JAE Group Human Rights Policy

1. Support for International Norms

   The JAE Group respects the following internationally recognized human rights standards and is committed to conducting its business activities in a manner that respects these principles:

   • Universal Declaration of Human Rights
   • International Covenant on Civil and Political Rights
   • United Nations Guiding Principles on Business and Human Rights
   • ILO Declaration on Fundamental Principles and Rights at Work
   • OECD Guidelines for Multinational Enterprises
2. Scope of Application
   This Policy applies to all officers and employees of the JAE Group, including contract employees and dispatched personnel. The JAE Group also expects its suppliers, business partners, and customers to respect human rights in accordance with this Policy.
3. Governance Structure
   Initiatives under this Policy are implemented under the responsibility of the Associate Senior Vice President overseeing the General Affairs and Human Resources Division. Progress on these initiatives is reported regularly to the JAE Group Risk Management Committee, which in turn reports to the Board of Directors for oversight.
4. Human Rights Due Diligence
   The JAE Group establishes and continually implements a human rights due diligence framework and process aligned with the United Nations Guiding Principles on Business and Human Rights to advance its efforts to respect human rights.
   1. Human Rights Impact Assessment
      The JAE Group continuously assesses actual or potential adverse impacts on human rights, including those within its value chain, to prevent and mitigate risks of salient human rights risks.
   2. Prevention and Mitigation of Adverse Impacts
      The JAE Group integrates measures to prevent and mitigate adverse impacts on human rights into its business processes and implements initiatives such as awareness‑raising and educational programs.
   3. Corrective Measures and Remedial Action
      Where actual or potential human rights violations are identified, the JAE Group conducts prompt and appropriate investigations and takes necessary corrective measures and remedial actions.
   4. Communication and Disclosure
      The JAE Group provides information on its human rights due diligence efforts through its website, the JAE Report, and other appropriate channels.
5. Salient Human Rights Issues for the JAE Group
   Based on input from internal and external experts, the JAE Group has systematically assessed human rights risks within the JAE Group and its value chain. These risks have been categorized into ten key areas, as outlined in the appendix. The JAE Group implements appropriate measures in these areas, conduct ongoing monitoring and continuous improvement, and work to build trust with stakeholders.
   Furthermore, taking into consideration human rights risks inherent to the industry as well as country-specific risks in the locations of the JAE Group’s business sites and business partners, the JAE Group reviewed internal interviews, human rights–related reports, and internal survey results from internal assessments. Based on this review, the following outstanding human rights issues have been identified:
   • Discrimination and Inhumane Treatment
   • Child Labor
   • Excessive Workloads and Long Working Hours
   • Occupational Safety and Health

   The JAE Group prioritizes efforts to strengthen its response to these outstanding human rights issues.

April 1, 2026
Seiji Takahashi
Associate Senior Vice President
General Manager General Affairs & Human Resources Division
Japan Aviation Electronics Industry, Ltd.

Appendix: Potential Human Rights Risk Areas for the JAE Group and Our Policy for Addressing Them

1. Elimination of Discrimination and Inhumane Treatment
   1. The JAE Group does not tolerate any form of discrimination in hiring or employment practices—including wages, promotion, access to training, and other working conditions—on the basis of race, color, age, gender, sexual orientation, gender identity or expression, ethnicity, nationality, disability, pregnancy, religion, political affiliation, union membership, veteran status, protected genetic information, or marital status.
   2. The JAE Group does not require medical tests or physical examinations that could be used in a discriminatory manner.
   3. The JAE Group strives to prevent all forms of harassment, inhumane or abusive treatment, violence, and verbal abuse in the workplace. Matters related to disciplinary actions—including applicable criteria, types, and procedures—are defined in the Work Rules and clearly communicated to all employees.
2. Prohibition of Child Labor
   1. The JAE Group does not employ any person below the minimum age for employment under applicable local laws, the age for completing compulsory education, or 15, whichever is highest.
   2. The JAE Group does not assign workers under the age of 18 to tasks that may jeopardize their health or safety, in accordance with applicable laws and regulations.
   3. For student workers, including interns and individuals working while enrolled in educational institutions, the JAE Group appoints qualified supervisors, maintains appropriate student records in compliance with applicable laws and regulations, and provides suitable support and training.
3. Prohibition of Forced Labor
   1. The JAE Group does not use forced, bonded, or involuntary labor; exploitative prison labor; or labor obtained through slavery or human trafficking. This includes recruitment, transfer, or receipt of people through threats, abduction, fraud, or other coercive means.
   2. The JAE Group provides written employment agreements that clearly state the terms and conditions of employment in a language understood by the employee.
   3. The JAE Group does not confiscate, retain, or otherwise prevent employees from accessing their original identity documents, including government‑issued identification or passports.
   4. The JAE Group does not require employees to pay recruitment fees or any other related fees charged by the company or third‑party employment agents.
   5. All employees of the JAE Group may take leave or terminate their employment without any penalty or penalty fees, provided that notice is given in accordance with their employment contract.
4. Prevention of Excessive Workloads and Long Working Hours
   1. The JAE Group complies with applicable local laws and regulations regarding working hours and manages working hours so that they do not exceed the maximum limits established by those laws.
   2. The JAE Group ensures that employees are provided with at least one day of rest in every seven‑day period.
   3. All overtime work at the JAE Group is performed with the employee’s voluntary and informed consent.
   4. The JAE Group strives to ensure that weekly working hours, including overtime, do not exceed 60 hours, except in emergency or extraordinary circumstances.
5. Appropriate Wages
   1. The JAE Group complies with applicable local laws and regulations regarding wage payments. We guarantee legally mandated minimum wages and compensate employees for overtime at pay rates higher than regular wages.
   2. The JAE Group clearly communicates wage structures and pay dates to all employees through wage rules and other internal policies, and provides payslips so that employees can verify wages paid for each pay period.
   3. The JAE Group does not make wage deductions as a form of disciplinary action.
6. Freedom of Association
   The JAE Group, in accordance with applicable local laws and regulations, respects the right of all employees to freely form and join labor unions and to engage in collective bargaining.
   Employees and/or their representatives are able to communicate and share their views and concerns with management regarding working conditions and management practices without fear of discrimination, intimidation, or retaliation.
7. Occupational Safety and Health
   The JAE Group establishes systems for preventing occupational accidents, maintaining the physical and mental health of employees, and responding to emergencies.
   Through these systems, we strive to create a safe, healthy, and comfortable work environment where all employees can fully demonstrate their abilities.
8. Right to Privacy
   The JAE Group thoroughly protects personal information in accordance with our Personal Information Protection Policy and takes measures to prevent the leakage of personal information resulting from cyber-attacks or other threats.
9. Local Communities
   The JAE Group respects local culture, customs, and history.
   We conduct our business activities with consideration for the living environment, health, and safety of local residents, and we strive to minimize any negative impact on human rights within the local community.
10. Consumer Safety and Health
    The JAE Group places the highest priority on the safety of customers and consumers who use our products and technologies.
    We also strive to prevent and mitigate any negative impact on human rights arising from unintended or improper use.