TSUDAKOMA

We aim to build a comfortable, fulfilling workplace that respects basic human rights, recognizes diverse individual values, and is free of discrimination.
To prepare for cases in which such things occur, we have established a human rights hotline and a law hotline, and strive to protect victims and whistleblowers.

TSUDAKOMA Hotline Rules

As an internal reporting system for legal violations, we have established the "TSUDAKOMA Law Hotline," where attorneys are the point of contact. In addition, to report human rights issues, we have established the "TSUDAKOMA Human Rights Hotline," in which the human resources department is the point of contact. The TSUDAKOMA hotlines operate as described below.

1. Company directors and all other people shall not respond to internal whistleblowers with disadvantageous treatment. Those who violate this will be subject to appropriate disciplinary action.
2. Whistleblowers shall not intentionally make deceitful reports.
3. The attorney or the head of the HR department who receives the report (hereinafter, referred to as the "responsible point of contact") shall take the following measures. Note that to protect whistleblowers, the facts of the reporting can be generalized or abstracted when being reported to the company.
   1. A report, statement, or consultation (hereinafter, referred to as "report, etc.") is received from a whistleblower, and a decision is made regarding whether investigations are necessary. Reports are received regardless of whether they are anonymous.
   2. For a report, etc. for which investigations are necessary, the necessary investigations, such as hearings, are held, and the results and opinions regarding legal judgments are reported to the director in charge of compliance. If a legal opinion is needed regarding a human rights-related report, the responsible point of contact requests the opinion of an expert.
   3. If it is decided that investigations are unnecessary, a notification of that decision is given to the whistleblower.
   4. There shall be no obligation to make such a report to an anonymous whistleblower.
   5. Except in the case of necessity in investigations, the responsible point of contact shall not disclose information that could identify the whistleblower to any other parties.
4. The director in charge of compliance who has received the report from the responsible point of contact shall promptly conduct an investigation regarding the facts, summon related parties to hold a response meeting as necessary, and carry out measures.

Established August 2008
Revised June 2019