Axcelead Group Human Rights Policy
Effective September 1, 2024
The Axcelead Group established our purpose to build a healthy future for people worldwide
through a groundbreaking healthcare platform, and we aim to contribute broadly to society bypromoting impact management.
Through management based on this purpose, we recognize that our business activities may
impact the human rights of not only our executives and employees, but also, various business
partners and stakeholders. We are committed to respecting the human rights of all individuals
involved in our business activities. To promote this initiative and fulfill our responsibility torespect human rights, we have formulated the Human Rights Policy in accordance with theUnited Nations Guiding Principles on Business and Human Rights.
1. Basic Principles
As our values place "Respect for Diversity" at the highest level, we respect the diversity, dignity,and individuality of not only our executives and employees, but also, all business partners andstakeholders. We do not tolerate any form of unreasonable discrimination based on birth,nationality, race, creed, religion, age, gender, gender identity, sexual orientation, disability, or
any other characteristic, or any harassment that damages individual dignity.
Furthermore, we respect the rights to freedom of association and collective bargaining, prevent
all forms of child labor or unfairly forced labor, and strive to provide a safe and healthy working
environment.
2. Respect for and Compliance with Norms and Laws
We support and respect international human rights norms, including the International Bill of
Human Rights and the International Labour Organization (ILO) Declaration on Fundamental
Principles and Rights at Work. We also comply with the laws and regulations of the countries andregions where we conduct business. In cases where local laws differ from international humanrights norms, we adhere to the higher standard, and in cases of conflict, we seek ways to respect
international human rights norms.
3. Scope of Application
This policy applies to all executives and employees of our group. We also require our business
partners, including suppliers, to support this policy.

4. Responsibility to Respect Human Rights
In our business activities, we fulfill our responsibility to respect human rights by ensuring that
we do not infringe on the human rights of others, and by taking corrective actions when wecause or contribute to negative impacts on human rights. In cases where negative impacts onhuman rights by our business partners, including suppliers, are suspected to be related to ourbusiness activities, we will actively seek them to ensure respect for human rights.
5. Education and Training
We will continue to provide education and training to all executives and employees working in
our group to ensure that this policy is widely communicated, understood, and consistently
implemented and practiced.
6. Responsibility and Reporting Channels
We will clearly designate an executive responsible for implementing this policy, and establish
and operate internal and third-party reporting channels for any violations of this policy. We also
prohibit any disadvantageous treatment of whistleblowers as a result of their reports.
7. Information Disclosure and Dialogue
We will disclose information about our efforts to respect human rights in a manner both timely
and appropriate. Additionally, we will engage in timely and appropriate dialogue andconsultation with relevant business partners or stakeholders.
Axcelead, Inc.
Executive Officer, CSO
Masamichi Sato