The Denka Group places great importance on compliance with international standards on human rights and strives to take action based on the United Nations Guiding Principles on Basic Human Rights. The Denka Group Human Rights Policy, established as part of those actions, embodies measures to eliminate human rights violations in all corporate activities and was approved by the Board of Directors on September 2023.
This human rights policy applies to all officers and employees in the Group, and we also require our business partners and suppliers to support and respect this policy. In addition, as a signatory to the United Nations Global Compact, we support the Ten Principles set forth by this initiative and will continue to fulfill our 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
Toshio Imai
President and CEO
Denka Company Ltd.

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

Denka identified notable human rights risks that may occur in the course of its corporate activities. Denka identified 10 risk items that should take priority by conducting interviews with business and management divisions and the labor union.
We will continue to conduct interviews with a wider scope to promote preventative and mitigation measures with the aim of establishing a human rights due diligence process.

Promotion of Human Rights Due Diligence

We organize related departments and Human Rights Working Team to coordinate in promoting initiatives on respecting human rights. The progress of initiatives is reported twice a year to the Board of Directors after being discussed by the Sustainability Committee.

Stakeholders and Engagement Activities

As stated in Article 7 of the Denka Group Human Rights Policy, Denka engages in continuous dialogue and discussion with relevant internal and external stakeholders to identify and resolve potential and actual human rights issues.

Dialogue with External Stakeholders

In order to correctly identify the human rights risks of major suppliers, we send a Self-Assessment Questionnaire (SAQ) based on the Ten Principles of the United Nations Global Compact to all suppliers and ask for their response. The results of the SAQ are listed by category, and we work systematically with suppliers that do not meet a certain score in dialogues and discussions aimed at improvement. In addition, we request that business partners with whom we sign new contracts to endorse our CSR Procurement Policies, which describe our commitment to human rights compliance.

Dialogue with Internal Stakeholders

We hold briefings for all Denka Group employees on the Denka Group Human Rights Policy and our future human rights initiatives. In addition, we conduct e-learning in conjunction with Denka’s compliance training to monitor employees’ level of understanding of human rights and use the information to determine future actions.
We will continue to promote awareness of and disseminate the Denka Group Human Rights Policy to all Group employees and work systematically together with expert third parties on human rights due diligence and redress mechanisms.

We have been encouraging the “maintenance of favorable human relationships” in line with the Denka Group Ethics Policy. Accordingly, all Denka Group officers and employees are called upon to respect individual human rights. The "Standards of Business Conduct" states the importance for officers and employees of the Denka Group to maintain high ethical standards and act as good corporate citizens in all the countries and regions in which the Denka Group operates, while recognizing that laws, customs, traditions, and culture vary by country and region. It further states the importance of ensuring that all officers and employees of the Denka Group are treated fairly and without discrimination in all aspects of their employment, including job assignments, promotions, transfers, and training opportunities, in accordance with the abilities and aptitudes required for the job and applicable laws and regulations, regardless of ethnicity, race, gender, religion, nationality, age, physical disability, or gender identity. Moreover, the Standards of Business Conduct provide clear and detailed guidelines regarding what practices must be observed and what constitutes prohibited action with the aim of living up to our commitment to complying with labor laws, ensuring equal employment and career opportunities without discrimination, and preventing workplace harassment. In particular, these standards feature case studies of actual workplace incidents involving power harassment and sexual harassment to be dealt with in a way conformant to guidelines issued by the Ministry of Health, Labour and Welfare. Thus, these standards include elaborative provisions designed to prevent harassment incidents from occurring within the Denka Group. Denka also signed the United Nations Global Compact in June 2023. Denka supports the 10 principles established by the initiative, respects other international human rights standards, and contributes to 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.