1. Scope of Application

This Policy applies to all officers and employees of the PHC Group. Furthermore, we expect all suppliers and business partners to support this Policy and respect fundamental human rights.

2. Respect for Human Rights

The PHC Group respects and promotes fundamental human rights across all areas of its business activities and across the entire value chain. The PHC Group respects international human rights standards, including the International Bill of Human Rights (comprising the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights) and the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work. We also support the United Nations Guiding Principles on Business and Human Rights and strive to meet our responsibility to respect human rights in accordance with these standards.

The PHC Group complies with the applicable laws and regulations of all countries and regions in which it conducts its business operations. In instances where there are conflicts or contradictions between domestic legal requirements and internationally recognized human rights standards, the PHC Group shall always comply with applicable laws, while striving to respect and uphold internationally recognized principles to the fullest extent possible, taking appropriate and responsible measures to address adverse human rights impacts.

3. Governance

The implementation of this Policy is overseen at the highest level by the Board of Directors, while the Sustainability Committee provides instructions for execution and conducts monitoring.

4. Due Diligence

The PHC Group respects and promotes fundamental human rights in all areas of its business activities and throughout its entire value chain. Through the due diligence process, we identify any adverse human rights impacts we are involved in, and work to prevent and mitigate such identified impacts. In cases where our products or services are directly linked to adverse human rights impacts through business relationships, we will work to support our business partners in managing such adverse impacts as appropriate and we will seek to use our leverage where appropriate to manage those impacts as required.

5. Stakeholder Engagement

The PHC Group recognizes the importance of the engagement with stakeholders in each stage of the human rights due diligence process, including impact assessment, implementation of preventive and mitigating measures, tracking the effectiveness of initiatives, and disclosure of information. In particular, we pursue to pay special attention to the human rights of vulnerable groups, such as those who frequently face discrimination and prejudice.

Furthermore, even in cases where it is challenging to directly engage with stakeholders due to the complexity of the value chain and difficulties in reaching upstream, the PHC Group strives to reflect the voices of stakeholders through methods such as utilizing third-party organizations or collecting information indirectly.

6. Remedy

In the event that we identify that we have caused or contributed to adverse human rights impacts, we will take appropriate and necessary remedial actions. For adverse human rights impacts directly linked to our operations, products, or services, we will seek to encourage our business partners and other relevant parties to provide remedy. We strive to establish effective whistleblowing and grievance mechanisms in order to identify and address human rights issues related to our business activities. These mechanisms include measures to ensure confidentiality and anonymity. Furthermore, we strictly prohibit retaliation against individuals who raise human rights-related concerns in good faith.

7. Communication and Training

The PHC Group will communicate the Policy to all officers and employees. In addition, they shall receive regular training on this Policy, as part of the compliance training program.

8. Disclosure

The PHC Group will continue to disclose this Policy and the progress of its efforts to respect human rights through its official website and Integrated Report.