Respect for Human Rights

In 2021, based on our mission, vision and Standards of Conduct, we formulated the Kioxia Human Rights Policy as a way to clarify our corporate responsibility to respect human rights. 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 Nations Guiding Principles on Business and Human Rights. The Kioxia Human Rights Policy constitutes one of our most important set of regulations, and has been endorsed by the Board of Directors of Kioxia Holdings Corporation.

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 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 assigned responsibility for raising employee awareness of human rights issues to staff within the Human Resources and Administration Division of Kioxia Corporation, with an Executive Officer in charge of human resources leading their efforts. This Executive Officer promotes Kioxia Human Rights Policy 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, proposes activities in line with the United Nations Guiding Principles on Business and Human Rights. The staff members promote these by collaborating with relevant department and group companies.

Additionally, these initiatives are reviewed by the Sustainability Committee as part of our sustainability management procedures, with any important issues being escalated to the Board of Directors after discussion at Sustainability Strategy Meetings.

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 Nations 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 assessing any human rights risks
• constructing a framework for the prevention and mitigation of these risks; implementing appropriate countermeasures
• tracking and investigating any identified situations
• disclosing relevant information.

The Kioxia Group identifies and assesses any potential human rights abuses across its value chain. We also conduct self-assessment surveys, using the RBA Code of Conduct as a reference point for our sustainability activities. We also request our suppliers to strengthen their own measures to protect human rights in line with this Code of Conduct; this includes the implementation of sustainability surveys and responsible mineral sourcing.

With the cooperation of external experts, in FY2021 we conducted human rights risk assessments across Kioxia Group companies in Japan to evaluate the impact of potential and apparent risks that our business activities might pose to human rights. We subsequently identified 18 human rights risks that are specific to our industry and business model.

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 FY2023, in addition to increasing our focus on these initiatives within Kioxia Group in Japan, we conducted human rights risk assessments at our overseas locations.

Kioxia Group has focused on minimizing the following human rights risks, utilizing our human rights due diligence procedures and the results of RBA audits at manufacturing sites.

Kioxia Group regularly monitors our business activities to ensure compliance with Kioxia Human Rights Policy and checks the progress and effectiveness of corrective actions. Additionally, where appropriate we reflect the outcome of dialogue with stakeholders, the status of our business operations, and the demands of society when formulating our human rights policies and initiatives.

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 FY2023, we conducted training to familiarize employees with the challenges faced by LGBTQ+ people. In addition, we have made the provision of our Harassment Consultation Service widely known across Group companies.

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 FY2023 Kioxia Corporation held a lecture on the prevention of harassment during the hiring process for employees involved in recruitment activities.

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.

Kioxia Group in Japan has established a Harassment Consultation Desk where employees can report issues related to power harassment, sexual harassment, and other types of harassment. We promote awareness of this service through the intranet and via training for all employees. In FY2023, the desk received 25 reports and consultations. When inappropriate situations are identified or suspected, and with the consent of the individuals who made the reports, we provide improvement instructions or warnings to the relevant departments. At Kioxia Group, it is strictly prohibited to subject anyone who reports harassment to any form of disadvantage or retaliation.

Kioxia Group is considering to establish more effective mechanisms to handle grievances related to human rights issues. In November 2022, Kioxia Corporation became a supporting member of the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER), which aims to create a common grievance handling platform for the industry. By participating in this organization, We are staying abreast of industry trends and seeking to enhance our own grievance handling processes.