The Denka Group places importance on compliance with international human rights standards and strives to act in accordance with the United Nations "Guiding Principles on Business and Human Rights." As part of these efforts, the Denka Group Human Rights Policy was established to concretely formulate measures to eliminate human rights violations in all corporate activities, and was approved and established by the Board of Directors in September 2023.
This Human Rights Policy applies to all officers and employees of the Denka Group, and requests that this Policy be supported and respected by our business partners and suppliers. Furthermore, as a signatory of the United Nations Global Compact, the Denka Group supports the ten principles set forth by this initiative and will continue to fulfill its responsibilities.

Denka Group Human Rights Policy

Denka Group Human Rights Policy

The Denka Group (“Denka”) aims to contribute to society by providing innovations and solutions under our Vision, consisting of Core value, Purpose and Mission, as the basis of business activities of all executives and employees of Denka. Denka understands that human rights are important matters in all our business activities. Denka has established this policy to fulfill our responsibility to respect human rights and to contribute to overcome human rights issues in accordance with the "Denka Group ESG Basic Policy" and the "Denka Group Corporate Ethics Policy” and will strive to achieve our objectives as set forth below. 
This policy was approved by the Board of Directors on September 11, 2023.

1. Scope

This policy applies to all executives and employees, including non-regular employees, of Denka.
Furthermore, Denka will encourage all our business partners, including suppliers, to understand this policy.

2. Support for International Norms and Standards

Denka will respect international standards of human rights set forth in (i) the International Bill of Human Rights, consisting of Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights, (ii) the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work and the fundamental principles established therein regarding "Freedom of Association and the Right to Collective Bargaining", " Elimination of all forms of Forced or Compulsory Labor", "Effective Abolition of Child Labor", "Elimination of Discrimination in Respect of Employment and Occupation", and "Safe and Healthy Working Environment," and (iii) the OECD’s "Guidelines for Multinational Enterprises.” Also, Denka will exert efforts to act in accordance with the United Nations Guiding Principles on Business and Human Rights and will support the Ten Principles of the United Nations Global Compact as a company that has signed the United Nations Global Compact. 
Denka will comply with the laws and regulations applicable in each country and region where we conduct business activities. However, should the laws and regulations of the country or region conflict with international human rights norms, Denka will pursue the methods that maximize respect for internationally recognized human rights principles.

3. Responsibility to Respect Human Rights

Denka will strive to ensure that our business activities do not violate the human rights of any person related to our business. We will not tolerate any form of discrimination based on gender, age, nationality, ethnicity, race, place of origin, religion, belief, disability, sexual orientation, gender identity, and other factors, and treat individuals fairly in all aspects of employment, including recruitment, job placement, and promotion. In the event of any adverse impact caused by our business activities, Denka will fulfill our responsibility to respect human rights by taking appropriate corrective actions.
Denka will not tolerate harassment and discrimination that hurt the dignity of individuals, and any form of child labor and forced labor. In addition to guaranteeing the payment of wages above the minimum wage necessary for a stable livelihood, we will make efforts to establish appropriate wage conditions, such as providing equal pay for equal work, and ensure that wages and benefits are provided without gender-based discrimination. Denka will respect workers' freedom of association and the right to collective bargaining, and will work to prevent excessive working hours, reduce overtime, and create a safe, healthy, and comfortable work environment with fair wages guaranteed. In addition, Denka will strive to provide our customers with safe products and services and to disclose appropriate information.

4. Governance

We will clarify a person who is responsible for overseeing our compliance with this policy and our efforts based on this policy.

5. Human Rights Due Diligence

Denka will seek to conduct human rights due diligence to identify and assess potential or actual human rights impacts by its business activities, and to take measures to prevent or mitigate risks to human rights.

6. Remedial Measures

If it becomes clear that Denka has caused adverse human rights impact, we will make efforts to correct and remedy such impacts through appropriate measures. Regarding adverse impacts on human rights that are directly linked to Denka’s business through business relationships, Denka will also make efforts to find a solution to human rights issues in our supply chain by encouraging our business partners to make efforts to correct and remedy such negative impacts.

7. Stakeholder Engagement

Regarding measures to address potential and actual adverse human rights impacts, Denka will exert efforts to take such measures through continuous consultation and engagement with relevant internal and external stakeholders.

8. Grievance Mechanism

Denka will take measures to improve the effectiveness of the correction and remedy of any concerns about human rights by establishing a system to report any concerns about human rights for all executives and employees of Denka, all business partners including suppliers and other stakeholders.

9. Education and Training

For the effective implementation of this policy, Denka will offer training to all officers and employees of Denka, including non-regular employees, to enhance their understandings as to respect for human rights.

Established on September 11, 2023
Revised on March 10, 2025
Ikuo Ishida
President and CEO
Denka Company Ltd.

Important Human Rights Risks of the Denka Group (10 items)

Denka has identified prominent human rights risks that may arise in the course of corporate activities. In identifying risk items, we conducted hearings with each business division, management division, and labor union, and extracted 10 risk items to be addressed as priorities.
In the future, we will continue to conduct hearings to expand the scope of targets, promote response measures for prevention and mitigation, and aim to establish a human rights due diligence process.

Promotion of Human Rights Due Diligence

Denka has organized a human rights working team with relevant departments and is promoting efforts to respect human rights in a coordinated manner. The progress of these efforts is discussed at The Sustainability Committee and reported to the Board of Directors twice a year.

Engagement activities with stakeholders

Denka conducts ongoing dialogue and discussions with relevant internal and external stakeholders to identify and address potential and actual human rights issues, as stated in Article 7 of the Denka Group Human Rights Policy.

Dialogue with external stakeholders

In order to correctly understand the human rights risks of major suppliers, we send a Self-Assessment Questionnaire (SAQ) based on the 10 Principles of the United Nations Global Compact (various risks including human rights risk) to all suppliers and request their responses. We list the SAQ results of each company by item, and for suppliers that do not meet a certain score, we will plan and implement dialogue and discussions for improvement. In addition, we request that new business partners agree to our CSR Procurement Policy, which states our commitment to human rights.

Dialogue with internal stakeholders

The Denka Group conducts explanatory meetings for the "Denka Group Human Rights Policy" and "Future Human Rights Initiatives" for all employees. In addition, we conduct e-learning together with Denka's compliance training, monitor employees' understanding of human rights, and link this to the next actions.
In the future, we will continue to raise awareness and promote the "Denka Group Human Rights Policy" among all Group employees, and systematically address human rights due diligence and human rights remedy mechanisms together with third parties with expertise in these areas.

The Denka Group Ethics Policy state that the Denka Group must maintain good human relationships and obliges all officers and employees of the Denka Group to respect individual human rights. Furthermore, the "Standards of Business Conduct" state that officers and employees of the Denka Group must recognize that laws, customs, traditions, and cultures differ from country to country and region to region, and that it is important to act as a good corporate citizen in all countries and regions where the Denka Group conducts business with a high level of ethics. Moreover, the Business Conduct Guidelines state that it is important for officers and employees of the Denka Group to be treated fairly without discrimination in all aspects of employment, including job placement, promotion, transfer, and training opportunities, based on the abilities and aptitudes required for the job, as well as laws and regulations, regardless of ethnicity, race, gender, religion, nationality, age, physical disability, or gender identity. Furthermore, the Business Conduct Guidelines clarify specific obligations and prohibitions that must be observed by all officers and employees of the Denka Group to ensure compliance with labor laws and regulations, provide equal employment opportunities and treatment without discrimination, and prevent harassment in the workplace. In particular, training materials for preventing workplace harassment include specific examples of power harassment and sexual harassment in accordance with guidelines set forth by the Ministry of Health, Labour and Welfare, and are carefully designed to prevent harassment in the Denka Group.
In addition, Denka signed the United Nations Global Compact in June 2023. Denka supports the 10 Principles of this initiative, respects various other international standards regarding human rights, and contributes to addressing human rights issues through its business activities.

As stated in Article 3 of the Denka Group Human Rights Policy, Denka does not permit child labor or forced labor in any form. The same prohibition is also stipulated within the Denka Group Employment Regulations. As a preventative measure, we prevent the occurrence of child labor by ensuring that the age of employees in Japan is verified by means of a copy of their Certificate of Residence or Residence Card, which is submitted at the time of employment. In addition, to prevent forced labor, we do not restrict employees’ freedom of movement or keep important documents such as passports in custody.

Denka employees are organized into Denka labor unions, which have the right to collective bargaining. In addition to holding labor-management consultations three times a year, we hold monthly liaison meetings, valuing an appropriate relationship with labor unions and respecting the unions’ aims and ideas for protecting workers’ rights. In addition, active discussions on working conditions and the working environment for employees are held between labor and management, and we are actively working toward improvements. Through these activities, we aim to build sound labor-management relations based on mutual understanding and trust and to realize inclusive workplace environments.