Procurement Policy

Eagle Industry Co., Ltd. and its group companies (hereinafter referred to as the “EKK Group”) conduct procurement activities based on our procurement policy in the countries and regions in which we do business.

1. Basic Procurement Policy

1. We comply with laws, regulations, and social norms.
2. Under the principle of free competition, we provide opportunities in a fair and equitable manner and strictly select our partner companies.
3. Under the principle of co-existence and co-prosperity, we respect mutual interests and do not engage in conflicts of interest.
4. We proactively engage in improvement activities in collaboration with our partner companies.
5. We build partnerships with our partner companies through open communication.

2. CSR Procurement Guidelines

In endorsement of the UN Guiding Principles on Business and Human Rights (United Nations Human Rights Council), the OECD Guidelines for Multinational Enterprises (Organization for Economic Co-operation and Development), the ILO MNE Declaration (International Labour Organization), and the SDGs (Sustainable Development Goals), and in order to fulfil our corporate social responsibility and sustainability requirements, we will conduct procurement activities based on the following guidelines.

(1) Compliance

1. Compliance with laws and regulations
   • We will comply with the laws and social norms of each country, including competition laws, trade-related laws, and environmental-related laws..
   • We will establish and implement policies, systems, and training to ensure compliance with laws and regulations.
2. Management of Confidential Information
   • We will properly manage and appropriately use customer information, partner company information, personal information, technical information, and other information acquired through transactions.
   • We will carry out strict control and protection of privacy and data acquired through transactions.
3. Protection of Intellectual Property
   • We will not infringe on the rights of third parties, including unauthorized acquisition or unauthorized use of intellectual property.
4. Prevention of corruption
   • We will strive to build transparent and fair relationships with our partner companies, and will not give or receive entertainment, gifts, money, or information for the purpose of obtaining or maintaining undue profit or unfair preferential treatment.
5. Exclusion of anti-social forces
   • We will not conduct transactions with organized crime groups, members of organized crime groups, persons affiliated with organized crime groups, other antisocial forces, or businesses associated with such groups.

(2) Human rights and labor

1. Respect for human rights
   • In all employment and treatment (application, hiring, promotion, compensation, right to receive education, job assignments, wages, employee welfare, discipline, termination, retirement, etc.), we will not tolerate any discrimination on the basis of gender, age, nationality, race, ethnicity, creed, religion, sexual orientation, gender identity, disability, marital or child status, or any other reason.
   • We will not tolerate any form of harassment, including power harassment, sexual harassment, or any other form of harassment.
2. Work environment
   • All work is voluntary, and we will not tolerate forced labor due to lack of consent to work and threat of punishment.
   • We will not tolerate child labor at ages below the minimum age at which a person may work as defined by the laws and ordinances, rules, and regulations of each country or region and international norms.
   • We will not tolerate illegal work by aliens or other forms of illegal work.
   • We will ensure the occupational safety and health of our employees, and comply with the laws and regulations of each country and region.
   • Minimum wages, overtime, wage deductions, piece wages, other benefits, working hours (including overtime hours), holidays, and granting of entitlement to annual paid leave for employees shall comply with the laws and regulations of each country and region.
   • Employees are not prevented from joining or forming labor unions in accordance with the laws and regulations of each country and region.
     We also approve the exercise of collective bargaining rights.

(3) Quality and safety

To earn the trust of our customers and consumers, we place the highest priority on “quality first” and “safety first” in our product development and procurement.

(4) Environmental conservation

Aiming at harmony with the environment, we will comply with the environmental laws and regulations of each country and region, and conduct procurement activities according to the “EKK Green Procurement Guidelines” in consideration of the global environment and the realization of a sustainable society.
In addition, we will strive to be environmentally conscious regarding transportation, and will actively work to simplify packaging, use recycled materials, use environmentally friendly packaging materials, and use packaging and cushioning materials that can be used repeatedly.

(5) Community and Society

1. Responsible procurement
   • We strive to avoid the procurement and use of products and raw materials from countries and regions that may cause social problems in terms of human rights, the environment, and so on.
   • We work toward the non-use of minerals and related processed products that are sources of funding for armed groups engaged in inhumane acts.
2. Conflict Minerals
   Our basic policy is to not use conflict minerals produced in the Democratic Republic of the Congo (DRC) and neighboring countries, and to eliminate conflict minerals that finance or benefit illegal armed groups in conflict areas. Furthermore, to ensure compliance with our policy, we require our partner companies to procure from smelters that have been certified as being free from complicity in conflicts or serious human rights violations.
   To realize this policy, we eliminate all forms of human rights violations in our corporate activities and supply chain, and promote efforts to procure raw materials that do not contribute to conflicts and to mitigate risks.
   • When purchasing raw materials, we conduct sufficient research and do not purchase conflict minerals (tantalum, tin, gold, tungsten) or cobalt produced in the Democratic Republic of the Congo or neighboring areas that could be a source of funding for armed groups.
     In addition, we will not purchase any materials that are unidentified by our partner companies.
   • We fully cooperate with our customers in their investigations of conflict minerals and work together to eliminate conflict minerals and to engage in responsible procurement activities.
   • We collect information related to conflict minerals and review the content and progress of these measures to make them more effective in light of the above objectives.
3. Contribution to local communities
   • In cooperation with local communities, we pay attention to issues facing communities, and aim to perform social contribution activities that will lead to solving them.
   • We contribute to the development of local communities through active transactions with local businesses.
4. Information Disclosure
   • We disclose business information related to management and finances, product handling, safety, quality, and the environment to all stakeholders in a timely and appropriate manner, and strive to maintain and develop mutual understanding and relationships of trust with stakeholders through open and fair communication.

(6) Crisis management for business continuity

We establish organized management systems for business continuity and ensure crisis management in preparation for the occurrence of crises such as cyber attacks, information leaks, natural disasters, infectious diseases, fires, and accidents.

(7) Sharing awareness with our partner companies

We work to ensure that the EKK Group’s “Charter of Corporate Behavior” and “Procurement Policy (Basic Procurement Policy and CSR Procurement Guidelines)” are respected throughout the procurement supply chain.

3. Requests to Our Partner Companies

(1) Request for understanding of our “Procurement Policy (Basic Procurement Policy and CSR Procurement Guidelines)”

We believe that sharing awareness of CSR activities throughout the procurement supply chain is important in fulfilling our corporate social responsibility.
We request that our partners understand the EKK Group’s “Charter of Corporate Behavior” and “Procurement Policy (Basic Procurement Policy and CSR Procurement Guidelines)” and make similar efforts.

(2)Expansion to our partner companies’ suppliers

We ask our partner companies to develop their own policies and guidelines for their suppliers based on the above objectives, and to disseminate their CSR initiatives.

(3) Declining kindnesses, etc.

1. We decline all kindnesses (money, gift certificates, book vouchers, gifts, special discounts on products, etc.) from our partner companies.
2. We decline to attend dinners, golf, etc., unless agreed upon in advance between the partner company and us.
3. We do not buy or sell shares based on internal information from our partner companies.
4. We will not receive any other favors that are considered to be inappropriate by socially accepted conventions.

4. Consultation Service

Our company has established a consultation service for compliance questions and other issues related to transactions with the EKK Group.
(Corporate Strategic Planning Office or Administration Department of the Corporate Administration Office, Eagle Industry TEL: +81（3）3432-3892)

1. This consultation service is intended to solve problems by receiving information from our partners when they become aware of violations (or suspected violations) of laws and regulations by the EKK Group’s employees, etc., in their transactions with us.
2. We will confirm the facts of the reported matter and take appropriate action.
   Note that we may ask for cooperation in fact-finding, investigation, etc.
3. In order to protect the informants and their employer, we will thoroughly maintain confidentiality regarding reports. In addition, we will not take actions to identify or search the informants and their employer, nor will we treat them disadvantageously because of their reporting.
4. The above does not apply if a report contains intentionally false information.

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