Business and Human Rights

The Metal One Group believes that respect for human rights is an essential element while running our wide-ranging businesses around the world.

Guided by the three pillars of our corporate philosophy—“global citizen,” “honesty and virtue,” and “aspirations and creativity”—the Group has promoted sound and fair business activities and advanced human rights initiatives through our corporate behavioral guidelines and code of conduct for executives and other employees.

To further clarify and organize Metal One’s approach to respecting human rights and advance initiatives on that basis, we established the following human rights policy in April 2026.

01A Commitment to Respect Human Rights

As we operate businesses centered on the steel industry worldwide, we believe that respect for human rights sits at the core of all our business activities.
In today’s increasingly complex business environment, we face a wide range of human rights issues. We believe that addressing them is directly linked to making our business activities sustainable. We have also long promoted sound and fair business practices in line with the three pillars of our corporate philosophy—“global citizen,” “honesty and virtue,” and “aspirations and creativity.” These principles embody the values of living together with people around the world, acting openly and fairly with confidence, and pursuing better forms of markets and distribution to open up a more prosperous future. We believe that respect for human rights is indispensable to turning these values into concrete action, and is a core foundation of our business.

02Scope of Application

This policy applies to all executives and other employees of Metal One. We share this policy with our Group companies and require them to promote initiatives to respect human rights in line with this policy in the management of their businesses.

03Engaging with Related Parties

We recognize our responsibility to address respect for human rights throughout the value chain of the businesses the Metal One Group operates. We therefore ask business partners such as suppliers and other related parties to respect human rights in line with this policy as well.

04Support for and Respect for International Norms

We support international human rights norms, including the International Bill of Human Rights, consisting of the Universal Declaration of Human Rights and the International Covenants on Human Rights; the ILO Declaration on Fundamental Principles and Rights at Work of the International Labour Organization; and the UN Guiding Principles on Business and Human Rights.

We comply with the laws and regulations of the countries and regions where we conduct business. If a conflict exists between internationally recognized human rights standards and the laws and regulations of the countries and regions where we operate, we seek ways to respect the international standards.

05Human Rights Due Diligence

To preserve the human rights of our stakeholders and give special attention to people who are socially vulnerable and at risk of social exclusion, we conduct due diligence on human rights to identify, prevent and mitigate actual or potential adverse human rights effects that the Group may cause or contribute to through our business activities, or that may be directly linked to the Group’s businesses, products or services through our business relationships.

06Human Rights Issues Related to the Metal One Group’s Business Activities

We recognize the following as the main human rights issues affecting stakeholders within the Metal One Group’s direct business activities and value chain, and are working to address them.

1. Prohibiting Discrimination
   We prohibit discrimination on any grounds, including race, ethnicity, creed, religion, gender, gender identity, sexual orientation, nationality, age, origin, physical or mental disability, and illness.
2. Prohibiting Inhumane Treatment
   We prohibit all forms of inhumane treatment, including physical and psychological abuse and harassment.
3. Providing a Safe, Sanitary and Healthy Working Environment
   We commit to providing employees with a safe, sanitary and healthy working environment.
4. Respect for Freedom of Association and the Right to Collective Bargaining
   We respect the right of employees to organize and to collective bargaining as a means of enabling labor-management discussions on working conditions, wage levels and related matters.
5. Securing Appropriate Working Hours and Wages
   We commit to properly managing employee working hours, pay at least the statutory minimum wage, and strive to pay wages above the living wage level.
6. Prohibiting Forced Labor
   We commit to hiring all employees of their own free will and to avoid subjecting any employee to compulsory labor.
7. Prohibiting Child Labor
   We will not employ children below the minimum working age or have children engage in work that could impair their development.
8. Rights of Indigenous Peoples and Local Communities
   We respect the rights and cultures of indigenous peoples and local residents as provided for under the laws and international agreements of the countries and regions where we conduct business, and commit to ensuring that our business activities do not cause or contribute to rights violations such as land dispossession.
9. Consideration for the Global Environment
   We recognize that deterioration of the global environment can adversely affect human rights. In carrying out our business, we will therefore give due consideration to the global environment, including climate change measures and the conservation and restoration of natural capital such as biodiversity.
10. Diversity, Equity and Inclusion
    We aim to help create a society in which all individuals, each with their own diverse values and individuality, are respected and can participate fairly.

07Remediation

If it becomes clear that the Group’s business activities have adversely affected human rights in some way, either directly or indirectly, we will alter them in accordance with appropriate procedures based on internal rules and relevant laws and regulations. If such impacts are directly linked to the Group’s business, products or services through business relationships, we will exercise our influence to alter them.

08Access to Remedies

We recognize that due diligence on human rights alone may not be enough to identify all actual or potential adverse human rights violations throughout the Group’s business activities and value chain. To identify such violations more broadly and to mitigate and/or prevent them, we will establish and maintain contact points to receive consultations from internal and external stakeholders. While operating these contact points, we will accept anonymous consultations and ensure that those seeking advice do not suffer disadvantages such as retaliation.

09Education and Raising Awareness

We will provide the education and capacity development needed so that executives and other employees throughout our Group understand the importance of respecting human rights and put those principles into practice.

10Information Disclosure

We disclose information on our human rights initiatives in an appropriate manner and scope, and ensure transparency.

11Stakeholder Engagement

We engage with relevant stakeholders and respond responsibly.

12Governance and Management System

Our corporate supervising officer in charge of sustainability measures oversees our human rights initiatives, which are submitted and reported on to the Board of Directors.