Supply Chain Management

In order to sustain the PERSOL Group's business, a healthy cooperative relationship with our business partners is essential. Our sustainability initiatives cannot be achieved by the PERSOL Group alone—this is only possible with the cooperation of our business partners throughout the supply chain (customers, contractors, suppliers of services and equipment, etc.).
In November 2024, we established the "Supplier Code of Conduct," outlining the compliance requirements for all our suppliers, and the "Procurement Policy," which we ask new suppliers to understand as the foundation for conducting business with us.

In order to fulfill its responsibility towards achieving a sustainable society, the PERSOL Group asks all suppliers to comply with the following principles:

1. Compliance with Laws and Ethical Conduct

• Comply with the applicable laws and regulations related to fair transactions in each country and region.
• Prevent fraud and conflicts of interest and ensure transparency and ethical conduct in all transactions.
• Refrain from engaging in any bribery, corruption, extortion, or embezzlement.
• Avoid participation in unfair trade restrictions, price fixing cartels, and other anti-competitive practices.
• Refrain from retaliating against employees or contractors that elect to report to relevant government authorities, any observed or suspected contraventions of applicable laws or this supplier code of conduct.

2. Respect for Human Rights

• Respect the human rights of all employees, and do not tolerate any form of forced labor, child labor, human trafficking, and unfairly low-wage labor.
• Avoid the use of conflict minerals (such as tantalum, tin, tungsten, and gold) which might infringe human rights.
• Eliminate any form of discrimination and harassment based on gender, sexual orientation, age, race, nationality, creed, religion, disabilities, etc.
• Strive to implement key international business and human rights standards, such as the UN Guiding Principles on Business and Human Rights.
• Strive to include the labor and human rights content of this Supplier Code of Conduct in contracts with your own suppliers.

3. Occupational Health and Safety

• Comply with laws on labor hours and make every effort to reduce excessive working hours for all employees.
• Provide a healthy and safe working environment for all employees.
• Comply with local safety laws and regulations, and take preventive measures to avoid workplace accidents and incidents.
• Implement procedures to effectively report and investigate workplace　incidents, injuries, and emergencies. And ensure timely medical assistance is provided to those affected.

4. Fair and Appropriate Payments

• Ensure that employee wages comply with the statutory minimum wage laws in each country and region, and pay appropriately.
• Consider paying wages to meet the basic needs of life in the countries where employees work.
• Adhere to applicable laws regarding wages and benefits, including minimum wage, overtime pay and allowances.
• Prohibit retention of identity documents and the charging of fees to prospective employees in your recruitment process.

5. Freedom of Association

• Respect for the right of freely forming association, unionization, and collective bargaining in accordance with laws in each country and region.

6. Environmental Considerations

• Comply with all applicable environmental laws and regulations in the countries and regions where business activities are conducted.
• Consider any risks for climate change and promote the reduction of greenhouse gas emissions and improvement of energy efficiency.
• Make every effort to use sustainable resources, select materials with low environmental impact, use water and energy efficiently, prevent pollution, and reduce waste.
• Embrace circular economy principles and strive to reduce environmental impacts throughout all stages of the product and services life cycle, including design, manufacturing, distribution, use and end-of-life management.
• Supply verified data on scope 1, 2 and 3 greenhouse gas emissions and energy consumption for the products and services provided as much as possible.

7. Quality Management and Stable Supply

• Establish a quality management system for products and services, and consistently maintain high quality.
• Ensure a stable supply of products and services, and minimize the risk of supply interruptions.

8. Information Security

• Strictly manage confidential information provided by PERSOL Group and its customers, and prevent unauthorized use, destruction, and leakage.
• Strictly manage personal information of your own company, customers, and third parties, and promote initiatives to protect privacy.
• Establish and maintain adequate processes and controls to ensure compliance with applicable security and privacy laws, as well as our contractual obligations of PERSOL Group companies involved in transactions with you.

9. Transparency and Accountability for Supply Chain

• Disclose relevant information timely, legally, and appropriately when the PERSOL Group evaluates compliance with this supplier code of conduct.
• Explain this supplier code of conduct　to your suppliers and promote their compliance with this supplier code of conduct.
• Ensure the traceability of conflict minerals and respond to requests for reports by the PERSOL Group.
• Respond to corrective actions requested by the PERSOL Group in case of violations of this supplier code of conduct.
• Establish procedures that enable employees to raise workplace concerns including human rights violations, code of conduct breaches with management for resolution, and ensure these procedures are clearly communicated.

PERSOL HOLDINGS CO., LTD.
Representative Director, President and CEO
Takao Wada
Enacted November 1, 2024

When commencing business with a new supplier, the Group's risk and compliance-related divisions conduct a variety of screening procedures before concluding a contract in order to minimize risk. On such occasions, we request that new suppliers understand the Group's approach to procurement and agree to abide by these principles.

One of our consolidated subsidiaries, Programmed a large Australian and New Zealand maintenance services and labour provider, does not engage in manufacturing activities, and therefore does not have significant supply chain concerns in relation to the sourcing of goods or materials. However, through the maintenance services and facility management activities it performs, it does leverage a pool of subcontractors and suppliers to assist in providing their services. As a result, Programmed maintains visibility over its subcontractors and suppliers through a range of controls to identify and minimise the risk of modern slavery exposures arising.

All of Programmed's suppliers must comply with all applicable human rights and employment laws in the jurisdictions in which they operate. This includes complying with the Modern Slavery Act 2018 as part of Programmed’s prequalification process. Suppliers and subcontractors are assigned a risk rating according to their procurement category and country. As part of Programmed’s commitment to continuous observation and improvement to its supply chain, Programmed have identified several high risk supply categories for ongoing review.

In response to the Modern Slavery Act, Programmed publishes its
Modern Slavery Statement annually.

Programmed has taken a number of steps to continue its commitment to the eradication of modern slavery in its supply chain. These actions have included;

• reviewing and revising its terms of supply ;
• implementing a training program across the Programmed business ;
• implementing a review of all relevant internal policies ;
• issuing Modern Slavery questionnaires to its suppliers;
• reinforcing our modern slavery expectations within our Subcontractor Handbook; and
• introducing a review program to ensure ongoing compliance with the Act.

In addition to supplier and subcontractor training, modern slavery training has been established to assist internal employees in understanding what modern slavery is, our modern slavery statement and the approach we take to ensuring human rights and protecting against modern slavery involvement both internally and within our supply chain. Mechanisms to raise grievances associated with identified modern slavery exploits such as coercion, exploitation, fair pay, servitude and the like are also described within the training.

Programmed assesses modern slavery risks on supplier and subcontractors through a questionnaire for existing suppliers and as part of our prequalification process for new suppliers and subcontractors. If the supplier indicates that they engage in any of the following types of activities, then they are required to complete a high risk questionnaire.

• Operational sites offshore
• Sub-contracting
• Third-party recruitment
• Workers engaged from overseas
• Promotional merchandising
• Village / home care or nursing works

Programmed continues to risk assess and classify our supplier and subcontractor pool through questionnaires, and to date, we have completed more than 600 assessments on our high risk suppliers. Updates on our progress are made through our annual Modern Slavery Statement.

Programmed plans to develop a modern slavery supplier/subcontractor audit program for those vendors determined to be in the high risk category.