Obayashi Corporation Statement on Modern Slavery and Human Trafficking (FY2023)

Obayashi Corporation (hereafter, the “Company”) is releasing the following statement about
initiatives to prevent slavery and human trafficking in the Obayashi Group (hereafter, the“Group”) and in our supply chain in FY2023 (April 1, 2023 to March 31, 2024), based on
Chapter 6, Section 54 of the UK Government’s Modern Slavery Act 2015 and Modern Slavery
Act 2018 of Australia.
“Slavery” and “human trafficking” are defined in both Acts. However, because the definitions
may differ depending on local circumstances, we are disclosing our initiatives in preventing all
forms of modern slavery and our compliance with related laws and regulations and international
norms in this statement.
Since 2019, the Company has published the statement annually based on a comprehensive
review with the support of external experts provided under an advisory contract regarding due
diligence on modern slavery and human trafficking in the business and supply chain.
1. The Organizational Structure, Business, and Supply Chain
1-1. Obayashi Group Business and Structure
The Company is a general construction contractor that was founded in 1892 and has its
head office in Tokyo. We have 118 subsidiaries, 28 affiliated companies, and 16,986
employees at the consolidated level (as of March 31, 2024). We operate a construction
business, real estate development business, green energy business, and businesses in new
areas such as PPP, etc. in 16 countries worldwide, mainly in Japan, North America, andAsia. The group has been executing due diligence of the entire group. The Company
established Human Rights Expert Committee chaired by the executive officer responsible
for human resources, to take initiatives to resolve human rights issues and to raiseawareness of human rights cross-departmentally with the departments responsible for
Human Resources in the companies throughout the Group.
The Group operates its business in the following countries and regions:U.S., Canada, Singapore, Malaysia, Thailand, Myanmar, Indonesia, Vietnam, Cambodia,
Taiwan, Bangladesh, UK, United Arab Emirates, Qatar, New Zealand, and Australia
Obayashi has a Europe Office and a local Group company named OBAYASHIPROPERTIES UK Limited (hereafter, “OPUK”) (established in June 2020) in London, in1

the UK, which operates a real estate rental and development business mainly focusing on
office buildings. We have an Australia Office in Sydney, Australia, which operates aconstruction business. The Group’s total consolidated net sales were 2.3 trillion yen in
FY2023. The UK and Australia account for roughly 0.20% and 0.10% of total consolidated
net sales, respectively. The total number of Group employees at the consolidated level
include four employees in the UK and four employees in Australia.
See the following website links for a profile of the Company and its businesses:
Company profile: https://www.obayashi.co.jp/en/company/
Office locations: https://www.obayashi.co.jp/en/company/group.html

1-2. Overview of the Supply Chain
The Group recognizes all business partners involved in the supply chains for the Group’s
entire business as suppliers, and regards each of them as its important stakeholders.
Suppliers for the construction business, the main business of the Group, are divided into
two main categories: labor subcontractors and suppliers of materials and equipment.
In Japan, we have recognized about 8,600 suppliers for our construction business, andamong them we have contracted Basic Contract with 3,200 suppliers. Basic Contract is tobe agreed with continuous suppliers, and it regulates common terms and conditions for all
the transactions. Also, we have established an organization called Obayashi Rin-yu-kai,with those who has been in cooperative relationships with the Company on technique,quality, and safety matters, which consists of approximately 1,200 main suppliers.
In FY2023, the value of transactions with those who contracted Basic Contract accounted
for 79%, and with those who are members of the Obayashi Rin-yu-kai accounted for 50%
of all supplier transactions with the Company in the construction business in Japan.
See the following website link for profile of the Obayashi Rin-yu-kai:
https://www.rinyu-kai.com/index.html

2. Policy on Slavery and Human Trafficking
2-1. Basic Principles
The “Obayashi Basic Principles,” which consist of the Obayashi Philosophy, Obayashi
Code of Conduct, and Obayashi Three Pledges, specify contributing to the realization of asustainable society. These principles are shared with and implemented by all officers andemployees in the Group. We believe that practicing our basic principles is the very essenceof conducting our corporate activities. Based on this belief, we have clearly specified oursocial mission and responsibilities and are implementing many sustainability-related
initiatives aimed at fulfilling CSR (corporate social responsibility) so that we will continue
to be a company that is trusted by all of our stakeholders.
2We have positioned respect for human rights as an important issue in fulfilling ourcorporate social responsibilities. The Obayashi Philosophy states that we “value each
person with a stake in our business.” The Obayashi Code of Conduct specifies theguidelines for putting the Corporate Philosophy into practice: “Value every one of ourassociates,” “Build stronger mutual trust with suppliers,” “Build good relationships with
communities,” and “Ensure strict adherence to corporate ethics.”
See the following website link for further information on the Obayashi Basic Principles:
https://www.obayashi.co.jp/en/company/philosophy.html

2-2. Human Rights Policy
The Group has set forth the Obayashi Group Human Rights Policy in accordance with the
Universal Declaration of Human Rights. We support the ILO International Labor
Standards and other international norms, and have specified the policy of respecting thehuman rights of all officers and employees and all people associated with our business. The
Obayashi Group Human Rights Policy declares the complete prohibition of any form ofchild labor, forced labor, or human trafficking and infringement of the human rights offoreign workers and others.
See the following website link for further information on the Obayashi Statement on Human Rights:
https://www.obayashi.co.jp/en/sustainability/employee.html#section1

2-3. Obayashi Health and Safety Principles and Policies
The Group has set forth the Obayashi Health and Safety Principles and Policies based on
its belief that ensuring the safety and health of all workers at construction sites in its main
construction business is of the utmost importance.
See the following website link for further information on the Obayashi Health and Safety Policies:
https://www.obayashi.co.jp/en/sustainability/safeenv.html#section1

2-4. Obayashi Group CSR Procurement Policy
The Group established the Obayashi Group CSR Procurement Policy to specify the actions
aimed at realizing a sustainable society described in the Obayashi Basic Principles. It
includes compliance with laws and regulations, respect for human rights, assurance ofsafety and health, ensuring quality, and consideration for the environment. The Basic
Policy on CSR Procurement Initiatives specifies items that the Group officers andemployees need to comply with in promoting CSR procurement.
The CSR Procurement Guidelines prescribe items that the Group expects its suppliers to3

implement and to make sure that everyone in the suppliers’ own supply chains understand,in line with the Basic Policy on CSR Procurement Initiatives. Specific guidelines state that
suppliers will “not discriminate . . . nor engage in harassment, or other activities that
infringe upon human rights,” “not engage in or permit misconduct such as the use of forcedlabor or child labor,” “ensure equal employment opportunity, practice appropriate labor
management, pay appropriate wages, and maintain and improve working environments sothey are healthy and easy to work in,” “guarantee freedom of association and collective
bargaining rights for employees,” “strive to understand and cooperate with the humanrights due diligence performed by Obayashi Group companies,” etc.
See the following website links for further information on the Obayashi Group CSR Procurement Policy
and CSR Procurement Guidelines:
Obayashi Group CSR Procurement:
https://www.obayashi.co.jp/en/sustainability/suppliers/csr_procurement.html
Obayashi Group CSR Procurement Guidelines:
https://www.obayashi.co.jp/en/sustainability/suppliers/csr_procurement.html#section2

2-5. Participation in the United Nations Global Compact
The Group has been a signatory to the United Nations Global Compact since 2013. As amember of the Global Compact, we respect human rights and support the complete
prohibition of forced labor and child labor in all forms, based on the principles of the Global
Compact.
3. Promotion of Due Diligence on Modern Slavery and Human Trafficking in the Businessand Supply Chain
On the executive side, the Group has established the Human Rights Expert Committee,
chaired by the executive officer responsible for human resources, and the Supply Chain
Management Expert Committee, chaired by the head of the procurement division. The
committees work on human rights due diligence, strive to solve human rights issues in theGroup and its supply chain, and work to raise human rights awareness, thereby enhancing
the effectiveness of human rights due diligence. Both committees promote crossdepartmental efforts with the departments responsible for Human Resources andProcurement playing a central role and relevant departments working together.
Both committees annually review the progress of the human rights due diligence and eachsurvey results such as “CSR guideline questionnaire survey”, “supplied materials traceability
survey”, and “foreign technical trainees survey”, and if necessary, improve the measures.
The procedure for conducting human rights due diligence followed by the Group thus far is4described below.
1. Identification of Main Human Rights Issues(1) Divided the business and supply chain into the Group’s main businesses of theconstruction business, the real estate development business, and businesses in new areas,
mainly the renewable energy business, and identified the risks of each stakeholder.
(2) Consulted the reports by the governments and NGOs of each country and, with the adviceof experts, evaluated the risks identified.
(3) Specified the human rights issues to be prioritized and addressed.
The main human rights issues of stakeholders are as follows:①Child labor②Forced labor and human trafficking③Reasonable consideration of people who are subject to discrimination or in a vulnerable
position④Harassment⑤Poor work and living environments⑥Establishment of appropriate labor conditions⑦Ensuring building and structure safety⑧Infringement of the lives and health of local residents⑨Infringement of privacy rights
The human rights issues related to modern slavery and human trafficking among those listed
above are ① through ⑥.
2. Assessment of the Actual State of Salient Human Rights Issues Identified(① through ⑨, above)(1) At the Company
In FY2020, we interviewed the corporate divisions, departments, and personnel
responsible in the Company. These interviews revealed that the Group does not employ
workers of an age considered to be child labor in Japan or foreign technical trainees basedon Japanese laws (hereafter, “foreign technical trainees”), and there is little risk of modern
slavery. However, we still need to continue investigations into the risk of humantrafficking of foreign technical trainees, forced labor, child labor, and other types of laborthat could potentially be considered modern slavery in regard to workers employed bysuppliers to the Group.
In FY2023, we conducted questionnaire and interview surveys with main business5

departments (Civil Engineering, Building Construction, Real Estate) concerning theirinitiatives addressing respect for human rights. We also conducted site investigation on
construction site. Throughout the survey we confirm that there is currently no obvious
risk of human rights violation. Although, we will continuously conduct the surveys toconfirm there is no legal violations or human rights violations by checking multi-lingual
notices and papers are prepared in construction sites as the consideration for foreign
workers, each supplier is correctly supervising the total working hours, working
environments and conditions of foreign workers.
(2) At the Group Companies in JapanIn FY2021, we interviewed six major Group companies: Obayashi Road Corporation,
Obayashi Facilities Corporation, Oak Setsubi Corporation, Naigai Technos Corporation,
Obayashi-Shinseiwa Real Estate Corporation, and Oak Information System Corporation.
These interviews revealed that none of these companies employs workers of an age
considered to be child labor in Japan or foreign technical trainees. They also revealed thatthey hire foreign workers in accordance with the same recruitment procedures as those
applicable to Japanese counterparts without resorting to intermediaries in their countriesof origin. These findings suggest that there is little risk of modern slavery.
In FY2023, we interviewed staff responsible for recruitment and foreign workers at
Obayashi Road Corporation and Obayashi Facilities Corporation, and we confirmed that
there are currently no obvious major human issues. On the other hand, in the medium- tolong-term, we will make efforts to create a more pleasant workplace environment by, forexample, developing a system to prevent discrimination and harassment and providing
employment regulations and other rules in multiple languages currently provided only inJapanese.
(3) At the Overseas Group Companies
In FY2022, we conducted questionnaire surveys with 19 of our overseas offices andoverseas Group companies* concerning their initiatives addressing respect for humanrights. The survey results confirm that all overseas offices and overseas Group companies
are offering human rights-related training and implementing initiatives such as languagerelated arrangements for officers and employees of foreign nationality and workers of
foreign nationality who work at construction sites.
To evaluate current circumstances and identify problems, we interviewed the North
American Regional Headquarters and the Asia-Pacific Regional Headquarters of the6Company in FY2023. We confirmed that these two headquarters offer harassment
prevention training on a periodic basis, and the North American Regional Headquarters
has developed its own relief mechanism. From now on, we will make efforts to grasp
current circumstances involving group companies of the two headquarters.

*The Asia-Pacific Regional Headquarters and offices and companies under the supervision of the Headquarters:
Australia Office, Taiwan Office (Taiwan Obayashi Corporation), Cambodia Office, Bangladesh Office, Middle East
Office, Thai Obayashi Corporation Limited, Obayashi Vietnam Corporation, Obayashi Singapore Private Limited,
PT Jaya Obayashi
The North American Regional Headquarters and offices and companies under the supervision of the Headquarters:
Guam Office, J. E. Roberts-Obayashi Corporation, JS Builders LLC, Kenaidan Group Ltd., Kraemer North America
LLC, Webcor L.P., E.W. Howell Co. LLC, MWH Management Inc
Other: OPUK (Europe Office)3. Development of the Human Rights Due Diligence Roadmap
We have developed a roadmap (action plan) for human rights due diligence for FY2023
through FY2026. Based on the human rights issues identified above and the circumstances
recognized, we have developed specific measures to build implementation processes forhuman rights due diligence. We promote our initiatives for respect for human rights basedon this roadmap.

See the following website link for further information on Obayashi’s sustainability promotion framework:https://www.obayashi.co.jp/en/sustainability/#section1

4. Specific Initiatives
4-1. Occupational Safety Initiatives
In connection with “abusive working and living conditions,” one of the International
Labour Organization’s Indicators of Forced Labour, we believe that the risks of forced labor
among foreign workers at our suppliers who cannot easily leave their jobs voluntarily will
increase if there is also a poor working environment. For this reason, Obayashi Central
Health and Safety Committee chaired by the president was established for appropriate
work environments. The committee meets at least twice a year to discuss and consider basic
matters concerning health and safety, such as preventing occupational accidents,
preventing impairment of health, and maintaining and improving health.
We operate Obayashi’s Occupational Health and Safety Management System, which has
systematized methods of safety management in order to ensure implementation of the7following Health and Safety Principles and Policies at all our construction sites in Japan.
Health and Safety Principles
Ensure the health and safety of all workers at construction sites and create comfortableworkplace environments.
Health and Safety Policies① Comply with the Industrial Safety and Health Act, other relevant laws, and Obayashi
Corporation’s internal rules.
② Appropriately implement and use Obayashi’s Occupational Health and Safety
Management System.
③ Help improve independent health and safety management efforts of suppliers.
Obayashi’s Occupational Health and Safety Management System helps each organization
clearly delineate its own Health and Safety Policy. The system manages the operational
structure, plan formulation, and procedures for the entire cycle, from implementation toachievement, revision, and maintenance. Under the Occupational Health and Safety
Management System, there are important goals that contribute to preventing poor working
environments that lead to modern slavery—namely, to “improve health and safety
management skills and provide better education” and to “promote creation of anenvironment that takes health into consideration.”
The Company develops specific implementation measures for achieving the goals, follows
the PDCA cycle, and monitors the implementation of the measures on a periodic basis,
aiming to continuously improve health and safety management activities. Twice a year
(every six months), we confirm with all field offices at construction sites the level of theirachievement of evaluation indicators under the Occupational Health and Safety
Management System, and implement improvement measures.
In addition to daily safety patrols by the Company’s employees who work at construction
sites and by subcontractors, the departments in charge of safety and the departments incharge of construction carry out regular patrols, and the central officer in charge of healthand safety and the health and safety officers of the head office and branch offices conductsafety patrols at construction sites. As a specific measure to improve health and safety
management skills and provide better education, we introduced in FY2022 an “interactive
method of patrol,” which is considered to be effective because it helps identify potential
risks and problems through dialogue at construction sites.
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We will continue safety and health training for our employees and support the educationof suppliers in order to prevent occupational accidents, raise awareness of safety and health,and deepen understanding of safety-related laws and regulations.
See the following website link for further information on Obayashi’s Occupational Healthand Safety Management System:
https://www.obayashi.co.jp/en/sustainability/safeenv.html#section2

4-2. Initiatives in Preventing Long Working Hours
Under the revised Labor Standards Act of Japan, a maximum limit on overtime work in theconstruction industry will be imposed in FY2024. To prepare for this, the Company has
formulated a “workstyle reform action plan” and is implementing the following initiatives
to reduce total working hours.
・Thorough and appropriate attendance management
・Use of ICT technology to improve work efficiency
・Reduction in overtime hours worked
・Promotion of taking vacation
・Leveling of work volume
To further improve employee awareness, in FY2023, we provided all of our officers andemployees with online training relating to viewpoints on working hours in excess ofstatutory limits, etc., and proper management of individual working hours (such training
was conducted four times in the fiscal year, and the participation rate was 85.2%, 87.2%,
87.5%, and 85.9%).
4-3. Supply Chain Management
The Group emphasizes building stronger mutual trust with suppliers in the Obayashi Codeof Conduct. We recognize that initiatives encompassing the entire supply chain are
essential to achieve this. To ensure that suppliers comply with the Obayashi Group CSR
Procurement Guidelines, we have incorporated the main actions of compliance with laws
and regulations, respect for human rights, assurance of safety and health, ensuring quality,
and others into contract provisions and confirm compliance when concluding contracts
with suppliers.
1. Initiatives Implemented at Construction Sites
In the construction work for which the Company accepts contracts in Japan, we confirm
the required facts (gender, age, whether someone is a migrant worker, years of experience,
health status, and other factors that must be considered for occupational safety) in advance9

for all people who will be involved in construction work. The people at high risk of having
their human rights violated are thereby specified, such as minors employed within thescope permitted by law, women, people of advanced age, and migrant workers including
foreign technical trainees. This information is shared among relevant employees andpreventive measures are implemented, such as considering work assignments andrestricting performance of hazardous work. All workers at construction sites must also
undergo mandatory advance training on the laws and regulations of the country, laws andregulations pertaining to safety, and international standards. Some of the documents
related to occupational safety have been translated into the native languages of the migrant
workers.
2. Promotion of CSR Procurement
The Company carries out the following surveys and inspections for member companies of
the Obayashi Rin-yu-kai and major domestic suppliers, aiming to deepen theunderstanding and awareness of CSR procurement, and monitors the soundness of thesecompanies on a periodic basis.
(1) Questionnaire Surveys Concerning the CSR Procurement Guidelines
Every fiscal year, we send the CSR Procurement Guidelines to member companies of the
Obayashi Rin-yu-kai and major suppliers to ensure that they fully understand and comply
with the Guidelines. We also conduct questionnaire surveys to determine the level ofunderstanding of the Guidelines. We aim that the companies responding to thequestionnaire surveys will account for over 70% of the total value of the Company’s
procurement, and we use this as a KPI.
Since FY2022, we have expanded the content of our surveys to include the employment
conditions of foreign workers and foreign technical trainees and the handling of conflictminerals and wood products procured. The survey response rate in FY2023 was 83%.
(The respondents accounted for approximately 78% of the total value of the Company’s
domestic procurement.)(2) Traceability Surveys on Materials Procured
We confirm with suppliers of materials and equipment that the quality of the goods they
deliver complies with relevant laws and regulations, international standards, and othercriteria. In addition, among materials that are used at construction sites in Japan, wood
products and solar panel components procured overseas are considered to carry high risks
of human rights violations. Therefore, we conduct traceability surveys on these materials
10every year. The FY2023 survey results confirm that there is currently no obvious risk ofenvironmental destruction and human rights violation. We aim that the number ofcompanies responding to the traceability surveys will be higher than the previous year,
and we use this as a KPI.
(3) Surveys Concerning Hiring of Foreign Technical Trainees
Since FY2022, we have been conducting questionnaire surveys to grasp the details of thesituation of hiring of foreign technical trainees by suppliers. Based on survey results, we
held individual hearings with several of these companies in order to directly confirm theworking environment for their foreign technical trainees and the specific initiatives thatthey are carrying out. The questionnaire surveys and interviews include issues related to
the ILO’s 11 Indicators of Forced Labour, such as working hours, payment of wages,
housing accommodations, and movement restriction.
The results of the FY2023 surveys show that among foreign technical trainees hired by
the Company’s primary suppliers (2,682 persons), approximately 32% (855 persons) haveworked at the Company’s construction sites, and approximately 60 ％ of them are
Vietnamese nationals. Furthermore, we were able to confirm that all of the respondentcompanies pay wages in accordance with the pre-approved plans, do not confiscate
trainees’ passports or other identification documents, and do not impose illegitimate
movement restrictions on trainees. We will continue our surveys to understand thesituation of hiring of foreign technical trainees.
(4) Raising Awareness about Supply Chain Management- In-house training (in FY2023)
We offered online training on the materials procurement from the viewpoint of humanrights and protection of environment for all of the Group’s officers and employees (theparticipation rate was 94.1%).
- Raising awareness among suppliers (in FY2023)
We provided training relating to human rights and CSR procurement for member
companies of the Obayashi Rin-yu-kai (68 companies participated in the training).
We will continue to educate suppliers to further improve their understanding in the future.
3. Initiatives by Group Companies (FY2023)
Our Group companies in Japan made efforts to familiarize their suppliers with our CSR
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procurement policy by, for example, sending relevant information by email and postal mail,putting up posters at their offices, and posting information on their websites. In addition,
we examined the employment conditions of foreign workers, including foreign technicaltrainees, at our Group companies in Japan, and we interviewed foreign workers at two ofthese Group companies about their employment conditions, working hours, wages, etc. We
confirmed that there is currently no obvious risk of human rights violations.
See the following website link for further information on the Obayashi Group ESG materialities and KPIs:
https://www.obayashi.co.jp/en/sustainability/upload/img/en_esg_kpi_20240417.pdf

4-4. Establishment of the Consultation Desk
We have established a human rights-related consultation desk under the Corporate Ethics
Consultation and Reporting System. We have also established a consultation desk
dedicated to harassment cases. Both desks are open to all officers and employees of theGroup as well as to the Group’s suppliers and other external stakeholders. We provide anenvironment that makes it easy for reporters to use the desks by enabling them to choose
whether to report by phone, email, or by post. Any report received by a desk is dealt withpromptly in accordance with its rules while ensuring that the person who has reported isprotected and is not subjected to disadvantageous treatment.
Number of consultations and reports received in FY2023- Corporate Ethics Consultation and Reporting Desk: 78**Including other issues than human rights cases, like violation of laws.
- Harassment Consultation Desk:194
In FY2023, no report or request for consultation was received concerning activities thatmight lead to slavery, human trafficking, and other violations of human rights.
1. Corporate Ethics Consultation and Reporting System
Under this system, two consultation desks are available for reporting illegal or suspicious
acts and raising various issues concerning human rights. One is an internal desk with adirect link to the Corporate Ethics Committee and the Audit & Supervisory Board. The
other is an external desk (law firm and others).
On various occasions, we endeavor to familiarize the persons concerned with the Corporate
Ethics Consultation and Reporting System. For the Group’s officers and employees, wepost it on our intranet, advertise it on in-house posters, explain it in regular training
sessions, and send an email once a year calling attention to it. For external stakeholders, we12post it on our website so that anyone can check it out. We also advertise it on posters in
offices and at construction sites and explain it at liaison meetings with our suppliers.
2. Harassment Consultation Desks
We have in place special consultation desks that provide harassment consultations, accept
reports, and deal with grievances. They come in three types: an internal desk (at each of
Obayashi’s main offices, branches, and overseas offices as well as at each Group company),
an external desk (domestic hotline), and a desk dedicated to job seekers.
On various occasions, we endeavor to familiarize the persons concerned with these
consultation desks. For the Group’s officers and employees, we post them on our intranet,
advertise them on in-house posters, explain them in training sessions of various kinds, andcall attention to them at the time of the annual questionnaire survey. By posting
information about these consultation desks on our recruiter’s website, we also enable job
seekers to learn about them at any time. Furthermore, as for student job seekers, our job
interviewers are required to inform them about the consultation desks.
3. Consultation and Reporting Desk for Foreign Workers Working at Construction Sites inJapan
We use an external consultation and reporting service called “JP-MIRAI Assist” for ourforeign workers working at construction sites in Japan. JP-MIRAI Assist is offered by JPMIRAI, a collaborative platform established in 2020 by private-sector corporations, local
governments, NPOs, academics, attorneys, and various other stakeholders. This service
responds to inquiries from foreign workers in Japan in easy-to-understand Japanese and 21
other languages. The service not only accepts reports involving possible human rights
violations, but also offers consultation relating to everyday troubles.
The Company obligates all workers to take training regarding legal compliance and laws,
regulations, and international standards concerning safety and other issues before starting
to work at each construction sites in Japan. It is ensured that during such training, foreign
workers are thoroughly informed about the consultation and reporting desk.
In addition to the Group’s consultation desks, in FY2020, OPUK established its own
consultation and reporting policy and has created whistle-blowing desks in charge ofgeneral corporate ethics: an internal desk (staffed by persons in charge of whistle-blowing)
and an external desk (a whistle-blowing support organization).
See the following website links for further information on “the Obayashi Group Corporate Ethics Reporting System”
and “Harassment Consultation Desks”:

13Consultation Desks (Corporate Ethics Consultation and Reporting System, Harassment Consultation Desks):
https://www.obayashi.co.jp/en/sustainability/employee/humanrights.html#section3
Reporting Process of Corporate Ethics Consultation and Reporting System:
https://www.obayashi.co.jp/en/sustainability/ethics.html#section1-2-3

4-5. Effectiveness
The Board of Directors has decided on the management policy on sustainability, which also
encompasses respect for human rights. Based on this policy, two kinds of committees havebeen established on the executive side: the Business Plan Committee and two expert
committees in the area of sustainability (the Human Rights Expert Committee and theSupply Chain Management Expert Committee). All these committees formulate policies
on human rights issues, develop and implement measures to address them, assess theimplementation status in each department, check the KPI performance, evaluate relevant
efforts, and improve them for better effectiveness.
In addition, the Sustainability Committee, established under the Board of Directors,
studies policies on how to address sustainability issues, including human rights issues,
provides relevant reports to the Board of Directors, and assesses the status of
implementation at the business execution departments.
The chairpersons of the expert committees in the sustainability field, the frequency ofcommittee meetings, and the main topics brought up for discussion in FY2023 are as
follows:
1. Human Rights Expert Committee
Chairperson: Executive officer responsible for human resources
Frequency of meetings: One regular meeting a year and special meetings as necessary
Main topics brought up for discussion in FY2023:- Implementation of human rights due diligence- Interview surveys for overseas headquarters- Investigation of Group companies in Japan and their activities- Implementation of online training relating to human rights, etc.
2. Supply Chain Management Expert Committee
Chairperson: Head of the procurement division
Frequency of meetings: At least one regular meeting a year
Main topics brought up for discussion in FY2023:-Considering development of an action plan relating to working environment improvement
at construction sites
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- Identifying risks in domestic and overseas supply chains and developing solutions-Implementing measures to deepen the understanding and awareness of CSR procurement
policy, etc.
5. Training on Modern Slavery and Human Trafficking
5-1. Promoting Awareness of Human Rights
The Group concentrates on raising awareness of human rights among its officers andemployees. We have established the Human Rights Expert Committee, which is chaired by
the officer in charge of the human resources. This committee prevents infringement of
human rights, ascertains human rights issues, and resolves such issues. It also promotes
initiatives aimed at increasing awareness of human rights.
Every fiscal year, we provide education concerning basic knowledge on human rights
during training sessions for newly hired employees and rank-specific training sessions. In
FY2023, we provided all of the Group’s officers and employees with online training on thematerials procurement from the viewpoint of human rights and protection of environment(the participation rate was 94.1%). During these training sessions, we make thoroughefforts to fully familiarize our officers and employees with our CSR procurement policy andhuman rights policy and our consultation desks.
The Harassment Prevention Department, a specialized unit, plays a central role in raisingawareness of harassment. Under our Harassment Prevention Guidelines, we are working
to prevent harassment by communicating the corporate policy on harassment, defining
each type of harassment, and providing information on the specific response when aharassment incident occurs to all officers and employees.
Furthermore, every fiscal year, we provide all of our officers and employees with online
training on the subject of harassment. The participation rate in FY2023 was 88.4%.
Training for our suppliers is detailed in “4-3 Supply Chain Management”.

See the following website link for further information on Obayashi Group initiatives on human rights:
https://www.obayashi.co.jp/en/sustainability/employee.html#section1

5-2. Compliance Training
The Group has established the Corporate Ethics Committee, which is chaired by thepresident. This committee works to ensure compliance and maintenance of corporate
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ethics. As one of these initiatives, the committee has mandated that all officers andemployees of the Group undergo compliance training every year. This training provides anopportunity to make officers and employees aware of their own actions from a corporate
ethics perspective. Additionally, this is intended to help them acquire abilities to root out
illegal conduct and corporate ethics violations within the Company and its supply chain.
For corporate ethics training KPI, we have set our goal for employees taking the training
by FY2023 as 100%, and we have achieved 100% in FY2023. We will continue to promotecompliance education to ensure that compliance awareness takes root in our corporate
culture.
See the following website link for further information on the Obayashi Corporate Ethics program:
https://www.obayashi.co.jp/en/sustainability/ethics.html

6. Cooperation with Domestic, Overseas, and Group Companies
We formulated operating rules on management through alliances between each company andthe managing department and business division at headquarters from FY2019. Such
operating rules not only apply to the Company itself, but also to the businesses of Group
companies in Japan and overseas. The local office and local Group company of the UK
business and the local office of the Australian business covered by this Statement continuallyshare information between the local office and the managing department and businessdivision at headquarters in Japan. They strive to form timely, appropriate alliances with awide range of individual Group companies through our networks in Japan and overseas, inaddition to alliances with Obayashi, when necessary.
In addition to sharing management policies and goals, the Company also works to strengthen
alliances between Group companies by having top management from Group companies inJapan and overseas participate in the regularly scheduled executive officers’ meetings alongwith the executive officers. We are also working to strengthen the network between locations
through regular business reporting meetings and liaison meetings held by Group companies
in each overseas region, mainly in our North American Regional Headquarters and the AsiaPacific Regional Headquarters.
At executive officers’ meetings, we offer training on such topics as “harassment prevention”
and “diversity and inclusion” and also explain the importance of initiatives aimed at
respecting human rights. Moreover, those responsible for human resources at the main
Group companies in Japan participate in the Company’s Human Rights Expert Committee toshare the awareness of human rights issues and launch joint initiatives aimed at preventing
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