Respect for Human Rights

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Human Rights Policy

The Nittetsu Mining Group set out this Human Rights Policy to function as a code for all Group executives and employees (including contract employees and temporary employees) to follow.
We recognize that our business activities may impact human rights and promote business activities that respect the human rights of all stakeholders by taking action in line with this policy.

1. Basic approach to human rights
   The Nittetsu Mining Group respects the human rights outlined in Declaration on Fundamental Principles and Rights at Work by the UN International Bill of Human Rights and the International Labour Organization (ILO), supports the UN Guiding Principles on Business and Human Rights and other international standards on human rights, and engages in business activities based on the principles therein.
2. Compliance with applicable laws and regulations
   The Nittetsu Mining Group complies with all domestic legislation, laws and regulations that apply in the countries and regions in which it engages in business activities. When there are discrepancies between internationally recognized principles of human rights and the domestic laws and regulations of individual countries or regions, we seek methods that comply with the internationally recognized principles on human rights while complying with local laws and regulations.
3. Scope
   This policy applies to all executives and employees of the Nittetsu Mining Group. Additionally, the Nittetsu Mining Group makes efforts to ensure that its business partners and suppliers also understand and support the policy so that everyone respects human rights together.
4. Priority initiatives for respecting human rights
   The Nittetsu Mining Group focuses on the following matters in efforts to respect human rights.
   1. ・We do not discriminate on the basis of race, nationality, sex, age, religion, beliefs, disability, gender, or sexual orientation.
   2. ・We prevent harassment from occurring in the workplace, and react swiftly and properly when it does occur.
   3. ・We do not engage in child labor, forced labor, or human trafficking under any circumstances.
   4. ・We properly manage working hours and holidays in accordance with laws and regulations, striving to prevent overwork.
   5. ・We pay wages that exceed the statutory minimum wage in a fair and equitable manner, striving to ensure wage standards that reflect living wage considerations.
   6. ・We respect the freedom of association and the right to collective bargaining, and we promote constructive dialogue between labor and management.
   7. ・We recognize that local communities and indigenous peoples have their unique cultures and histories, and we respect their rights as stipulated by local laws and international norms.
   8. ・We acknowledge that the use of weapons by security companies entails potential risks of human rights violations, and if armed security is deemed necessary, we commit to referencing international norms and respecting human rights.
   9. ・We make efforts to establish working environments that are sanitary, comfortable, and healthy in both physical and psychological terms.
   10. ・We aim to foster a bright, open culture that respects free, broad-minded discussion.
5. Implementing human rights due diligence
   The Nittetsu Mining Group implements human rights due diligence in order to identify, assess, and prevent or reduce any negative impacts of our business activities on human rights.
6. Corrective action and relief
   When it is clear that the business activities of the Nittetsu Mining Group are causing or promoting negative impacts on human rights, we take corrective action and provide relief accordingly.
7. Dialogue and discussion with stakeholders
   The Nittetsu Mining Group engages in sincere dialogue and discussion with stakeholders to understand and remedy impacts of our business activities on human rights.
8. Implementing education and awareness-raising activities
   The Nittetsu Mining Group engages in education and awareness-raising activities to ensure the effectiveness of this policy.
9. Whistleblowing systems
   The Nittetsu Mining Group has established and makes efforts to increase the effectiveness of whistleblowing systems for receiving internal and external inquiries and complaints about human rights associated with the Group's business. In the course of responding to these reports, we maintain confidentiality and protect personal information, and do not use the fact that whistleblowers filed reports or complaints as a reason to treat them disadvantageously.
10. Disclosures
    The Nittetsu Mining Group discloses the appropriate information about the status of our efforts to respect human rights through our website, integrated reports, and other means.
11. Systems
    The Nittetsu Mining Group's Sustainability Committee, which is chaired by the Representative Director and President, discusses and considers key challenges pertaining to respecting human rights in addition to responses to the challenges, and discusses and reports the results to the Board of Directors. The Board of Directors complies with this policy and supervises initiatives associated with it.

Established on October 28, 2022
Revised on May 22, 2025

Initiatives

Implementation of Human Rights Due Diligence

We are advancing human rights due diligence initiatives based on the Human Rights Policy to identify and assess potential adverse impacts of its business activities on human rights and to prevent or mitigate such impacts.
Mining is one of the Group's principal businesses, and we are positioned upstream in the resources and materials supply chain. In light of these business characteristics, we are taking a phased approach, initially focusing on identifying and managing human rights risks at the Group's own operating sites as a priority issue.
Human rights due diligence is led by the Human Resources Development Section of the Human Resources Department in cooperation with each business site and affiliated company. The status of these initiatives is also reported to the Sustainability Committee for ongoing review and improvement.
Specifically, we seek to identify potential human rights risks, primarily in labor and ethical areas such as the working environment, occupational health and safety, discrimination and harassment, and working hours, through SAQs (self-assessment questionnaires) for the sites concerned, on-site inspections, employee interviews, and reviews of relevant documents.
We also provide human rights education and awareness-raising activities at the sites concerned to promote understanding of respect for human rights.
In FY2025, we conducted human rights due diligence at two operating sites in Japan. As a result, no serious human rights issues were identified. At the same time, we made recommendations for improvement to the sites concerned regarding matters identified during the review as having room for improvement and subsequently confirmed that corrective actions had been taken.
In addition, to appropriately identify human rights concerns and requests for consultation, we have established a human rights consultation contact through the “Contact Us” section of our website and put in place a system for receiving consultations from both inside and outside the Group. For consultations received, we verify the facts in cooperation with the relevant departments in accordance with the Human Rights Policy and take corrective measures and measures to prevent recurrence as necessary.
Going forward, we will progressively expand the scope of human rights due diligence according to priority and work to reduce human rights risks and raise human rights awareness throughout the Group through continuous monitoring, process improvement, and enhanced education and awareness-raising activities.

Preventing Harassment

We prohibit and have set out policies and regulations to prevent all forms of harassment and discrimination. We will continue to implement awareness-raising activities, including incorporating harassment prevention into training at all levels, having all employees participate in e-learning, and distributing booklets and showing videos to all employees. We will also establish contact points for reporting and consultation to equip the company to take the proper steps to prevent the recurrence of any incidents that occur.

Number of participants in harassment prevention training (total)

1. Note: Only training sponsored by the Human Resources Department of the head office