Social

Human Capital

Respecting Human Rights

Basic Approach

The HOYA Group respects the human rights of all officers and employees of the HOYA Group and all stakeholders involved in the business activities of the Group. The Group advances efforts on human rights in accordance with the UN Guiding Principles on Business and Human Rights.

To clarify its commitment to respecting human rights, the HOYA Group established the HOYA Group Human Rights Policy with the approval of the Board of Directors. The policy is based on international principles and guidelines, including the UN International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, and the Ten Principles of the UN Global Compact. Based on this policy, the Group puts its respect for human rights into practice through human rights due diligence, relief measures, stakeholder dialogue, awareness-raising and education, and disclosure. The Human Rights Policy is published on the HOYA Group website in Japanese and English to promote awareness among stakeholders.

HOYA Global Code of Conduct
Formulated based on the Group’s Corporate Mission and values, the HOYA Global Code of Conduct stipulates basic guidelines to be complied with when performing operations. The Code clearly states that basic human rights must be respected, discrimination and harassment eliminated, and child labor, forced labor, and human trafficking prohibited. It also aims to create a safe and healthy workplace where employees can feel secure while they work.

Reflecting the Group’s global operations, the Code has been translated into 27 languages. To promote understanding of the Code, all Group employees participate annually in e-learning and confirmation testing. The Group also conducts internal audits to verify that these procedures are properly implemented. In FY2025, the submission rate for confirmations of compliance with the Code of Conduct by Group employees was 99.5%.

Framework
Under the authority of the Chief Sustainability Officer (CSO), the ESG Promotion Office at Group headquarters plays a central role in developing Group-wide human rights policies and plans and monitoring their progress, in collaboration with relevant corporate functions, including compliance, legal, and human resources.

In addition, under the global compliance risk management framework overseen by the Chief Compliance Officer (CCO), the Group addresses compliance matters, including human rights-related issues such as labor compliance, consumers’ and patients’ rights to safety and information, privacy protection and personal information management, and the prevention of bribery and corruption. These activities and their progress are reported regularly to the Board of Directors, and continuous improvement is pursued under the Board’s oversight.

Due Diligence on Human Rights

Due Diligence Policy
Following approval by the Board of Directors, the HOYA Group established the HOYA Group Due Diligence Policy to clarify its basic approach and framework for identifying and assessing adverse human rights impacts, as well as the processes for preventing, mitigating, and remedying such impacts. Based on this policy, the Group identifies and assesses human rights risks in its business activities and value chain and promotes initiatives aimed at preventing and mitigating adverse impacts.

Identification and Assessment of Human Rights Issues (Adverse Impacts)
To identify human rights risks in its value chain, the HOYA Group conducted a human rights impact assessment covering four business divisions: the Eyeglass Lens Division, Medical Endoscope Division, Semiconductor Mask Blank Division, and HDD Glass Substrate Division, taking into account the nature of their businesses and the external environment. In conducting the assessment, the Group drew on the expertise of external specialists and considered international standards and guidelines*1, industry characteristics, country risks, and other external data, as well as interviews with business divisions and relevant corporate functions. Based on these inputs, the Group identified and organized potential human rights issues for each stakeholder group.

The Group subsequently reassessed certain issues through ongoing stakeholder engagement and reviewed its human rights issues based on the results of that reassessment. The revised assessment results for FY2025 are presented in the table below. The Group continues to assess the risk of forced labor within labor compliance and will update its assessment as appropriate in response to changes in circumstances.

*1 These include the UN International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the Ten Principles of the UN Global Compact, and OECD Guidelines for Multinational Enterprises.

Potential Human Rights Issues Identified for Each Stakeholder

Addressing Potential Issues Within the Group

■Wages Paid to Employees
The HOYA Group confirms that employees across its operations are paid appropriately and in compliance with the minimum wage requirements of each country in which it operates. Beyond compliance with statutory minimum wage requirements, the Group continues to examine appropriate wage levels that enable employees to maintain a decent standard of living.

■Prevention of Forced Labor
To prevent forced labor among its employees, the HOYA Group conducts surveys of all employees to better understand actual working conditions.

■Measures for Preventing Bribery and Corruption
In line with the HOYA Global Code of Conduct, the Group has been strengthening its efforts to prevent bribery and corruption. The Anti-Bribery and Anti-Corruption Policy, approved by the Board of Directors, sets out specific rules, management frameworks, and education and training measures designed to prevent bribery and corruption.

Compliance with the Policy and related divisional policies is regularly audited by the Group’s internal audit departments. In addition, all employees receive training on the HOYA Global Code of Conduct. In addition, the Group continues to provide specialized training programs for employees in its Life Care businesses, which are exposed to relatively higher bribery and corruption risks due to the nature of their operations.

In FY2025, there were no politically related contributions and no material violations of anti-bribery or anti-corruption laws requiring public disclosure.

 In the event of suspected misconduct, procedures have been established in accordance with the Company’s disciplinary committee regulations. The responsible department conducts fact-finding investigations, including interviews with relevant parties and the collection of evidence. Based on the findings, the Company determines whether the disciplinary committee should be convened.

The committee deliberates after providing the individual concerned with an opportunity to respond and determines any disciplinary measures through the prescribed decision-making process. To ensure fairness, the process includes safeguards such as the exclusion of persons with conflicts of interest and confidentiality requirements.

For information on how other issues are addressed, please refer to the following webpages.

• Preventing discrimination and harassment: HOYA Global Code of Conduct, Prevention of Harassment

• Providing access to assistance: HOYA Helpline (Whistleblowing and Consultation System)

• Protecting privacy and the security of personal information: Protection of Privacy

• Promoting gender equality: Diversity and Inclusion

• Maintaining occupational health and safety: Health and Safety

Ensuring Compliance Among Suppliers

■HOYA Supplier Code of Conduct
To ensure that suppliers uphold standards of legal compliance and ethical business practices equivalent to those of the HOYA Group, we have established the HOYA Supplier Code of Conduct and request suppliers to acknowledge, sign and comply with it. Reflecting growing global concern over human rights and environmental issues in supply chains, as well as the increasing importance of responsible procurement, we revised the Code in FY2024.

The revised Code requires suppliers to prohibit forced labor, child labor, discrimination, harassment, corruption and bribery, while respecting freedom of association and the right to collective bargaining, securing occupational health and safety, and supporting environmental protection. The HOYA Group will continue to require suppliers to comply with the Code.

To promote responsible mineral procurement, the Group conducts conflict minerals surveys and monitors results based on targets for supplier response rates and the number and percentage of smelters compliant with the Responsible Minerals Assurance Process (RMAP). Through these efforts, the Group works to reduce risks across its supply chain.

• › Supply Chain Management

■Early Initiatives by Business Divisions
Some business divisions have taken the lead in identifying and assessing potential negative impacts within the supply chain ahead of Group-wide initiatives.

The MD Division conducts supplier assessments, including human rights risks, by confirming supplier compliance with the Responsible Business Alliance (RBA) Code of Conduct at the start of business relationships and on a regular basis thereafter.

In addition, PENTAX Medical conducted a pilot questionnaire at selected Europe-based entities prior to global rollout in order to identify and assess human rights risks among suppliers. Human rights policies and declarations, as well as the presence of any negative news, were reviewed as part of the assessment. Based on the results, the division has engaged with suppliers to help mitigate potential adverse impacts.

Going forward, the HOYA Group intends to integrate and expand these divisional initiatives across the Group, with a focus on identifying human rights issues involving a broader range of stakeholders and promoting collaboration through stakeholder engagement.

Ensuring Product Safety for Consumers and Medical Patients
To ensure rigorous compliance with domestic and international standards applicable to Life Care products, as well as relevant laws, regulations, and other guidelines related to product quality and safety, and thereby strengthen its product safety management system, the HOYA Group has operated a Healthcare Compliance Committee composed of Independent Directors since FY2022. Drawing on the objective advice of the Independent Directors serving on the Committee, as well as expert advice where necessary, the Group carries out activities to ensure product safety, led by personnel responsible for regulatory affairs and compliance.

• › Product Safety and Quality

• › Privacy and Data Protection

Corrective and Grievance Mechanisms

As part of its compliance framework, the HOYA Group has operated the HOYA Helpline since 2003 to receive whistleblowing reports and requests for advice from both internal and external stakeholders, including employees of business partners. When violations or suspected violations of laws, regulations or the HOYA Global Code of Conduct are reported, the Group seeks to identify issues at an early stage and respond promptly and appropriately while protecting whistleblowers, thereby supporting sound business operations across the Group.

The HOYA Helpline provides an environment in which anyone can raise concerns with confidence, including 24-hour multilingual web-based reporting, consultation in local languages and the option to report anonymously. Based on rules governing the operation of the helpline in compliance with applicable laws and regulations, the Group strictly prohibits any disadvantageous treatment of whistleblowers and ensures the confidentiality of both reports and whistleblower information. The status of reports received and related responses is reported quarterly by the Chief Compliance Officer (CCO) to the Audit Committee.

In FY2025, there were no reports from within or outside the Group that had a material impact on the Group's business.

• › HOYA Helpline (Whistleblowing and Consultation System)

Employee Education and Training

The HOYA Group conducts ongoing education and awareness initiatives to deepen employees’ understanding of and commitment to compliance, including respect for human rights. To ensure that the HOYA Global Code of Conduct is thoroughly understood and embedded across the Group, all employees are required to complete annual e-learning programs and knowledge assessments.

In addition, to uphold the dignity of every employee and foster a workplace free from harassment, HOYA has established the HOYA Group Policy and Guidelines on Measures to Prevent Harassment. Based on these guidelines and applicable local laws and regulations, the Group provides anti-harassment training to all employees and offers role-specific training programs for managers and supervisors.

Modern Slavery Statement

In accordance with the UK Modern Slavery Act 2015, the HOYA Group publishes a statement describing its efforts to prevent slavery, human trafficking and related practices.

• › HOYA Group – Modern Slavery Statement