KIOXIA Human Rights Policy

<Preamble>

Guided by its mission of uplifting the world with memory, KIOXIA Group is committed to contributing to the development of industry and society with cutting-edge products such as flash memory and SSDs. With the growing interest in “corporate social responsibility,” we also recognize that corporate activities based on respect for human rights are a prerequisite for the sustainable development of companies and society.

KIOXIA Group considers human rights to be uninfringeable basic rights and we believe it is most important to realize a society where the human rights of all people are respected. The rapid changes in society, economic change, and advances in technology impact continuously on our business environment. We are always aware of the risk of infringing human rights directly or indirectly through our business activities. Therefore, in addition to observing applicable laws and social norms as a matter of course, we will fulfill our responsibilities with regard to respecting human rights as our moral duty and thereby create the values for our employees, stakeholders, and the society as a whole.

<Scope>

This policy is applied to all directors and employees (including part-time employees). And by means of the KIOXIA Group Procurement Policy, we also require our suppliers to observe applicable laws and social norms, as well as to respect KIOXIA Human Rights Policy.

<Respect for Human Rights>

KIOXIA Group observes human rights-related laws in the countries and regions in which we operate. In addition, we respect the International Bill of Human Rights (the Universal Declaration of Human Rights and International Covenants on Human Rights), the ILO Core Labor Standards, the U.N.'s Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. As an RBA (Responsible Business Alliance) member, we also act in accordance with the RBA Code of Conduct.

<Responsibility for Respecting Human Rights>

KIOXIA Group responds appropriately if we find that our business activities are having an adverse impact on human rights. In addition, we require our suppliers to implement improvement measures if we observe any negative impact on human rights arising from their activities.

KIOXIA Group has assigned our Executive Officer in charge of Human Resources as Human Rights Promotion Officer, responsible for implementing our human rights policy and ensuring these are followed.

<Education>

KIOXIA Group educates its directors and employees (including part-time employees) about our human rights policy in order to ensure they respect human rights in all areas of business activity.

<Human Rights Due Diligence>

KIOXIA Group will work to identify and assess any risk or negative impact associated with the KIOXIA Group, and will then seek to prevent or lessen such risk or impact.

<Relief>

If KIOXIA Group establishes that we have directly or indirectly had a negative impact on human rights, we will take appropriate steps to address the situation. We will set an up an anonymous reporting facility and ensure there are no negative consequences for those who report such incidents or support our investigations.

<Dialogue>

KIOXIA Group will engage in dialogue with relevant stakeholders regarding its response to any potential or actual cases of human rights being infringed.

<Information disclosure>

KIOXIA Group provides details of our human rights policy initiatives on our website or by means of reports.

<Observation of Applicable Laws>

KIOXIA Group observes human rights-related laws in the countries and regions in which we operate. If there is any conflict between such local laws and internationally recognized human rights, we always endeavor to respect the latter.

(We formulated the KIOXIA Human Rights Policy following passage of a resolution by the Board of Directors of KIOXIA Holdings Corporation on 27 August 2021.)