Infra-Sharing not only reduces costs, but also the material and construction work, as well as electricity consumption, which leads to a lower environmental impact.

We will strive to reduce risks in business by establishing a risk management system that includes not only JTOWER but also partner companies and suppliers in terms of safety in construction and procurement.

1.Basic Concept

JTOWER Inc. (the “Company”) recognizes that respect for human rights is an essential foundation for achieving our vision: "Infra-Sharing Services from Japan Lead the World." We hereby declare our commitment to fulfilling our responsibility to respect all internationally recognized human rights.

2.Scope of Application

This policy applies to all directors and employees of the Company. Furthermore, we expect all business partners and suppliers involved in our business activities to understand and act in accordance with this policy and respect human rights.

3.Commitment to Respect for Human Rights

Support for International Norms

We support international human rights norms, including the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work.

Compliance with Laws

We comply with the laws and regulations of the countries and regions where we operate. If there is a conflict between international norms and domestic laws, we will pursue responses based on the principles of respecting human rights by honoring the higher standard.

Implementation of Human Rights Due Diligence

To identify, assess, prevent, and mitigate potential or actual adverse impacts on human rights from our business activities, we will establish, operate, and monitor (evaluate the effectiveness of) a continuous human rights due diligence mechanism.

Correction and remediation

If it is found that the Company’s business activities have caused or contributed to adverse impacts on human rights, we will work toward correction and remediation through appropriate procedures and dialogue.

Information Disclosure

We will periodically disclose information regarding the status of our initiatives based on this policy.

4.Key Human Rights Issues

Based on the characteristics of our business (sharing, construction, and maintenance of telecommunications infrastructure) and industry trends, we will focus particularly on the following human rights issues:

Forced Labor and Child Labor

We prohibit all forms of forced labor, human trafficking, and child labor. We will strive to ensure that our suppliers involved in the construction and maintenance of telecommunications infrastructure are free from these human rights violations.

Discrimination and Diversity

We do not tolerate any form of discrimination based on race, gender, age, nationality, origin, sexual orientation, gender identity, gender expression, disability, religion, or any other status. We will foster a corporate culture that recognizes diverse values and respects the individuality and diversity of every person.

Harassment

We do not tolerate any form of harassment that undermines individual dignity, including power harassment and sexual harassment, and ensure a healthy working environment.

Occupational Health and Safety

Since construction and maintenance of telecommunications infrastructure involve high-altitude work, we will comply with laws and regulations related to occupational health and safety. We will provide an environment where all employees and partners can work safely and healthily, and strive to prevent industrial accidents.

Freedom of Association and Right to Collective Bargaining

We comply with labor-related laws and respect employees' freedom of association and the right to collective bargaining.

Working Hours and Wages

We manage working hours and pay wages appropriately in accordance with labor-related laws. We respect the concept of equal pay for equal work and strive to maintain a fair compensation system.

Privacy and Personal Information

We will establish a strict management system for the protection of personal information, including customer information, and respect the right to privacy.

Local Communities

We will consider the impact of telecommunications tower construction and maintenance on local communities (such as noise and landscape) and respect dialogue with local residents

5.Responsibility and Structure

The Company will clarify the personnel responsible for promoting the implementation of this policy, with the management team demonstrating their commitment. We will also conduct regular and continuous education and training to ensure that employees act with respect for human rights and to enhance their awareness.

Responsible Officer：Atsushi Tanaka, Representative Director, President and CEO
Structure：Policy decisions are made at Management Meetings. The Human Resources Department and the Administration and Communication Department will lead the promotion of this policy in collaboration with relevant departments.

6.Stakeholder Engagement

In addressing human rights issues, we will engage in sincere dialogue with relevant stakeholders—including employees, business partners, suppliers, local communities, and NGOs/NPOs—and utilize their opinions to promote our initiatives.

7.Grievance Mechanisms

We will establish effective grievance redress mechanisms for both internal and external stakeholders to consult on issues or concerns related to this policy. We will handle such matters with consideration for anonymity and confidentiality so that whistleblowers do not suffer any disadvantage. If a human rights violation is confirmed, we will promptly work toward its correction and remediation.
(Details of the reporting and consultation desks are currently being finalized.)

Safety and Health Patrols

Efforts to identify risks and hazards at an early stage, eliminate them and take measures to reduce them, prevent equipment accidents and information accidents, and ensure thorough safety awareness among workers in construction work.

Efforts for Safety and Health Patrols

• Check whether there is any risk of disaster at a construction site.
• If confirmed, direct the correction on the spot.
• If ""cannot be implemented immediately,"" the work will be discontinued and countermeasures will be considered as soon as possible.
• Check whether the instructed approaches are actually conducted at Safety and Health Meeting and morning meeting.
• Maintain an appropriate tension and focus in the implementation of on-site work.

Safety Conferences

Efforts to review accidents and complaints associated with construction work, prevent the occurrence of similar problems, share the same understanding of construction safety and aim for safe and high-quality construction.

Implementation

Date	June 14, 2024
Participants	Subcontractors of IBS Construction Dept., Tower Construction Dept., and Construction Management Dept. of JTOWER Inc.
Style	Online（Zoom）
Number of participants	37 companies（261 people *Including the number of connections）
Contents	Review accidents and complaints Introduction of safety initiatives at each construction company Feedback from JTOWER for the completion inspection reports (submitted from construction companies)
Plans for future initiatives	We plan to hold the next meetings in December, 2024.

RoHS Compliant

The components and products used comply with RoHS (Restriction of Hazardous Substances Directive), the European Union directive on Restrictions on the Use of Certain Hazardous Substances in Electronic and Electric Equipment.

ISO9001/ISO14001

We have introduced ISO9001 and ISO14001 acquisitions as terms for suppliers that we believe are relevant to environmental and employment issues, and we continually review their condition, including their subsequent renewals.

Factory audits

Periodic factory audits of suppliers are conducted to verify safety and health, the qualifications of workers, and the working environment.

Utilization of Recycled Materials

Utilize recycle materials for interior design.

Reduction of office furniture disposal

Use a subscription service for office furniture. Realized a system that does not dispose furniture while flexibly responding to changes in working styles.

Promoting Wellness

In addition to comfortable working spaces, we will provide office spaces that enable employees to work in good physical and mental health by making communication and refreshing spaces.

Company-wide meeting

Regular company-wide meetings are held to promote understanding of the company and share information. At the same time, a social gathering is held aiming for further communication among employees.

President Lunch

President Lunch is held regularly to deepen communication between top management and employees and to share various opinions and thoughts.

Corporate Vision Committee

Established a committee to promote understanding of the corporate vision by young employees across departments.

Codes of Conduct Award

The award system for the employee who embodies Code of Conduct.

Human resource development

Based on JTOWER Code of Conduct, we aim to create an organizational structure in which diverse human resources can realize their own growth and corporate growth while maximizing their own capabilities and individuality.

Indicator	FY2023 result	Target
Training costs per employee	36,173 yen /person	5 times by FY2026 (compared to FY2022, 46,490 yen/person)
Number of training programs	Manager：4	3 times by FY2026 (compared to FY2022, Manager 9, General employee 3)
	General employee：3 New graduate：28	3 times other than new graduates by FY2026 (compared to FY2022, Manager 9, General employee 3)
Retirement rate	15.5%	Less than10%

Establishment of Internal Environment

In line with the changes in employees' life stages, we have established a system that enables employees to control their work-life balance.
At the same time, we have set the targets with the aim of creating a safe and secure work environment.

Indicator	FY2023 result	Target
Paid vacation usage rate	73.3%	75% by FY2026
Return to work after childcare leave	100%	Keep 100%
Number of Industrial accidents	0	Keep 0

JTOWER Code of Conduct

1	Always be sincere	Face with our customers, business partners, colleagues, and all of our stakeholders in a sincere manner. And always ask ourselves if we are sincere.
2	Take on challenges until we know better	With high aspirations, we will take on challenges without compromising the status quo. Learning both success and failure, we aim to grow day by day.
3	Snap into action	Reduce the time to start moving into zero. No matter how valuable it is, there is no point without working on it.
4	Keep going until we achieve our goals	We take full responsibility for the work ensuring results. We don’t let our guard down until the very end.
5	Ask for help	When in trouble or distress, talk to people around you and ask for support. We have no members who are asked for support and do not respond to it. So feel free.

Empowering Women in the Workplace

Active recruitment and nomination to motivated women can work energetically. As of April 1, 2024, female workers accounted for 7.5% of managers.

* % of JTOWER Inc.

Given this recognition, and in order to improve the soundness and transparency of management, improve efficiency, and raise corporate value consistently over the long term, JTOWER makes every effort to enhance its corporate governance in the pursuit of speedy, rational decision-making and more efficient business operations.

Corporate Governance System

We have established General Meeting of Shareholders, Board of Directors, Audit & Supervisory Board Members, and Accounting Auditors as organizations under Companies Act. The Board of Directors, which is composed mainly of directors who are familiar with our business, carries out basic management policies and important business execution decisions and Audit & Supervisory Board Members with expertise in each field conduct audits from a fair and independent perspective. We believe the current system is effective in ensuring the soundness, transparency and efficiency of management. In addition, we collaborate with outside lawyers when making compliance and important legal judgments.

Strengthening compliance

In order to fulfill our social responsibility to take a part of the telecommunications network, achieve sustainable growth and realize our vision of "Infra-Sharing Services from Japan Lead the World," we set "Integrity" as an important keyword and have expressed the following basic policy for compliance(*).

*“Compliance” refers to the efforts of each and every employee under the managements, with high ethical standards, to comply with laws, regulations, and social norms, and to thoroughly conduct themselves with integrity.

Supplemental Principles

(1) Act with integrity as a member of society and in compliance with laws and regulations

• We will conduct fair business transactions in compliance with laws and regulations, social norms, and internal rules.
• We will always act with an attitude of sincerity, being aware that we are a member of society.
• We will strive for a smooth exchange of opinions and make fair internal decisions in accordance with internal rules.
• Each of us will faithfully perform our duties and will not commit any wrongful acts.

(2) Protect and manage information appropriately

• We will strictly manage information obtained through our business operations in compliance with relevant laws.
• We will adopt an adequate framework to manage information security and provide a safe IT environment.
• We will strictly manage and handle personal information in accordance with our personal information protection policy.

(3) Strive to disclose information appropriately

• We will disclose information in an appropriate manner to gain the understanding and trust of society.

(4) Maintain sound relationships with business partners

• We will not engage in transactions with anti-social forces such as organized crime groups and corporate racketeer.
• We will maintain fair and free relationships with business partners and will not make unreasonable demands (including bribery and other corrupt acts).
• We will not engage in any illegal or corrupt activities.

(5) Realize a safe and healthy work environment with high moral standards

• We will comply with laws, regulations, and other requirements related to health and safety.
• We will strive to prevent harassment of any kind and maintain a working environment with high morals.
• We will respect each other and create an attractive working environment.

Compliance system

We are implementing various initiatives to ensure thorough compliance by establishing a compliance system in which the head of Corporate Department is responsible for company-wide compliance. In addition, the person in charge of internal audits under the direct control of Representative Director and President is appointed to conduct periodic audits of the business execution and compliance status of each department, and the evaluation is reported to Representative Director and President and Audit & Supervisory Board Members.

Compliance hotline

We have established an internal reporting system and set up a contact point to properly operate and respond to violations of laws and other legal suspicions. In order to strengthen compliance managements, we have established the system for appropriate handling of requests for advice or reports of organizational or personal violations of laws and regulations from our employees, contract employees, part-timers, temporary workers, dispatched workers, and retirees, ensuring early detection and correction of improprieties.

Corruption prevention initiatives

We have set Compliance Rules and Anti-Bribery and Corruption Rules which do not allow any bribery or corruption, and our managements and employees shall not be involved in any bribery or corruption. We strive for fair transactions based on the premise of compliance with the anti-corruption laws of each country and will continue to strengthen our anti-corruption efforts.

Basic approach and systems to exclude anti-social forces

Our basic policy is to not have any relationships with antisocial forces and to reject any unfair demands, and we have clearly stated this in various internal rules and regulations. In addition, when it is found that a business partner is an individual, company, or organization involved with antisocial forces, the business is terminated.

Corporate Department acts as the responsible department for antisocial forces, and centrally manages and accumulates related information. In the event of undue claims by antisocial forces, we cooperate with the police, external law firms, and other external specialized organizations to establish a cooperative system in the event of an emergency.

Corruption prevention initiatives

We have set Compliance Rules and Anti-Bribery and Corruption Rules which do not allow any bribery or corruption, and our managements and employees shall not be involved in any bribery or corruption. We strive for fair transactions based on the premise of compliance with the anti-corruption laws of each country and will continue to strengthen our anti-corruption efforts.

Management system

Entertainment expenses and gifts will be provided only after following the required procedures based on the rules stipulated in regulations and accurate records of all transactions will be kept.
In compliance with laws and regulations, we prohibit the expenditure of entertainment expenses for public officials except in exceptional cases where the expenditure is in accordance with social norms without being extravagant or excessive. We also prohibit facilitation payments (small informal payments made to individual public officials for the purpose of facilitating ordinary administrative measures) and political contributions.

Obligation to report

Managements and employees shall report any bribery or corruption in accordance with the internal reporting system regulation.

Thorough understanding

• Legal Department, which is responsible for compliance-related operations, is responsible for Anti-Bribery and Corruption Rules.
• Legal Department shall ensure that managements and employees are fully aware of this rule and shall prevent bribery and corruption.
• Legal Department shall disseminate relevant information at least once a year (including the notification in writing).

Training

Annual training plans are established for managements and employees, and regular training sessions are conducted on compliance, harassment, prevention of insider trading, information security and other subjects.

JTOWER believes that Infra-Sharing in itself leads to the realization of Sustainable Society