Human Rights|Sustainability|ULVAC, Inc.

Human Rights

We believe that consideration for human rights is an important management issue in the context of further global business development. We support international norms and are strengthening promotion of the protection of and respect for human rights. Moreover, we respect fundamental human rights based on the laws and regulations of each country and region.

Approach to Human Rights

ULVAC has formulated the "ULVAC Human Rights Policy" in accordance with UN Guiding Principles on Business and Human Rights, in response to recent changes in international awareness and challenges regarding human rights. Furthermore, we have established the "ULVAC Group Corporate Code of Ethics" as a standard for all officers and employees to adhere to, in order to ensure their work does not infringe upon human rights.

As a company that conducts business globally, ULVAC will, in accordance with this policy, promote business activities that respect human rights more than ever before, based on a clear and common understanding of how human rights should be respected in business activities.

ULVAC Human Rights Policy

The ULVAC Group, consisting of ULVAC, Inc. and its subsidiaries (hereinafter referred to as "ULVAC"), has established the ULVAC Human Rights Policy (hereinafter referred to as "this Policy") to respect human rights in all aspects of its business activities and to implement initiatives that uphold human rights.
Should ULVAC's business activities result in adverse impacts on human rights, ULVAC will take appropriate corrective measures in accordance with this Policy. Furthermore, ULVAC will comply with the laws and regulations of each country regarding human rights and labor, while ensuring safety and security and implementing measures to prevent human rights violations.
ULVAC will establish an internal framework to implement initiatives that respect human rights and will continuously improve this framework.

Scope of Application and Requirement to Respect Human Rights

This Policy applies to all ULVAC personnel, including officers, regular employees, contract employees, and temporary agency workers (hereinafter referred to as "all officers and employees, etc."). Furthermore, ULVAC requires its business partners within its supply chain to respect human rights.

Compliance with Laws and Regulations and Respect for International Norms

ULVAC complies with the laws and regulations applicable to its business activities and respects international norms, including the "International Bill of Human Rights," the "ILO Declaration on Fundamental Principles and Rights at Work," the "ILO Core Labour Standards," the "OECD Guidelines for Multinational Enterprises," and the "Guiding Principles on Business and Human Rights."
Furthermore, in the event of a conflict between local laws/regulations and international norms, ULVAC will pursue methods that respect international norms to the maximum extent possible. In addition, ULVAC will promote initiatives to respect human rights based on international guidelines such as the "United Nations Global Compact" and the "RBA Code of Conduct."

Human Rights Due Diligence

ULVAC will establish and continuously implement a human rights due diligence framework to identify, prevent, mitigate, and avoid adverse impacts on human rights. In addition, ULVAC will engage with stakeholders throughout the process of conducting human rights due diligence.

Remedy and Corrective action

ULVAC will establish a system (hereinafter referred to as the "Grievance Mechanism") that allows individuals to report to ULVAC if its business activities cause or contribute to an adverse impact on human rights. If ULVAC identifies a human rights violation through the Grievance Mechanism, it will promptly conduct an investigation, verify the facts thoroughly, take appropriate measures, and work toward remedy and correction. Furthermore, ULVAC will not tolerate any retaliation against whistleblowers.

Training

ULVAC will provide necessary training to all officers and employees, etc. in a timely and appropriate manner.

Informing Relevant Parties

ULVAC will inform the contents of this Policy to all officers and employees, etc., business partners, and other relevant stakeholders, including customers. In addition, ULVAC will require its business partners to comply with the laws and regulations of the countries or regions where they operate and request their adherence to the "Requests to Our Business Partners."

Disclosure

ULVAC will disclose its initiatives regarding respect for human rights in a timely and appropriate manner.

Effective Date of Revision: July 1, 2026
ULVAC, Inc.
Junya Kiyota, President and Executive Officer

ULVAC Human Rights Policy (English Edition)

ULVAC Human Rights Policy (Japanese Edition)

ULVAC Human Rights Policy (Simplified Chinese Edition)

ULVAC Human Rights Policy (Traditional Chinese Edition)

ULVAC Human Rights Policy (Korean Edition)

Key Human Rights Issues

- Prohibition of Discrimination and Harassment

ULVAC does not engage in or tolerate discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, marital status, or any other status. Furthermore, ULVAC will not tolerate any form of inhumane treatment, including harassment, and will ensure equal opportunity and fairness in recruitment, placement, training, compensation, promotion, and other employment practices.

- Freely Chosen Employment

ULVAC will not tolerate child labor, forced labor, bonded labor, human trafficking, or prison labor under any circumstances. All work must be voluntary, and workers shall be free to resign from their employment in accordance with the standards stipulated by the relevant laws and regulations of each country or region.

- Freedom of Association and Collective Bargaining

ULVAC respects the right of workers to freely form, join, or leave labor unions, as well as the right to bargain collectively and participate in peaceful assemblies. In addition, ULVAC will provide opportunities and environment that enable workers to communicate with management regarding working conditions and employment practices without fear of discrimination, retaliation, intimidation, or harassment.

- Occupational Health and Safety and Employee Well-being

ULVAC complies with laws and regulations related to health and safety enacted in the countries or regions where it operates, and strives to maintain a safe, secure, and healthy working environment.

- Ensuring Appropriate Working Conditions

In conducting its business activities, ULVAC respects the right of employees to lead a healthy life and complies with applicable laws and regulations regarding working hours and taking a break, day off, and leave.

- Ensuring Product Safety

ULVAC pays attention to safety related to the products and services it manufactures or provides, respects the human rights of customers who may be affected by its business activities, and takes necessary measures for them.

ULVAC Group Corporate Code of Ethics (Excerpt)

1) Compliance with Laws and Regulations and Respect for International Norms of behavior

We uphold the highest ethical standards in all aspects of our business activities and comply with applicable laws and regulations. In light of the ULVAC Group's global business operations, we respect and comply with applicable international standards.

2) Respect for Privacy and Protection of Personal Information

We respect the privacy of every individual and treat personal information with the utmost care. We comply with applicable laws and regulations and handle personal information only to the extent strictly necessary for business purposes, ensuring that it is collected, recorded, used, and disposed of properly. Personal information is also safeguarded against loss, alteration, or leakage.

3) Respect for Human Rights

We recognize the inherent value of every individual and respect the human rights of all people involved in our business activities, including officers, employees, customers, suppliers, and residents of local communities. We comply with applicable laws and regulations and uphold international standards on business and human rights. In line with these standards, we strive to prevent human rights violations arising from our business activities. Should any adverse impacts on human rights occur, we will take appropriate measures to address them.

4) Non-Discrimination and Harassment-Free Workplace

We do not tolerate any form of discrimination based on race, color, age, gender, political beliefs, sexual orientation, gender identity or expression, ethnic or national origin, disability status, pregnancy, religion, place of origin, social origin, partnership status, or any other grounds. Furthermore, we strictly prohibit all forms of harassment and do not engage in such behavior.

5) Respect for Workers' Rights

We respect the rights to freely form, join, or leave trade unions, bargain collectively, and engage in peaceful assembly. We ensure opportunities and an environment where employees and others can engage in dialogue with the company regarding working conditions and management practices without fear of discrimination, retaliation, intimidation, harassment, and similar conduct. In addition, we do not tolerate forced labor or child labor under any circumstances.

6) Safe and Healthy Workplace

We recognize that the safety of our officers, employees, and other personnel is our top priority in all business activities. We comply with applicable laws and regulations, meet customer requirements, operate our management systems appropriately, and maintain a safe and healthy workplace and working environment for all ULVAC Group employees. We remain prepared for emergencies, including disasters, and unite in such events to safeguard everyone's safety.

7) Promotion of Diversity, Equity, and Inclusion (DEI)

We respect the character and individuality of each person and mutually recognize the diverse values they bring. We strive to create a diverse, fair, inclusive, and collaborative workplace where all employees feel a sense of belonging and are empowered to reach their full potential.

Freedom of Association

ULVAC has concluded labor agreements with labor unions and promised to sincerely work together with them to adhere to these agreements in order to establish and develop labor-management relations based on mutual faith and trust. Furthermore, we engage in close dialogue with labor unions on management plans and measures, in addition to labor conditions.

Human Rights Initiatives

We respect the United Nations Guiding Principles on Business and Human Rights as well as the international norms and standards set forth in the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights) and the ILO Declaration on Fundamental Principles and Rights at Work. We respect human rights in accordance with the Ten Principles of the UN Global Compact and other guidelines of the international community and industry guidelines.

Due Diligence on Human Rights

We have incorporated international norms into the ULVAC Human Rights Policy and have established human rights due diligence processes according to the procedures corresponding to the international norms. We are making an effort to further strengthen relief mechanisms by recognizing, preventing, and addressing negative effects that may have on human rights through business activities.

Group's Issues with Significant Impact on Human Rights and Relations with Rightsholders

Business-related human rights risks/rightsholders Employees Workers in the supply chain Customers*1 Local community residents*2
Forced labor, child labor, and human trafficking
Violations of workers' right (e.g., the rights to collective bargaining and decent working conditions)
Occupational Safety and Health Deficiencies
Discrimination and harassment
Violations of privacy rights
Infringement of freedom of expression
Personal Injury Resulting from Product Misuse
Negative Impacts of Conflict (e.g., Conflict Minerals)
Disruptions to the daily lives of local residents (noise, vibration, foul odors, environmental pollution, etc.)
  • *1 Individuals who may be affected by the safety of our products and services
  • *2 Local residents living near our facilities

Supply Chain Initiatives

We endeavor to comply with the RBA Code of Conduct, which is a CSR promotion group focused on the electronics industry. In addition to implementing, evaluating and correcting self-evaluations and thoroughly managing labor hours at major production bases, we request business partners to work with us on these initiatives. We conducted questionnaire surveys mainly for major business partners and have incorporated the questionnaire items into the evaluation at the time of periodic renewal. Furthermore, we have established a policy on the handling of conflict minerals and conduct due diligence.

Remedies and Corrections

ULVAC will establish a mechanism (complaint handling mechanism) to receive reports of negative human rights impacts caused by or involving ULVAC's business activities. Through this mechanism, upon recognizing human rights violations, ULVAC will promptly investigate, take appropriate measures after thorough fact-finding, and work toward remediation and corrective action. ULVAC employs an internal whistleblowing system with guaranteed independence. Reports can be made either under real name or anonymously.
The anonymity and privacy of whistleblowers are protected, and retaliation or harassment against whistleblowers is strictly prohibited. The Compliance Committee implements appropriate responses to reported cases, works toward prompt resolution, and strives to prevent recurrence.

Reporting and Consultation Desk for Human Rights

We have adopted a whistleblowing system that ensures independence.
The Compliance Committee will implement appropriate measures with adequate consideration for confidentiality, anonymity and protection of whistleblowers, and strive to promptly resolve issues and prevent their recurrence.

Education

We educate all officers and employees about human rights and compliance so that they are well-informed and able to act appropriately.

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