dentsu

roup Human Rights policy
Policy number
Date created 11/06/2024
ιastrevised 11/06/2024

Applicable to: dentsu group inc and its associated companies.
Classification: dentsu extemal

Purpose: to set out our commitment to embedding respect for human rights across ourOperations, defining the minimum expectations that everyone working for and withdentsu, must comply with.
Scope: This policy applies to everyone who works at or is engaged by dentsu, induding
employees and contingent workers.
Policy owner: Global chief Governance 0什icer

Group Human Rights pohContentsExecutive summary

P.3

010ur risks & 1mpacts

P.4

020ur commitments

P.5

02.0I Equality and non・discrimination
02.02 Freedom ofThought, opinion, Religion and Belief, and Freedom ofExpression and Access to lnformation
02.03 Laborrights and harassment
02.04 Privacy and data secur北y
02.05 Child's rights
02.06 Right to a healthy environment

dentsu03 Governance and Due D川gence

P. 804 Grievance and Remedy

P.905 Enactment and Amen ment

P. 906 Policy information

P.10

07 Related policy documents

P.11

ecu

VearDentsu is committed to respeding human rights by upholding a11intemationa11y
recognised human rights instruments and the uN Guiding principles on Business andHuman Rights in every asped of our operations.

Our Group Human Rights policy is informed by the f0110wlng lnternatlonalinstruments and industry prindples
Universal Declaration of Human Rlghts
International covenant on clvil and p011tlcal Rights
Internatlonal covenant on soclal, Economic and cultural Rights
United Natlons Guiding prlnclples for Business and Human Rights
United Nations Global compact princlples
Internatlonal Labor 0四anlsation'S Declaration on Fundamental princlples and Rights at vvork
United Natlons conventlon on the Rights of the child
Global AⅡlance for Responsible Medla prlndples

Promoting and respecting human rights as core business strategy not only aligns withOur vision to be at the forefront of people‑centred transformations that shape society,but is also essential to our long‑term success.

This policy aims to establish a standardised and consistent approach to managing humanrights impacts across the organisation, regardless of geographica110cation or entity, andCovering a1Πndividuals and groups who may be impacted by dentsu's adivities orthrough our business relationships and suppliers.

dentsu

OU

明

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dentsu identifies key areas where our operations intersed with human rights
Considerations through ongoing due diligence such as:. Realtime alerts on societal, environmental, and security events,. periodical assessment ofthe risk profiles of our regions/ dusters, or markets(once per year at least),● Engaging with oursuppliers and partners, and● Annualemployeesurvey.

Vve also undertake in‑depth Human Rights salience Assessments conduded by expert
external stakeholders. This includes interviews with internal and external stakeholders

and incorporates a仟eded stakeholder engagement through employee and consumer
Survey results. The Human Rights salience Assessment covers a11 aspects of our globalOperations, induding our supply chain.

The findings ofthe most recent Human Rights salience Assessment determined our mostSalient risks which indude:Our most salient risks include:

Equality and non・dlscrimination

Freedom of Thought, opinion, Re11gion and Be11e , and Freedom of Expresslon and Access toInformation

Labor rights and harassment
Privacy and data security
Child's rightsRight to a healthy environment

For further detail on our salient impacts vlsit
Us overnance hum己n・rl hts.html

dentsu

杜:WWWroudentsu.com en about・Respecting human hghts is at the core of our code of conduct and is embedded
throughout policies and procedures that govem our wider business adivities andrelationships.(see sedion 7) vve set out our minimum expectations of our suppliers in
Our supplier code of conduct

Vve comply with a11 applicable laws and regulations in each country and region in which
We operate. vvhere internationa11y recognised standards of human rights and national orregiona11aws and regulations are in conflict, we seek ways to honor the principles ofinternational human rights whilst complying with loca11egislation.
02.0I Equa1託y and Non‑disc"mination.

Vve do not discriminate against any person on the basis of race, religion,nationality, ethnic or social origin, gender, gender identity, sexual orientation,age, pregnancy, neuro・diversity, di仟ering physical or mental abnities, or any
Other charaderistic.
.

Vve uphold the principles of equality and diversity in a11 aspects of our operations
and strive to eliminate the perpetuation of stereotypes and bias throughout ourbusiness.

02.02 Freedom of Thought, opinionl Religion and Belief, and Freedom ofExpression and Access t0 王nforma"on

Vve are committed to upholding the prindples of Freedom of Thought, opinion,Religion and Belief, and Freedom of Expression and Access to lnformation,
recognising that diversity of perspedives is essential to fostering creativity,innovation, and progress.
Vve strive to ensure that our dients' messages are not associated with content
that promotes misinformation, disinformation, division or discrimination bydentsuC011aborating with global and localindustry organizations that focus on safety andresponsibility as we11 as with Ad Tech partners that focus on advertiser protection.
V、/e work closely with our partners and plaザ0rms to promote access to accurate
and reliable information, uphold ethical standards and contr山Ute to a safer andmore indusive online environment.

02.03 Labor "ghts and harassment.

Vve adhere to internationa11abour standards and local regulauons for a11
employees, conungent 、Norkers, visitors, clients, customers, and suppliers and inSome circumstances, job applicants, candidates, and ex‑employees at dentsu andits assodated Companles.

Vve do not tolerate bU11ying, discrimination, harassment, and vicumisation (i.e.
reta1治tion) in the workplace, and provide anonymous channels for reporting andaddressing concerns.
.

Vve have a zero・tolerance approach to a11 forms of slavery and a commitment toComply with applicable employment and human rights legislation, including
relevant child labor laws. vve require the same from our partners.
Vve resped the right of a11 Workers to form and join a trade union of their choice
Or bargain c011ectively without fear of intimidation or reprisal, in accordance withnauona11aw.

.

In conflict・a仟eded areas,、Nhere additional cha11enges may arise, we wi" takeextra precautions to ensure the safety and security of our employees, working
dosely with local authorities and stakeholders to mitigate risks and uphold humanrights.

02.04 P"vacy and Data security

dentsuVve implement appropriate governance and assurance measures to ensure

Compliance with our data protection obligations. our approach and commitment
to this is enshhned in our Data protection principles.
.

Vve see data protection as a fundamental human right, SO 、Ne treat people andtheir personal data carefU11y and with resped so we can be a force for goodamong the organisations, partners and communities in which we vvork and live.

.

Vve are committed to being transparent in our handling and processing of
Personal data at a11 times in accordance with applicable privacy and data
Protection laws.

Vve adhere to laws and regulations governing the protedion of children's privacy
and ensuring that any data c011ected from or about children is handled fairly andresponsibly.

02.05 Child'S Rights.

Vve acknowledge the special protections a仟orded to children under internauonal
human rights laい/ and commit to respecting and promoting the rights of children
in a" aspects of our い10rk.

02.06 Rightto a hea吐hy environment

Vve integrate environmental sustainab"ity into our business pradices, minimize
Our environmental footprint, and advocate for policies and initiatives that protedand preserve the environment for present and future generations.

dentsuCeGovernance

The Group Human Rights policy is owned by the‑Group chief Govemance 0仟icer, who isthe executive level sponsor on human rights issues at dentsu.
Our Head of Human Rights are responsible for day・to・day implementation ofthe Group
Human Rights policy, vvorking closely with our group functions teams to build and embed
Capacity for the prevention, mitigation and remediation of our human rights impacts.
Human Rights is a standing agenda item at the executive Group sustainab川tyCommittee.

Due Diligence

Vve conduct human rights due d"igence throughout our operations and supply chain toidentify, prevent and mitigate risks. our approach is aligned with the united Nations
Guiding principles on Business and Human Rights. The process includes ongoing risk
assessments (see our Risks and lmpads), policy controls, capacity building and training,
tracking performance and transparent disdosure.

Vve provide training and communication to develop human rights awareness amongst
Our employees to ensure that this policy is embedded throughout our business activities.
Vve are committed to engaging in dialogue and consultauon with relevant stakeholders
On measures for addressjng potential and actual human rights impacts.
Vve disclose information on progress and outcome of human rights initiatives through ourWebsite and relevant reporting tools.

V、/e encourage aⅡ employees and external stakeholders to raise any human rights
Concern. vve provide a variety of channels for employees to raise concerns anddentsu

grievances induding our speakup @dentsu portal which is externa11y operated, free,anonymous and confidential, and available in 己11 appropr治te languages.
Our supplier code of conduct requires suppliers to raise any actual or potential concerns
Or suspicions of wrongdoing related to their engagement or relationship with dentsu,
induding any breaches of the supplier codel using the speak up @ dentsu portal.
Vve undertake thorough invesugations into concerns raised, and where they are
Substantiated we take appropr治te remedial and corrective actions.

Employees and contingent workers receive annualtraining on our code of conduct,
induding information on speakup @dentsu.

The Human Rights policy was developed through cross・functional c011aboration andexternal expert stakeholder consultation and is approved by the Group Management
Board. n is reviewed periodica11y to renect operational changes, and comP1治nce istracked V治 ongoing engagem
Controls framework

Signed bydentsu

ノ、、t by our human rights team and through our internal

06 Po icy lnfot' at'0
6.o lnforma"onTitle
Document number

PurposeAudience

Group Human Rights policy
G/0/S/001
To set out our commitmentto embedding
respect for human rights across ourmlnlmum
Operations, defining theexpectations that everyone working forand with dentsu, must comply with.
Regional cEOS, Regional cFos andGlobal communications

CategoryOperational

Subcategory

Sustainability

Approving Authority
Policy owner

GMB

Policy Author

Global General counsel and Group

Global chief Governance 0什icer andGlbal chief Finandal 0仟icer

Corporate secretary and Deputy Global
General counsel

Approval date

11/06/2024

E仟edive dateSame as Approval date

Revie、N date

Two years

フ.O Related policy Documents and supporting Documents
PolicyHR policy, speak up policy, physical
Security policy, procurement policy, Data
Protedion and privacy policy, Data
Protedion prindples, contentious clients

Policy, and Generative Al policy. supplierCode of condud
Forms

dentsuN/A