PHC Group provides products and services in precision technology for healthcare, guided by our mission of “contributing to the health of society through our diligent efforts to create healthcare solutions that have a positive impact and improve the lives of people.” As a corporate Group, we consider it a vital responsibility to respect the human rights of all stakeholders involved in our business activities. We are committed to contributing to a more sustainable and equitable society.

Basic Approach

PHC Group’s fundamental approach is to support and respect internationally recognized human rights norms, including the International Bill of Human Rights, the ILO Core Labour Standards, the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, and the OECD Due Diligence Guidance. In 2025, we revised our Human Rights Policy in conjunction with the launch of our Human Rights Due Diligence Project, with advice from external experts and approval from Audit and Supervisory Board. The following points were revised and added:

This policy applies to the entire PHC Group, and we expect suppliers and other business partners to comply with the policy and cooperate in its implementation.

Human Rights Policy https://www.phchd.com/global/sustainability/social/humanrights

PHC Group Code of Conduct https://www.phchd.com/global/sustainability/governance/code-of-conduct

Human Rights Due Diligence

In fiscal year 2025, PHC Group conducted an initial assessment of human rights risks across our entire value chain, making reference to the UNGPs and OECD Due Diligence Guidance. Specifically, we identified and evaluated potential human rights risks by combining the following three approaches:

• Questionnaire targeting internal stakeholders (departments involved in personnel, procurement, human rights, risk management, and other matters)
• Interviews of outside experts (including ESG risk evaluation companies and an NGO in the medical device field)
• Analysis of public and media information

Based on these results, we evaluated the locations where human rights risks are most likely to occur within the value chain and the severity (high, medium, or low) and created a human rights risk map. Through this assessment, we structurally organized an overall picture of the Group’s human rights risks. We confirmed that these risks are most likely to materialize in the following areas:

• Risks relating to the upstream value chain (procurement and raw materials)
• Risks relating to stakeholders unique to healthcare companies such as patients and clinical trial participants

Based on this, we identified key topics that we should address as a Group in the future.

Starting in fiscal year 2026, we are implementing risk screenings, self-assessment questionnaires (SAQs), monitoring of high-risk areas, and preparation of human rights due diligence operational manuals for Group companies and business partners, in stages, centered on these topics. In parallel, we published a Third-party Code of Conduct to clarify our expectations toward business partners in fiscal year 2026.

Remediation and Redress

PHC Group operates the PHC Group Compliance Helpline to enable employees to report any compliance-related concerns, including human rights issues. In addition to supervisors, the Human Resources department, the Legal and Compliance department, PHC Group CEO and Corporate Officers, and members of Audit and Supervisory Board, we have established external reporting channels that allow for anonymity and protection of whistleblowers.

Future Initiatives

Human rights initiatives are never completed. As an enterprise involved in global healthcare, PHC Group will fulfill our responsibilities regarding human health and dignity and make ongoing improvements while continuing dialogue with stakeholders.