Respect for Human Rights

SMS Human Rights Policy

Recognizing that respect for human rights is a social responsibility, SMS and its consolidated subsidiaries (hereinafter "SMS") have established the SMS Human Rights Policy (hereinafter the "Policy") in order to realize our Management Philosophy of "continual growth and contribution to society as an everlasting corporate group," and promote initiatives to respect human rights in accordance with the Policy.

Our basic approach to human rights

SMS supports and respects the International Bill of Human Rights of the United Nations (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), the principles on fundamental rights under the 10 core conventions listed in the Declaration on Fundamental Principles and Rights at Work of the International Labour Organization, and the Ten Principles of the UN Global Compact across its four areas as internationally recognized principles and standards to be observed at a minimum in relation to human rights.

Scope

The Policy applies to all officers and employees of SMS in Japan and overseas. In addition, we encourage SMS's business partners to support the Policy and work together to respect human rights. If the business partners' efforts to respect human rights are inadequate, we request them to take appropriate actions.

Governance Structure

The Sustainability Committee, chaired by the CEO, is responsible for deliberating, formulating, and monitoring the progress of initiatives related to the respect for human rights. Implementation of specific initiatives is managed by the Human Resources Department and the Sustainability Promotion Office, in collaboration with the Risk Management Department.

Human rights due diligence

SMS establishes a human rights due diligence system in line with the UN's Guiding Principles on Business and Human Rights. After assessing the negative impacts on human rights caused or contributed to by our business activities, we incorporate efforts to prevent or mitigate any identified negative impacts into relevant internal processes and take appropriate measures. We continuously monitor the effectiveness of these measures and strive to improve them. We also encourage relevant business partners to respect the Policy in the event that our business relationships result in negative impacts on human rights involving SMS services.
In addition, we will provide education and training to all officers and employees to deepen their understanding of the Policy and respect for human rights, and strive to promote understanding of the Policy among our business partners.
We will appropriately disclose the progress and results of our efforts to respect human rights on this website.
Human rights issues of particular importance to SMS are specified at the end of the Policy.

Correction and remediation

In the event that SMS's corporate activities clearly cause or contribute to negative impacts on human rights, we will take appropriate procedures to address them.

Specifically, we have established a 24/7/365 whistle-blowing hotline for all officers and employees of SMS and its domestic subsidiaries to report or consult on any violations of laws, regulations, or internal rules, as well as workplace harassment. We have also made all officers and employees aware of the guidelines for this system. Officers and employees using the hotline can choose to report by name or anonymously. We also have an external hotline managed by outside lawyers in case a whistle-blower feels uncomfortable about reporting to the internal hotline. Furthermore, it is also possible to request a female lawyer.
Our whistleblower protection policy stipulates that all information related to internal reports must be kept strictly confidential. The policy also prohibits any attempts to identify the whistleblower and any form of adverse treatment, including retaliatory personnel actions. Furthermore, it stipulates that any individual who engages in such adverse treatment will be subject to strict disciplinary action in accordance with our employment rules.
The person responsible for investigating internal reports shall report the results of the investigation at meetings or similar forums. If any illegal acts or other violations are confirmed, the investigator shall, while seeking expert advice as necessary, recommend corrective actions and preventative measures to the relevant departments and parties.
MIMS has established procedures for internal reporting and ensures that employees are free to choose whether to report anonymously or not, and that they will not suffer any disadvantages by the reporting.

Dialogue with stakeholders

In implementing the Policy, we recognize the importance of the perspective of stakeholders who may be subject to human rights violations. Therefore, we strive to promote initiatives to respect human rights by constantly engaging in close dialogue with stakeholders and utilizing external expertise on human rights.

Human rights issues of particular importance

Prohibition of discrimination and harassment

SMS prohibits all discrimination based on race, gender, nationality, ethnicity, language, religion, political or other opinion, national or social origin, property, sexual orientation, gender identity, health condition, or disability.
We prohibit power harassment, sexual harassment, and all other forms of harassment, whether mental or physical.
We strive to provide services that can be used in safety by all people regardless of age, gender, location, or disability, and give maximum consideration to provide services without causing or contributing to discrimination or harassment.

Prohibition of forced labor and child labor

SMS prohibits all forms of forced labor and child labor, including slavery and trafficking, and also requires business partners to comply with this provision.

Fair wages and appropriate management of working hours

SMS complies with all applicable laws and regulations in every country and region where we operate, ensuring the consistent payment of fair wages, including statutory minimum wages. Particularly in our overseas operations, we stipulate that even in the absence of a legal minimum wage, compensation must always be sufficient to meet basic needs (a living wage) and align with local industry standards. Furthermore, we strive to provide fair, merit-based compensation regardless of personal attributes, upholding the principle of "equal pay for equal work." To ensure the physical and mental well-being and safety of our employees, we strictly adhere to local labor standards and regulations. By implementing rigorous management of working hours and days off, we are committed to eliminating excessive overtime and fostering a healthy work-life balance.

Respect for freedom of association and the right to collective bargaining

In accordance with the laws and regulations of each country, SMS respects not only the right to form or join labor unions and the right to participate in collective bargaining for the purpose of discussing working conditions and employment terms, but also the right not to participate in these activities.

Respect for privacy and protection of personal information

SMS respects privacy at all times and strives to appropriately protect and manage personal information of all customers, service users, officers and employees, and other stakeholders.

Established in March 2023
Revised in March 2026