Respect for Human Rights

In 2021, we formulated the Kioxia Human Rights Policy as a way to clarify our corporate responsibility to respect human rights, and positioned it as one of our key internal regulations. This policy stipulates that we must respect the International Bill of Human Rights to the fullest extent, and that we will make every effort to respect human rights in accordance with international standards such as the United Nation Guiding Principles on Business and Human Rights. Kioxia Group is also committed to conducting business activities that are in line with the Responsible Business Alliance (RBA) ¹ Code of Conduct. Examples include progressing our own sustainability initiatives and requesting our suppliers to respect human rights.

The Kioxia Human Rights Policy was established on the basis of advice from outside experts and endorsed by the resolution at a meeting of the Board of Directors of Kioxia Holdings Corporation.

The Kioxia Group is implementing procedures whereby we minimize human rights risks in our business activities in order to fulfill our responsibility to respect human rights. We have appointed a staff member within the Human Resources and Administration Division of Kioxia Corporation. The Executive Officer in charge of human resources is designated as the person responsible for promoting human rights awareness. This Executive Officer promotes the company’s human rights policies and oversees compliance with these.

In addition, the Diversity and Human Rights Due Diligence Task Force, which comprises staff from a variety of business areas, examines and promotes measures related to human rights due diligence. The Executive Officer manages human rights risks in conjunction with other departments and group companies in line with the Task Force’s recommendations.

Furthermore, after thorough discussion at Sustainability Committee and Sustainability Strategy meetings, any important issues are escalated to the Board of Directors.

In order to respect the human rights of those impacted by our business activities throughout our overall value chain, Kioxia Group conducts human rights due diligence in accordance with the United Nation’s Guiding Principles on Business and Human Rights. We are implementing an ongoing cycle of activities aimed at mitigating human rights risks.

These activities include

• identifying and assessment the human rights risks
• constructing a framework for prevention and mitigation of these risks; implementing appropriate measures
• tracking and investigating the situations
• disclosing relevant information.

The Kioxia Group identifies and assesses any potential human rights abuses across its value chain, using the RBA Code of Conduct as our reference point. We conduct surveys aimed at ensuring sustainability and responsible mineral procurement, and encourage our suppliers to strengthen their own measures to protect human rights in line with this Code of Conduct.

With the cooperation of external experts, in FY2021 we conducted human rights risk assessments across Kioxia Group in Japan to evaluate the impact of potential and apparent risks that our business activities might have on human rights. The below risks were identified following interviews with relevant departments, RBA audits at our manufacturing sites, and the completion of RBA self-assessment questionnaires by our suppliers.

In addition, the Kioxia Group conducts various assessments when it builds new facilities to evaluate the environmental impact of these in the surrounding area.

In FY2022, Kioxia Group in Japan determined the priority of initiatives aimed at addressing the aforementioned potential risks, taking into consideration the severity of their impact on human rights as well as the company's level of involvement and response. In the process, we established criteria based on which we have formulated five levels of response aimed at preventing or mitigating individual risks, ascertained the current level of response, and set targets.

Kioxia Group in Japan has prioritized the following human rights risks, utilizing the results of RBA audits at manufacturing sites.

Kioxia Group in Japan checks the status of target achievement for each category of risk every year. We evaluate the effectiveness of our countermeasures and formulate improvement measures based on internal and external trends. While we implemented various countermeasures during FY2022, there were some measures that will be carried over to FY2023 and beyond, such as those requiring the establishment of internal rules. We will follow up on these issues continuously.

Kioxia Group provides training on human rights and harassment issues to all employees once a year. By doing this, we seek to raise awareness of internationally recognized human rights issues, such as those concerning socially marginalized groups that often become the target of human right abuses. In FY 2021, we conducted training to familiarize employees with the challenges faced by people with disabilities, and in FY2022, we conducted similar training covering LGBTQ issues.

At Kioxia Corporation, we provide additional training for our staff on human rights and harassment issues during the employee onboarding process, part of our Basic Training program.

In addition, in FY2021 Kioxia Corporation held a lecture on "Business and Human Rights" by an outside expert for Executive Officers to deepen their understanding of changes in the external environment surrounding business and human rights, efforts required by companies, and advanced examples from other companies.

Kioxia Group has established contact points where employees and business partners can report and discuss possible violations of the laws and regulations of each country or region, the Kioxia Group Standards of Conduct, and other internal regulations.

To prevent and remedy harassment, including instances of power harassment and sexual harassment, Kioxia Group in Japan has established a "Harassment Consultation Service" to offer assistance and guidance to employees. At Kioxia Group, it is strictly prohibited to subject anyone who reports harassment to any form of disadvantage or retaliation.

In order to establish a more effective grievance mechanism on human rights issues, in FY2021, Kioxia Holdings Corporation became a member of the CSR Committee of the Grievance Mechanism Working Group³ at the Japan Electronics and Information Technology Industries Association (JEITA). We participate in discussions of the issues surrounding the operation of a common industry platform allowing access to remedies, which is one of the pillars of corporate responsibility in terms of respecting human rights.

In November 2022, Kioxia Corporation became a supporting member of the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER), and is gathering useful knowledge and information by participating in its meetings and training sessions.

Kioxia Group will establish a cycle of human rights due diligence in its overseas groups in the future, and will strengthen its efforts to respect human rights throughout the Group.