Date Created: March 31, 2024

Human Rights Report 2023
The TODA KOGYO Group has established the “TODA KOGYO Group
Human Rights Policy” based on the Guiding Principles on Business andHuman Rights adopted by the United Nations Human Rights Council.
We always respect fundamental human rights. We support and respect
theUnitedNations

International

BillofHumanRightsandtheInternational Labour Organization (ILO) Declaration on Fundamental
Principles and Rights at Work.
The Policy was approved by the Board of Directors in April 2023 for its
establishment and disclosure. The Policy applies to all directors, officers,and employees of the TODA KOGYO Group. We also expect all ourbusiness partners and other parties linked to our business, products, andservices to support and comply with the Policy.
＞＞ TODA KOGYO Group Human Rights Policy

Framework for Promoting Human Rights Initiatives
The Group’s Corporate Administration Division serves as the secretariat
for promoting initiatives to respect human rights. The status of theinitiatives is regularly reported to management and supervised by thePresident and CEO. From 2024, we are going to establish a more crossfunctional structure to promote our human rights initiatives.
We receive expert advice from outside expert, Caux Round Table Japan(CRT Japan) to ensure the objectivity and legitimacy of our initiatives torespect human rights.

Initiatives
Education and Training on Human Rights
The Group provides regular education and training on business andhuman rights to our directors, officers, and employees.
For management, we have training sessions with outside experts todeepen understanding of business and human rights, catch up with thelatest trends, and strengthen commitment to efforts to respect humanrights. In the training session in March 2023, the Officers learned about
domestic and global trends on business and human rights and responses
required of companies and discussed the content of our human rights
policy. In the session in January 2024, the Officers reviewed the Group's
initiatives and cultivated a better understanding on human rights duediligence.
For employees, we held a training program in February 2023 to deepen
their understanding of business and human rights and how to engage asa practitioner. On the occasion of human rights due diligence workshop
for division and department managers in October 2023, we invited Mr.
Hiroshi Ishida, Executive Director of CRT Japan, to give a lecture tocultivate their understanding of the global trends regarding business andhuman rights.

Human Rights Due Diligence
Basic Concepts and Approach
TheGroup

conducts

humanrights

duediligence

initiatives

inaccordance with the methods based on the Guiding Principles on
Business and Human Rights.
Specifically, we continuously implement a process that includes:
identifying adverse human rights impacts in which we may be involved,
assessing the actual situation regarding the identified impacts and taking
appropriate measures to prevent and mitigate the impacts, tracking theimplementation status and results of the measures, and disclosing theprogress and results of the initiatives to the public.

<Human Rights Due Diligence Basic Flow>

Identification of Human Rights Themes (Implementation of RiskAssessment)
The Group analyzes a variety of information from both external andinternal perspectives to identify potential human rights themes ofconcern.
As for organizing and analyzing information from external perspective,
we conducted a desktop survey on human rights risks and gathered
information from international organizations, NGOs, government agencies,and other research organizations, as well as the insights of external
experts. By cross-checking such information with the data regarding eachbasis of the Group and procuring raw materials that was collected withsurvey sheets, we identified potential human rights themes based on
objective data. In this work, we analyzed information based on the typesof risks proposed in the OECD “Due Diligence Guidance for Responsible
Business Conduct” (sector risks, product risks, geographic risks, andenterprise-level risks). We have identified human rights issues in thechemical sector, the issues related to minerals as raw materials, and theissues in each country and region where the Group's bases are located.
As for organizing and analyzing information from an internal perspective,
we held a human rights due diligence workshop for managers from various
departments and Group companies. At the workshop, participants
discussed human rights themes that could be envisioned from a Groupinsider’s perspective. Potential human rights risks of concern from apractical standpoint in the Group's value chain were identified.
Based on the results of the above identification of human rights themes
frombothexternalandinternalperspectives,

andtakinginto

consideration the opinions of external experts, we have identified thefollowing human rights themes that are of concern for their potentiallysignificant adverse impact on society.

<Human Rights Themes of Potential Concern>
・Migrant workers at domestic manufacturing sites
・Workers at overseas manufacturing sites
・Conflict minerals (Responsible sourcing of minerals)
・Workers at suppliers of raw materials and other materials and subcontractors
・2024 Problem in Logistics・Inappropriate use and disposal of products by customers and end consumers

<Risk Assessment Process Flow>Future Initiatives
After considering the priority of the human rights themes which havebeen identified in Risk Assessment, the Group will conduct an assessmentof the issues (Impact Assessment) and check on the existence or
possibility of human rights violations through direct dialogue with rights
holders. If we recognize an existence or possibility of adverse impact onhuman rights, we will take action to prevent or mitigate it. We also trackthe effectiveness of the actions we have taken.
The Group will repeatedly and continuously implement these humanrights due diligence processes and disclose the progress and results of
its efforts to disclose to the public.

Grievance Mechanism
TODA KOGYO Corp. has established the following whistleblower
systems.
Compliance Helpdesks
We have established compliance helpdesks both internally andexternally. Internal personnel including the full-time Audit andSupervisory Committee member work for the internal helpdesk and ourlegal advisors are available for outside helpdesk. Each helpdesk has atleast one female member. To facilitate contacts and to protect those who
do contact helpdesks, we provide a broad range of options for contact,
including oral communication, phone, e-mail, and writing. The helpdesks
also accept anonymous contacts. The fact that any of the helpdesks iscontacted and the information provided is treated as confidential
information and under strict control to prevent those who make contactfrom being disadvantaged.
From 2021 to 2023, we have received contacts at a rate of two per year.
Many of the matters regarding which helpdesks were contacted recently
were about harassment.

Harassment Helpdesk Program
We have set up helpdesks at the Personnel & General Affairs
Department and at an outside law firm. These helpdesks receive inquiries

and complaints about acts of harassment and abuse and take proper
actions in accordance with our Harassment Prevention Regulations.
In accordance with the Guiding Principles on Business and Human
Rights, the Group will gradually establish a grievance mechanism
targeting rights holders who may be negatively affected by corporate
activities, including those outside the Group, while engaging in dialogue
with rights holders through Impact Assessments and other initiatives.

Contact: Personnel & General Affairs Group