Policy

Policy

DE&I vision

Diversity of human resources is essential to realize our group's vision of "a future where everyone can be themselves and shine with vitality through the creation of attractive and diverse lifestyles. Our group will create innovation by recognizing differences in diverse attributes, eliminating discrimination based on gender, age, nationality, race, ethnicity, religion, social status, disability, gender identity, sexual orientation, gender expressionand and other factors, providing fair opportunities for advancement, and creating an environment in which everyone can work as they wish and be themselves, We will work to create value through our business activities.

Tokyu Fudosan Holdings

Management Structure

In our group, to align human resources strategy, including health and safety, with business strategy, the Sustainability Committee and the Risk Management Committee report the challenges and progress of human resources strategy, including KPIs, and discuss the policy among the executive management. The results are then reported to the Board of Directors.

Management Structure

In our group, to align human resources strategy, including health and safety, with business strategy, the Sustainability Committee and the Risk Management Committee report the challenges and progress of human resources strategy, including KPIs, and discuss the policy among the executive management. The results are then reported to the Board of Directors.

For the implementation of the human resources strategy, our Group Human Resources Department oversees and manages the human resources departments of the five major companies within the company. As part of specific monitoring functions, the Group Human Resources Council is held twice a year to report and share the challenges and progress of KPIs among the various group companies. Additionally, individual subcommittees are established for specific themes such as diversity, recruitment, and labor management, ensuring a solid framework for the effective execution of human resources strategy.

System for Advancing Human Resources Strategy

 System for Advancing Human Resources Strategy Image

Tokyu Fudosan Holdings

Objectives and Initiatives/Performance

Goals, Initiatives, and Achievements

Promotion of Women's Participation and Advancement in the Workplace

Action Plan for Act on Promotion of Women's Participation and Advancement in the Workplace

Based on Act on Promotion of Women’s Participation and Advancement in the Workplace, Tokyu Land Corporation is committed to realize a society where everyone regardless of gender is free to exert his/her individuality and capability, and hereby establish action plans in pursuit of this goal.

1. Period : FY2022 to FY2025

2. Present issues :
Although the percentage of women hired is steadily increasing, the talent pool of female management candidates remains small compared to that of men.

3. Quantitative Goal :

  1. The ratio of female hires among new graduates will be approximately 40%.
  2. By FY2025, the ratio of female managers will be approximately 10%.

4. Actions and Implementation Period

  1. Incorporation into management policy from FY2022
    Management will commit to and communicate the importance of promoting women's activities in the management strategy.
  2. Recruitmentーongoing efforts
    Actively publicize to job seekers that the company is a workplace where diverse human resources, including women, can play an active role.
  3. Training from FY2022
    Consider development measures for female employees and supervisors.
  4. Flexible work stylesーongoing efforts
    Promote flexible work styles, including telework.
  5. Fostering a corporate culture ーongoing efforts
    Conduct training on diversity, equity and inclusion for all employees.
TOKYU LAND CORPORATION

Promoting diversity and creating dynamic workplaces

In April 2013, TOKYU LIVABLE, INC. became the first major real estate distribution company to establish a division dedicated to diversity, followed by the establishment of a division dedicated to work style reform in April 2018.

Promoting diversity and creating dynamic workplaces

In April 2013, TOKYU LIVABLE, INC. became the first major real estate distribution company to establish a division dedicated to diversity, followed by the establishment of a division dedicated to work style reform in April 2018. Tokyu Livable aims to be a company where each and every employee, regardless of gender, age, or disability, can fulfill their potential in their own way, and is committed to promoting diversity and reforming the way they work. For example, we have established a "partner system" for female sales and brokerage salespeople working shorter hours to work on projects with a partner in conjunction with reduced targets, to provide backup for customer service and a shift system for days off.

The company also has a Career Expert Re-employment System in place that enables the continued employment of employees that fulfill certain internal standards until age 70 if they wish to remain employed. In addition to promoting the proactive use of female employees, the Group will actively work towards creating a workplace that can take advantage of the abundant experience and personal connections of senior employees that are expected to increase in the future so that they can be effectively used in the organization.

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TOKYU LIVABLE, INC.

Diversity promotion and enhancement

Tokyu Fudosan Holdings Group organizes Diversity Conference where representatives from group companies come together to promote group-wide diversity.

Diversity promotion and enhancement

Tokyu Fudosan Holdings Group organizes Diversity Conference where representatives from group companies come together to promote group-wide diversity. The conference set KPI targets and monitor progress on percentage of female employees and women in managerial positions. It also serves as a place to share innovative measures within and outside the group to improve group-wide diversity.

Tokyu Fudosan Holdings

Achieving Work-life balance

Work style reform

Achieving Work-life balance

Our group offer diverse working arrangements to achieve better efficiency and productivity as well as employees’ work-life balance. Thanks to advanced IT, Tokyu Fudosan, Tokyu Community,Tokyu Livable and Tokyu Housing Lease have introduced telework scheme to accommodate more flexible work style. Many employees have already been taking advantage of the arrangement, which have proven to lead to more efficient use of time, improving productivities and employee satisfaction.
TOKYU COMMUNITY CORP. enables employees to work even more flexibly by simultaneously using a "sliding work hour system" that allows them to move up or down their work hours.

TOKYU LAND CORPORATION, TOKYU COMMUNITY CORP., TOKYU LIVABLE, INC., Tokyu Housing Lease Corporation, NATIONAL STUDENTS INFORMATION CENTER CO., LTD.

Employee satisfaction survey

Improvement of work engagement (Employee satisfaction survey)

Tokyu Land Corporation continues to conduct employee satisfaction surveys. We aim to create a more organized organization and workplace by visualizing the involvement situation of employees and improving organizational capabilities.

TOKYU LAND CORPORATION

Support for childcare and eldercare

Support for balancing work, childcare and eldercare

Each company in Tokyu Fudosan Holdings Group has been taking measures suitable to its business environment, to achieve a workplace where employees can balance their work and various life events or personal commitments including childcare and eldercare, and continue in their career.

Support for childcare and eldercare

Tokyu Land Corporation, TOKYU COMMUNITY CORP., Tokyu Housing Lease Corporation, NATIONAL STUDENTS INFORMATION CENTER CO., LTD., and other companies providepaidleave (2days, 5days, etc.)for childcare purposes tosupportmale employees' participationinchildcare.

Tokyu Land Corporation

In order to encourage male employees to take childcare leave, Tokyu Land Corporation provides e-learning programs for all employees, explaining the importance of childcare leave and how to adjust work duties during childcare leave.

TOKYU COMMUNITY CORP.

TOKYU COMMUNITY CORP. holds seminars for managers on nursing care, where they learn about support measures based on specific examples, in an effort to prevent employees from leaving their jobs to care for family members, and to support employees who are working while caring for family members.
In addition, the company has prepared a "Work-Life Balance Promotion Guidebook" that outlines childcare, nursing care, and other benefit programs, and continues to promote awareness of these programs.

TOKYU LIVABLE, INC.

TOKYU LIVABLE, INC. has introduced a system for employees on childcare leave to exchange information and conduct interviews before and after returning from maternity leave to help employees balance work and childcare.
At the same time, we have introduced a "partner system" for employees who wish to work shorter hours, which, in conjunction with reduced targets, provides a system for working on projects with a partner to provide backup in dealing with customers and a shift system for days off.

Tokyu Fudosan Holdings, TOKYU LAND CORPORATION, TOKYU COMMUNITY CORP., TOKYU LIVABLE, INC., Tokyu Housing Lease Corporation, NATIONAL STUDENTS INFORMATION CENTER CO., LTD.

Employment for people with disabilities

Role of elderly and workers with disabilities

Employment for people with disabilities

Tokyu Livable Staff Corporation, a subsidiary of Tokyu Livable offers employment opportunities for those with disabilities, where everyone finds right work for his/her skills and competencies and becomes a valuable member of the company. Many physically or mentally challenged employees, or “satellite staff” have been teleworking, drawing plans and guide maps on PC, while mentally disabled employees or “challenge staff” have been working as a team at the head office and each division, taking on wide range of back office tasks including handling interoffice mails and issuing certificates.

Tokyu Fudosan Holdings' employment rate for staff with a disability in fiscal 2022 was 2.4%.

Tokyu Fudosan Holdings, Tokyu Livable Staff Corporation

Employment for older workers

Employment for older workers

Tokyu Livable’s “Career expert re-employment” program ensures extended employment up to 70 years of age for older workers who are willing and meet the company standards. Tokyu Community’s retirement extension program, just introduced in October 2017, extends  retirement age to 65 years old from current 60 for their technical staff. Both schemes are intended for growing number of older workers to take active roles in the workplace, as well as for the companies to tap on senior workers’ valuable experience and connections. Tokyu Land Corporation supports the diverse work styles of its senior employees by introducing a side job system for rehired contract employees and a partner system that allows them to choose the number of days they work.

TOKYU LAND CORPORATION, TOKYU COMMUNITY CORP., TOKYU LIVABLE, INC.

Correspondence to Muslims

Tokyu Land Corporation has set up a prayer room for Muslims in Shibuya SOLASTA, our headquarter, to create an environment where people can play an active role regardless of race, religion, or nationality for the local employees in Indonesia, where our affiliated companies operate.

Correspondence to diverse races, religions, and nationalities]

Correspondence to Muslims

Tokyu Land Corporation has set up a prayer room for Muslims in Shibuya SOLASTA, our headquarter, to create an environment where people can play an active role regardless of race, religion, or nationality for the local employees in Indonesia, where our affiliated companies operate.

TOKYU LAND CORPORATION

Education on Diversity and Inclusion

Various training programs

Education on Diversity, Equity and Inclusion

Tokyu Fudosan Holdings believes that creating a workplace where a diverse workforce can work with vigor and enthusiasm leads to increased corporate value. To this end, we regularly conduct e-learning programs to deepen understanding of the importance of diversity, equity and inclusion in corporate management.

Tokyu Fudosan Holdings

LGBTQ Initiatives

Various awards, rankings, etc.

Recognition for LGBTQ Initiatives through the 'PRIDE Index'

In the 'PRIDE Index,' which evaluates corporate and organizational efforts towards LGBTQ inclusion, Tokyu Real Estate Co., Ltd. and Tokyu Community were awarded the highest ranking of 'Gold' (as of 2023).

Under the Tokyu Land Holdings Group Human Rights Policy, the Tokyu Land Holdings Group is committed to eliminating discrimination based on gender, age, nationality, race, ethnicity, religion, social status, disability, gender identity, sexual orientation, and other factors, and to creating a mutually respectful organization that provides value to society. We will give back to society by creating an organization that respects each other.

work with Pride Logo
Tokyu Fudosan Holdings, TOKYU LAND CORPORATION, TOKYU COMMUNITY CORP.

L-boshi certified with highest ratings

L-boshi certified* with highest ratings

Tokyu Community develop support programs to balance work and childcare/eldercare to ensure women’s continuing career. This project was highly evaluated for achieving more employment opportunities and continuous career for women, and led in L-boshi certificate awarded by Health, Labor and Welfare Minister as a company with excellent program implementation for advancement of women in workplace.

  • *L-boshi(star) certification is given to companies that meet criteria set forth based on the Act on Promotion of Women’s Participation and Advancement in the Workplace.
L-boshi Logo"L-boshi" Logo
TOKYU COMMUNITY CORP.

Third-party Verification of Social Data

Third-party Independent Verification

The Tokyu Fudosan Holdings Group receives independent verification of its environmental data from a third-party in order to ensure the reliability of this information.
For fiscal 2022, the scope of this verification includes data for our Employee(Percentage of female managers,Percentage of full-time female employees and Percentage of new hires that are women).

Third-party Independent Verification Report on Social Data (Diversity)

Fiscal year 2022 Independent Third-Party Assurance Report.
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Tokyu Fudosan Holdings
Society
Supply Chain (Society)

Policy

The Tokyu Fudosan Holdings Group recognizes the cooperation of stakeholders...

Society
Supply Chain (Society)

Sustainable Procurement Policy

This card shows Tokyu Fudosan Holdings Group Sustainable Procurement Policy...

Society
Supply Chain (Society)

Management Structure

In our group, to address challenges in the supply chain, we have establishe...

Society
Supply Chain (Society)

Property portfolio management policy

Goals, Initiatives, and Achievements Management policy Property portfol...

Society
Supply Chain (Society)

Supply Chain Management

Supply Chain Management Critical Suppliers The buildings developed by o...

Society
Supply Chain (Society)

Redevelopment project in Shibuya

Creating a Safe and Secure Community Redevelopment project in Shibuya ...

Society
Supply Chain (Society)

Real estate development with excellent access to transit

Consideration of access via public transport during design and development ...

Society
Supply Chain (Society)

Disabled persons access is assessed for all buildings

Disabled persons access is assessed for all buildings Tokyu Land Corpora...

Society
Supply Chain (Society)

Arrangement of Real Estate business value chain

Arrangement of Real Estate business value chain Supply Chain in the Real...

Society
Supply Chain (Society)

Request for supply chain policy on social issues

Request for supply chain policy on social issues In our group, individua...

Society
Supply Chain (Society)

Stakeholder Engagement on Human Rights, etc. - Due Diligence on Suppliers

Risk Assessment carried out regarding environmental and social issues for P...

Society
Supply Chain (Society)

Capacity building for suppliers 

Capacity building for suppliers Tokyu Re・design Corporation conducts tra...

Society
Supply Chain (Society)

Monitoring of suppliers for social issues 

Tokyu Land Corporation conducts on-site audits of suppliers regarding safet...

Society
Supply Chain (Society)

Addressing Social Issues through Dialogue with the Local Community and Tenants.

Stakeholder Engagement Resolving Social Issues through dialogue with loc...

Society
Supply Chain (Society)

Engage with Local communities on social issues

Tokyu Land Corporation aims to solve social issues through business activit...

Society
Supply Chain (Society)

Building homes that take customers views into account

Improvement of Services and Quality Building homes that take customers v...

Society
Supply Chain (Society)

Service-way Forum

Service Way Forum aiming for improved customer service. In 2009, the Tok...

Society
Supply Chain (Society)

Tenant satisfaction survey

Tenant satisfaction survey Tokyu Land SC Management Co., Ltd. invest...

Society
Supply Chain (Society)

Communication with customers

Facilitating Communication Communication with customers Ref...

Society
Supply Chain (Society)

Communication with tenants

Communication with tenants With the aim of helping the office workers ...

Society
Supply Chain (Society)

Strengthening disaster preparedness measures

Pursuit of Safety and Security in Buildings Strengthening disaster prepa...

Society
Supply Chain (Society)

Clear evacuation plans and Regular evacuation training for tenants

The Group prepares a clear evacuation plans in accordance with the Fire Ser...

Society
Supply Chain (Society)

Condominium design that emphasizes safety and peace of mind

Condominium design that emphasizes safety and peace of mind Tokyu La...

Society
Supply Chain (Society)

Strengthening seismic resistance through home renovation

Strengthening seismic resistance through home renovation Tokyu Re・de...

Society
Human Rights and Community

Policy

The Tokyu Fudosan Holdings Group recognizes that respecting the human right...

Society
Human Rights and Community

Human Rights Policy

Human Rights Policy Tokyu Fudosan Holdings Group Human Rights Po...

Society
Human Rights and Community

Management Structure

Management Structure The Group has established the Sustainability Commit...

Society
Human Rights and Community

Identification of salient human rights issues specific to the business

Goals, Initiatives, and Achievements In FY 2019, the Group conducted a hum...

Society
Human Rights and Community

Target for 2030 – 100% Sustainable Wood for Concrete Formworks

Target for 2030 – 100% Sustainable Wood for Concrete Formworks Much of p...

Society
Human Rights and Community

Human rights impact or risk assessments

Human rights impact or risk assessments Regarding the potential new proj...

Society
Human Rights and Community

Continued positive assessment of negative impacts on human rights

Continued positive assessment of negative impacts on human rights The Gr...

Society
Human Rights and Community

Actions implemented for avoidance, prevention and mitigation of human rights issues

Actions implemented for avoidance, prevention and mitigation of human right...

Society
Human Rights and Community

Clear communication of human rights expectations to stakeholders

Clear communication of human rights expectations to stakeholders The Gro...

Society
Human Rights and Community

Efforts to respect human rights of suppliers and ensure sustainable procurement

Efforts to respect human rights of suppliers and ensure sustainable procure...

Society
Contribution to Local Communities and Society

Policy

The Tokyu Fudosan Holdings Group recognizes the sustainability of communiti...

Society
Contribution to Local Communities and Society

Commitments

Commitments We are committed to take the Group’s business and advance it t...

Society
Contribution to Local Communities and Society

Management Structure

Management Structure In our group, to address challenges in the community ...

Society
Contribution to Local Communities and Society

Community investments​

Goals, Initiatives, and Achievements The town development in the Greater...

Society
Contribution to Local Communities and Society

Creation of local employment opportunities

Community Contribution Activities Creation of local employment opportuni...

Society
Contribution to Local Communities and Society

Contributing to communities in the tourist haven of Palau

Contributing to communities in the tourist haven of Palau For ...

Society
Contribution to Local Communities and Society

Continuing to support disaster-stricken areas in the recovery effort

Continuing to support disaster-stricken areas in the recovery effort ...

Society
Contribution to Local Communities and Society

Contribution to the community through partnerships with NPOs

Promoting Local Community Revitalization Programs Tokyu Land C...

Society
Contribution to Local Communities and Society

Supporting local activities

Supporting local activities Tokyu Land Corporation is involved with the ...

Society
Contribution to Local Communities and Society

Senior life business

Initiatives Through Customer Engagement Initiatives to Address Social Is...

Society
Contribution to Local Communities and Society

Junior golf lessons

Tokyu Land Corporation and Tokyu Resort Service Co., Ltd. have been arrangi...

Society
Contribution to Local Communities and Society

Supporting child raising through condominiums

Supporting child raising through condominiums In September 201...

Society
Health and Safety

Policy

The Tokyu Fudosan Holdings Group recognizes that ensuring the health and sa...

Society
Health and Safety

Board of Directors to Oversee Health and Safety Issues

Tokyu Land Holdings conducts monthly labor management surveys at each Group...

Society
Health and Safety

Named position responsible at Board level to Oversee Health and Safety Issues

The director responsible for promoting occupational safety management is th...

Society
Health and Safety

Health management

Goals, Initiatives, and Achievements Health management Tokyu Land Hol...

Society
Health and Safety

Health committees , Labor liaison meetings

Health committees , Labor liaison meetings The Group has established Hea...

Society
Health and Safety

​​Risk Assessment carried out regarding health and safety ​

In all development projects in which Tokyu Land Corporation is a principal ...

Society
Health and Safety

Employees’ physical health and mental health

The Group endeavors to offer sound workplaces that are dynamic so that each...

Society
Health and Safety

Number of staff trained on health and safety standards

Number of staff trained on health and safety standards Tokyu Fudosan Hol...

Society
Health and Safety

Addressing Global Health Issues

Addressing Global Health Issues Currently, HIV (AIDS), tuberculosis, and...

Society
Health and Safety

Application to Stakeholders

Application to stakeholders We have concluded a construction contract wi...

Society
Health and Safety

Percentage of Facilities Certified with OHSAS 18001

The ratio of workplaces certified with OHSAS 18001: Currently, there are...

Society
Health and Safety

Monitoring and managing health and safety performance

Monitoring and managing health and safety performance In order to ensure...

Society
Health and Safety

Number of fatal occupational accidents, Injury and morbidity rate with leave (LTIFR), Absentee Rate

Status of Workplace Accidents Since FY2017, we have had no workplace acc...

Society
Health and Safety

Seven Companies Certified as Outstanding Health and Productivity Management Companies in 2024

Various Awards History Six Companies Certified as Outstanding Health and...

Society
Health and Safety

Independent Third-Party Verification

Third-party Independent Verification The Tokyu Fudosan Holdings Group re...

Society
Labor Standards

Policy

Policy The Tokyu Fudosan Holdings Group will respect the following matte...

Society
Labor Standards

Management Structure

Management Structure In our group, to align human resources strategy, in...

Society
Labor Standards

Launched and Participated in Builders and Realtors Human Rights Due Diligence Workshop

Goals, Initiatives, and Achievements Launched and Participated in Builde...

Society
Labor Standards

Participate in industry collaboration in labor standards

External response to labor issues Participate in industry collaboration ...

Society
Labor Standards

Risk Assessment regarding labour issues carried out for Potential new operations or projects

When Tokyu Fudosan Holdings invests in a new project such as an M&A, it...

Society
Labor Standards

Whistleblower System

Whistleblower System Whistleblower System of the TFHD Group assumes it s...

Society
Labor Standards

Corrective and remedial initiatives

Corrective and remedial initiatives Respect for human rights and mechani...

Society
Labor Standards

The number of incidents of labour standards non-complianceーNumber of helpline reports

The number of incidents of labour standards non-complianceーNumber of helpli...

Society
Labor Standards

Initiatives to create an employee-friendly work culture

Initiatives for respecting human rights With the exception of a few comp...

Society
Labor Standards
Society
Labor Standards

Acceptance of foreign technical intern trainees and effots to respect their human rights

The Group responds to the fact that forced labors related to the foreign te...

Society
Labor Standards

The Employment of under-privileged groups and Internship Programs for Youth unemployment initiatives

Tokyu Land Corporation and TOKYU LIVABLE, INC. provide an environment where...

Society
Labor Standards

Information Provision to Employees

Information Provision to Employees The 'Guidebook for Preventing Sex...

Society
Labor Standards

Preventing child labor or forced labor

Improvement of working conditions. The Group is committed to preventing ch...

Society
Labor Standards

Management of work hours

Each subsidiary of the Group monitors employees for chronic and constant pr...

Society
Labor Standards

Equal Pay for Equal Work Policy

In accordance with the provisions of the Part-Time and Fixed-Term Worker La...

Society
Labor Standards

Dialogue between labor and management

Communication with employees Tokyu Land Corporation has instituted a lab...

Society
Labor Standards

Communicate labor standards globally to employees

Tokyu Land Corporation explains labor laws, employment regulations, labor c...

Society
Labor Standards

Employee training dedicated to skills development

Various training programs. Employee training dedicated to skills develop...

Society
Labor Standards

Skill Development Programs for Employees

In order to foster innovation within the Group required to create values fo...

Society
Labor Standards

Training on human rights policy

Training on human rights policy The Group conducts human rights policy t...

Society
Labor Standards

Harassment training for all employees and managers

The Group regularly holds e-learning and training by inviting external lect...

Society
Labor Standards

Freedom of Association

Various data Freedom of Association ESG Data : Labor Union-Related

Society
Labor Standards

Turnover rate

Turnover rate ESG Data : Turnover rate Ratio of non-regular employe...

Society
Diversity Promotion

Policy

Policy DE&I vision Diversity of human resources is essential to rea...

Society
Diversity Promotion

Management Structure

In our group, to align human resources strategy, including health and safet...

Society
Diversity Promotion

Objectives and Initiatives/Performance

Goals, Initiatives, and Achievements Promotion of Women's Participation an...

Society
Diversity Promotion

Promoting diversity and creating dynamic workplaces

In April 2013, TOKYU LIVABLE, INC. became the first major real estate distr...

Society
Diversity Promotion

Diversity promotion and enhancement

Tokyu Fudosan Holdings Group organizes Diversity Conference where represent...

Society
Diversity Promotion

Achieving Work-life balance

Work style reform Achieving Work-life balance Our group offer diverse w...

Society
Diversity Promotion

Employee satisfaction survey

Improvement of work engagement (Employee satisfaction survey) Tokyu Land C...

Society
Diversity Promotion

Support for childcare and eldercare

Support for balancing work, childcare and eldercare Each company in Tokyu ...

Society
Diversity Promotion

Employment for people with disabilities

Role of elderly and workers with disabilities Employment for people with...

Society
Diversity Promotion

Employment for older workers

Employment for older workers Tokyu Livable’s “Career expert re-employmen...

Society
Diversity Promotion

Correspondence to Muslims

Tokyu Land Corporation has set up a prayer room for Muslims in Shibuya SOLA...

Society
Diversity Promotion

Education on Diversity and Inclusion

Various training programs Education on Diversity, Equity and Inclusion ...

Society
Diversity Promotion

LGBTQ Initiatives

Various awards, rankings, etc. Recognition for LGBTQ Initiatives through...

Society
Diversity Promotion

L-boshi certified with highest ratings

L-boshi certified* with highest ratings Tokyu Community develop supp...

Society
Diversity Promotion

Third-party Verification of Social Data

Third-party Independent Verification The Tokyu Fudosan Holdings Group re...

Society
Human capital management

Human Capital Management

To achieve GROUP VISION 2030 and our medium-term management plan, the aim o...

Society
Human capital management

Human Capital Strategy

Human Capital Strategy To achieve GROUP VISION 2030, our vision for what w...

Society
Human capital management

Strategy measures and human capital KPI

Strategy measures and human capital KPI One of the risks in promoting the ...