DeNA Group Human Rights Policy
Established September 26, 2022
Amended April 1, 2024
Preamble“We delight people beyond their wildest dreams” is the Mission of DeNA Co., Ltd. and allits subsidiaries (hereinafter referred to as the “DeNA Group”). The DeNA Group
cooperates appropriately with a variety of stakeholders to bring Delight to many areasand create a world where people’s individuality can shine.
Under the DeNA Promise (our social promise) in Value, the DeNA Group promotes
cooperation & prosperity for all, respect for diversity, and other sustainable corporate
activities. The DeNA Group Code of Conduct also establishes a respect for all
fundamental human rights and an appreciation of cultural and/or regional differences anddiversity in business operations.
Based on the above, the DeNA Group has formulated the “DeNA Group Human Rights
Policy” (hereinafter the “Policy”) as the guideline promoting respect for human rights
throughout the DeNA Group, and the Policy was adopted through a board of directors
resolution.
The Policy applies to all officers and employees of the DeNA Group. We sincerely
appreciate the understanding and cooperation of our business partners, suppliers, andother business operators with the intent and content of this Policy so that the Group canfulfill our commitment to human rights in our business activities.
1. Fundamental Principles
The DeNA Group supports human rights as set forth in international norms suchas the International Bill of Human Rights (including the Universal Declaration of
Human Rights), the ILO Declaration on Fundamental Principles and Rights atWork, the Guiding Principles on Business and Human Rights, and the Ten
Principles of the UN Global Compact.
2. Appreciation for Diversity and Prohibition of Harassment/Discrimination
The DeNA Group shall conduct its business operations with appreciation forregional and cultural differences and diversity, and will not tolerate any type ofharassment, including, but not limited to, sexual harassment, or discrimination
based on race, religion, gender, sexual orientation, gender identity, age,nationality, origin, disease, disability and/or other factors.
In addition, the Group will always strive to ensure equal opportunity, etc. in our
recruitment activities and in the treatment of executives and employees.
3. Prohibition of Forced Labor/Child Labor
The DeNA Group shall not require its employees to work involuntarily, and shallnot use child labor under any circumstances.

4. Management of Working Hours and Wages
The DeNA Group shall comply with all labor-related laws and regulations
applicable in the countries in which it operates, and shall strive to pay appropriate
wages that exceed the minimum wage, prevent overwork, and provide
appropriate days off.
5. Respect for Freedom of Association and the Exercise of the Right toCollective Bargaining
The DeNA Group respects the right of employees to form labor unions and tobargain collectively in labor-management relations.
6. Safety and Health
The DeNA Group will provide a safe and healthy workplace environment for its
officers, employees, and visiting partners, etc.
7. Freedom of Expression and Consideration for Privacy
The DeNA Group respects freedom of expression and privacy in transmissions
and internet communications, and takes the utmost care to ensure that there isno infringement thereof.
8. Education and Training
The DeNA Group will provide its officers and employees with ongoing educationand training necessary to put this Policy into practice.
9. Structure for Respecting Human Rights
The DeNA Group has established a whistleblowing hotline for consultation orreport on human rights issues that arise internally. The Group Code of Conduct
and internal rules specify anonymity and confidentiality for the person who madea report and prohibition on retaliatory treatment of said person. In the event of areport to the whistleblowing hotline, a summary of the report is also provided todirectors, corporate auditors, the Board of Directors, and the head of thecompliance and risk management department.
Appropriate action will be taken against violations of laws, regulations, andinternal rules including this Policy, such as correcting the violation, punishing theviolator, and introducing measures to prevent recurrence.