, but which
are directly linked to our operations, products, or services by a business relationship, we strive tocooperate with the business partner(s) concerned toward remediation.
Grievance mechanisms
We establish effective operational-level grievance mechanisms for individuals and communities who
may be adversely impacted by human rights, or participate in grievance mechanisms set up byindustry, multi-stakeholder and other collective initiatives.4
Officers and employees of the Pigeon Group (including former officers and employees within
their first year after leaving the company) can report or discuss violations of the Human Rights
Policy via Pigeon's “Speak Up Desk”5 (either through an internal contact point at Pigeon or an
external contact point), or at other contact point established by a Pigeon Group company.
Our business partners can report or discuss violations of the Human Rights Policy by sending
an e-mail or mailing a letter to the “Pigeon Partners Line”6 (either through an internal contact pointor an external contact point).
Training
We provide the necessary training for our officers and employees to ensure that the Human Rights
Policy is understood and effectively implemented.
DialogWe sincerely engage in dialog with stakeholders affected by our business operations.
Communication and disclosure
We communicate and report on our human rights initiatives through various channels, including thePigeon Corporation website and the UN Global Compact's Communication on Progress.

4

Regarding grievances against RSPO (the Roundtable on Sustainable Palm Oil) members, the Complaints System isoperated by the RSPO. For details, see the following website: https://rspo.my.site.com/Complaint/s/
5

The Speak Up Desk is available in multiple languages and allows anonymous reporting and discussion.

6For details on the Pigeon Partners Line, see the following website:

https://www.pigeon.com/sustainability/social_top/clients/#headline-1581399685

High-priority human rights areas
While we respect all internationally recognized human rights throughout our value chain, werecognize the following human rights as high-priority human rights areas in the context of thePigeon Groupʼs business operations and business relationships. Our positions with respect to thesehigh-priority areas are described below.
We also expect our business partners, including suppliers and contractors, to act inaccordance with these positions.
Non-discrimination: We prohibit discrimination based on race, color, national origin, gender,age, religion, gender identity or sexual orientation, disability, union membership or nonmembership, ethnic or social origin, or other personal characteristics in all aspects ofemployment and the workplace, including recruitment, hiring, assignment and job allocation,
promotion, compensation, training, and benefits, and provide equal opportunities to ouremployees.

Prohibition of harassment: We recognize that harassment7 is an affront to a personal dignity
and prohibit all forms of harassment in the workplace, verbal or non-verbal, including sexual
harassment, power harassment, racial harassment, and physical or mental harassment such as
corporal punishment, along with bullying, abuse and any other behavior harmful to personaldignity. We take every possible action to prevent and remedy harassment in the workplace.

Prohibition of child labor and protection of young workers: Child labor deprives children of
their childhood, their potential, and their dignity, and is harmful to physical and mental
development. Throughout our value chain, including our own operations as well as those of
suppliers and contractors, we do not use, and will not be complicit in or tolerate the use of, labor bychildren under the age of 15.8 We also do not engage, and will not be complicit in or tolerate theengagement of, young workers under the age of 18 in hazardous work, night shifts, or overtime work.

Prohibition of forced and compulsory labor: Forced or compulsory labor is any work orservice that is exacted from any person under the menace or threat of a penalty, and which theperson has not entered into of his or her own free will. Forced labor is a violation of the basic
human right to work in freedom and freely choose oneʼs work.

7

Harassment is unwelcome or inappropriate conduct based on the personal characteristics specified in “Non-discrimination.”
8

In countries where the legal minimum working age is 14 or 16 years or older, child labor is defined as work by children

below the minimum working age stipulated by the applicable national law. However, if the age for completing
compulsory education is higher than the legal minimum working age, child labor is defined as work performed bychildren below the age for completing compulsory education.

Throughout our value chain, including our own operations as well as suppliers andcontractors, we do not use, and will not be complicit in or tolerate the use of, any form of forcedlabor, including debt bondage or bonded labor,9 forced prison labor, modern slavery, andhuman trafficking.
We employ all workers of their free will and provide a document stating conditions ofemployment when they start work.

We do not charge any fees or related recruitment costs, directly or indirectly, to recruitedemployees or jobseekers in recruitment and hiring, in accordance with the International
Labour Organization (ILO)ʼs international labor standards.



We do not retain deposits, passports, or other identity documents of employees.10

Working conditions, including wages and working hours: We comply with applicable laws
and legal agreements with employees on working conditions, including wages and working
hours, in the country where they are employed.
We pay our employees and workers wages that meet legal minimum standards and are
sufficient to afford a decent standard of living for the worker and her or his family (livingwage).

We do not make unauthorized disciplinary wage deductions that are not based on
conditions and within the extent prescribed by national laws, regulations, and labor‒
management agreements. We pay overtime wages at a premium rate in accordance withnational laws or regulations.

Limits on working hours prescribed by laws or regulations of the country where theworkers are employed or by a labor‒management agreement reached on the basis of thelaws or regulations shall not be exceeded.

We will work to reduce and eliminate excessive working hours. Periods of rest shall be
granted to workers as prescribed by the laws or regulations of the country where theworkers are employed or by a labor‒management agreement reached on the basis of thelaws or regulations. 11

9

We notify employees and workers in writing of their working conditions.

Bonded labor or debt bondage is a practice in which people are obliged to work in slave-like conditions to repay debts

of their own or their parents or relatives.
10

If these are retained in exceptional circumstances for reasons of safekeeping, this must only be upon the request

and with the consent of the employee, both of which must be genuine, and the employee or worker must be able to usethem at any time.
11

For workers in the country or region where no laws on rest periods for workers exist, or to whom the laws on rest

periods of the country where they are employed do not apply, a rest period of at least 24 consecutive hours every sevendays or at least 4 rest days over a period of 4 weeks shall be granted to workers.

Freedom of association and the right to collective bargaining: We respect the right of all
employees to form or join a trade union of their choice without fear of intimidation or reprisal, inaccordance with national law.
We prohibit any acts of interference in trade unions and do not discriminate on the basis oftrade union organization, membership, or activity in such areas as applications for
employment and decisions on advancement, dismissal, or transfer.

Collective bargaining is a voluntary process or activity through which employers andemployees discuss and negotiate their relationship, particularly the terms and conditionsof work and the regulation of relations between employers and employees. We will
facilitate genuine and constructive dialogue and negotiations with trade union
representatives or representatives freely designated by employees, and provide them with
the information required for meaningful bargaining in the context of bona fide negotiations.



We will respect the right of employees to submit grievances without suffering.

Occupational health and safety: We comply with health and safety laws, regulations, andindustry standards applicable to our operations and ensure a safe and healthy workplace forour employees, workers, and contractors. To prevent occupational accidents, injuries andillnesses, we implement an occupational health and safety management system at ourproduction sites and work to continuously improve our occupational health and safety
performance.

Indigenous peoples and local communities: We respect the right of indigenous peoples andlocal communities to lands, territories and resources that they legally or customarily own,
occupy, use, or acquire in the agricultural supply chains linked to our business, such as palm oiland pulp. We also respect the cultural heritage, traditional knowledge and practices ofindigenous and local communities.
On projects affecting their lands, territories, or resources, we respect good faithconsultation and free, prior, and informed consent through indigenous and local
communities' own representative bodies.

We will not forcibly remove or relocate indigenous peoples and local communities fromtheir lands or territories without the free, prior, and informed consent of the indigenouspeoples and local communities concerned accompanied by agreement on just and faircompensation, nor will we be complicit in such forcible removal or relocation of theindigenous peoples and local communities. We uphold the right of those affected byrelocation and resettlement due to our operations to receive adequate compensation.

Supplementary provisions
Effective date: 14/ 5/2024