Human Rights Initiatives Human Rights Initiatives

Ateam Group Human Rights Policy

ATEAM GROUP HUMAN RIGHTS POLICY

Our Group hereby declares our commitment to respecting the fundamental human rights of all involved in our activities, including stakeholders, employees, and business partners. We recognize that through our operations, we have a responsibility to address any potential adverse impacts on human rights, whether direct or indirect.

While upholding the international standards on human rights, we adhere to high ethical standards to contribute to the creation of a sustainable society. To advance our initiatives, we will assess the various impacts our business has on human rights. By establishing and continuously improving effective internal systems to prevent human rights violations, along with transparent disclosures, we are committed to upholding fundamental human rights as universal rights.

Positioning of the Human Rights Policy

We support international norms and standards on human rights, including the United Nations’ International Bill of Human Rights, leading us to establish our own policy. This policy expresses our commitment to respecting human rights and outlines our initiatives which are grounded in our corporate philosophy, Ateam Purpose, and internal regulations such as the Code of Conduct and corporate behavior guidelines.

Scope of Application of the Human Rights Policy

This policy applies to the officers and employees of our Group, who are both the direct beneficiaries and the primary implementers of it. We also expect our users, consumers, business partners, and other entities involved in our activities to respect human rights and refrain from violating them. Furthermore, we seek the support of all stakeholders for this policy and promote respect for human rights through dialogue and consultation with them.

Commitment to the Human Rights Policy

As set forth in our Code of Conduct and corporate behavior guidelines, we believe that the sincere actions of each officer and employee contribute to the realization of our corporate philosophy. Given this context, as a company expected by society to grow and develop, we fulfill our “corporate responsibility to society” by respecting fundamental human rights and ensuring that all individuals are treated with dignity and respect.

We support fundamental human rights principles based on widely recognized international standards, including the International Bill of Human Rights (comprising the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), and the International Covenant on Economic, Social and Cultural Rights (ICESCR)), the ILO Declaration on Fundamental Principles and Rights at Work (including core labor standards), the United Nations Guiding Principles on Business and Human Rights (UNGPs), and the OECD Guidelines for Multinational Enterprises. In addition, we endorse principles concerning children’s rights, including the Convention on the Rights of the Child (CRC) and the UNICEF/UN Global Compact Children’s Rights and Business Principles, and are committed to upholding the rights of children.

We comply with applicable laws and regulations in Japan, our primary area of business. We also strive to comply with relevant laws and regulations in each country and region where we operate. In cases where domestic laws conflict with internationally recognized human rights standards, we will endeavor to uphold the international standards.

Our Group respects the internationally recognized human rights of our employees and of those who may be affected by our operations. Furthermore, we ensure our activities, products and services, and commercial relationships do not cause or contribute to adverse human rights impacts. In the unlikely event that such impacts occur, we will act responsibly and in good faith to remedy them.

Governance and Implementation Structure for Human Rights Management

Human rights risks, the scope of impacts, and measures for mitigation and remediation in our Group are deliberated by key governance bodies such as the Board of Directors and communicated from the Representative Director to the implementing organizations. Corporate departments, including the Sustainability Promotion Department, Legal Department, Human Resources Department, Labor Department, and Information Systems Department, function as the implementing organizations, promoting initiatives in coordination with each business division.

Human Rights Due Diligence

Under our governance structure for implementing this policy and our initiatives, we strive to continuously conduct human rights due diligence in accordance with internationally recognized frameworks such as the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises. In carrying out these efforts, we continuously assess human rights impacts, taking into account the characteristics of each business sector and the key value chains of each business area within our Group. When significant and severe adverse human rights impacts are identified, or when potential concerns arise, we promote measures to prevent or mitigate such impacts and continuously monitor and evaluate progress.

Addressing Human Rights Issues in Respect of Human Rights

We do not tolerate forced labor, human trafficking, child labor, discrimination, harassment, poor working conditions, bullying, or unfair treatment. Furthermore, the Group does not accept any discrimination or human rights violations based on nationality, race, gender, language, age, religion, beliefs, political or other opinions, social class or status, sexual orientation or gender identity, disability, birth, or other grounds, across our operations and businesses. The Group also respects human rights related to freedom of expression, unconscious bias, privacy, and those affected by the use of technology and AI.

In addition to our commitments mentioned above, the Group identifies the following as key human rights issues and, based on our human rights due diligence, strives to protect and uphold the following fundamental human rights.

Workplace health and safety
Respecting and protecting the rights of children
Management of working hours and fair wages
Equal pay for equal work
Ensuring freedom of expression
Freedom of association and the right to collective bargaining
Prohibition of discrimination
Prohibition of harassment
Communication and actions that respect diversity
Ensuring user safety and security
Information security and respect for privacy
Technology and human rights (considerations related to AI usage)
Respect for intellectual property rights
Protection of whistleblowers and provision of remedies

Grievance Mechanism

We have established a whistleblowing system to receive reports of misconduct, legal violations, or other significant compliance breaches within the company. This system aims to detect human rights violations, legal violations, and actions contradictory to corporate ethics at an early stage, enabling us to respond appropriately. Reporting channels are available both within and outside the company, and the Group strictly safeguards the privacy of whistleblowers and the confidentiality of reports. The Group also ensures the protection of whistleblowers so that they do not suffer any disadvantage as a result of their reporting.

If a human rights violation is confirmed, we will promptly implement appropriate remedial measures to prevent recurrence. Furthermore, if it becomes evident that our operations negatively impact human rights, the Group will respond rigorously. We will take suitable actions, including engaging with business partners like suppliers to enforce the necessary corrective actions.

Education and Awareness

We provide appropriate education and awareness-raising activities on the respect for human rights to our officers and employees, ensuring they understand this policy and are able to put it into practice in their own activities.

Stakeholder Engagement and Disclosure

Our Group actively utilizes internal and external expert knowledge and engages in dialogue with relevant stakeholders to advance human rights initiatives based on this policy. The Group also ensures transparency through disclosure of information on our compliance with this policy, including through our sustainability website.

Continuous Review of the Human Rights Policy

We recognize that human rights issues may evolve in response to changes in societal values, international human rights challenges, and the advancement of our own business activities. To continuously ensure the effectiveness of our initiatives, we will conduct periodic reviews and update this policy as necessary, incorporating insights gained through dialogue and consultation with stakeholders and external experts.

Approval

This policy is approved by the President and Representative Director of Ateam Holdings Co., Ltd. and comes into effect on September 5, 2025.

Enacted: Sep 5, 2025
Ateam Holdings Co., Ltd
Takao Hayashi, President

Attachment: “Ateam Group Human Rights Policy”

Our Approach to Respecting Human Rights

Under our corporate philosophy of “To Be a Company where All Can Achieve Happiness Together” and “To Be a Company that Continues 100 Years from Today,” our group aims to realize the “Ateam Purpose”: “To make the world more convenient and enjoyable through Creativity × Tech.” We believe that by achieving sustainable management and a society oriented toward the happiness envisioned in our corporate philosophy, we can realize happiness for all stakeholders, including employees, users, consumers, business partners, shareholders, and local communities.

Fulfilling our corporate philosophy requires sustained growth and creating value for society. To achieve this, we recognize upholding basic human rights as fundamental for our group and business activities. In the fast-changing IT industry, maintaining an adaptable, fair, and respectful environment gives us a competitive advantage. Respecting human rights is a natural duty for our group, and we position it as a key issue for our growth and sustainability.

As unpredictable societal shifts occur and digital technology rapidly advances, we recognize we may unintentionally infringe upon others’ rights. Our group is committed to addressing the human rights risks we face across all of our business operations, in accordance with international standards, as our duty to society.

Human Rights Due Diligence

Under our governance structure for promoting human rights, our group conducts impact assessments in accordance with the frameworks of the United Nations Guiding Principles on Business and Human Rights (UNGP) and the OECD Guidelines for Multinational Enterprises (MNE Guidelines). We are committed to preventing potential adverse impacts through four key steps:

Conducting human rights impact assessments
Identifying risks highly relevant to our group’s business activities
Implementing preventative and corrective measures in priority areas
Operating grievance mechanisms, including reporting and consultation channels

Conducting Human Rights Impact Assessments

Our group is committed to identifying and mitigating human rights risks through group-wide impact assessments. We map out potential issues by creating a list of human rights issues based on international standards including the UNGP, the MNE Guidelines, the OECD Due Diligence Guidance for Responsible Business Conduct and the Japanese government’s Guidelines on Respecting Human Rights in Responsible Supply Chains. Our assessments take into account the characteristics of our industry, business models, and company-specific context for pinpointing highly relevant risks.

Even risks categorized as lower priority by the impact assessment are treated as fundamental responsibilities that our group should fulfill in accordance with international norms and applicable Japanese laws and regulations.

Identifying Priority Areas

In coordination with our Legal & Compliance, HR, and core businesses, we have evaluated the severity and likelihood of risks impacting rights holders involved in our group’s business activities, and prioritized issues that are highly relevant to us. These discussions were further supplemented with past internal research data to identify critical risk areas.

Human Rights Risks Identified in Impact Assessments and Their Preventive/Corrective Measures

We identified high-priority human rights risks based on our assessments and will establish corrective measures to prevent or minimize adverse impacts.

Issue	Business Area	Target	Specific Human Rights Risks	Preventive/Corrective Measures
Appropriate Working Hours and Wellbeing in the Workplace	ALL	Employees	Unpaid wages resulting from incorrect attendance management Overtime exceeding legal limits, consecutive working days, and restrictions on taking leave Physical and mental health issues caused by overwork or harassment	Conduct internal awareness-raising activities and training for managers and supervisors to ensure proper attendance management Regular monitoring by Human Resources and issuance of corrective recommendations to managers and supervisors
Harassment	ALL	Employees	Hostile work environment created by the abuse of power dynamics, sexual harassment, and pregnancy discrimination from colleagues, supervisors, etc. Abuse of power dynamics and sexual harassment from business partners Customer harassment from users	Conduct compliance and harassment training for all employees, as well as training for managers and supervisors Conduct regular internal questionnaires regarding harassment Establish internal/external whistleblower systems and harassment consultation desks Formulate and publicize our customer harassment policy
Technology and AI	ALL	Business partners, users, and employees	Leakage or potential leakage of personal information due to cyberattacks, etc. Infringement of third-party copyrights, design rights, trademarks, or portrait rights due to the generation or acquisition of game and design materials through AI, as well as the promotion of bias or discrimination by AI-generated content	Create plans including the Basic Information Security Policy Create and adhere to our generative AI guidelines
Protection of Personal Information and Third-Party Rights	All	Business partners, users, and employees	Loss or leakage of personal information due to unauthorized access, misdirected emails, or human error Inadequate management of personal and confidential information pertaining to employees, customers, etc.	Conduct training on the handling of personal information, etc. Establish a policy for managing personal information
	All	Other parties	Infringement of third-party patent rights, utility model rights, design rights, trademark rights, or copyrights (infringement of intellectual property rights)	Establish a workflow to thoroughly conduct prior clearance for high-risk matters that exceed certain thresholds
Ensuring User Safety and Security	All	Users and business partners	Violating regulations through inappropriate or unjustified expressions in advertisements or on websites (false, exaggerated, or misleading representations)	Conduct training on expressions used in advertisements and on websites
	Digital Marketing	Users	Failure to operate safe and proper comparison websites, leading to an inability to ensure a sound trading environment and resulting in disadvantages to consumers	Set criteria for initiating business transactions Develop and inform employees regarding the terms of use and guidelines for transactions
	Entertainment	Users	Lack of measures for harassment, discrimination, or privacy-infringing remarks and actions occurring within the communities of our services	Comply with platform guidelines Establish an in-game reporting system for users
	D2C	Users	Product safety or health hazards resulting from inappropriate labeling or inadequate quality control	Conduct training on labeling Establish criteria for selecting manufacturing facilities/factories
Respect Through Our Communications and Actions	All	Employees	Behaviors, remarks, or practices that create a hostile work environment for our employees	Establish the Internal Whistleblowing System and harassment consultation desks
Respect Through Our Communications and Actions	All	Users	Dissemination of information or customer service that violates ethical standards (advertisements, promotions, customer contact, product descriptions, etc.)	Conduct various training sessions within business divisions

Our Commitment to Addressing Human Rights Issues

We are committed to respecting fundamental human rights by ensuring full compliance and taking proactive measures across the following key areas.

1.Workplace Health and Safety

Establishing a safe and healthy workplace environment is a key management issue. Ensuring this is at the forefront of our efforts so our employees can work with peace of mind while their wellbeing and health are supported.

2.Respecting and Protecting the Rights of Children

We maintain a zero-tolerance policy against child labor, forced labor, slavery, or human trafficking. In alignment with standards including the Convention on the Rights of the Child and the UNICEF/UN Global Compact Children’s Rights and Business Principles, we are dedicated to protecting our younger users through measures including age verification and usage restrictions to restrict harmful content, prevent misuse, and protect users. Additionally, our advertising and communications will be carefully vetted to avoid expressions that mislead children or adversely affect their physical and mental well-being.

3.Working Hours and Fair Wages

We strictly comply with applicable laws and regulations regarding minimum wage guarantees, living wages, and overtime management. Preventing overwork to foster a healthy working environment is also important to us. To support our employees, we enforce attendance tracking and use other measures when necessary, such as adjusting workloads and occupational health consultations. Wages are paid in full compliance with laws and labor-management agreements, ensuring transparency through pay slips. Laws and agreements defining our rules are made accessible to all employees for review at any time.

4.Equal Pay for Equal Work

We are committed to creating an equitable workplace by adhering to the simple principle of equal pay for equal work. Any employee performing equivalent duties and responsibilities receives fair and equal compensation.

5.Ensuring Freedom of Expression

We respect the right of individuals to freely express their thoughts and opinions. Across our group’s web services, games, and platforms, we support freedom of expression, but will also take action against discriminatory, violent, or rights-infringing content to create a secure and reliable environment.

6.Freedom of Association and Right to Collective Bargaining

We respect fundamental labor rights, including the freedom of association and workers’ rights to organize and engage in collective bargaining.

7.Commitment to Non-Discrimination

We strictly prohibit any form of discriminatory treatment or human rights violations based on nationality, race, gender, language, age, religion, beliefs, opinions, social class or status, sexual orientation, gender identity, disability, or birth. This is enforced through our internal rules.

8.Zero Tolerance for Harassment

Abuse of power dynamics, sexual harassment, family responsibilities discrimination, and third-party harassment from business partners or users will not be tolerated. We focus on prevention through internal regulations, dedicated consultation channels, and training. All reported incidents will be addressed promptly to prevent recurrence. Furthermore, we are committed to building an environment of mutual respect in all relationships with business partners and users.

9.Respect Through Our Communications and Actions

We uphold high ethical standards across all our customer touchpoints, from our websites and marketing to our product design and support. In all public-facing channels, we take care to use objective and professional language and conduct to avoid discriminatory expressions, stereotyping, or bias.

10.Ensuring User Safety and Security

Providing a secure environment where users can safely use our services is of the utmost importance to our group. We are committed to running our services properly and complying with relevant laws and regulations regarding expressions in our advertisements, promotions, games, and websites. We also strive to maintain a fair business environment where users can use our services with confidence.

11.Information Security and Respect for Privacy

Our information management systems are designed to safeguard personal and confidential information for our users, business partners, and employees against leaks and unauthorized access. Through continuous monitoring, vulnerability assessments, and rapid incident response, we work to defend against cyberattacks and minimize potential damage. In alignment with our Basic Information Security Policy, we remain committed to taking appropriate action and refining our systems.

12.Technology and AI Usage

For services utilizing AI and algorithms, we emphasize transparency, fairness, and accountability to prevent bias and discrimination. Guided by international ethical standards, we ensure our use of AI respects human dignity and freedom.

13.Respect for Intellectual Property Rights

We respect the rights of third parties, including intellectual property rights such as patents and trademarks, and avoid unauthorized use. Guided by laws and internal regulations, we ensure proper IP management and usage, and will promptly resolve any infringement issues. By protecting our own IP assets, we foster creative innovation and support a fair, competitive environment.

14.Whistleblower Protection and Remediation

Our internal and external whistleblowing systems enable us to identify human rights violations and compliance breaches at an early stage. We maintain strict privacy and confidentiality of reports so whistleblowers do not face detrimental treatment. Upon receiving a report, we promptly implement remedial and mitigation measures to correct the issue.

Measures for Respecting Human Rights

1.Grievance Mechanisms (Reporting and Consultation Desks)

We act swiftly to remedy any adverse impacts linked to our group through appropriate channels. To ensure effective remediation, we maintain dedicated reporting channels for both internal and external stakeholders. Whenever violations are identified, we move quickly to provide remedies to rights-holders and implement preventive measures, including engaging directly with our business partners and suppliers to enforce necessary corrections.

In addition, for individuals seeking to consult or file a report through the internal/external whistleblowing systems, we guarantee the confidentiality of all reports, ensuring full protection from any form of detrimental treatment.

（1）Internal Whistleblowing System

Our group has established an internal whistleblowing desk where employees can report or seek guidance on potential legal violations, compliance breaches, or infractions of internal rules and regulations. This desk allows anyone to report directly to legal counsel alongside the heads of Corporate Administration and Internal Auditing, so compliance breaches or situations that carry risk, including legal violations or misconduct, can be addressed properly.
We also offer a dedicated channel to consult on fair treatment and working conditions. All inquiries are handled promptly and confidentially, with strict guarantees against detrimental treatment toward any reporting employee.

（2）External Whistleblower System

Since 2024, our group has maintained a dedicated whistleblower desk for business partners and other external entities. We accept confidential reports and inquiries regarding non-compliant behavior, human rights violations, or potential violations involving the group’s officers or employees. In accordance with internal regulations, our group protects the privacy of whistleblowers, prohibits retaliatory acts, and does not permit any detrimental treatment. All reports are thoroughly investigated and properly addressed in compliance with relevant laws and internal regulations.
https://www.a-tm.co.jp/en/ir/strategy/ex-hotline/

（3）Reception and Response to Feedback and Complaints

Each business division has a dedicated customer support team to handle feedback and complaints quickly and with care. Our sales departments also serve as the primary touchpoint for maintaining our relationships with business partners, fostering a continuous dialogue with them by gathering their requests and input. By analyzing the trends in our feedback and complaints, we are able to constantly improve our services and address causes to prevent issues from recurring.

2.Training and Awareness Programs

We provide the following training and awareness programs to address key human rights issues facing our group.

（1）Business and Human Rights Training

We conduct training covering fundamental human rights concepts, societal trends in business and human rights, and business risk management. In August 2025, we conducted executive-level training for all group leadership, followed by company-wide training in December 2025 to coincide with UN Human Rights Week. All training remains available on the company portal. Through this training, we hope to promote risk awareness and mitigation across all our businesses.

（2）Compliance Training

To strengthen compliance across the entire group, we regularly conduct compliance training to raise awareness by covering various laws, regulations, ethics, and morals. We also have targeted programs, including onboarding for new hires and newly promoted managers, and updates on legal developments.

（3）Harassment Training

We conduct manager training on topics including the impact of harassment on teams, corporate risk, and managerial responsibility. Employees can contact human resources directly about interpersonal relationships and harassment concerns, which, alongside our company-wide anonymous surveys, aids us in uncovering and preventing risks that hinder a healthy working environment.

（4）Information Security Training

New hires begin training on information security from day one, covering basic practices and internal rules. For managers, we focus on security risk management, incident response, and managerial oversight so they can fully understand their responsibilities and roles. We have also created an environment where all employees can remain up-to-date on security awareness through E-learning modules on the latest cyber threats and mitigation practices, as well as targeted phishing simulations.

（5）Legal Compliance Training

Respecting human rights and maintaining legal compliance are fundamental to our operations. We offer ongoing training and E-learning modules in key business areas. Our group positions digital marketing and content distribution at the core of its business model, so a clear understanding of the Premiums and Representations Act is critical. In addition, we emphasize a working knowledge of the Pharmaceuticals and Medical Devices Act among relevant departments to protect consumers. Through education based on domestic and international laws, regulations, and social expectations, we empower our employees.

（6）Endorsement of the “My Declaration of Human Rights” Project

We have endorsed the purpose of the “My Declaration of Human Rights” project promoted by the Ministry of Justice, and have published our own declaration. This initiative, through declarations by companies, organizations, and individuals, aims to realize a society grounded in mutual respect for human rights with concrete actions.

Special Website for the Ministry of Justice’s “My Declaration of Human Rights” Project