Business and Human Rights

• 1. Establishment and Disclosure of Human Rights Policy
• Structure
• 2. Human Rights Due Diligence
• 3. Remedy Mechanisms
• Dialogue with Stakeholders

1. Establishment and Disclosure of Human Rights Policy

Our Group recognizes that all business activities in global markets have the potential to cause adverse impacts on human rights. Based on this recognition, we have supported the UN Global Compact since 2006, and respect international human rights norms, including the ILO Declaration on Fundamental Principles and Rights at Work.
In addition to respecting these international norms, we also value the Group Policy for Human Rights, which our Group has independently established and is shared by all executives and employees, as an important guideline in all our business activities.
Our Group does not tolerate any form of forced labour, human trafficking, child labour, or discrimination and harassment related to employment and occupation (such as sexual harassment, power harassment, and customer harassment).
Going beyond compliance with applicable laws and regulations, we respect fundamental human rights, including children's rights (including support for the "Children's Rights and Business Principles"), women's rights, gender equality, freedom of association and the right to collective bargaining, and a safe and healthy working environment.
Furthermore, to establish sound labor practices, we promote the payment of appropriate living wages, the realization of equal remuneration for men and women, the avoidance and reduction of overtime and excessive working hours, the setting of maximum working hours, and the taking of annual paid leave, based on our wellness management strategy.
In cases of dismissal, with a view to ensuring employment stability and protecting the livelihoods of our workers, we comply with relevant laws and regulations, such as the Labor Standards Act1 and the Labor Contract Act2, and handle all matters appropriately.
These principles and policies serve as the fundamental stance for all our executives and employees. At the same time, we actively encourage our business partners, collaborative partners, and contractors to understand and adopt similar initiatives, working collaboratively to promote these practices.
For details on policies regarding the human rights of stakeholders, please refer to the following.

• Group Policy for Human Rights
• Wellness Management
• ESG Data

1. Rules regarding dismissal and termination of employment (Japanese)
   https://www.mhlw.go.jp/stf/houdou/2r98520000014uzs-att/2r9852000001dhat.pdf
2. Decree and rule about employment contract (conclusion of contract, change in the labor condition and dismissal, etc.) (Japanese)
   https://www.mhlw.go.jp/stf/seisakunitsuite/bunya/koyou_roudou/roudoukijun/keiyaku/index.html

Structure

To promote appropriate sustainability practices, the Group has established a promotion framework centered on the Group Sustainable Management Committee (the “Committee”) and is strengthening its initiatives related to business and human rights. Under the Committee, we have established the “Business and Human Rights Working Group (WG),” comprising working-level members from each Group company. With the Sustainable Management Office serving as the secretariat, we have built an effective Group-wide promotion framework.

2. Human Rights Due Diligence

In accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs), the Group conducts human rights due diligence (“human rights DD”) on an ongoing basis, covering our own business activities as well as our entire supply chain (including business partners, contractors, agents, investee and borrower companies, and insurance underwriting counterparties).
This global and comprehensive process is not limited to specific countries or products, and is positioned as a regular annual initiative.

Roadmap

Starting in FY2025, the Group has embarked on establishing a framework for business and human rights within our organizations. In the first year, we established Working Groups (WGs) at 26 Group companies. We conducted a new human rights risk assessment to identify human rights risks and select priority issues based on the business characteristics of each company. In this way, by establishing promotion frameworks at each company, we have created a system for formulating, executing, tracking the effectiveness of, and continuously improving our response measures. The WGs periodically hold opportunities to exchange opinions on each other's initiatives, striving for continuous awareness-raising.
We have formulated a three-year roadmap for our initiatives to respect human rights spanning from FY2025 to FY2027, and will continue to steadily promote these initiatives moving forward.

Step1 Identification and assessment of adverse human rights impacts (Risk assessments)

To identify human rights risks, the Group obtains professional expertise from external human rights experts, in addition to conducting surveys based on international guidelines. Furthermore, going beyond desk research, we engage with potentially affected stakeholders in our business operations and supply chains.
Through interviews and questionnaire surveys, we directly gather first-hand voices regarding potential human rights issues on the ground and utilize them to improve the accuracy of our risk assessments.
In investment decision-making processes such as M&A transactions, we conduct comprehensive due diligence covering finance, tax, legal affairs, compliance, and business aspects. In these DD processes, depending on the characteristics and requirements of each transaction, we also identify and assess related risks—including ESG and human rights risks—and utilize these findings for investment decisions and post-acquisition risk management.
For the fiscal year 2025, human rights risk assessments were carried out across 26 Group companies within the scope of our ERM.

<FY2025 Human Rights Assessment - Details>

• The development of mitigation measures is mandatory upon the identification of human rights risks, ensuring a 100% coverage of identified risks with mitigation plans.

Human rights risk map for FY2025

Based on the assessment results, we create and update our “Human Rights Risk Map” once a year.
In this map, we evaluate identified risks on a two-axis matrix of “severity”^*1 and “likelihood of occurrence”^*2. At the same time, we analyze these risks from multiple perspectives, considering the Group’s relationship to each risk (whether solely or collectively) and our degree of involvement (whether we cause, contribute to, or are directly linked to the impact), to organize and determine priority issues to be addressed.

1. Evaluated based on scale (gravity of the adverse human rights impact), scope (range of the adverse impact), and irremediability (difficulty of restoring affected individuals to their original state prior to the impact).
2. Evaluated based on the likelihood (frequency) of the risk actually occurring, specifically on a scale of 'approximately once every n years.'

Step2･3 Identification of Priority Issues, Prevention & Mitigation of Adverse Impacts, and Tracking of Execution Status & Results (Monitoring)

The Group promotes specific initiatives to prevent and mitigate adverse impacts on the priority issues identified through our human rights risk assessments. We also assess the effectiveness of these initiatives through ongoing monitoring and strive for continuous improvement.
In FY2025, we newly designated “Access to Services” as a priority issue. This encompasses risks that could infringe upon customers’ right to access services due to business suspension or stagnation caused by extreme weather events driven by climate change, earthquakes, pandemics, system failures, or labor shortages.

FY2025 Priorities: Building Human Rights DD Frameworks and Enhancing Group Knowledge

To embed business and human rights initiatives across all Group companies, we continuously conduct study sessions and training tailored to different organizational levels. In our WG activities for FY2025, we prioritized “building a framework for implementing human rights DD” and “enhancing knowledge across the Group” for our members.

■Shift in Participant Mindsets and Tangible Outcomes
The greatest achievement of our FY2025 activities was the “transformation of mindset” among participants. Through the WGs, the recognition has taken root that addressing human rights is not merely about regulatory compliance, but is a key strategy for enhancing corporate value, creating business opportunities, and protecting our corporate reputation.
In particular, the study sessions with invited external experts (Sessions 1 and 2) provided valuable opportunities to deepen understanding of international trends and the perspectives of rights holders. This led to concrete behavioral changes, with approximately 60% of participants reaching the level of “being able to take action on their own.” Furthermore, the learning within the WGs has developed into concrete actions across the entire organization, such as reflecting these insights into each company's own human rights risk assessment and conducting independent internal training.

■Practical Learning in WGs and Future Outlook
In the third WG session, we conducted small-group discussions and shared best practices on highly requested topics, including “how to conduct risk assessments” and “embedding human rights awareness internally,” thereby fostering opportunities for Group-wide collaborative problem-solving.
The activities in FY2025 served as a solid foundation for advancing from acquiring foundational knowledge to proactive, independent implementation in each company. In the post-session survey, we received many practical and forward-looking comments indicating a commitment to securing management buy-in and embedding awareness throughout the organization, such as, 'I want to utilize this when briefing our management' and 'It helped us identify potential human rights risks within our business.'

Human Rights Awareness Training for All Executives and Employees

With the aim of deepening mutual understanding among employees based on respect for human rights and creating a supportive, rewarding, and vibrant workplace, we conduct “Sustainability and Human Rights Training” for all executives and employees every year.
In this training, while promoting awareness of the “Group Policy for Human Rights” and continuously learning about the outline of “Business and Human Rights,” participants also study a wide range of human rights issues that reflect contemporary social concerns.

Study Sessions for Group Executives

In addition to human rights awareness training for all employees, we conducted study sessions for Directors and Executive Officers, inviting an external attorney as a guest speaker. The sessions aimed to deepen understanding and proactive implementation at the management level.
We reaffirmed “why SOMPO needs initiatives to respect human rights now,” and, in light of global sustainability trends and the current landscape of Japanese companies, deepened discussions on the specific responses and roles required of Directors and Executive Officers.

"Leakage of Customers' Personal Information or Infringement of Privacy"

We recognize that the “leakage of customers' personal information or the infringement of their privacy” is an issue of extremely high priority from both human rights and compliance perspectives. To improve the knowledge and awareness of our employees and the organization as a whole, we conduct regular mandatory training.
In this training, we classify potential accident types and strive to enhance knowledge and awareness through both self-study and organizational learning. Furthermore, in the unlikely event of an information leakage incident, we respond based on specific rules that define a clear, sequential process—from the initial response flow to the formulation of preventive measures and confirming that they are fully embedded across the organization.

Establishment of Customer Harassment Response Framework

We believe that creating a workplace environment where employees can work safely and in good health, both physically and mentally, is essential. Protecting each and every employee from acts that may be considered customer harassment is also necessary to ensure the continued provision of high-quality services to our customers.
To this end, we provide Group companies with materials to support the establishment of customer harassment response frameworks, referencing sources such as the “Manual on Customer Harassment Prevention for Corporations” published by the Ministry of Health, Labour and Welfare.
At the Group company level, for example, Sompo Japan Insurance is promoting initiatives such as publishing its “Policy on Customer Harassment,” conducting employee education and training, and establishing consultation and reporting frameworks for employees.

Initiatives for deterrence and prevention of harassment incidents

In order to build a sound work environment free from harassment, the Group positions the deterrence and prevention of harassment incidents as an important management issue. To achieve this, we have set the year-on-year reduction in the number of harassment cases recognized as a key KPI and are prioritizing the initiatives below to strengthen prevention and appropriate responses when incidents occur.

1) Through the “Group Common Competencies,” which were formulated in November 2024 based on SOMPO’s Values (Integrity, Self-motivation, and Diversity), we encourage behaviors such as recognizing others with respect, active listening, and constructive dialogue. By integrating these perspectives into our evaluation system and promoting daily behavioral change, we seek to foster a corporate culture that prevents harassment.
For further details, please refer to Human Resource Strategy.

2) Based on the revised standards for appointing Directors and Executive Officers and for promoting employees to management positions, we are thoroughly ensuring that we do not appoint employees who were involved in past harassment incidents or who are considered to pose harassment-related risks.

3) In the Guidance on the Compliance Code of Conduct, an explanatory guide to the Sompo Group Compliance Code of Conduct, we present zero tolerance for all forms of harassment as a behavioral standard and clearly identify consultation channels for employees who become aware of concerns or issues, with the aim of fostering an environment in which employees feel comfortable seeking advice.
For further details, please refer to Sompo Group Compliance Code of Conduct.

4) We have revised our disciplinary rules to clarify what types of misconduct may result in disciplinary action and the level of disciplinary action that may be taken. This is intended to raise employee awareness of appropriate conduct. We have also introduced a new Group-wide process for determining disciplinary action. By clarifying the standards and the factors considered in determining the severity of disciplinary action, we aim to promote consistency in decision-making and enhance transparency.

5) We have revised our harassment prevention training for all managers across the Group. The training incorporates case-study videos based on actual incidents within the Group, presenting both the perpetrator’s and the victim’s perspectives. Through discussions, the training is designed to enhance awareness of harassment risks and encourage participants to reflect on their own behavior and make necessary changes.
The training also uses specific examples to clarify the distinction between appropriate guidance and harassment, helping managers carry out their responsibilities with confidence without becoming overly cautious. In the post-training survey, 98% of participants responded that the training helped them view harassment as an issue relevant to themselves.

Through these initiatives, we have observed increased employee awareness of human rights and a stronger sense of responsibility for creating a healthy workplace, as reflected in an increase in early-stage consultations and reports from third parties. In FY2025, 23 harassment incidents were substantiated across the Group, representing a decrease of 10 cases from the previous fiscal year.
Where incidents occurred, we took appropriate measures, such as disciplinary actions, based on the circumstances of each case.
We will continue to strengthen our efforts to prevent and eliminate harassment.

Excessive working hours

The fiscal year 2025 risk assessment revealed that 80.7%^* of the Group companies within the scope of ERM identified the risk of "excessive working hours for their employees and for workers in their supply chain. "All affected organizations are formulating and implementing measures aimed at mitigating the risk of excessive working hours.

• Calculation based on the number of companies

Migrant workers—Coexistence with diverse talent and respect for human rights

Sompo Care is promoting the development of an environment where diverse talent can thrive regardless of nationality, in order to help resolve the social issue of the supply-demand gap in Japan’s nursing care workforce.
In light of this, to ensure that overseas personnel are able to work and grow with confidence, we provide an initial orientation program (a 16-day group training) and first-year training after arrival in Japan. These programs aim to foster mutual understanding of cultures and customs, while preventing discrimination and harassment. In addition to improving job-related skills, the training also offers practical support for daily life in Japan, such as guidance on using public transportation and navigation apps.
Following assignment to a workplace, we continue to provide on-the-job and follow-up training, along with ongoing support for Japanese language learning and professional certification. Through these efforts, we are building a work environment where overseas personnel can enhance their expertise, and where individuals with diverse backgrounds can grow together.

Step４　Disclosure of information

In accordance with the “SOMPO Group Policy for Human Rights,” we actively disclose and report on the progress of our initiatives to address adverse impacts on human rights through our official website and sustainability reports, and also publish our Statement on the UK Modern Slavery Act.
We place great value on two-way communication with stakeholders through these disclosures, reflecting the feedback received in our human rights impact assessments, reviews of various processes, and the continuous improvement of our framework.

• Integrated Annual Report
• Our Response to the Modern Slavery Act
• Modern Slavery Act Policy and Statement

3. Remedy Mechanisms

Basic Policy and Commitment to Remedy

The Group is deeply aware that our business activities have the potential to cause adverse impacts on human rights. Mitigating these adverse impacts and providing appropriate remedy are essential elements for us to fulfill our responsibility to respect human rights.
To fulfill this responsibility, in addition to our existing whistleblowing system, we have established and maintained a framework to broadly accept complaints, consultations, and opinions related to human rights from a diverse range of stakeholders and rights holders. Through this framework, we aim for the early detection and swift resolution of human rights violations, provide appropriate remedy to victims, and ensure that the insights gained are integrated into robust measures to prevent recurrence.

Protection of Persons Making Reports or Seeking Consultation and Strict Privacy Safeguards

In receiving reports and consultations, we strictly ensure anonymity and take the utmost care in handling personal information and consultation details. We thoroughly protect those who make reports or seek consultation, as well as all stakeholders, to ensure that they are not subjected to retaliation or any other adverse treatment for doing so.
Furthermore, to continuously enhance the effectiveness of our grievance mechanisms, we engage in constructive dialogue with external parties, including NGOs with specialized expertise in human rights. By transparently sharing the current status and operational challenges of our consultation channels, we obtain feedback aimed at improving accessibility and establishing rights-holder-centric (victim-centric) operations, which we directly reflect in refining our operational framework.
Going forward, alongside further improving accessibility to our remedy channels, we will promote group-wide awareness of our internal whistleblowing system and enhance the expertise of personnel handling consultations. Through meaningful dialogue with all relevant stakeholders, we remain dedicated to building and refining grievance mechanisms with even greater effectiveness.

Receiving and responding to opinions and complaints (voice of customers)

Sompo Japan Insurance considers expressions of dissatisfaction from customers regarding its overall business to be complaints. We handle all complaints received from customers seriously, addressing them through a fair and highly transparent process. By aggregating and analyzing the trends and details of these complaints, we use the findings to identify and prevent adverse impacts on human rights and prevent their recurrence. In addition, we will promote continuous improvements to our operations, products, and services.

• System to Utilize Voice of Customer (VOC) in Management (in Japanese)
• Complaints Received (in Japanese)

Reporting and consultation systems from employee and corrective measures

In order to build a comfortable workplace environment, the Group strives to quickly identify information related to problematic conduct in the workplace, including harassment, bullying, and abusive behavior.
As part of this effort, in addition to a reporting and consultation hotline for compliance in general, we have established a human rights consultation hotline and accept individual consultations by phone and email.
If any of the reports or consultations received raise concerns or problems that are suspected to be in violation of laws and regulations, internal rules, or the spirit of the Sompo Group Compliance Code of Conduct, the Company will conduct an investigation in a strict and fair manner.
If misconduct is confirmed, we will implement corrective measures, such as disciplinary action, against the violators based on the standards and requirements stipulated in employment contracts and the Rules of Employment.

• Whistle-blowing and Consultation System
• Sompo Group Compliance Code of Conduct

Human Rights Consultations from Outside the Company

As an important channel for receiving opinions and consultations on human rights from a diverse range of external stakeholders, including the Group's direct business partners and suppliers throughout our supply chain, we have permanently established an “Inquiry Form” on our official website.
Even in cases where we do not directly cause or contribute to adverse human rights impacts, we place strong emphasis on dialogue with both affected rights holders and investee companies when we are “directly linked” to such impacts through our investee companies or business relationships.
As a concrete example in 2025, upon receiving a consultation from a user of a facility operated by one of our investee companies regarding their initial response and communication, we engaged in sincere dialogue with the affected rights holder (the facility user) to gain a deep understanding of their concerns. Simultaneously, we conducted direct engagement with relevant departments of the investee company, encouraging them to consider appropriate remedial actions and a review of their operational procedures. Through dialogue with both parties, we successfully facilitated a sincere response and a commitment to continuous improvement from the investee company.
Our specialized and relevant internal departments take all submissions seriously and handle them appropriately. The learnings and insights gained through this process are reflected in the formulation of preventive measures against recurrence and the continuous improvement of our overall business activities.
This consultation channel also supports English-language inquiries, accommodating consultations from overseas. Considering the official languages of our key operating regions, we have established and maintained a framework that ensures accessibility for the vast majority of our stakeholders.

• Other Inquiries to Sompo Holdings

Dialogue with Stakeholders

To further deepen our initiatives to respect human rights, the Group places great importance on dialogue with a diverse range of stakeholders, including Group companies. Through dialogue, we deepen our understanding of the mutual impacts between human rights issues and business activities, as well as adverse impacts, reflecting the insights gained in the initiatives of each Group company.

Dialogue with Group Companies

As the Secretariat of the Business and Human Rights WG, we identify specific needs through direct dialogue with each Group company and provide support for human rights risk assessments and framework development. In addition, within the WG, we promote the following activities to enhance knowledge across the Group and raise the overall level of our initiatives:

• Study sessions to enhance knowledge: regularly providing a forum to learn about the latest trends and expert knowledge related to “Business and Human Rights”
• Sharing good practices and discussions: sharing exemplary cases from each company and promoting their adoption across the Group.
• Conducting status surveys: visualizing the progress of initiatives at each company through regular surveys and using the results to refine our operations and support.

Human Rights Consideration in Advertising Activities

In dialogue with external experts (attorneys, etc.), we received advice that, regarding the decision-making processes for our advertising activities, “ensuring transparency that allows us to explain the basis for our judgments to stakeholders” is essential. In addition, in dialogue with media companies, we were advised that it is extremely important not to stop at a superficial or checklist-based approach, but to address the following points:

• Clarifying the purpose of the dialogue and devising appropriate methods to disclose the information obtained.
• Systematically establishing “principle-based internal rules” rather than relying solely on ad-hoc, case-by-case responses.

Taking these recommendations and insights seriously, we will further enhance our initiatives to respect human rights in advertising activities by building transparent decision-making processes, strengthening dialogue with media companies, and referencing international best practices.

Integrated Initiatives for Climate Change and Human Rights

We engaged in meaningful dialogue with external experts regarding the impacts of climate change on human rights, the importance of integrating environmental and human rights initiatives, and effective information disclosure.
Through this dialogue, we gained multifaceted insights that will contribute to our future tangible initiatives, such as the potential for business collaborations that simultaneously mitigate environmental impacts and support vulnerable populations. Furthermore, we held in-depth discussions on further deepening human rights considerations in our nursing care business and the importance of comprehensively re-evaluating our existing products and services from both human rights and environmental perspectives, strengthening our commitment toward the realization of a sustainable society.
Through this series of dialogues, the Group has once again deeply recognized the necessity of embedding respect for human rights into the foundation of all business activities, and we will proceed with integrating this perspective into our operations.