The JTB Group maintains the following human rights policies:

• Anti-Discrimination and Anti-Harassment Policy
• Anti-Slavery and Human Trafficking Policy
• Diversity & Inclusion Policy

The JTB Group backs each of these policies with the following commitments.

Commitment to a Work Environment Free of Discrimination and Harassment

The JTB Group does not tolerate any form of discrimination or harassment in the workplace. Every employee is responsible for maintaining a positive work environment free of discrimination and harassment.
Employees who are found (after appropriate investigation) to have violated this policy will be subject to disciplinary action up to and including immediate termination.

Commitment to a Work Environment Free of Slavery and Human Trafficking

The JTB Group maintains a zero-tolerance policy for modern slavery. We are committed to acting ethically in all of our business dealings and relationships. We implement and enforce effective systems and controls to prevent modern slavery from occurring anywhere in our organization or supply chain. We expect similar high standards from all of our business partners, vendors and suppliers.

Commitment to DEIB

JTB is committed to fostering and maintaining a culture of diversity, equity, inclusion, and belonging (DEIB). We believe that our employees should reflect the diversity of the communities in which they work and live.

Human Rights Due Diligence

JTB's human rights due diligence is aimed at identifying, mitigating and preventing human rights risks in our organization and supply chain. We are committed to safeguarding human rights and to transparent reporting about the methodology and effectiveness of our efforts.

Purpose of Due Diligence

• Identify, analyze and assess human rights risks and implement appropriate mitigation measures.
• Ensure the ongoing creation of corporate value through business integrity predicated on a fundamental respect for human rights.
• Contribute to the broader wellbeing of society by promoting respect for human rights within the JTB Group and across our supply chain.

Survey Participants

All JTB employees
Respondents: 8,564 Response Rate: 72%

Due Diligence Period

December 11-29, 2023

Identification of Human Rights Risks based on Analysis of Survey Results

With input from outside experts as well as our in-house human resource planning, legal and DEIB teams, we analyzed the results of our due diligence survey and identified the following three priority areas of human rights risk:

〈 3 Priority Areas of Human Rights Risk 〉

• （1）Harassment and Abuse
• （2）Occupational Safety and Health
• （3）Work Hours

Taking the Next Step

We are committed to adopting mitigation measures to address the above-identified priority areas of human rights risks. We will conduct annual progress monitoring in order to track and assess the effectiveness of our efforts. Looking ahead, we plan to expand out the scope of our efforts to include all JTB Group companies as well as domestic and overseas suppliers.

Key initiatives aimed at addressing our 3 priority areas of human rights risk

In alignment with the guiding principles described below, we are committed to adopting mitigation measures to address the three priority areas of human rights risk identified through our due diligence survey.

(1)Harassment and Abuse
①Guiding Principles
In order to ensure that harassment has no place in our business, we strive to deepen our people's understanding of its many forms. We take comprehensive preventive action and are working to strengthen remedies available for aggrieved employees.
②Key Initiatives
・Human rights training
・DEIB training (LGBTQ+ issues, unconscious bias, etc.)

(2)Occupational Safety and Health
①Guiding Principles
JTB is committed to promoting workforce wellbeing by encouraging our employees to take ownership of their own health and adopt healthier lifestyles. To this end, we offer our people information, training, digital tools and a variety of wellbeing programs and events. We seek to be recognized as an FY2025 "White 500" Health & Productivity Management Outstanding Organization.
②Key Initiatives
・Mandatory registration on the Pep Up Health Management Web Portal
・Programs to promote sleep hygiene and regular exercise as well as healthcare guidance to support
　employee efforts to achieve greater health
・Wellbeing checks to prevent adverse health impacts from overwork
・Training and mentoring programs to promote mental and emotional health
・FemTech services to address women's health issues
・Analysis of stress survey results and guidance for teams reporting high levels of stress

(3)Work Hours
①Guiding Principles
JTB Corp. is pursuing a number of initiatives aimed at reducing the number of annual hours worked* by its employees to 1,650.
　* 1,800 total annual working hours (7.5 hours x 240 days) - 150 hours of annual paid leave (7.5 hours x 20 days)
②Key Initiatives
・Better training for managers and supervisors
・Use of labor management comprehension checks to deepen manager understanding of best practices
・Increased use of flextime, variable work hours, telework, and continuous leave
・Implementation of 'Work-Interval System' to ensure sufficient off-duty time (11 hours) between shifts

Future Considerations

In addition to taking corrective action to address the priority risks described above, we also intend to undertake a broader exploration of human rights issues and implement any necessary responsive action.

• Ongoing re-examination and disclosure of human rights policies
• Identification and assessment of human rights risks
  • Identification of risks specific to JTB Group companies
  • Identification of supply chain risks
• Mitigation measures
  • Analysis of survey results and identification of issues
  • Establishment of targets and KPIs
  • Development of HR programs and mechanisms
  • Development of in-house systems and clarification of responsibility
  • Education, training, awareness raising activity, senior management communications
• Monitoring of human rights risks
  • Review progress of mitigation measures: Reporting to Management Committee and Board of Directors
  • External Assessment: Human rights audits and independent evaluations (UN Global Compact)
  • Supply chain management
  • Design, implementation and ongoing re-examination of complaint response and remedy mechanisms
• Disclosure regarding human rights risks
  • Use of Sustainability Reports to disclose information on human rights issues
  • Transparency with stakeholders
  • Stakeholder dialogue

JTB Group Code Hotline

The JTB Group Code Hotline is our whistleblowing mechanism that allows employees to report genuine concerns about illegal or inappropriate conduct without fear of retaliation. Concerns reported to the Hotline are subject to objective investigation and appropriate follow-up. The Hotline may also be used to report suspected human rights violations.

Human Rights Training

In order to promote awareness and understanding of the Group's human rights policies, we periodically conduct training and administer workforce comprehension checks.

Specific Initiatives 1：〈 Training & Testing 〉Compliance Quizzes
Administered on a Group-wide basis in January and June each year (the January quiz is administered together with the JTB Group Code of Conduct Comprehension Check) with the goal of raising compliance awareness in the workplace.

Specific Initiatives 2：〈 Training & Testing 〉Compliance Workshops
Conducted on an ongoing basis in order to deepen our colleagues' understanding of the JTB Group Policy.

Compliance Quizzes Administered in June 2023 and January 2024

No. of test-takers	June 2023: 14,851 January 2024: 13,895
Registered employees	June 2023: 19,641 January 2024: 19,375
Sit rate	June 2023: 63.7% January 2024: 71.7%
Quiz languages:	Japanese, English, Chinese (simplified), Chinese (traditional), Korean

Compliance Workshops (March 2024)

Workshop participants	7,224
Registered personnel	18,663
Coverage rate	38.7％
Workshop languages:	Japanese, English