1. Sustainable Procurement Policy

The sustainability vision of the Tokyu Fudosan Holdings Group (hereinafter, “the Group”) is, “We will solve social issues through our business activities and work with stakeholders to realize a sustainable society and growth.” To achieve this vision, the Group will treat environmental, social, and governance (ESG) matters as important management issues and promote ESG management.

As social and environmental issues have become even more pressing in recent years, stakeholders and society increasingly expect that corporate decision-making and other business activities be based on sustainability as well as profitability.

With the aim of always maintaining stakeholder trust, the Group strives to contribute to economic and social development by maintaining sound business operations based on proper fulfillment of social responsibilities and its public mission, while striving for thorough compliance. To recognize and fulfill the social responsibilities pertaining to its business activities, the Group recently established the Sustainable Procurement Policy (hereinafter, “this Policy”) with a view to realizing its Sustainability Vision.

By promoting procurement under this Policy, the Group will strengthen ESG management to realize corporate growth and a sustainable society. Therefore, it will be necessary and important to engage the entire supply chain, including business partners. The Group asks its business partners to understand the purpose and content of this Policy, and to help it implement sustainable procurement activities.

[Sustainable Procurement Policy Articles]

1. Legal compliance
   1. Total compliance with relevant laws and regulations
2. Respect for human rights
   1. Compliance with and respect for international human rights and labor standards
   2. No tolerance of discrimination
   3. No tolerance of harassment
   4. Respect for local residents
   5. Respect for minority rights
   6. Protection of the rights of all migrant workers
3. Ensuring a work environment based on safety, health and well-being
   1. Freedom of association, collective bargaining rights
   2. No tolerance of forced labor
   3. No tolerance of child labor
   4. Fair wage
   5. Prohibition of excessive working hours
   6. Workplace health and safety measures
   7. Emergency preparedness
   8. Prevention of occupational accidents and illness
   9. Industrial hygiene measures
   10. Measures for physically demanding work
   11. Ensuring adequate environment for sanitation facilities, meals, and housing
4. Ensuring proper business ethics
   1. Preventing corruption
   2. Preventing contact with organized crime
   3. Ensuring fair trade practices
   4. Appropriate response to conflicts of interest
   5. Responsible political involvement
   6. Prohibition of insider trading
   7. Protection of intellectual property rights
   8. Maintaining confidential information and disclosure
   9. Compliance hotline and whistleblower protection
5. Consideration for the Environment
   1. Response to climate change
   2. Biodiversity protection
   3. Pollution prevention
   4. Effective use of resources
   5. Appropriate use of water resources
   6. Protection of forests and natural ecosystems
   7. Development of Environmental Management System
6. Improving service and quality
   1. Ensuring safety
   2. Quality control and quality assurance systems
   3. Proper information disclosure for products and services
7. Proper information management
   1. Proper information management
8. Business Continuity Planning
   1. Business continuity planning
9. Contributing to local communities
   1. Contributing to local communities
10. Extension of the Sustainable Procurement Policy
    1. Extension to business partners
    2. Cooperation for monitoring

2. Scope

This Policy applies to the Group’s entire supply chain, including direct and indirect suppliers of all products, services and raw materials procured by each Group company.

Established January 6, 2020
Revised April 1, 2025

1. Legal compliance
   1. Total compliance with relevant laws and regulations
      Comply with all applicable laws and regulations, including national and international laws, maintain a complete understanding of regional social norms and corporate ethics, and act based on sound judgement and a sense of responsibility.
2. Respect for human rights
   1. Compliance with and respect for international human rights and labor standards
      Promote international human rights and labor standards,* and conduct business activities in a way that respects human rights.
      • The International Bill of Human Rights (Universal Declaration of Human Rights, and the International Covenant on Civil and Political Rights), ILO Declaration on Fundamental Principles and Rights at Work, UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises, etc.
   2. No tolerance of discrimination
      Discrimination based on nationality, race, religion, creed, gender, age, sexual orientation, gender identity, disability, or other such characteristics is not permitted. Eliminate discrimination and ensure fair employment and recruitment opportunities.
   3. No tolerance of harassment
      Never engage in any form of harassment, including sexual and power harassment, and no demeaning remarks or actions are permitted in the workplace.
   4. Respect for local residents
      Respect the local cultures and customs of the locations in which it operates, as well as local residents and communities.
   5. Respect for minority rights
      Respect the rights of vulnerable persons and minorities.
   6. Protection of the rights of all migrant workers
      Do not engage in any unlawful or unjust actions against migrant workers in accordance with relevant laws and regulations. Additionally, provide employment contracts and working conditions in a language that is understandable to the workers.
3. Ensuring a work environment based on safety, health and well-being
   1. Freedom of association, collective bargaining rights
      Guarantee freedom of association and the right to collective bargaining, and work to solve issues through labor-management dialogue in countries and territories where trade unions are not permitted by law or practice.
   2. No tolerance of forced labor
      Eliminate and prevent all forms of forced labor.
   3. No tolerance of child labor
      Prohibit and work to prevent child labor.
   4. Fair wage
      Comply with applicable laws and regulations, including minimum wage, overtime pay, and deductions. Give due consideration to the payment of a living wage that is sufficient for employees and their families to secure an adequate standard of living.
   5. Prohibition of excessive working hours
      Ensure proper management of working hours in accordance with relevant laws and regulations, and also strive to reduce excessive working hours.
   6. Workplace health and safety measures
      Conduct health and safety management based on relevant laws and regulations. Prevent occupational accidents and establish safe working environments and conditions that are safe and sound from both the physical and mental perspectives. Take appropriate safety measures for machinery and equipment, such as establishing the necessary internal safety rules and inspecting equipment. Provide workplace health and safety information and training in the employee’s native or working language.
   7. Emergency preparedness
      Implement safety measures to prepare for emergencies such as fire or earthquakes and ensure personnel safety through regular disaster drills.
   8. Prevention of occupational accidents and illness
      Take appropriate measures to prevent occupational accidents and illness and take corrective measures in the event of any incidents. In such cases, a process has been established for employees to report hazards.
   9. Industrial hygiene measures
      Manage hazardous organisms and chemicals properly and provide training and protective equipment in cases when employees may come into contact with them.
   10. Measures for physically demanding work
       Identify work that is physically demanding or that poses a health risk and take appropriate measures to prevent injury and/or illness.
   11. Ensuring adequate environment for sanitation facilities, meals, and housing
       Provide employees with safe water, proper sanitation and hygiene (WASH). Additionally, when meals and housing are provided, they will be maintained in a safe and sanitary manner, ensuring that these facilities meet appropriate environmental standards.
4. Ensuring proper business ethics
   1. Preventing corruption
      Do not engage in or facilitate any form of corruption, such as money laundering, bribery, embezzlement, or obstruction of justice.
   2. Preventing contact with organized crime
      Tolerate no contact with organized crime and firmly refuse any improper demands.
   3. Ensuring fair trade practices
      Comply with relevant antitrust and subcontracting laws. Do not use superior position to impose unilateral conditions on business partners and do not hinder the business activities of competitors by unfair means.
   4. Appropriate response to conflicts of interest
      Take appropriate measures to prevent conflicts of interest in all transactions, such as buying, selling and outsourcing.
   5. Responsible political involvement
      Maintain sound, standard relations with politicians and administrative officials in accordance with relevant laws and regulations. Prohibit the provision of entertainment and gifts to politicians, as well as to Japanese and foreign government officials and equivalent persons.
   6. Prohibition of insider trading
      Prohibit corporate officers and directors or other insider employees from using confidential corporate information to reap a profit (or avoid a loss) by trading in the Company’s stock. Also prohibit “tipping” of confidential corporate information to third parties.
   7. Protection of intellectual property rights
      Protect intellectual property rights (patents, copyrights, design rights, etc.) from infringement by third parties. Likewise, do not infringe on the intellectual property rights and trade secrets of third parties.
   8. Maintaining confidential information and disclosure
      Maintain an awareness of information that needs to be disclosed and that which needs to be kept confidential. Perform timely and appropriate information management in compliance with relevant laws and regulations.
   9. Compliance hotline and whistleblower protection
      Maintain a compliance violation hotline to quickly identify and resolve compliance issues. Keep strictly confidential all information concerning those who report or inquire about compliance violation cases. Take appropriate measures to prevent hotline users from suffering disadvantageous treatment, including internal retaliation, as a result.
5. Consideration for the Environment
   1. Response to climate change
      Mitigate the impact of climate change by promoting the efficient use of energy and the utilization of renewable energy throughout the lifecycle of your products and services, as well as within your business activities. Understand and reduce greenhouse gas (GHG) emissions across your supply chain, including upstream operations.
   2. Biodiversity protection
      In material procurement and other business activities, reduce the impact on the surrounding natural environment, biodiversity, and ecosystems. Do not use raw materials derived from endangered species of animals and plants for which measures have not been taken to conserve resources and ensure reproduction.
   3. Pollution prevention
      Do not pollute the air, water, or soil, based on relevant environmental laws and regulations. Manage chemical substances appropriately and work to prevent the emission of pollutants while reducing the materials that cause them.
   4. Effective use of resources
      Work to use resources in business activities effectively and to reduce waste, based on relevant environmental laws and regulations.
   5. Appropriate use of water resources
      Identify water sources and drainage points, investigate their impacts, and engage in water resource conservation through appropriate management and efficient use tailored to local issues.
   6. Protection of forests and natural ecosystems
      In order to eliminate deforestation and ecosystem conversion in the supply chain for wood procurement and to respect the human rights of all relevant rights holders, aim to ensure that timber and wood products procured and used are produced in accordance with the following points.
      • Preserve and protect forests with high biodiversity and conservation value.
      • Respect the cultures, traditions, and economies of communities that coexist with forests.
      • Comply with the laws and regulations in the countries and regions of harvesting.
      • Strive to use forest products that are produced through sustainable methods, such as recycled and certified wood.
      • Do not procure timber that leads to the reduction and destruction of natural forests and the conversion of important natural ecosystems to other uses, compared to the state in 2020 when the sustainable procurement policy was established.
      • Respect the rights of indigenous peoples by upholding international norms such as the principles of “free, prior and informed consent (FPIC)” in accordance with “United Nations Declaration on the Rights of Indigenous Peoples”.
      • Encourage the participation of smallholders in the supply chain through cooperation with suppliers, NGOs, and other parties and certification programs.
      • Ensure supply chain traceability regarding the products and services provided by collecting information not only from direct business partners but also, as necessary, from upstream partners and the origin of raw materials.
   7. Development of Environmental Management System
      To conserve the global environment, identify an undertaking’s environmental impacts, establish an environmental policy, and develop a framework for continuous improvement through the PDCA cycle, including establishing targets such as obtaining SBTi certification. Provide information to stakeholders regarding the environmental issues outlined in section 5)-1 to 5)-6.
6. Improving service and quality
   1. Ensuring safety
      Always consider the safety and security of customers in every aspect of product and service planning, design, provision and after-sales service, to ensure customer health and safety.
   2. Quality control and quality assurance systems
      Establish quality management systems, comply with design and quality standards for products and services and always strive to improve quality. When procuring products, services, or raw materials, confirm that suppliers ensure animal welfare and are not involved in armed conflicts or criminal activities.
   3. Proper information disclosure for products and services
      Explanations of the products and services comply with relevant laws and regulations, and important matters that may affect the decisions of consumers and end users must be described to them in a way they can understand. In addition, do not use definitive predictions, make false or excessive statements about products or services (such as misrepresentation), use ads that are discriminatory or misleading, or release ads that may have an adverse effect on children.
7. Proper information management
   1. Proper information management
      Establish and properly maintain information management systems to protect and prevent the unauthorized disclosure of information used in business activities, such as personal, privacy-related, and confidential information.
8. Business Continuity Planning
   1. Business continuity planning
      Maintain business continuity plans (BCPs) to prepare for disasters or unforeseen emergencies.
9. Contributing to local communities
   1. Contributing to local communities
      Respect the local cultures and customs of the communities where it conducts business. Also seek to gain an understanding of social issues in those communities through dialogue and strive to implement business activities and social contribution activities that help solve those issues.
10. Extension of the Sustainable Procurement Policy
    1. Extension to business partners
       Encourage companies in the supply chain to understand and share this Policy.
    2. Cooperation for monitoring
       Cooperate with any monitoring of the status of the activities based on this Policy.

[Compliance Violation Reporting or Inquiries]

If you are aware of any actual or possible violation of this Policy, please contact us using the inquiry form below. Do not report anything that you know to be false, denigrating, or defamatory, and avoid any threats, or statements that would obstruct business, etc.
You may be required to cooperate in an investigation of the facts.
Anyone who reports a non-compliance issue, reports something by means of an inquiry, or who makes an inquiry will be protected from any reprisals or other disadvantageous treatment by any members of the Group and its entire supply chain.

Link

Established January 6, 2020
Revised April 1, 2025