LY Corporation Group Human Rights Policy

All officers and employees (hereinafter collectively referred to as “officers and employees,” or “we” regardless of employment type) of LY Corporation and its Group companies (hereinafter collectively referred to as the “LY Corporation Group”) are engaged in a variety of business activities both online and offline under the mission statement, “Create an amazing life platform that brings WOW! to our users.”

We acknowledge that our business activities are conducted in accordance with the LY Corporation Group Code of Conduct, which establishes respect for fundamental human rights as an essential value in our relationships with stakeholders, including officers and employees, customers, business partners, local communities, shareholders and investors.

We have established the LY Corporation Group Human Rights Policy (hereinafter referred to as the "Policy") as the highest-level policy regarding our efforts to respect human rights in our business activities and throughout the value chain, and we commit to adhering to the Policy.

1. Basic Approach to Human Rights

We understand and respect the fundamental human rights set forth in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work as the minimum standard.

We also advance our efforts to respect human rights based on principles and guidelines, such as the United Nations Guiding Principles on Business and Human Rights and Children's Rights and Business Principles.

We comply with applicable laws and regulations in all countries and regions, in which we conduct business (hereinafter referred to as "applicable laws"). In the event of a conflict between applicable laws and international human rights norms, we seek ways to respect internationally recognized human rights principles to the greatest extent possible.

2. Scope of Application

This Policy applies to all officers and employees of the LY Corporation Group. We also require our business partners, including suppliers, to support and respect this Policy and international human rights norms and to advance human rights efforts based on these principles.

3. Implementation of Human Rights Due Diligence

In fulfilling our responsibility to respect human rights, we establish a human rights due diligence framework in adherence with the United Nations Guiding Principles on Business and Human Rights to identify and assess actual and potential adverse impacts on human rights in our business activities and across the value chain, and to prevent and mitigate these impacts. We continuously implement this framework and monitor its associated results.

4. Remedy

We will seek to remediate adverse impacts on human rights through appropriate measures should we identify any events that cause or contribute to the adverse impacts through our business activities. Furthermore, when our business activities are directly linked to adverse impacts on human rights, we strive to play a role in remedy by collaborating with business partners and other stakeholders

5. Grievance Mechanism

We maintain a whistleblowing hotline available to all officers and employees of the LY Corporation Group and to the business partners of the LY Corporation Group, which functions to prevent human rights infringements and for those impacted to pursue remedies. We foster an environment that facilitates easy access to the hotline by allowing anonymous reporting and prohibiting any adverse treatment, retaliation, or investigation against whistleblowers.

6. Human Rights Governance System

The implementation of this Policy and efforts to respect human rights are undertaken by the Human Rights Working Group, which is under the jurisdiction of the Sustainability Committee and chaired by the President and Representative Director of LY Corporation. Important matters, including revisions to this Policy, are resolved by the Sustainability Committee and subsequently submitted and reported to the Board of Directors of LY Corporation, which oversees these human rights measures.

7. Stakeholder Engagement

We actively utilize external expertise in addressing actual and potential adverse impacts on human rights and engage sincerely in dialogue and consultation with relevant stakeholders.

8. Communication

To ensure the principles of this Policy are incorporated and practiced in our business activities, we offer appropriate training and awareness programs to our officers and employees and strive to promote understanding among our business partners. In addition, we disclose the progress and results of our efforts to respect human rights based on this Policy in a timely and appropriate manner through our website and other channels.

9. Key Human Rights Themes

We strive to deliver a positive impact on society through our business activities, address social issues and advance sustainable management with accountability to future generations. In the area of human rights, we will pursue our efforts in alignment with international human rights norms, considering the characteristics of our business activities, with the following items prioritized as key themes.

(1) Respect for diversity and prohibition of discrimination

We respect every individual as a person and do not tolerate discrimination or adverse treatment based on differences such as political beliefs, ideology, religion, sex, gender identity, sexual orientation, physical characteristics, illness, age, national origin, race, ethnicity, social origin, family or marital status, or background.

(2) Prohibition of inhumane treatment

We do not tolerate any harassment, nor do we condone any inhumane treatment, whether physical or psychological that threatens individual dignity, including violence, corporal punishment, or abuse.

(3) Prohibition of forced labor and child labor

We do not tolerate any labor practices that infringe on human rights, such as forced labor, human trafficking, or child labor, within our business activities or across the value chain.

(4) Respect for freedom of association and right to collective bargaining

In accordance with applicable laws, we respect the right of employees to form labor unions at their own discretion, as well as their right to choose whether or not to participate and to exercise their right to collective bargaining. Each company within the LY Corporation Group conducts negotiations in good faith, maintaining constructive dialogue with the representatives of employees.

(5) Management of working hours and payment of appropriate wages

We comply with applicable laws to manage appropriate working hours, rest breaks, overtime, late-night work, holidays, leaves, and wages, and eliminate unreasonable disparities in treatment due to employment type under the principle of equal pay for equal work. In addition to compliance with applicable laws, we strive to provide remuneration that surpasses living wages. We also strive to reduce excessive working hours and realize flexible work styles for our employees.

(6) Maintenance of safety and health

In accordance with applicable laws, we strive to ensure a safe work environment where employees can work safely and in good physical and mental health. In addition, we strive to maintain and enhance employees’ health by addressing their health risks appropriately.

(7) Respect for privacy

We regard the protection of personal information (hereinafter referred to as "Personal Data") as one of our top management priorities. We comply with relevant applicable laws and strive to protect Personal Data of our users and other stakeholders.

(8) Respect for freedom of expression

We respect the ability of individuals to freely send and receive opinions and information and to communicate without censorship or regulation on the internet media to the greatest extent possible. At the same time, as an internet media service provider, we are responsible for maintaining a proper environment for open dialogue. Therefore, we take appropriate actions against expressions that infringe on human rights of others, such as defamation or discrimination, false information, harmful content, and antisocial expressions that contravene public welfare as necessary.

(9) Responsible advertising and marketing activities and financial inclusion

We carefully consider the possibility of advertisements contributing to discrimination and prejudice, and the impact on minors and vulnerable users, and strive to enhance our advertising review system to prevent adverse impacts on human rights. In addition, to fulfill our responsibility as an advertising platform provider, we advance efforts to ensure transparency and fairness in our advertising business. In providing financial services, we leverage information technology to create an environment where a greater number of users, including those in vulnerable positions, can access convenient and appropriate financial services.

(10) Respect for children's rights

We support and respect the Children's Rights and Business Principles, conduct business activities that take into account the development and characteristics of children, and work on children’s safety and their healthy growth.

(11) Ethical use of technology

We leverage technology, including AI, to foster the development of a healthy society, create a better future, and contribute to humanity. Throughout the AI system life cycle, we respect human rights and values such as user privacy, diversity, non-discrimination, equality, freedom, dignity, individual autonomy, and fairness. In addition, we monitor factors such as data, algorithms, and outputs to avoid inappropriate biases in AI outcomes, pursuing impartiality in AI.

(12) Assurance of accessibility

We strive to create an accessible environment on our websites and applications, referencing international standards to ensure that all users, including diverse users, such as those with visual, auditory, and other disabilities, can equally access our products and services.

(13) Contribution to local communities

We strive for harmonious coexistence with local communities by recognizing the impact of our business activities and respecting the traditions and cultures of each country and region. We contribute to the realization of a more prosperous society by utilizing resources such as human capital and IT technology, to advance measures such as disaster response and recovery support.

10. Amendment and Abolition of this Policy

The amendment and abolition of this Policy shall be carried out with the approval of the Sustainability Committee and the Board of Directors of LY Corporation.

Enacted on October 7, 2021
Revised on October 1, 2023
Revised on April 24, 2025

Unless otherwise specified, English-language documents are prepared solely for the convenience of non-Japanese speakers. If there is any inconsistency between the English-language documents and the Japanese-language documents, the Japanese-language documents will prevail.

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