Respect for Human Rights
The LY Corporation Group (the “Group”) is committed to supporting and respecting international human rights standards such as the “International Bill of Human Rights,” “ILO Declaration on Fundamental Principles and Rights at Work,” and “Children’s Rights and Business Principles” in its corporate activities. In October 2021, the Group established the LY Corporation Group Human Rights Policy to strengthen its commitment to respecting human rights of all those involved in its business activities. The Group actively engages in dialogue and collaboration with various stakeholders such as its employees, suppliers, customers, and local community to further drive these efforts.
LY Corporation Group Human Rights Policy
The mission of the LY Corporation Group is: "WOW Our Users!" Under this mission statement, the Group engages in diverse business activities involving various stakeholders, including users, business partners, and shareholders. Respect for human rights is considered a fundamental and indispensable value in conducting these activities. As the highest-level policy covering human rights throughout the Group’s business operations and its value chain, the Group has established the LY Corporation Group Human Rights Policy (the “Policy”). This Policy was formulated (or revised) with input from external experts in human rights, then reviewed and approved by the Board of Directors before being disclosed publicly. It applies to all executives and employees of the LY Corporation Group. Furthermore, the Group also encourages suppliers and other business partners to understand the Policy and incorporates human rights clauses into contracts with business partners, collaboratively promoting respect for human rights and undertaking initiatives across the entire value chain.
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Promotion Structure
The Group promotes initiatives to respect human rights through an executive structure centered on the Sustainability Committee, which is chaired by the President and Representative Director and operates under the supervision of the Board of Directors.
The Board of Directors resolves the establishment and revision of the LY Corporation Group Human Rights Policy, which sets out the Group’s fundamental policy on respect for human rights. In addition, respect for human rights is incorporated into the material topics identified by management: “Establishing Governance to Support Sustainable Growth” and “Maximizing Human Capital Value.” The status of human rights initiatives is reported to the Sustainability Committee following each meeting of the Human Rights Working Group, and significant matters are submitted and reported to the Board of Directors.
Furthermore, the Group has developed a Human Rights Risk Map as part of the process for identifying significant human rights issues. The risk map is shared with the Sustainability Committee and coordinated with the Company-wide risk management division to ensure alignment with the Group’s overall risk management framework.
Major Topic Deliberated and Resolved by the Board of Directors
- Resolution on the revision of the human rights policy: In March 2025, the Board of Directors deliberated and approved the revision of the LY Corporation Group Human Rights Policy.
Structure of the Human Rights Working Group
The Human Rights Working Group is composed of human rights officers from each Group company. Through the identification and assessment of risks and the sharing of response measures at each Group company, the Group monitors the progress of its human rights due diligence and promotes collaboration aimed at risk mitigation. The assessment results of identified risks and related response measures are reported to the Sustainability Committee.
- Chair: Lead of Human Capital & General Affairs CBU
- Vice Chair: Corporate Officer in charge of sustainability
- Members: Human rights officers from each Group company
- Secretariat: Led by the ESG management division, in collaboration with the human resources and compliance divisions
Main Activities of the Human Rights Working Group (FY2025)
| Meeting session | Date | Major agenda |
|---|---|---|
| 15th meeting of the Human Rights Working Group | September 2, 2025 | Sharing of activity reports from Group companies and discussion of the Human Rights Risk Map |
| 16th meeting of the Human Rights Working Group | February 27, 2026 | Sharing of activity reports from Group companies and exchange of views on the preliminary results of the FY2025 human rights survey |
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Human Rights Due Diligence
Human Rights Due Diligence Process
In accordance with the UN Guiding Principles on Business and Human Rights, LY Corporation has established a human rights due diligence process to clarify, assess and identify, and mitigate and correct human rights issues that are at risk of adverse impacts due to the Company’s business activities.
Identification and Assessment of Human Rights Risks
The LY Corporation Group (the “Group”) has identified human rights issues that could result in adverse impacts across its business activities and value chain, and has created a Human Rights Risk Map based on the evaluations of both severity and likelihood of occurrence, with the most recent assessment conducted in fiscal year 2024. This assessment integrates insights from external experts and was developed in line with the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Due Diligence Guidance for Responsible Business Conduct. In this round of assessment, the Group analyzed actual data, including the number of employees by country, suppliers’ countries of operation and industries, and transaction volume (monetary value), covering the main Group companies in three areas: Media Business, Commerce Business, and Strategic Business (finance sector). These data were combined with external human rights risk indices to be reflected in the Group’s overall risk profile. The findings are incorporated into the human rights due diligence process, where measures are strengthened first for those issues deemed most severe. Going forward, the Group will expand the scope in stages based on the magnitude of risks and business growth, regularly and continuously reviewing the Risk Map in light of changing business environments and stakeholder dialogue outcomes.
Process for Creating the Human Rights Risk Map
| Identifying Human Rights Issues |
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|---|---|
| Evaluating Severity and Likelihood |
②Scope (extent of impact) – the number of people affected, including actual and potential impacts, and their proportion within the affected population. ③Irremediable character – the extent to which the harm can (or cannot) be remediated, including the time required and the difficulty of restoring those harmed to their prior situation.
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| Creating the Human Rights Risk Map |
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*1 External human rights risk indices by international organizations (e.g., UNICEF, World Bank) and international NGOs (e.g., Business & Human Rights Resource Centre, Walk Free Foundation’s Global Slavery Index 2023) that provide data by country and industry.
Human Rights Risk Map
Responsible Marketing and Financial Services: Avoid spreading false or misleading information in advertising or promotion, and provide fair, appropriate financial services to all customers, including those who may lack adequate IT literacy or financial knowledge.
Customer health and safety: Ensure that products and services do not threaten customers’ health or safety by taking appropriate measures and due care at every stage from design to delivery.
Job security: Do not destabilize employment by imposing baseless dismissals or limiting the renewal of fixed-term employment contracts. Where necessary, conduct fair procedures and provide fair and clear explanations.
Human Rights Issues Related to AI and the Environment
LY Corporation (the “Company”) leverages generative AI in a variety of services, including LINE and Yahoo! JAPAN, and acknowledges the corresponding human rights risks. Particular emphasis is placed on fairness, transparency, and privacy as critical risk areas, and appropriate measures are taken accordingly. Highlighting the ethical aspects of AI, the Company established an Expert Panel on AI Ethics in 2021 to promote ongoing dialogue with external professionals. Based on the insights gained through this dialogue, in 2022, under a resolution by the Board of Directors, the Company formulated its Basic Policy on AI Ethics to safely utilize AI while protecting users’ privacy. The Company will remain vigilant about human rights risks arising from AI from multiple perspectives.
In addition, based on the LY Corporation Group Human Rights Policy, the Group has positioned environmental factors that can affect human rights as another crucial risk area. This approach recognizes respect for the rights of people living in communities closely connected to nature and seeks to contribute to sustainable environmental and social development across all areas of corporate activity. Under the Board’s oversight, the Company has established a Sustainability Committee, under which the Human Rights Working Group and the Environment Working Group operate in coordination to monitor the progress of policies and initiatives. Suppliers and business partners are likewise required to uphold human rights in accordance with international human rights standards and the LY Corporation Group Code of Conduct.
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Measures by Segment
Human Rights Assessment for the Company’s Employees
Every year, the Company provides training and educational content for employees on human rights, with a focus on discrimination and harassment. The Company also provides all employees with information on the contact point for human rights violations, and in the event of a human rights violation, the Company deals with the case in a strict manner in accordance with its internal regulation. In 2025, the Company conducted an e-learning and harassment survey targeting all employees who were affiliated with the Company at the time of implementing the e-learning and survey (permanent employees, contract employees, fixed-term employees, part-time employees, seconded workers, and temporary staff). The Company will continue to strive to prevent human rights violations and respect the human rights of employees through regular training, surveys, and analysis.
Human Rights Assessment for Group Companies
Since FY2021, as part of the human rights due diligence, the Company conducts surveys targeting Group companies to assess the status of business and human rights initiatives and the details of human rights risks. The survey did not identify any material human rights impacts that had manifested. Meanwhile, for areas requiring ongoing attention, including potential human rights risks and compliance requirements involving business partners, the Group provides follow-up tailored to each company’s circumstances and promotes efforts to identify, mitigate, and remediate risks. In collaboration with each company, the Group works to strengthen its initiatives on business and human rights. The Group will continue to use this survey to monitor the status of initiatives across the entire Group and to pursue further improvement.
Results of Human Rights Assessments
| Fiscal year | No. of target companies (Japan/overseas) |
No. of companies surveyed (Japan/overseas) |
Survey coverage | No. of companies requiring mitigation measures | Ratio of companies requiring mitigation measures | No. of companies to which mitigation measures were implemented | Ratio of implementation |
|---|---|---|---|---|---|---|---|
| FY2025 |
No. of target companies |
No. of companies surveyed |
Survey coverage : 100% |
No. of companies requiring mitigation measures : 0 |
Ratio of companies requiring mitigation measures : 0% |
No. of companies to which mitigation measures were implemented : － |
Ratio of implementation : － |
| FY2024 *1 |
No. of target companies 5 (4/1) |
No. of companies surveyed 5 (4/1) |
Survey coverage : 100% |
No. of companies requiring mitigation measures : 0 |
Ratio of companies requiring mitigation measures : 0% |
No. of companies to which mitigation measures were implemented : － |
Ratio of implementation : － |
| FY2023 |
No. of target companies |
No. of companies surveyed |
Survey coverage : 100% |
No. of companies requiring mitigation measures : 6 |
Ratio of companies requiring mitigation measures : 11% |
No. of companies to which mitigation measures were implemented : 6 |
Ratio of implementation : 100% |
*1 In FY2024, among the six companies that were subject to risk mitigation measures in FY2023, two were excluded from the scope due to business reorganizations or other factors, leaving four. Adding one new company to that group, the Company conducted the survey on a total of five companies (four in Japan, one overseas).
Identified Risks and Mitigation/Corrective Measures (FY2025)
Based on the analysis of the FY2025 human rights assessment and survey results, the Group has identified key areas for improvement commonly observed across the Group. This summary reflects trends identified in the results for the fiscal year. The prioritization of responses and specific implementation measures will be determined through dialogue with relevant divisions and Group companies and incorporated into future initiatives as appropriate.
| Outline of major potential risks | Mitigation/corrective measures |
|---|---|
| Embedding human rights risk assessment processes | Conducted hearings on the status of each company’s measures and implemented the following actions, alongside continuous monitoring:
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| Establishment and education of AI ethics rules | |
| Strengthening supply chain management |
Human Rights Assessment for Suppliers
The LY Corporation Group stipulates the Basic Policy on Procurement in order to establish sustainable and fair business relationships. The Basic Policy on Procurement consists of nine items, including compliance with laws and regulations, offering fair opportunities for competition, rational selection of business partners and suppliers, rejection of relationships with antisocial forces, building mutual trust, CSR initiatives, environmental conservation, approaches to social problems, and respect for human rights. Furthermore, LY Corporation has introduced a new supplier management policy under the Basic Policy on Procurement from July 2024.
Supplier Survey Process
In principle, LY Corporation conducts a supplier survey in its procurement activities, targeting suppliers providing goods and services to the Company. The items included in this survey is determined from the viewpoints of anti-social behavior, anti-corruption, economic security, financial integrity, and ESG factors, including environmental concerns, human rights, prohibition of child labor, and compliance with labor and wage laws. In addition, for suppliers with whom business continues, the Company generally requests a similar survey every two years to keep information up to date on a regular basis.
Furthermore, when entering into outsourcing contracts with certain suppliers, the Company incorporates human rights compliance clauses, among other provisions, into these contracts as part of its efforts to promote respect for human rights through procurement activities. These clauses emphasize diversity, prohibit harassment, forbid forced and child labor, manage working hours and wages, respect freedom of association, uphold the right to collective bargaining, and ensure the safety and health of employees. Through such procurement activities, LY Corporation deepens engagement with suppliers, building cooperative partnerships that give due consideration to human rights.
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Grievance Mechanism
LY Corporation has established a consultation desk for all stakeholders involved (customers, suppliers, supply chain workers, employees, etc.) and has established a grievance mechanism to ensure that human rights issues related to its business activities are known and addressed. This includes the whistleblowing system for reporting violations of laws and regulations, including human rights issues such as discrimination and harassment, as well as compliance violations.
In order to ensure that whistleblowers can use the internal reporting system with peace of mind, the system allows for anonymous reporting, and any disadvantageous treatment, retaliation or investigation of whistleblowers is strictly prohibited. Furthermore, the confidentiality of the reported information is strictly maintained. Reports can be made 24 hours a day, and are accepted in multiple languages, including Japanese, English and Korean. An external law firm is one channel for receiving reports, and a mechanism is in place to improve the situation and prevent recurrence in the event that a violation of laws or compliance is discovered as a result of reports from officers, employees or business partners.
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Response to Customer Abuse
LY Corporation believes that ensuring a safe working environment for employees serves as a foundation for the sustainable delivery of its services. The Company has created “LY Corporation’s Response to Customer Abuse,” recognizing that not only maintaining good relationships with valued customers but also protecting employees from abusive language and excessive demands is essential for creating a workplace where employees can work securely and provide better services.
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Specific Human Rights Initiatives
For Employees
The LY Corporation Group conducts ongoing education programs for employees of LY Corporation and Group companies in order to foster a corporate culture that respects human rights across the Group. Group companies also implement their own human rights education and policy awareness initiatives tailored to their respective characteristics.
Dissemination of Human Rights Policy
LY Corporation regularly conducts training to promote understanding of the LY Corporation Group Human Rights Policy and to ensure its dissemination throughout the Company. Following the policy revision in April 2025, e-learning was provided to all employees. In addition to providing information on the LY Corporation Group Human Rights Policy, explanatory videos were used to outline the significance of respecting human rights and the reasons for corporate engagement. A high training participation rate drove company-wide adoption of the policy.
- Ensuring awareness of the revised human rights policy (e-learning)
- Target: All employees of LY Corporation (full-time, contract, and part-time employees)
- Implementation period: June to August 2025
- Participation rate: 95% (Total eligible employees: 10,343; participants: 9,824)
Topic-Specific Seminars on Material Issues
The Group organizes seminars featuring external experts on the latest international developments in business and human rights, as well as on specific issues related to its business activities, such as AI and the environment, in order to promote deeper expertise. These seminars are also open to employees of Group companies and are intended to enhance literacy across the Group.
Human Rights Training Record
| Seminars held | Training title | Speaker | Training type | Total no. of participants |
|---|---|---|---|---|
| 12 sessions including the seminar held on September 19, 2025 | Human Rights Seminar “AI and Human Rights” (Bias and Discrimination Risks Associated with the Evolution of AI and a Human-Centered Future) |
Kazuo TASE (President and CEO, SDG Partners, Inc.) |
Online Training and Recorded Session | 165 |
| 5 sessions including the seminar held on September 25, 2024 | Human Rights Seminar: “Business and Human Rights” (Latest Trends and Response Strategies for Human Rights Issues) |
Ayumi YAMORI (Principal, Owls Consulting Group, Inc.) |
Online Training and Recorded Session | － |
For Customers
Initiatives in LY Corporation’s Media Services
LY Corporation believes that respecting human rights is crucial in media services. This commitment is clearly stated in LY Corporation’s “Commitment in Its Media Services", and the Company strives to provide appropriate information to realize this commitment.
For Children
LY Corporation prioritizes the protection of children's privacy and provides educational content related to the use of internet services. Additionally, the Company strives to create a safe online environment for children by enhancing filtering functions and promoting information ethics education.
Leveraging the characteristics of internet media, the Company undertakes initiatives related to children’s human rights. In 2019, in collaboration with the Japan Committee for UNICEF, the Company invited children to post their comments on a special page, the "Children's Public Comments," to reflect children’s voices in an action plan to end violence against children, which was being developed by government ministries, agencies, and NPOs. Furthermore, in partnership with Japan’s Ministry of Education, Culture, Sports, Science and Technology, it has introduced features in the search function of Yahoo! JAPAN Kids to address children's human rights violations, such as bullying.
Since the 2023 Human Rights Day, the Company made information regarding human rights available on Yahoo! JAPAN Kids, geared towards children. Yahoo! JAPAN Kids widely disseminates information on human rights to children and introduces related videos.