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Sustainability > Governance Initiatives > Code of Conduct > Safe and Secure Working Environments

PHC Group Code of ConductSafe and Secure Working Environments

Table of contents

Respect for Individuals

We acknowledge the unique characteristics and values of each individual
and strive to create an organization where people with diverse backgrounds and
opinions are respected and treated fairly and equally.

  • At PHC Group, we foster a culture of respect and collaboration by encouraging diverse communication, learning to understand and embrace differences, and supporting each other's growth, thereby strengthening trust and teamwork.
  • We aim to build a workplace environment where diverse perspectives resonate, leading to richer ideas and solutions.
  • We are committed to maintaining a healthy and positive work environment free from discrimination and harassment, and to building an organizational culture that respects diversity.
  • Even when differences in communication styles, languages, or values make collaboration challenging, we promote inclusion so that every PHC Group employee is respected as a member of the team. This creates an environment where all individuals feel comfortable expressing their opinions and working towards problem-solving.
  • We achieve equity by providing fair opportunities for growth and success, including recruitment, training, and career development, taking into account different backgrounds and circumstances.

Examples of Key Relevant Laws and Regulations, including but not limited to:

Laws and regulations related to diversity, inclusion, and equity (equal opportunity):

  • International Standards CompetitionUnited Nations Sustainable Development Goals (SDGs), International Labour Organization (ILO) Standards
  • JapanLabor Standards Act, Equal Employment Opportunity Act, Act on Employment Promotion of Persons with Disabilities, Childcare and Family Care Leave Act
  • United StatesCivil Rights Act, Americans with Disabilities Act (ADA), Rehabilitation Act, Age Discrimination in Employment Act,Genetic Information Nondiscrimination Act, Equal Pay Act, Pregnancy Discrimination Act (PDA)
  • EuropeEuropean Convention on Human Rights, Charter of Fundamental Rights of the European Union, Equal Treatment Directive (Directive 2006/54/EC), Equal Pay Directive, Pay Transparency Directive, Gender Equality Directive, Pregnant Workers Directive (Directive 92/85/EEC)
  • ChinaLabor Law, Law on the Protection of Women's Rights and Interests, Employment Promotion Law

Safe and Healthy Working Environments

We aim to help each individual work in a comfortable environment
that is physically and mentally healthy, safe, and hygienic.

  • We comply with Laws and Regulations, and Internal Rules related to occupational safety and health to support daily safety, including transparently reporting to the relevant authority.
  • The company collaborates with employees to create an organized, safe, and hygienic workplace, by preventing accidents and injuries, and minimizing incidents.
  • For handling hazardous substances, dangerous materials, other chemicals, and operating machinery, we establish and provide training on appropriate safety-conscious work procedures, which employees are required to follow.
  • We do not tolerate any discrimination based on race, nationality, gender, religious beliefs, birth, age, physical or mental disabilities, sexual orientation or any other factor. We also promote a workplace environment free from harassment and aggressive behavior. Harassment includes acts or threats that cause physical, psychological, sexual, or economic harm.

Examples of Key Relevant Laws and Regulations, including but not limited to:

International Rules and Laws to Protect Workers’ Rights and Working Conditions:

  • International Standards Competition International Labour Organization (ILO) Standards
  • JapanLabor Standards Act, Industrial Safety and Health Act, Labor Contracts Act
  • United StatesNational Labor Relations Act, Fair Labor Standards Act, Occupational Safety and Health Act (OSH Act)
  • EuropeWorking Time Directive, Equal Treatment Directive, Framework Directive on Safety and Health at Work
  • ChinaLabor Law, Labor Contract Law, Work Safety Law

Information Management

We properly use and protect the information owned by or under the control of
the PHC Group in accordance with Laws and Regulations, and Internal Rules, designed to prevent loss,
theft, misuse, unauthorized access, and leakage of information.

  • We take appropriate measures to protect the information held by the PHC Group,such as product information, sales information, technical information, personal data, business records, and financial records,from external cyberattacks and internal misconduct or leakage.
  • We correctly identify confidential information and take appropriate preventive measures to protect against leakage or damage.
  • We properly manage confidential information obtained from other companies, to help distinguish it from our own information and avoid confusion.

Examples of Key Relevant Laws and Regulations, including but not limited to:

Laws to Promote Fair Competition and Prevent Unfair Competitive Practices:

  • JapanUnfair Competition Prevention Act
  • United StatesDefend Trade Secrets Act (DTSA), Uniform Trade Secrets Act (UTSA), Economic Espionage Act (EEA), Federal Trade Commission Act (FTC Act)
  • EuropeTrade Secrets Directive (Directive (EU) 2016/943)
  • ChinaAnti-Unfair Competition Law

Laws Establishing Basic Policies and Frameworks for Cybersecurity Measures:

  • JapanBasic Act on Cybersecurity
  • United StatesCybersecurity Information Sharing Act (CISA)
  • EuropeEU Cybersecurity Act
  • ChinaCybersecurity Law

Laws to Prevent the Misuse of the Internet and Computer Systems:

  • JapanAct on Prohibition of Unauthorized Computer Access
  • United StatesComputer Fraud and Abuse Act (CFAA)
  • EuropeDirective on Attacks against Information Systems
  • ChinaCybersecurity Law

Accurate Record Keeping

We diligently and accurately record various business-related
information to maintain the trust of all PHC Group stakeholders, including customers,
shareholders, investors, auditors, and regulators.

  • We create and record documents and data generated in daily operations accurately and in a timely manner, in compliance with Laws and Regulations, and Internal Rules, and store them appropriately.
  • We do not engage in any fabrication or false alteration of records. We do not inappropriately destroy or conceal records.

Examples of Key Relevant Laws and Regulations, including but not limited to:

Laws and Regulations requiring the Creation, Storage, and Retention of Accurate Records:

  • JapanCompanies Act, Financial Instruments and Exchange Act
  • United StatesDelaware General Corporation Law, Sarbanes-Oxley Act of 2002 (SOX), Securities Exchange Act of 1934
  • EuropeEU Company Law Directives, Transparency Directive, EU Audit Directive, Market Abuse Regulation (MAR)
  • ChinaCompany Law, Securities Law, Accounting Law

Social Media

We utilize social media as a valuable communication tool to
appropriately share information with stakeholders such as customers, shareholders,
investors, employees, and business partners.

  • We do not post or share internal information that has not been approved for external disclosure. We do not post or share information that is inaccurate or misleading, so as not to damage the values and reputation of the PHC Group.
  • When posting, we respect the privacy of our customers and related parties, and strictly refrain from making false, inaccurate, misleading, defamatory, slanderous and/or derogatory remarks.

Examples of Key Relevant Laws and Regulations, including but not limited to:

Laws and Regulations regulating Statements or Posts that Damage the Reputation of Others:

  • JapanLaws regarding libel and slander on the Internet
  • United StatesCommunications Decency Act (CDA), State Laws prohibiting Defamation, State Laws regarding Cyberbullying
  • EuropeGeneral Data Protection Regulation (GDPR), European Convention on Human Rights (ECHR), Defamation Act 2013 (United Kingdom), StGB (Criminal Code) (Germany), Penal Code (Poland), Civil Code (Poland), Penal Code (France), Civil Code (France)
  • ChinaCriminal Law, Civil Code, Law on Penalties for Administration of Public Security
Providing Value to Customers Lawful and Fair Business Activities
PHC Group Code of Conduct

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