Sustainability and Major Issues◆ Basic Concepts◆ Sustainability at the COMSYS Group
With the emergence of climate change, human rights
and other global issues, we have established a basic
sustainability policy based on our management philosophy. The COMSYS Group will help build a sustainable
society by focusing on its core businesses such as telecommunications infrastructure and social infrastructure that come with high level of social responsibility.

Major Issues

Contributing to local
communities throughengineering capabilities and innovation●Promote businesses that meet the needs of an increasingly
diverse infrastructure society●Develop new technologies and business fields throughco-creation with new partners●Reform of construction methods and operations through DX
promotion●Promote projects that develop together with local communities through engineering●Promote disaster prevention and mitigation projects to respond to increasingly severe disasters

Ensuring safety andsecurity and compliance●Instill a culture that puts safety first●Strengthen the company’s ability to respond to natural disasters●Ensure the health of employees and their families●Thorough implementation of the Group’s Code of Conduct,
including the supply chain●Promote renewable energy power generation projects andfacility construction●Promote our Group’s efforts to achieve carbon neutrality●Promote initiatives for resource recycling●Appoint female directors to increase diversity on the Boardof Directors●Optimize the number of directors necessary to ensure theeffectiveness of the Board of Directors and strengthen its
supervisory function

Board of Directors

Under the basic policy, we will
strengthen and promote the
COMSYS Group’s sustainability initiatives, led by the Sustainability Committee, which
was established in July 2022.

Approval,
supervision

Reporting

Sustainability Committee
Chairperson: President of COMSYS Holdings
Sustainability Promotion Oﬃce
Sustainability promotion division at each Group company

Contributing to local communities

SDGs to Aim forContributing to society
through engineering●Constructed of various social infrastructure such as telecommunication infrastructure facilities, gas/water andsewerage maintenance works, and data centers●Participated in disaster prevention and mitigation projects, such as utility undergrounding and regional flood
control projects●Recovery support activities in the event of a disaster

P3-6●Digital transformation of sports through SAVREQTeamSports and creation of new value in regional sports

P5

Growth through innovation
Promotion of SAVREQ

Diversity of human resources, expansion of work style options, and improvement of employee satisfaction

Status of Initiatives

1

Main Initiatives

Human resource
utilization and work
style reform (Improved
engagement)

Strengthening corporate governance◆ System

Under its management philosophy of building a company that customers continue to choose throughthe construction of diverse infrastructure that carries our era forward, contributing to our country
and local communities by building social infrastructure that supports affluent lifestyles, and aiming tofurther increase corporate value with unrelenting reform, as a comprehensive engineering company
that leads the construction of telecommunications and social infrastructure, the COMSYS Group iscommitted to building the infrastructure for a smart society, shaping the future. Through these endeavors, we not only aspire to contribute to society in line with the SDGs but also to the sustainablegrowth of our Group. This commitment forms the cornerstone of our sustainability policy.

●Promote the active participation of diverse human resources (external human resources, women, etc.)●Foster and raise awareness of respect for human rights
among all employees●Expand human resource development programs, reskilling,
and recurrent education●Expand the personnel system in line with the times and promote work-life balance

Making efforts for
global environmental
conservation

Basic Sustainability Policy (formulated in May 2022)

Promoting diversity and developing human resources●Implemented training to foster awareness of respect for
LGBTQ and other human rights●Hired diverse human resources and developed new female managers●Utilized human resources platform across the Group

Promote work-life balance●Implemented management-level training to improve therate of male employees taking childcare leave

P13-14

Pursuit of safety and security
Ensuring safety and quality
as top priorities●Strengthened safety measures through ICT and thoroughsafety education using images(Number of personal injury accidents: 10)●Strengthened cybersecurity measures

P11-12

Achieving carbon neutrality
Green power purchasing●Planed for the Group to purchase approximately
10GW (just under 30% of total electricity usage) in
FY2023

Install solar power on facility rooftops●Scheduled installation on the rooftop of the company’s
facilities this fiscal year

Start of use of combustion
accelerators●Started using diesel oil combustion accelerators to reduce oil consumption in business vehicles

Switch to BEVs and HEVs

●Planed to switch a total of approximately 280 vehicles to
BEVs and HEVs by FY2023

Pioneering GX solutions●Promoted initiatives such as registration in the METI-led
GX League and carbon offset business with venture companies

P7

Strengthening corporate governance
Optimization of the numberof directors● Increased the ratio of outside directors, including female
directors, to 40%

P15-18Sustainability and Major Issues

2

Segment Business Strategy:
Carrier-Related Business(NTT Engineering Business / NCC Engineering Business)◆ Business Outline
troubleshooting for communications equipment.
Work in the Mobile business mainly comprises theinstallation of mobile phone base stations for the NTT
DoCoMo Group, our biggest customer in this field, as
well as negotiations and consultations leading up to
those projects (including negotiations with landowners), design work, and network construction related
to mobile communications facilities. Following the deregulation of communications in the 1980s, new telecommunication vendors entering the field came to be
known as “new common carriers” (NCCs), and SANWA COMSYS Engineering has played a central role inthe construction of facilities for these NCC companies.
Work in the NCC Engineering Business is almost thesame as in the NTT Engineering Business; we handle
the construction of Access, Network, and Mobile facilities for telecommunications carriers such as KDDI,SoftBank, Rakuten Mobile, and other customers suchas CATV companies, and electric power companies.
Compared to the NTT equipment business, the NCC
equipment business is characterized by a large shareof mobile-related work.

The NTT Engineering Business, which comprises theAccess business, the Network business, and the Mobile business, is the most important business in termsof revenues, and handles the construction work for
NTT facilities nationwide. The main customers for theAccess and Network businesses are the NTT East and
NTT West Groups, and the NTT Docomo Group (including the former NTT Communications Group), andthe work mainly comprises construction and maintenance related to those customers’ fixed-line communication networks.
In the Access business, we construct, install, replace,remove, and respond to breakdowns of communications cables (both metal and optic fiber) installed on
utility poles and in underground pipes, and handle the
new installation and replacement of utility poles forcommunications.
In the Network business, our work mainly involves
the installation, relocation, and removal of communication and information processing equipment in communication stations and data centers, as well as wiring installations and the construction of electric power
facilities. We also handle configuration settings and◆ Medium- to Long-term Market Trends
communications networks by the NTT East and WestGroups will continue decreasing and revenue from the
COMSYS Group’s NTT fixed-line business is expected
to decline as well.
In the Mobile business and the NCC Engineering Business, a certain amount of business is also expected as
telecommunications carriers promote 5G deployment.
However, there are concerns that the number of newbase station construction projects will decline as thecarriers continue to utilize 4G frequencies, and that

There are new business opportunities such as data
center-related operations to handle the increase intelecommunications traffic, the new medium-term
management strategy centered on the IOWN Initiative
announced by NTT, the electric power operations related to the Smart Energy Business, and the development of optical fiber networks in line with the Digital
Garden City Nation vision promoted by the Ministryof Internal Affairs and Communications. However, it
is projected that capital investment in fixed-line tele-smaller construction projects will be made possibleby the miniaturization and simplification of telecommunications facilities. In the future, it will be necessary to respond quickly and efficiently to carrier trends
such as the government’s request to accelerate 5Gbase station development plans in line with the Digital
Garden City Nation vision and the institutionalizationof local 5G.

◆ Topics for This Fiscal Year
Removal of old equipment for the purpose of OPEX
reduction and decarbonization began with KDDI’s
3G removal in FY2022 and SoftBank’s PHS removal
in FY2023, to be followed by SoftBank’s 3G removal
in FY2024 and NTT DoCoMo Group’s 3G removal in

2022

2023

2024

〜

2025

2030〜

In the NTT Engineering Business, in order to expand
peripheral businesses to respond to large fluctuations
in earnings, we will expand our sales area beyond thecarrier periphery to include public and municipal offices and the private sector for operations that are compatible with mobile skills.
Business performance in the NCC Engineering Business is greatly affected by trends in telecommunications carriers’ capital expenditures. To avoid such asituation, we will expand orders to peripheral businesses surrounding the telecommunication construction of each NCC company and maintain our businessstructure.
Peripheral businesses include 5G and its peripheral
growth fields and services, DC facility construction, inNet Sales (Consolidated) in the Carrier-Related Business*

Digital Garden City Nation superhighway
National
concept

5G population coverage:

95%

Optical ﬁber household coverage:

99.85%

97%

Beyond 5G
（6G）

294.2

289.4

302.9
279.7

269.0

NTT
Fixed-Line

Wireless base stations: road (expressway and national highway) coverage: 99%

3

Value Creation Topic: Local 5G initiatives
Local 5G, which allows
companies, local governments, and otherentities to flexibly construct on-site 5G systems on a spot basis in
response to the individual needs ofregions and industries, is expandingin popularity. The COMSYS Group is
responding to customer’s requests OutdoorRU GPS antenna installation
by building proposals from research
design to construction and maintenance, and is also focusing on
developing multidisciplinary engineers who integrate fixed and mobile technologies.

Value Creation Topic: Rapid recovery from natural disasters
NTT
Mobile99%(FY2030)
99.9%(FY2027)

house facility construction, IoT, Wi-Fi, private 5G, andrenewable energy power generation infrastructure
construction for telecommunications carriers.
Leveraging the human resources and technologies
we have cultivated through the construction of 5Gbase stations, networks, and power equipment, we
will expand our horizons to further evolve 5G (Beyond5G) and create the foundation for peripheral growthfields and businesses (services) surrounding 5G.
In the DX-related field, we will promote buildingof data center facilities and in-house facilities as corporate work style reform efforts, improvement of productivity, enhancement of networks (ultra-high speed,
ultra-multiple connection, ultra-low latency), and safe
and secure security initiatives.

(Billions of Yen)

Digital Garden City Nation infrastructure development plan
Large-scaledata centers

FY2026. Taking advantage of the expertise we haveaccumulated through our construction and maintenance work, the COMSYS Group is also actively engaged in this removal work in parallel with the construction of 5G base stations.

◆ Strategies and Initiatives

Outlook for Carrier-Related Business: Medium- to Long-Term Market Trends(FY)

In the NCC Engineering Business, we have been
expanding 5G capital investment to realize the Digital Garden City Nation vision. However, carriers haveslowed investment due to the repurposing of existing
frequencies for 5G, the impact of telecommunications
cost reductions, and the moderate spread of 5G. Investment will be curbed in FY2023 compared to theprevious fiscal year.

NCC
FY2019FY2020

FY2021

FY2022

FY2023(Plan)*The breakdown of the graph shows the ratio of the simple sum of
non-consolidated figures of supervisory business companies.

To protect people’s lives
from devastating natural
disasters, the COMSYSGroup is united in its efforts to provide support
for the rapid restorationof damaged telecommunications andsocial infrastructure.
Typhoon damage recovery support

Segment Business Strategy: Carrier-Related Business (NTT Engineering Business / NCC Engineering Business)4Segment Business Strategy:

Segment Business Strategy:

IT Solutions BusinessSocial System-Related Business◆ Business Outline◆ Business Outline

SWOT Analysis●Extensive track record in nationwide multi-site deployment
work●Relationships of trust with a wide range of alliance partners●Offers “Full Layer x Full Life Cycle” from application development and IT infrastructure construction to maintenanceand operation●Provides operation and maintenance services for on-premises and cloud environments 24 hours a day, 365 days a year
●Multi-vendor support●Diverse engineer base

The IT Solutions Business comprises three sub-segments: Solutions, Software Development, and Maintenance. Two notable drivers for growth in the Solutions segment have been the Alliance Business andcorporate projects undertaken as a partner of the
NTT Group. “Software Development” is mainly undertaken under contract, but we also cater to cloudand modernization projects. “Maintenance” operations include server and network, cloud monitoring,customer reception, on-site response, and operational support.

S●To expand in business areas focused on IT
infrastructure construction and software development, the lack of resources such as engineers and sales force is a challenge.

W

Strengths

Weaknesses

0T●Creation of new business areasusing AI, IoT, XR, robotics, etc.
●Acceleration of DX in the public,
municipal, and private sectors●Increase in businesses related
to clean energy construction
based on SDGs
●Acceleration of the shift from offshore to nearshore in application development●Increase in urban redevelopment projects andsmart agriculture-related businesses

Opportunities

Threats

Countermeasures:
Strengthen new graduate/mid-career recruitment, collaborate withGroup companies to establish asystem, consider M&A deals, create service-oriented businesses●On-premise
construction
decreasing due to progress in thecloud●Decrease in development scaledue to the progress of agile, lowcode, and no-code development

Countermeasures:
Accelerate the development of engineers to respond to changing needs◆ Strategies and Initiatives
To expand in what is a key segment for our Group’s
growth, we will pursue the following three initiatives.
1) Expanding high added value business: In responseto the steady growth of the cloud market, we will
expand managed services and other stock businesses. We will also provide high added value
solutions in the Smart X market, including smart
cities that utilize AI, IoT, robotics, etc., and work
toward achieving DX for government offices, companies, and local communities in the fields of digital government and educational ICT.
2) Securing manpower capable of handling cutting-edge technologies: In addition to strengthening new graduate and midcareer hiring, we will
Net Sales (Consolidated) in the IT Solutions Business(Billions of Yen)

116.0
105.5
98.1
Software 27.1
Development

Solutions 65.9

Maintenance

5

27.7

109.5
101.3
30.7

31.7

32.3

strengthen the training (reskilling) of engineers necessary for future challenges in new business areas.
3) Strengthening unified operations throughout the
COMSYS Group: We will strive for overall optimization while clearly identifying “Business fields tobe optimized and maximized in individual areas leveraging the strength of supervisory business companies,” and “Business fields in which synergies canbe achieved as the COMSYS Group.” In particular,
we will work on full-layer solutions by integrating
the operations of COMSYS Group companies in
the Tokyo metropolitan area to bolster our capability in the area.

Value Creation Topic: Sports DX and new value creation in regional sports

The Social System-Related Business comprises threesub-segments: “Electric and Telecommunications
Facilities,” “Renewable Energy,” and “Infrastructure
and Other.” In “Electric and Telecommunications
Facilities,” we undertake electrical construction andtelecommunications construction for expressways
and for Ministry of Defense projects. The Renewable
Energy sub-segment revolves mainly around theconstruction of solar power plants. Going forward,
we anticipate a greater push toward decarbonization by companies and other entities. Therefore, weplan to leverage our existing expertise to venture
into supporting business management for decarbonization. In “Infrastructure and Other,” our main
business includes undergrounding of utility poles
and civil engineering construction related to watersupply and sewerage based on orders placed by regional municipalities and the national government.

63.8

70.2

Amid increasing activities among various ministries
aimed at putting in place and maintaining social infrastructures, we expect that the Social System-Related
business will be the segment demonstrating the highest
level of growth during the period of the Medium-Term
Vision. While we will engage in M&A activity, internal
growth will be the pillar of our business growth.
In the fields of electricity and communications, wewill leverage the comprehensive strengths of our virtual company frameworks to expand our road and data
center businesses.
In the field of renewable energy, demand is expected to expand with companies and local governments
Net Sales (Consolidated) in the Social System-Related Business(Billions of Yen)TOSYS Corporation has started providing SAVREQTeamSports*1, a service jointly developed with K&F
Computer Service. SAVREQ TeamSports is an IoT
cloud service with an AI auto-tracking function*2 thatenables recording and editing sports scenes using
multiple 4K cameras installed at sports facilities. The
captured videos can be automatically tracked and edited throughsimple operations, and can be used for various sports scenes.

76.0

5.1

6.6

6.7

7.5

7.7

FY2019FY2020

FY2021

FY2022

FY2023(Plan)*1 SAVREQ is a registered trademark of TOSYS Corporation.
*2 The AI auto-tracking function has been implemented in cooperation with“SCORER” provided by Future Standard Co., Ltd.

●Construction and maintenance capabilities
covering the entire country●High ability to estimate and manage risks
based on past experience●Abundant qualified personnel
and construction experience toensure consistent high-quality
results●An unparalleled construction
lineupS

Strengths

0●The government has declareda policy of achieving “net zero
greenhouse gas emissions by
2050,” further accelerating the
deployment of renewable energy●Government ministries and agencies are developing various infrastructure projects to address aging social infrastructure andincreasingly severe natural disasters●There are several large-scale private sector
redevelopment projects in the works

Opportunities●Weak sales capabilities in the private sector●Shallow base of technicians in such areas aselectric power and air-conditioningW

Weaknesses

T

Threats

Countermeasures:
Shore up these areas, including
possibility of M&A deals●End of the feed-in tariff (FIT)
system for solar power. Solar
power business will continue
thanks to growing demand forsolar self-consumption installations◆ Strategies and Initiatives

185.0

184.7
168.5

Infrastructure
and Other

71.1

SWOT Analysis

90.9

173.8

168.2

86.7

102.9

111.6

121.7

playing a leading role in realizing a carbon-free society,so we will take advantage of our wealth of experienceand expertise to seize this opportunity.
In the Infrastructure field, we are working to acquireutility undergrounding and water supply and sewerage projects, as well as to participate in river basin
flood control projects as a new business.
In order to secure construction resources, whichis the biggest challenge in business expansion, weare strengthening both new graduate and midcareer
recruiting, horizontally developing measures to trainengineers utilizing virtual company frameworks, andflexibly utilizing resources within the Group.
Value Creation Topic: Outreach activities in the surrounding communities of construction locations
In the Tokyo Metropolitan
Government’s Bureau of Waterworks’ 10-year project toearthquake-resistantinstall
joint pipes for water pipelines (FY2021–FY2030), the
COMSYS Group’s seismic joint work at
three locations in Tokyo received the Excellent Construction Award and the ExcellenceAward in the Image Enhancement Competition. Our communication activities with local
communities based on the characteristics ofthe construction environment were highly
evaluated.

Children from a nearby elementary school were asked to draw
pictures related to water whichwere posted along the roadsideat the site

Value Creation Topic: Reducing environmental impact during manufacturing

Renewable
Energy

29.3

38.3

46.9

Electric andTelecommunications
Facilities

48.3

43.2

FY2019FY2020

27.8

20.9

34.8

34.4

42.4

FY2021

FY2022

FY2023In FY2022, Fujiki Corporation established a new
coating plant that contributes to reducing environmental impact when coating steel structures.

Coating plant(Plan)

Segment Business Strategy: IT Solutions Business / Social System-Related Business6

Tackling Environmental Issues

Disclosure Based on TCFD Recommendations

Stance on Global Environmental Issues
The COMSYS Group will promote reduction of GHG emissions, which has become an urgent issue worldwide,
so that we can continue to develop together with society. We will also make effective use of limited resources
so that the next generation can continue to live affluent lives.
Specifically, we are promoting initiatives to achieve carbon neutrality in society through the use of renewableenergy and the commercialization of carbon offsets.

◆ Carbon-Neutral Initiatives
Switching to Green PowerThe COMSYS Group is switching the power it procuresto green power generated from renewable energy. In
FY2021, TOSYS Corporation began switching to green
power, and in FY2023, NDS and Nippon COMSYS followed suit. Nippon COMSYS is presently proceedingwith the conversion to green power at seven of its 26
target sites, starting from May 2023.
Through these initiatives, the amount of green power used by our Group is expected to reach approximately 10GWh (approximately less than 30% of allelectricity used) in FY2023. We are also considering
a planned switch to green power at our Osaki head
office, company-owned buildings, and leased offices.
We will continue to promote the switch to green
power.
Installation of Solar Panels on the Rooftops ofFacilities
We plan to actively introduce solar power generation
for the purpose of committing to greater use of renewable energy at our facilities. In FY2023, SYSKEN
will install solar panels on the rooftops of two of its
facilities. As the COMSYS Group, we will further study
and promote the greening of our office buildings.

GX Initiatives(Reducing emissions and commercializing
carbon offsets)
In addition to reducing its own CO2 emissions, the
COMSYS Group is considering measures to reduce
CO2 emissions throughout society by collaboratingwith various organizations and companies.
TOSYS Corporation is cultivating initiatives for emission reduction strategies and the commercializationof carbon offsets. These initiatives include registrationin the METI-led GX League*, engaging in carbon offset business discussions with venture companies, andparticipating in a project to visualize CO2 emissions
under the Nagano City Smart City Council.
* GX League: A forum for cooperation between a group of companies and the government, universities, and academic institutions in order to meet greenhouse gas
reduction targets and increase industrial competitiveness by using Japan’s goal ofcarbon neutrality by 2050 as an opportunity for economic growth. This initiative,
led by the Ministry of Economy, Trade and Industry, is focused on transforming
the entire economic and social system (GX: Green Transformation) and serves asa platform for both discussion among these companies and the practical creationof new markets.

Switching Business Vehicles to HVs, EVs,
and Other Fuel-Efficient Vehicles
The COMSYS Group conducts its business using approximately 2,700 vehicles (excluding special vehicles
and vehicles for work at heights) at its nine operatingcompanies. Because of this, reducing CO2 emissions
from vehicles is one of our Group’s most importantmanagement issues.
In response to this issue, we are actively transitioning our business vehicles to low-emission options likehybrid vehicles (HVs) and electric vehicles (EVs) to reduce gasoline consumption and associated CO2 emissions while at the same time enhancing operational
efficiency by minimizing repetitive tasks.

◆ Basic Approach◆ Strategies

The COMSYS Group has set forth addressing global
environmental conservation as a major issue basedon its management philosophy, and has positioned
addressing climate change as an important initiative
within this.
The COMSYS Group announced its support for the
TCFD recommendations in November 2021, from theperspective of reflecting climate change response in
our management strategy, and joined the TCFD Consortium. We aim to contribute to the creation of a sustainable society and will actively disclose information
based on the requirements of the TCFD.

Identification of short, medium, and long-termclimate-related risks, opportunities, and their impact
on business
The COMSYS Group analyzed climate change-relatedrisks and opportunities that could occur in the future
by referring to the below 2°
C (1.5°C) and 4°
C scenarios. As a result, we identified the impacts of the conceivable future events associated with the transition
to a carbon-free society and the physical impacts ofclimate change as risks. In FY2022, we quantitatively
estimated the financial impact on our Group, especially with regard to the respective cost increases associated with the introduction of a carbon tax and theswitch to electricity derived from renewable energy.
In relation to our business, the Group has identified
possible opportunities in the growing demand for renewable energy projects and also in the need for utility undergrounding and the renovation and seismic retrofitting of social infrastructure. In response to theserisks and opportunities, we will review our businessstrategy in order to realize a carbon-free society.

◆ GovernanceOversight of the Board of Directors on
climate-related risks and opportunities
In order to maximize sustainable corporate value
and contribution to the SDGs, the COMSYS Grouphas established a Sustainability Committee under
the supervision of the Board of Directors, chaired by
the president of COMSYS Holdings. The Committee
is responsible for determining sustainability-related
directions, strategies for climate-related risks and opportunities, setting indicators and targets, and deliberating, evaluating, and monitoring major action plans.
It reports to the Board of Directors on key topics. In
FY2022, the Board of Directors approved a greenhouse gas reduction target for FY2030, which was announced in May 2022. Going forward, we will examineand formulate more specific reduction measures and
KPIs, and further promote efforts to address climatechange issues.

【Scenarios】
The following scenarios were set in order to identify
and evaluate climate-related risks and opportunities.
Scenario

Reference scenario

Below 2°C (incl. 1.5°C) scenario

Scenario for transition to a carbon-freesociety (Transition Scenario)

4°
C scenario

Scenario in which physical impacts
become apparent

・IEA World Energy Outlook 2018
SDS
・IEA「Net Zero Emissions by
2050」
・IPCC Fifth Assessment Report
RCP2.6, RCP8.5
・IPCC Special Report on Global
Warming of 1.5°
C, etc.

【Change in Global Average Surface Temperature】◆ Risk Management
Recognition of the need to assess and respond toclimate-related risks
The Risk Management Committee, chaired by thepresident and with the directors and the presidents
of supervisory business companies as its members,
meets as needed to identify business risks throughout
the Group and address them according to the level of
their impact.
Each COMSYS Group company similarly addresses
risks through its appropriate body.
The Sustainability Committee oversees climate-related risks and opportunities. It monitors changes in external and internal environments arising from climatechange, and it identifies climate-related risks and opportunities that may affect our business. The identified
risks and opportunities are evaluated and analyzed
based on the level of impact on our company and other factors in order to determine which presents thehighest level of risk or opportunity.
Going forward, critical matters will be reported to
the Board of Directors and we will consider creating atransition plan that considers company-wide risks andopportunities.

6.0（℃）

3-4°
C world

4.0

Conceivableglobal range

2.0

1.5-2°
C world

0.0
Timeframe
-2.0
2000

2050

2100

（year）【Conceivable Scenarios】
Below 2°C (incl. 1.5°C) scenario● Introduction of carbon tax● Significant decrease in fossil fuel power generation● Increase in demand related with renewable energy business● Growing demand for facilities with a high level of environmental performance4°
C scenario● Widening damage caused by increasingly severe natural disasters● Increased need for disaster preparedness and mitigation● Reduced productivity due to heat stress● Summer labor constraints due to more extremely hot days

EVs introduced

7

Tackling Environmental Issues / Disclosure Based on TCFD Recommendations

8

Disclosure Based on TCFD Recommendations【Potential Risks and Opportunities】
Below 2°C (incl. 1.5°C) scenario: Scenario for transition to a carbon-free society (Transition Scenario)
Classification

Timeline*

Risks and opportunities

Responses & initiatives

Opportunities●Reduce GHG emissions (energy conservation,energy efficiency, switching to BEVs for businessvehicles, etc., switching to green power at company-managed facilities)

Short/●Higher electricity costs due to switch to power
medium/from renewable energy sources
long term●Greening of offices through the introduction of solar power generation systems and rooftop greenery

Short/●Customer defections and damage to corpoMarkets/
medium/rate image if customers believe environmental
Reputation
long term
initiatives are inadequate●Acquire SBT certification for set GHG reduction
targets and implement specific reduction measures●Proactive disclosure of information on environmental measures●Growing renewable energy business (solar,
Short/
wind, etc.) demand
Products services/
medium/ ●Expand equipment demand through the deEnergy sources
long termvelopment of new environmental technologies(hydrogen and CO2 recovery)●Promote renewable energy projects (solar, wind
power, etc.)●Win orders for EPC projects covering everythingfrom design to procurement and construction●Actively participate in new environmental
technology projects

Transition

Risks

Medium/●Increased operating costs due to carbon tax
long term

Policy &regulation◆ Metrics and Targets
Targets and results for managing climate-related risks andopportunities (Scope 1+2+3 emissions)
In May 2022, our Group set targets based on the Science Based
Targets (SBTs)* for FY2030, and acquired SBT certification in
October 2023.
In order to achieve carbon neutrality
in FY2050, we will forge ahead withinitiatives aimed at achieving these targets.
*Based on the Near-term SBT concept

Acute
Physical

Risks

Chronic

Opportunities

Markets/
Resilience

Timeline*

Risks and opportunities●Delays in construction due to supply chain
Short/
disruptions caused by direct or indirect
medium/damage to employees or partner compalong termnies due to natural disasters●Implement an employee safety check system tograsp the situation and promptly take action forrecovery activities●Decreased productivity as more constructionengineers suffer from health hazards such asheat stroke and they avoid working in extremely hot hours of the day●Enhancements to create a safe work environment, including equipment and facilities toprevent heatstroke●Improve productivity using ICT to reduce the burden on technicians and save manpower●Increase opportunities to receive orders byreviewing disaster prevention and mitigationplans in response to increasing frequency andseverity of natural disasters●Build highly resilient telecommunications facilities
and base stations●Capture construction investment in infrastructuredevelopment areas such as utility undergrounding
and river improvement projects by local governments*Short-term: 1–3 years, Medium-term: 3–5 years, Long-term: 5 years or more

Item

Risks

Transition●Carbon tax
Policy &regulation●Rates for electricity derived
from renewable energy

Scope 3

Taxation cost
(Case where GHG reduction measures
are not implemented)

Below 2℃ scenario (including 1.5℃)
Approx. ¥1.8 billion

Taxation cost
(Case of achieving the 42% reduction
target compared to FY2020)

Approx. ¥1.1 billion

Increase in power procurement costs

Approx. ¥60.0 million(Assumptions for 2030)●Carbon tax price: $130/t-CO (see IEA “Net Zero Emissions by 2050”; estimated at USD1.00=JPY140.00)●The COMSYS Group GHG emissions (Scope 1+2): approx. 60,000 t-CO2 (42% reduction target achieved compared to FY2020)●Electricity derived from renewable energy: approx. ¥1.20/kWh (higher price compared to normal electricity rate)

By FY2030, reduce 25% fromFY2020 baseline

Indirect emissions from the
supply chain (emissions
from other companies related to the activities ofthe business)

25

GHG emissions（Scope 3）％
reduction(from FY2020 baseline)％
reduction

100

1,730

（kt CO2 e/y）

（kt CO2 e/y）CarbonneutralScope1

FY2020

FY2021

FY2022

FY2030Target

FY2050TargetFY2020

FY2021

FY2022

FY2030TargetBreakdown of Greenhouse Gas (GHG) Emissions* （kt CO ）1

Scope, category

Calculation boundary and method2

FY2020*2

FY2021*2

FY2022

Scope 1+2

106

112

100

Scope 1
（Direct emissions）

90

95

84

Scope 2
（Indirect emissions）

16

17

17

Scope 3
（Value chain total）

1,868

1,812

1,730

297

306

271

46

38

33

Category 1（Purchased goods & services）

For the main suppliers, emissions are calculated from the value-based
emissions intensity unit determined from the values published by eachcompany, and the weighted average is applied for other suppliers

Category 2（Capital goods）

Calculated from the capital investment amount

15

Category 3（Fuel and energy related activities） Calculated from annual consumption by energy type
Category 4（Transportation, distribution (upstream)） （Distribution is included in Category 1 and not subject to calculation）

Expected financial impact on our Group in 2030
Classification

Indirect emissions from theuse of electricity, heat, andsteam supplied by othercompanies

42

Scope2

Responses & initiatives●Analyze the frequency and impact of natural disasters at branch offices and business locations
and formulate measures to address them
●BCP measures in preparation for abnormal weather and changing weather patterns

Short/
medium/long term● By FY2030, reduce 42%from FY2020 baseline● Become carbon neutral in
FY2050

Scope 2(from FY2020 baseline)●Increased restoration costs for branch offices,
Short/
construction sites, and company facilities due
medium/to devastating natural disasters
long term ●Longer construction periods due to frequent
natural disasters

Short/
medium/long term

Greenhouse gas emissions(GHG) made directly by
the business itself

Track Record of Reducing Greenhouse Gas (GHG) Emissions and Targets

GHG emissions（Scope 1+2）

4°
C scenario: Scenario in which physical impacts become apparent
Classification

Reduction goal

Scope 1

−

16
−

17
−

Category 5（Waste generated in operations） Calculated from the volume of waste by type

9

12

9

Category 6（Business travel）

2

2

2

Calculated from the number of employees (consolidated-basis)

Category 7（Employee commuting）

Calculated from the number of employees (consolidated-basis)

Category 8（Leased assets (upstream)）（Emissions from leased buildings, etc. are calculated in Scopes 1 & 2）

4

4

4

−

−

−

Category 9（Transportation, distribution (downstream)） （Not subject to calculation）

−

−

−

Category 10（Processing of sold products） （Not subject to calculation）

−

−

−

1,490

1,430

1,391

Category 11（Use of sold products）

Telecommunications is calculated from the Scope 2 figures published by major
customers. Non-telecommunications is calculated by multiplying the sales volume by the assumed standard unit during use and the number of years of use

Category 12（Disposal of sold products）

Calculated from the volume of waste of products that are not removed by us

Category 13（Leased assets (downstream)） Calculated from the total floor area of rental condominiums

4

4

2

0.4

0.4

0.5

Category 14（Franchises）（Not subject to calculation）

−

−

−

Category 15（Investments）（Not subject to calculation）

−

−

−

*1 In order to ensure accuracy and transparency in information disclosure, the COMSYS Group has obtained third-party assurance for CO2 emissions.
For more information, please visit the COMSYS Holdings website.
*2 Revised due to improved calculation accuracy

9

Disclosure Based on TCFD Recommendations

10

Promoting Safety and Quality◆ Basic Approaches to Safety
Safety, quality, and trust are top priority items in the
COMSYS Group’s business operations. The COMSYSGroup emphasizes three key points in terms of ensuring safety: (1) Entrenching and carrying on a corporate
culture in which securing safety and quality are the top
priority, regardless of the situation or environment; (2)Actively introducing tools and safety equipment to ensure a safe work environment; and (3) Continually operating tools and equipment correctly. To ensure thatthese three activities do not become mere formalities,
we review them as required so that they evolve, andare subject to a continuous PDCA process.
In terms of specific accident prevention measures,in addition to day-to-day meetings before starting
work and safety patrols, we have introduced vehicles

equipped with automatic brake systems and other safety equipment, provide traffic safety guidance
based on information recorded by onboard cameras,
provide training that incorporates “hazard experiences” using VR technology, conduct safety conferences
and accident prevention campaigns that include partner companies, and draw attention to accident prevention using case studies of past accidents both in
the COMSYS Group and at other companies. Whenan accident occurs, the background factors are thoroughly investigated based on fundamental principles
for operating rules, prevention measures are studied,and the various workplaces are advised of key points
requiring attention and rules to be followed in the future.

◆ Work-Related Accidents*1 Frequency rate: Expresses the frequency of work-related accidents based on
the number of work-related injuries or deaths recorded for every 1 million workhours
Calculation method: (number of work-related injuries or deaths / total numberof work hours) × 1,000,000*2 Severity rate: Expresses the severity of work-related accidents based on thenumber of workdays lost due to workplace accidents, recorded for every 1,000
work hours
Calculation method: (Total number of workdays lost / total number of work
hours) × 1,000

Frequency Rate of Work-Related Accidents (Yearly Base)Severity Rate of Work-Related Accidents (Yearly Base)

1.00

0.30

0.85

0.80

Construction industry*

FY2020

FY2021
13

FY2022
13

22

The COMSYS Group receives facility information,technical information, and personal information from
customers, and conducts its business based on that
information. Preventing information leaks is extremely
important in securing the customers’ trust. To strengthen information security, we have obtained information
security management system (ISMS) certification andPrivacyMark at each company, always working to protect personal information and business information,and to respond appropriately to cyber-attacks. Each

year, we conduct information security training for all
employees, including contract employees and employees of partner companies, as part of unflagging
efforts to protect customer information.
Serious Information-Related Incidents
FY2020

FY2021
1

FY202200(Number of information-related incidents involving leaks of customer information or
personal information as defined by COMSYS Holdings)

0.21

0.60

Respect for Human Rights

Nippon COMSYS

0.40

0.28

0.42

Construction industry*0.06
0Dec. 2020

Dec. 2021

0.09

0.10

0
Dec. 12Source: Ministry of Health, Labour and Welfare; 2019/2021 Trends in Workplace

0.00

0.01

Dec. 2020

Dec. 2021

Nippon COMSYS

0.02

Dec. 2022(both in NTT Engineering Business)◆ Activities Aimed at Ensuring Quality
COMSYS Group companies have obtained ISO 9001
certification for multiple workplaces, and quality management systems are in operation to meet goals andenable continuous improvements on various themes.

11

Facility Accidents and Human-Initiated Failures

0.24

0.79

0.20

0.20

ty concerns are found, we promptly offer corrective
guidance. Furthermore, if there are recommendable
practices aimed at enhancing safety quality, we horizontally disseminate them nationwide.
Additionally, the Safety and Quality Management
Division of the Tokyo Head Office provides support
to maintain the skills of the department in charge ofself-checks and to deal with cases where the area of
responsibility is wide. We strive to ensure quality by
constantly sharing and discussing results and issues sothat this initiative does not become a mere formality.

◆ Information Security and Personal Information Protection

The COMSYS Group is committed to its efforts toeliminate workplace accidents. Both the work-related
accident frequency rate*1 and the work-related accident severity rate*2 at supervisory business company
Nippon COMSYS are below the industry averages. To
ensure that tragic accidents are not repeated, we endeavor to rigorously analyze the causes of accidents
and implement measures to prevent recurrence.

0.81

NTT Engineering Business as part of efforts to improve
quality and prevent human-initiated failures.
Nippon COMSYS, the main supervising company, hasbeen conducting self-checks on branches and organizations nationwide since FY2021. Our basic motto
for safety management is that it starts from the site.
The objective is to prevent accidents and violationsof laws and regulations and improve the safety level of the site by having an organization close to theworksite office, such as a branch office, conduct work
inspections, detect on-site issues (signs of accidents),
and reflect improvement items in the safety process(PDCA cycle) of the construction division. Taking into
consideration the tendencies and vulnerabilities ofeach organization, we prioritize inspecting sites thatpose a high risk of causing serious accidents. If safe-

Employees participate in kaizen activities and skill
competitions, construction systems have been put inplace for work process management, and photographic inspection systems have been introduced in the◆ Stance on Respect for Human Rights and Training Initiatives
COMSYS Holdings respects fundamental human rights
as a matter of basic ethics under the “CHD Compliance
Regulations.” In the course of our business, we do notdiscriminate for reasons including race, religion, creed,nationality, sex (gender identity), disability, and age.
To instill awareness about human rights in groupcompany employees, we provide human rights education in our training for new employees and in hierarchical training sessions.
To realize a healthy workplace environment, we are
currently working on formulating a new human rights
policy aimed at explicitly outlining the content of the
COMSYS Group’s compliance, such as refraining fromengaging in any form of sexual harassment or power
harassment that lacks consideration towards others,
regardless of the circumstances. We aim to announce
this policy within FY2023.

Human rights training

Promoting Safety and Quality / Respect for Human Rights

12Cultivating Human Resources◆ Basic Approach to Human Resources
The COMSYS Group’s greatest management resource
is its people. The Group’s business could not exist
without engineers who have national certifications
and advanced knowledge and experience, and thestaff who support them. Amid drastic changes in theenvironment surrounding the telecommunications industry, securing, training, and utilizing human resources who can respond to these changes in the businessenvironment is an extremely important management
theme. In Japanese society, however, where the labor
shortage is a growing concern, it is becoming increasingly difficult to secure outstanding labor. For this reason, the COMSYS Group is strengthening recruitmentof both new graduates and mid-career hires, making
optimum use of human resources by increasing theflexibility of staff within the Group. In addition, we are
actively promoting diversity and undertaking workstyle innovations with a view toward creating an attractive workplace environment, so that we are able
to recruit diverse and outstanding individuals.

Our training policies are designed to foster individuals who can respond to new business environments;
this includes level-specific training with a focus ondeveloping management skills, “multi-skilling” of engineers, and implementing various systems to support
employees in acquiring certifications. As the COMSYSGroup’s business domains expand, in addition to project management as a primary construction contractor,
our work demands comprehensive management skills.
Meanwhile, on the front lines, as telecommunications
carriers gradually reduce their capital investments andundergo a full scale shift toward outsourcing, including maintenance and operations, the key to improving
productivity will be “multi-skilling” that is not limited byconventional frameworks.
At the same time, we have created a “CHD humanresource training platform” with the goal of fostering
talent that can undertake the business operations of
the future, to provide human resource training througha Groupwide operational system.

◆ Recruiting Plan
In April 2023, the COMSYS Group’s nine companies(eight supervisory business companies and COMSYS
Shared Services Corporation) hired a total of 218 new
graduate employees, mostly in the Group’s core businesses: The Carrier-Related Business, the IT Solutions
Business, and the Social System-Related Business. In
terms of hiring activities for new employees entering
the company in April 2024, we are planning to hire approximately 250 new employees at nine companies,
most of whom will be engineers required to strengthen
the Group’s businesses. In order to secure a broader
range of diverse and outstanding personnel, rather thanhiring all new graduates at once, as has been the common practice in Japan, we will continue hiring throughthe year; for example, targeting students returning toJapan from overseas studies in the summer onward, as
well as mid-career hires and recent graduates with one
to three years of work experience.
In particular, when hiring new graduates, we strive toprevent employment mismatches, which is the biggest
factor in early turnover, by ensuring that employees
fully understand job duties at the hiring stage. The
turnover rate for new graduates within three years of
joining the company is 10.7%, while the turnover rate
for new graduates (university graduates) in the general
workforce is 31.5% (Ministry of Health, Labor and Welfare data on job turnover: March 2019 graduates), so
the COMSYS Group has a high retention rate.

◆ Mid-career Hiring and Re-employment System
The COMSYS Group actively undertakes mid-career
hiring of qualified and experienced candidates who
can contribute to business immediately, in order tomake up for the labor shortfall resulting from businessexpansion. In order to respond to technology innovations and the telecommunications technologies, which
are evolving at a dizzying pace, each year, we hire acertain number of skilled engineers with knowledge
and experience in advanced and specialized technolo-gies, as well as managers with managerial experience.
We also conduct re-hiring after retirement, to best utilize the experience and expertise of senior employees.
To maintain and increase corporate competitivenessin the future as well, we will strive to make maximum
use of in-house manpower, including rehired employees, increase the motivation to work even after retirement age, and form an in-house environment where all
employees can actively participate.

◆ Promoting Diversity
The COMSYS Group promotes diversity based on the
belief that a diverse workforce is essential to continued growth. Specifically, we feel that we can (1) Discover skilled labor; (2) Cultivate a corporate culture inwhich all employees can generate novel ideas regardless of their background or gender; and (3) Respond tothe changes and needs of society.

13

Because the construction industry has typically
been a male-centric society, the COMSYS Group first
focused on promoting active participation by women; for example: (1) Reforms in the corporate culture
through president’s messages and training (employee
awareness reforms regarding diversity); (2) Supporting
career development for women (strengthening recruit-

ing, career training for female employees, and training
for managers with female subordinates); and (3) Promoting work/life balance (providing support in childraising, including short working hours and encouraging
male employees to take childcare leave [in line withchanges to the law, in April 2022 the COMSYS Groupmade adjustments to our own program and how it
operates; for example, supervisors are required tohave individual interviews with employees who havenotified the company about their own childbearingor that of their spouses]; establishing satellite offices
for teleworking; and introducing flex-time and working
from home systems). As a result of these activities, anenvironment has been put in place to enable diverse
workstyles, and employees better understand themeaning of diversity within the company.
Issues still remain, however; for example, in the low
number of female hires, and the low ratio of female
managers. Regarding the hiring of employees, we aretaking measures to expand the scope of hiring regardless of academic field, recruiting outstanding students
in the humanities as well. In this way, we are increasing the ratio of female new graduate hires (21.6% of
new graduates in April 2023, target is 30% by March
2025), at the same time actively recruiting women in
midcareer as well, in order to increase the ratio overall. In terms of appointing female managers as well, we
will increase the number of female managerial candidates and put in place appropriate human resource
training and workplace environments to increase theratio of women in managerial positions (2.5% as of
May 2023).

We are also promoting the hiring of non-Japaneseemployees; 10 have already been hired at the ninesupervisory business companies (as of May 2023). In
terms of hiring persons with disabilities, we take into
consideration the status of each person’s disability to
put in place workplace environments where all employees can participate actively and energetically, forexample by collaborating with companies that support workers with disabilities (2.5% in the fiscal year
ended March 31, 2023).
As a result of efforts to raise awareness of the system and encourage male employees to take childcare
leave, Nippon COMSYS significantly increased the rateof taking childcare leave to 83% in FY2022.
We will strive to be a Group in which diverse employees can be actively involved, regardless of gender,
life stage, disabilities, or nationality.
Ratio of Female New Graduate Hires
（％）

30

20

18.9

18.7

18.7

FY2018FY2019FY202020.6

21.6

FY2021

FY2022

100◆ Workstyle Innovations
The COMSYS Group is promoting workstyle innovations as part of efforts to achieve diverse workstyles
and increase productivity. Up to now, we have institutionalized telework and flextime systems, andintroduced an area employee system.
We are also reducing total annual working hours
from the perspective of health management for employees and reducing labor costs, and a variety ofother initiatives are being rolled out at all Group en-tities. Specifically, we are taking steps to optimize
work hours. For example, we are using robotics
process automation (RPA) robots to automate routine tasks and reduce working hours. Additionally,in anticipation of the March 2024 expiration of the
exemption on overtime limits in the constructionindustry, we are strengthening labor management,
including using visualization tools and systems tocheck work hours.

◆ Strategic HR Training and Retention
The telecommunications industry is experiencing rapid technological innovation, and by actively working totrain and retain engineers, our goal is to evolve into a
company that can provide a one-stop response to thevaried needs of our customers. To prevent accidents
and improve quality, these training initiatives include
strengthening the training for workplace representatives and promoting technical training through participation in skills competitions; offering skills training toemployees, including partner companies, at our own
educational and training facilities; and encouraging
senior employees to share their expert skills with
their juniors. We are also considering expanding per-formance-based remuneration to increase employee
motivation. In addition to distributing bonuses thatare tied into individual performance evaluations, we
are working to increase motivation by introducing incentives linked to team performance, and teams that
demonstrate particularly notable results receive acommendation in the form of the President’s Award.
We recognize that in the future it may be necessary toestablish a more involved incentive structure, especially to retain the outstanding talent needed to pursue
the expansion of the IT Solutions Business and the Social System-Related Business.

Cultivating Human Resources

14

Corporate Governance◆ Key Corporate Governance Initiatives(As of June 29, 2023)◆ Board of Directors

Share of Outside Directors
Increased to 40%
At the Ordinary General Meeting of Shareholders heldon June 29, 2023, the Board of Directors was restructured to foster strategic and agile decision-making.
This involved reducing the number of internal directors (excluding directors who are Audit and Supervisory Committee members) whose terms were expiring by three, from eight to five, with the appointmentof five internal directors. Additionally, among the six
directors (including five outside directors) serving as
Audit and Supervisory Committee members whoseterms were expiring, the number was reduced by one.
Consequently, five directors (including four outside directors) were appointed to the committee. As a result,the share of outside directors increased from 36% to40%, as the number of outside directors increased tofour out of a total of 10 directors.

◆ Basic Approach to Corporate Governance
The COMSYS Group supports the foundations of community life through the execution of its core business—the construction of telecommunications and social infrastructures. Through the growing Renewable Energy
and IT Solutions businesses as well, we contribute to
reducing environmental impact and improving productivity in both private- and public-sector services. As
such, the COMSYS Group’s business in and of itself
contributes to and plays an important role in society,but we are also aware of the great responsibility thatcomes with this role. To continue to earn the trust

Number of owned shares on March 31, 2023

of, and be selected by, a variety of stakeholders in
the future—including customers, employees, business
partners, and regional society—we must ensure appropriate management in accordance with laws andregulations, and at the same time make optimum management judgments that lead to increased corporate
value. We are aware that strengthening corporate governance, which is the foundation for “legal” and“appropriate” management, is of paramount importance for
the COMSYS Group.

Takashi Kagaya

Hiroshi Tanabe

President,
Representative Director

Vice President,
Representative Director

Number of the Company’s
shares owned 42,400
Tenure as Director 8 years
Attendance at Board of Directors Meetings 9/9 (100%)

Number of the Company’s
shares owned 14,100
Tenure as Director –Attendance at Board of
Directors Meetings –◆ Corporate Governance Structure

Hideyuki Noike

Kunihiko Uchide

Toru Mashimo

Atsushi Yasunaga

Director(In charge of Business Strategy— Carrier Business)

Director(In charge of Business Strategy— Non-Carrier Business)

Director(General Manager of Finance& Accounting Department andGeneral Manager of Corporate
Planning Department)

Director(Full Time Audit and Supervisory Committee Member)

Number of the Company’s
shares owned 9,000
Tenure as Director 3 years
Attendance at Board of Directors Meetings 9/9 (100%)

Number of the Company’s
shares owned 9,300
Tenure as Director 3 years
Attendance at Board of Directors Meetings 9/9 (100%)

Number of the Company’s
shares owned 3,000
Tenure as Director –Attendance at Board of
Directors Meetings –Number of the Company’s
shares owned 4,800
Tenure as Director 2 years
Attendance at Board of Directors Meetings 9/9 (100%)
Attendance at Audit and Supervisory Committee meetings
11/11 (100%)

Accounting auditors

In June 2017, the COMSYS Group made a transition to aa Nomination and Remuneration Advisory Committee
company with an Audit and Supervisory Committee, tothat includes outside directors, as an advisory function
strengthen transparency and accountability in the comfor the Board of Directors, to guarantee transparency
pany’s management. The COMSYS Group’s Board of Diin nomination and remuneration decision processes.
rectors comprises 10 directors, five of whom are on the
Audit and Supervisory Committee, which includes four
Corporate Governance Structure
outside directors (as of June 29, 2023).
The Audit and Supervisory Committee audits the execution of operations by directors
General Meeting of Shareholders
not only from the perspective of legal compliAppointment/dismissal Appointment/dismissal
Appointment/dismissal
ance, but also from the perspective of approDirectors
Directors(Audit and Supervisory
priateness for corporate management. This
Committee members)committee also has the authority to express
Comprising members
Comprising members / participation
opinions on matters such as the appointment,
Collaboration
Consultations
Nomination anddismissal, and compensation of directors
Audit and Supervisory
Directors
Remuneration Advisory
Committee
Auditing /ReportingCommittee
who are not a part of the committee. The Ausupervision
Auditing / supervision
dit and Supervisory Committee comprises five
Collaboration
Appointment/dismissal and supervision
directors, four of whom are outside directors
whose status as independent directors has
Instructions, reporting
Internal Control
President(management meetings)
been notified to the Tokyo Stock Exchange,
Auditing Department
Instructions,to guarantee more objective direction andreportingInternal
auditsmonitoring of management. Through theThorough disseminationtransition to a company with an Audit andBusiness execution
Committees
of information
divisionsSupervisory Committee, we have established
Overview of Governance Structures

Management,
monitoring

Board of Directors
ChairmanPresident and Representative Director

Number of members (Tenure: 1 or 2 years)

10

Outside directors (Independent directors)

4（4）

Audit and Supervisory Committee
Chairman
Number of members
Full-time Committee members

In-house Director
5 (1 In-house director + 4 outside directors)
1(As of June 29, 2023)

15

Accounting
auditsInternal audits
reporting

Reviews /reporting

COMSYS Group
Nippon COMSYSGroup

SANWA COMSYSEngineeringGroup

SYSKEN GroupTOSYS Group

Hokuriku
Denwa Kouji GroupTSUKEN GroupCOMSYSJOHO SYSTEM GroupNDS Group

COMSYS
Shared Services

Kenichi Nakatogawa

Hiroyuki Asai

Kyoko Ichikawa

Masaya Hirano

Outside Director(Audit and Supervisory Committee member)

Outside Director(Audit and Supervisory Committee member)

Outside Director(Audit and Supervisory Committee member)

Outside Director(Audit and Supervisory Committee member)

Number of the Company’s
shares owned 0
Tenure as Director 4 years
Attendance at Board of Directors Meetings 9/9 (100%)
Attendance at Audit and Supervisory Committee meetings
11/11 (100%)

Number of the Company’s
shares owned 0
Tenure as Director 2 years
Attendance at Board of Directors Meetings 9/9 (100%)
Attendance at Audit and Supervisory Committee meetings
11/11 (100%)

Number of the Company’s
shares owned 0
Tenure as Director –Attendance at Board of
Directors Meetings –Attendance at Audit andSupervisory Committee
meetings –Number of the Company’s
shares owned 0
Tenure as Director –Attendance at Board of
Directors Meetings –Attendance at Audit andSupervisory Committee
meetings –Corporate Governance16

Corporate GovernanceCorporate Governance Transformation Over TimeIn-house directors

20

16

16

Outside directors

15

15

Auditors

15

Outside auditors

14

15

12

12

12

12

12

11

11

11

10

10

0

5
2

5
2

1 3

1 3

4
2
1 2

2012

2013

2014

5

4
2
2 2

4
2
2 2

2015

2016

12

10

10

10

9

6

4

4

5

5

5

5

4

2017

2018

2019

2020

2021

2022

2023

Skills Matrix/Attendance Record (Board of Directors, Audit and Supervisory Committee)
Skill

Attendance

Facilities
DigitalNew businessconstruction &transformation(DX), Legal, risk
Businessdevelopment,
operation,technologicalmanagement
managementbusiness expansion
project management
development

HR, labor,
diversity

Finance

Sustainability

Board ofDirectors(times)Audit andSupervisory
Committee(times)In-house directors

Takashi Kagaya

●

●

●

●

●

●

9/9
（100％）−

Hiroshi Tanabe

●

●

●

●

●

●

−

−

Hideyuki Noike

●

●

●

●

9/9
（100％）−

Kunihiko Uchide

●

●

●

●

9/9
（100％）−

Toru Mashimo

●

−

−

Atsushi Yasunaga

●

●

●
●

●

Outside directors

●

●

●

●

●

Kenichi Nakatogawa●

9/9（100％） 11/11（100％）●●

Kyoko Ichikawa●●

Masaya Hirano

●

●

●

●

9/9
（100％） 11/11（100％）●

9/9（100％） 11/11（100％）

●

−

−

●

−

−

Note: Indicates areas in which each director is expected to particularly contribute.
The above skills matrix does not necessarily present the entire scope of each director’s expertise and experience.

◆ Director Remuneration
An overview of director remuneration is presented below.
●Method for determining remuneration for directors who are not members of the Audit and Supervisory Committee

17

Representative Director

50％

20％

30％

Directors who are not members of the Audit
and Supervisory Committee

60％

20％

20％

Classification

Total
remuneration

Directors(excluding Audit and Supervisory
Committee members)¥168 million¥84 million¥28 million¥55 million

１0

Directors(Audit and Supervisory
Committee members)(Outside directors)¥55 million(¥40 million)¥55 million(¥40 million)

－

－

6
（5）

Total
(Outside directors)¥224 million(¥40 million)¥140 million(¥40 million)¥28 million(－)¥55 million
(－)

16
（5）

Company with Audit and Supervisory Committee

As a result of efforts to ensure diversity on the Board of Directors, which had been an issue, a female outside director was appointed at the Ordinary General Meeting of Shareholders held in June 2023. We will continue to put forth our utmost efforts to secure
diversity in COMSYS’s Board of Directors, from the perspectives of both gender and nationality.

Hiroyuki Asai

Non-monetary remuneration(Long-term incentive compensation)

Total by type of remuneration

Initiatives to Ensure Diversity Within the Board of Directors

Name

Performance-linked
remuneration (Bonuses)●Remuneration structure for directors who are members of the Audit and Supervisory Committee／
Fixed remuneration only
Total Director Remuneration

12

Company with Board of Auditors

Fixed remuneration(Basic remuneration)●Method for determining remuneration for directors who are members of the Audit and Supervisory Committee／
Decided by the Audit and Supervisory Committee, within limits approved by the shareholders

1010●Remuneration structure for directors who are not members of the Audit and Supervisory Committee

Nomination and Remuneration
Advisory Committee→

Board of Directors

Deliberation

Presentation

Decision

Fixed remuneration(Basic remuneration)

Performance-linked Long-term incentive compensation(Restricted stock compensation andremuneration
ordinary stock options)(Bonuses)

Number of
eligible directors

Notes:
1. The above table includes one director (not an Audit and Supervisory Committee member) who retired as of March 31, 2021, and one director (also not an Audit and Supervisory
Committee member) who retired at the conclusion of the 19th Ordinary General Meeting of Shareholders held on June 29, 2022.
2. The amounts of compensation tied to performance for the above directors (excluding Audit and Supervisory Committee members) include expected amounts of payments for
director bonuses for the business year in question.
3. The long-term incentive compensation amounts for the above directors (excluding Audit and Supervisory Committee members) include the amount recorded as expenses in thefiscal year in connection with the restricted stock compensation plan, and the amount recorded as expenses during the fiscal year related to share subscription rights granted
as stock options.

◆ Cross-Shareholdings Policy
In order to increase the Group’s corporate value froma medium- to long-term perspective, the COMSYSGroup holds shares in cases where it deems that suchownership offers advantages in terms of maintaining and strengthening trust-based relationships withcustomers and business partners, as well as throughcollaboration and expanding business transactions.
Shares owned for the purpose of cross-shareholding
are inspected by the Board of Directors to verify thesignificance of ownership for each individual stock,and to ensure that profits and risks accompanying
ownership are in line with capital costs.
In the fiscal year ended March 31, 2023, the Boardof Directors held a meeting on March 24, 2023, verified these holdings as of December 31, 2022, and approved a policy to proceed with reducing or eliminating holdings that have been deemed to be no longer
meaningful or appropriate.

◆ Evaluation of the Board of Directors’ Effectiveness
COMSYS conducts a survey of our board members as
one means of evaluating the effectiveness of the Boardof Directors. In the fiscal year ended March 31, 2023,
this survey for the evaluation of the Board of Director’s
effectiveness covered the topics described below.
【Survey topics:】●Ensuring appropriate composition and diversity, including the size of and overall balance within the
Board of Directors●Ensuring effective deliberations, including appropriate risk-taking in management decisions●Support for the directors, such as ensuring that there
is a framework for liaising with management, the independent auditor, and internal audit departments
The results of the analysis of the survey were referredto the Board of Directors, and based on the analysisof the current situation, the effectiveness of the COMSYS Board of Directors was confirmed. Meetings arealso held to exchange views, in order to strengthen
the functioning of the Board of Directors.

Corporate Governance18

Corporate GovernanceCompliance Promotion Structure◆ Maintaining Internal Control Systems
Basic Policies for Internal Controls
COMSYS created basic policies for internal controls
at a meeting of the Board of Directors in May 2006.
At a meeting of the Board of Directors in April 2015,
it decided on partial revisions to the details of thosebasic policies, in keeping with amendments to theCompanies Act and the Ordinance for Enforcementof the Companies Act. At a meeting of the Board of
Directors in June 2017, it decided on further partial
revisions to the details of the basic policies, in keepingwith the transition to a Company with an Audit andSupervisory Committee. Based on these policies, we
strive to maintain a structure that ensures appropriate
internal control operations, such as strengthening corporate governance, maintaining compliant structures,and strengthening risk management.
Specific details related to the structure of internal
control systems and an outline of their operational
status can be found on the COMSYS Holdings website (https://www.comsys-hd.co.jp/company/outline/
outline4.html) (in Japanese). These internal control
systems are decided and created to be in compliancewith COMSYS Holdings, and improvements are madeas deemed necessary in keeping with the subsequent
implementation and monitoring of those systems. Auditing methods are recognized as being appropriate,
covering the effectiveness of operations and the utility of system maintenance status in accordance withthe “Auditing standards related to internal control systems” created by the Audit and Supervisory Committee in conformance with auditing standards stipulatedby the Japan Audit & Supervisory Board Members Association.
Status of Audit and Supervisory Committee Meetings
As a rule, meetings of the Audit and Supervisory Committee are held on the same day as meetings of theBoard of Directors. Resolution items at Audit and Supervisory Committee meetings include: The creation ofauditing plans and auditing reports; deciding opinions
on the naming and remuneration of directors who are
not members of the Audit and Supervisory Committee;
the appointment and dismissal of accounting auditors;
and agreement on auditor remuneration. Deliberation
items include remuneration amounts for Audit and Supervisory Committee members. Report items include
information sharing on important meetings attended
by full-time Audit and Supervisory Committee members (e.g., management meetings and COMSYS Groupauditor contact meetings), and the results of site audits by full-time Audit and Supervisory Committee
members. In the fiscal year ended March 31, 2023,
there were five outside Audit and Supervisory Committee members. These outside Audit and Supervisory
Committee members have attended all nine meetingsof the Board of Directors and all 11 Audit and Supervisory Committee meetings, making statements fromthe perspective and position of an outside Audit andSupervisory Committee member.
Full-time auditors at supervisory business companies (eight auditors at eight main companies) regularly
hold COMSYS Group Full-time Auditor Contact Meetings (five in the fiscal year ended March 31, 2023, twoof which were attended by CHD Full-time Audit andSupervisory Committee members and full-time auditors from seven supervisory business companies, andthree of which were attended by CHD Full-time Audit

19◆ Basic Compliance Policies
and Supervisory Committee members and full-time
auditors from eight supervisory business companies)
to report on management conditions for the COMSYSGroup as a whole, and also request reports, mutually
exchange opinions, and share information on management conditions and internal controls at the supervisory business companies. Twice each year, they also receive explanations on all aspects of management fromthe presidents of the supervisory business companies.
The Group’s Internal Controls
As part of audits targeting “Status of execution of
duty to build internal controls for directors,” the Audit and Supervisory Committee members are involvedin checking and expressing opinions on the results ofinternal control audits based on the Financial Instruments and Exchange Act. The scope of internal control
evaluations is decided through deliberations with accounting auditors. During the fiscal year ended March
31, 2023, out of a total of 73 consolidated subsidiaries and COMSYS Holdings, evaluations covered eightsupervisory business companies and 11 subsidiaries.
Furthermore, to ensure the appropriateness of the
COMSYS Group’s operations, 13 members of the
COMSYS Holdings Internal Auditing Office conduct internal audits for the Group as a whole.
Full-time staff(Division Manager; Seconded employees): 13
Concurrent duties as heads of supervisory businesscompany organizations: 9
Total: 22
Internal Controls Related to Financial Reporting
The Audit and Supervisory Committee receives explanations from the company and accounting auditors
regarding audit results. Consequently, up to now,there have been no reports of “serious omissions indisclosure,” and we recognize that internal controls
related to financial reporting are effective. The Audit
and Supervisory Committee also receives reports fromaccounting auditors on the status and progress of internal control audits in accordance with the Financial
Instruments and Exchange Act. In this case as well,there have been no reports of “serious omissions indisclosure,” and we recognize that internal controls
based on the Financial Instruments and Exchange Act
are effective.
Internal Audits
The COMSYS internal audit organization comprises
the Internal Auditing Office and the Internal Control
Office, which have been established as internal organizations within the Internal Control Auditing Department. These offices are staffed by 22 and 3 persons,respectively, as of June 29, 2023.
The Internal Auditing Office formulates internal audit
policies based on policy set by top management, andit strives to minimize various business risks and contribute to the quality of the company by conducting
internal audits of COMSYS and the COMSYS Group
companies to ensure that business is executed in a
lawful and appropriate manner.
The Internal Control Office formulates internal control policies related to financial reporting, and it provides guidance on, and evaluates the effectiveness of,internal controls at COMSYS and the COMSYS Group
companies.

The COMSYS Group positions the establishment oflegal compliance and other areas of corporate ethics as important management issues. Based on the“Compliance Program” created in January 2004, wehave instituted the “COMSYS Group Code of Conduct”
describing the conduct to be demonstrated by eachand every director and employee. Compliance Committee meetings are also held on a regular basis.
The Code of Conduct clearly lays out guidelines forfair and transparent business transactions placing toppriority on compliance with laws and social norms,
prohibiting bribery and relationships with anti-social
forces, emphasizing respect for individual humanrights, and abolishing discrimination, and we have apolicy that strictly prohibits harassment in any form.
The Compliance Committee, which is chaired by
the president of COMSYS Holdings, and is comprisedof members selected from COMSYS Holdings andsupervisory business companies, and all membersof the Audit and Supervisory Committee. It oversees
and deliberates on compliance structures for COMSYS
Holdings Corporation and the COMSYS Group, in aneffort to improve and cultivate a “compliance mindset”
throughout the entire COMSYS Group. Specifically,
cases arising at supervisory business companies and

COMSYS Holdings
Management meetings
Instructions

Reporting / suggestion*Important cases

Compliance Committee
Chairman: President of COMSYS HoldingsGroupwide notiﬁcation

Reporting on activities

Compliance Committees at supervisory business companies

Groupwide notiﬁcationand guidance

Reporting on activities

Groupwide notiﬁcationand guidance

Reporting on activities

Supervisory business companies
Business companies【Outline of Compliance Committee Meetings】

Main items reviewed:
Compliance issues at Group companies; recurrence prevention
measures; status of educational activities
Status of recent meetings:
Four meetings held during the fiscal year ended March 31, 2023

incidents reported to consultation contact points arereviewed by the Compliance Committee at the company in question, and the results of those reviews arethen reported to the Compliance Committee at COMSYS Holdings. All Group companies are notified andthoroughly briefed regarding important cases, as partof Group-wide measures to prevent recurrence.

◆ Internal Reporting System
The COMSYS Group positions compliance with theWhistle- Blower Protection Act as an important partof building the Internal Control System, and has enacted Whistle-Blower Protection regulations that
stipulate strict compliance with the intent of the law,and rules for submitting and receiving whistleblower
reports within the COMSYS Group. Internal reporting
systems are one effective way of preventing scandals

in the company, and we believe that by identifying andweeding out the “seeds of problems” early on fromamong many consultations and reports, we are able
to prevent serious scandals before they occur. The total number of internal reports, including consultations,for the Group as a whole was 87 in the fiscal year ended March 31, 2023 (16 violations) and 66 in the fiscal
year ended March 31, 2022 (19 violations).

◆ Prevention of Bribery
Bribery and corruption are in opposition to the business of the COMSYS Group, which contributes to society and plays an important role in society. Such behaviors are strictly prohibited and controlled, regardlessof the business situation. We have an ironclad rulethat under no circumstances will we engage in bidding
collusion or other corrupt practices in Japan. In glob-

al business, because it is essential to enter contracts
with subcontractors in various countries, there could
be an increased risk of bribery or corruption in contract relationships, for example in emerging countries,
but because our business activities are currently centered in Japan, in our view, there is little risk of bribery
incidents involving the COMSYS Group.

◆ Prevention of Collusive Bidding
As part of measures to prevent the recurrence of corruption and scandal, we are working to strengthen
compliance through systematic training for all employees. To prevent the recurrence of bidding collusionin particular, we hold seminars every year, mainly for
managers and employees handling government agencies, welcoming experts as instructors, to ensure compliance with the Antimonopoly Law and the Construc-tion Business Act.
We hold training sessions where the Group’s newly appointed executive officers receive guidance fromlawyers and CPAs, and we have introduced a compliance curriculum into the level-specific training for newly appointed managers, middle level employees, andnew employees to prevent corruption and scandals.

Corporate Governance20Non-Financial Data

“The world of cows is beautiful”
Unit

FY2018FY2019GHG emissions Scope1

kt-CO2

−

−

90*1

95*1

83,663

GHG emissions Scope2

kt-CO2−−

1

1

16,533

GHG emissions Scope3

kt-CO2

−

−

1,868

1,812

1,730,392

Energy consumption

GJ

−

−

−

121,217*2

1,575,198

Renewable energy utilization

％

−

−

−

Water consumptiont−Industrial waste emissionst−Green purchasing rate%−

(9 main companies)

FY2020

FY2021

17*

FY2022

17*

Environment

0.6

2.1

−

3

44,210*113,284

98,321−

97,386*4

196,955

127,627

−

−

87

87

Number of employees (Consolidated)

16,70016,844

17,066

17,52017,512

Number of employees

−

−

−

8,284

8,213

Of which, Male

−

−

−

7,413

7,333

Of which, Female

−

−

−

871

880

−

−

−

260

218

−

−

−

209

171

Number of new graduate hires
Of which, Male
Of which, Female

−

−

−

51

47

−

−

−

2,064

2,011

Of which, Male

−

−

−

1,741

1,709

Of which, Female

−

−

−

323

302

−

−

−

2,123

2,091

Of which, Male

−

−

−

2,073

2,043

Of which, Female

−

−

−

50

48

Of which, number of mid-career hires

−

−

−

−

−

−

Number of mid-career hires (number of hires in each fiscal year)

Number of employees in management positions

SocialAverage years of service

708
−

670
15.2

New graduate turnover in first three years

％

6.4

6.3

5.2

6.4

10.7

Ratio of new female graduates hired

％

18.9

18.7

18.7

20.6

21.6

Ratio of women in management positions

％

1.4

1.4

2.1

2.4

2.5

Gender wage difference (ratio of women's wages to men's wages)％

Ratio of employees with disabilities％

Number of non-Japanese employees
Number of retirees rehired
Investment in human resources per employee (full-time employees, training costs)

Tens of thousandof Yen

−

−

−

−

71.0
2.1

2.5

−

−

−

9

10

−

−

−

129

113

2.0

2.1

2.1

−

−

−

−

7.9

Training hours per employee (full-time employees)

−

−

−

−

20.5

Average annual overtime hours worked (full-time employees)

−

−

−

−

27.2

Employee awareness survey implementation rate (Nippon COMSYS only)％−

Average number of days of paid leave taken per year

−

12.6

13.0

100

100

100

13.2

13.9

14.7

Percentage of male employees taking childcare leave*5

％

−

−

−

−

83

Percentage of female employees taking childcare leave*

％

−

−

−

−

100

−

−

−

−

5

Number of employees taking nursing care leave
Internal reporting

Cases

Total number of directors
Governance

Of which, outside directors
Ratio of outside directors％

Of which, number of female directors
Percentage of female directors％

The artist KURUMI ABE signed an employment contract as part of the diversity and inclusion (D&I) promoted
by NDS Co., Ltd. This takes advantage of a system for hiring artists with disabilities (a form of work-from-homeemployment in which artists sign an employment contract with the company and conduct creative activities
at home, and report and meet with the company as appropriate), which has been realized through collaboration between Hello Work, the Aichi Prefectural Government, and welfare and art experts. The COMSYS Group
promotes the creation of companies and workplaces where diverse human resources, regardless of nationality
or disability, can work together, leveraging their individuality and talents, and demonstrate their full potential.

3

78

97

83

66

87

15

15

15

14

10*6

5

5

5

5

4*6

33.3

33.3

33.3

35.7

40.0*6

0

0

0

0

1*6

0.0

0.0

0.0

0.0

10.0*6[KURUMI ABE’s award history]
2015
2016
2018
2018
2019
2021
2022

Aichi Art Brut Exhibition Excellence Award
Aichi Art Brut Exhibition Excellence Award
17th Kirakiratto Art Contest Excellence Award
78th National Educational Art Exhibition Special Mention
12th Fureai Art Exhibition Nagoya Mayor’s Award
13th Fureai Art Exhibition Aichi Prefectural Governor’s Award
14th Fureai Art Exhibition Nagoya Holding Hands Inclusion Association Chairman’s Award*1 Revised due to improved calculation accuracy *2 Figures for FY2021 are for Nippon COMSYS only. *3 Figures for FY2020 are for Nippon COMSYS only. *4 Figures for FY2020
are for only the six major companies excluding TOSYS Corporation, COMSYS JOHO SYSTEM, COMSYS Shared Services Corporation, and consolidated subsidiaries. *5 Only forchildcare leave, which is a national system. *6 Appointed at the regular general meeting of shareholders held on June 29, 2023

21

Non-Financial Data / Share Data

22