1. Policy and Basic Concept

Individual Human Rights Policy

• Respect for Diversity
  • One of our strengths is that diverse human resources can work in diverse styles. That is one of the reasons why we proactively promote activities to respect human rights. On the other hand, we provide all our employees with human rights training for the friction among them that is one of the problems of our highly diverse workplaces. We understand this friction and respond to it with a whistleblower system.
  • We consider various individual differences to be the richness of individuality and characteristics. We will continue to create workplaces without discrimination based on mere differences.

    

    

    

• Respect for the Rights of Children (Nurturing the Next Generation)
  • The child poverty rate in Japan is particularly high among developed countries. In response to this social issue, we proactively contribute to nurturing the next generation with NPOs and other stakeholders. We do this from a stance that extensively supporting human resources is important both in terms of business and society.
  • We support the United Nations Convention on the Rights of the Child and the Children's Rights and Business Principles.
  • We do not use child labor. We support all national and international policies to eradicate child labor.
• Response to Modern Slavery and Human Trafficking
  • We engage in business activities in Japan and overseas based on the United Nations Global Compact and the Guiding Principles on Business and Human Rights according to the human rights policy we have established. All our policies, rules and regulations include initiatives to prevent modern slavery and human trafficking.
• Respect for the International Labor Organization (ILO) Core Labor Standards
  • We consider the four ILO core labor standards to be basic human rights. Those four standards are freedom of association and the right to collective bargaining; the elimination of all forms of forced labor; the abolition of child labor; and the elimination of discrimination in respect of employment and occupation. We support and comply with these rights.
• Consideration for Foreigners
  • We aim to provide fair and equitable working conditions and environments to foreign employees, interns and trainees. We comply with laws/ordinances of the countries concerned and observe a position of respecting human rights at our overseas contact centers. Our grievance handling mechanism and human rights due diligence system apply to our whole group.
• Respect for the Rights of Indigenous Peoples
  • We recognize that indigenous peoples have unique culture and history in our business activities in regions where they live as part of our commitment to respecting human rights. We respect and take into consideration the rights of indigenous people established in the laws of countries and regions where we engage in business activities and international agreements such as the United Nations Declaration on the Rights of Indigenous Peoples and the International Labor Organization (ILO) Convention No. 169. We also thoroughly check in advance the impact of our business on the rights of indigenous people when considering new business investment projects.
• Initiatives with Various Stakeholders
  • We define the value we provide to stakeholders and our initiative policy as our CSR Policy. We promote human rights, diversity and various other themes together with our stakeholders.

2. Promotion Organization and Systems

• We have assigned a director in charge of human rights and clarified the responsibilities of the Board of Directors. The director in charge reports the related risks and important themes to the Board of Directors.
  • The director in charge considers human rights management policies while cooperating with the officer in charge of risk management who is responsible for the Risk Management Division.
  • The Legal and Compliance Division plays a central role in monitoring human rights violations. The division engages in various activities in cooperation with the Risk Management Division with both divisions serving as permanent organizations. Those activities include the planning and execution of measures, the provision of related training, and external activities.
  • There have so far been no disputes caused by human rights violations.

    

• Human Rights Due Diligence
  • Our business model, that is, the call center model, accounts for almost all of our sales.
  • Our in-house full-time employees, contract employees, temporary employees from employment agencies, and part-time employees and other short-term employees work at approximately 40 contact centers in Japan and approximately three contact centers overseas.
  • We also engage in small-scale temporary employee business. We place our employees with client companies.
  • We have been conducting human rights due diligence since 2019. We broadly ascertained an overall sense and the whereabouts of risks as the first step. We then prepared full-scale human rights due diligence.
  • We have also created human rights training based on those results. We are giving that training to all our employees on a mandatory basis.
  • We will increase the sophistication of our process for human rights due diligence together with human rights due diligence experts in the future.
• New Investment Projects
  • We conduct overall due diligence including human rights when we consider joint ventures, mergers and acquisitions overseas. The Board of Directors oversees that due diligence.
• Existing Business
  • We rigorously conduct comprehensive screening before entering into business with new business partners.
  • We ask our business partners to submit detailed information before starting business with them. We do that to avoid risks that may arise from that business. We conduct individual reviews based on the information our business partners submit. We carry out confirmation with those business partners if necessary.
• Risk Management
  • We mainly grasp human rights risks through our whistleblower system and human rights due diligence. We have appointed a Director in Charge of Human Rights and the Board of Directors oversees the work of that director.
• Human Rights Whistleblower System (Human Rights and Other Areas of Compliance and Harassment)
  • We established the Whistleblower System Operation Rules in 2017. We have set up two contact points.
    • Corporate Ethics Hotline

      Point of contact for reports of legal violations, internal regulation violations, dangerous acts and ethical violations

    • Harassment Counseling Desk

      Point of contact for reports of grievances, concerns and dissatisfaction about sexual harassment, workplace bullying, workplace discrimination against pregnant women, psychological abuse and other forms of harassment

  • These points of contact can be used by all the officers and full-time employees, contract employees, temporary employees, short-term employees (part-time employees), retired former employees and permanent contractor employees in our group.
  • The Whistleblower Protection Act and other laws/ordinances and our Whistleblower System Operation Rules protect whistleblowers (those seeking advice), those providing their cooperation to confirm the facts of the situation and the contents of reports. We prohibit disadvantageous treatment such as retaliation against whistleblowers. It is also possible to make reports anonymously.
  • We have established the Rules for Prevention and Elimination of Harassment and Appropriate Measures for Harassment Cases to combat harassment. The rules stipulate the basic prohibitions and the method of managing and dealing with incidents.
  • We have also appointed an external full-time female counsellor to deal with harassment.
• Overview of the Whistleblower System and Grievance Reporting System

  

Consultation Desk for the General Public(including Stakeholders)

• BELLSYSTEM24 has established a system to accept opinions, proposals, and grievances and to accept inquiries from the general public and all our stakeholders, as described below.
  • In the BELLSYSTEM24 Group, we make use of opinions and suggestions from customers to improve customer satisfaction, facilitate stakeholder understanding, prevent risks, and other purposes, thereby helping to improve our corporate value.
  • We treat reports as confidential. We protect the contents of reports, personal information and rights under all circumstances both according to laws and our internal rules. We also prohibit retaliation against whistleblowers.

Basic Policy for Customer Harassment

Our purpose is to "sustain the prosperity of society, through innovation and communication." To realize this purpose, we believe it is essential that our employees (all employees who work for the BELLSYSTEM24 Group regardless of their employment status including full-time employees and part-time employees) can work safely and with peace of mind. We have now enacted this basic policy for customer harassment against our employees. We have enacted this policy in line with the Call Center Association of Japan's "CCAJ Code of Ethics Guideline."

1. Our Responsibility to Protect the Human Rights of All People Involved in Our Business Activities and Transactions

Our basic stance in our Human Rights Policy is that "we respect the rights of all people involved in any of our business activities and transactions." We consider it our basic responsibility to protect the human rights of our customers such as companies and consumers (hereinafter "Customers etc."). We prohibit all forms of harassment in our Human Rights Policy. We aim to create safe workplaces where our employees can work with peace of mind. As such, we believe it is our important responsibility to also protect our employees from the striking risk of customer harassment in running a call center business.

2. Definition of Customer Harassment

The orders and inquiries from Customers etc. that we handle as a call center also include grievances and complaints. Grievances and complaints are important to improve products and services. On the other hand, some grievances and complaints are malicious including excessive demands and unreasonable abusive behavior. Such maliciousness may infringe on the human rights of our employees and make it difficult for them to work with peace of mind. Under the assumption such cases of maliciousness will arise, we define customer harassment as follows in this policy based on the Ministry of Health, Labour and Welfare's "Corporate Manual on Measures against Customer Harassment."

Definition: Customer harassment refers to complaints, words and acts by Customers etc. which employ a means and manner of realizing their requests that is inappropriate in terms of socially accepted standards in light of the validity in the requests of those complaints, words and acts and which, through such means and manner, infringe upon the human rights and the safe and secure working environment of our employees.

3. Our Stance on Customer Harassment

We will continue to respond in good faith to the various inquiries we receive as before to achieve our purpose. However, we will work to prevent harm caused by customer harassment to ensure we do not sacrifice the human rights of our employees. If there is a risk of the human rights or working environment of our employees being violated due to customer harassment, we will work to resolve that as an organization. At the same time, we will seek the understanding of those involved including our Customers etc. for our response to our Customers etc. and the continuation of transactions.

4. Our Response to Protect and Provide Relief to Our Employees

It is important to discover the risk of customer harassment early to protect our employees from such harassment. Accordingly, we have established and are appropriately operating a desk to receive inquiries and grievances from our employees. If we discover there is a risk of customer harassment through this desk or otherwise, we will work with lawyers and other external experts as necessary to protect and provide relief to our employees. Moreover, we will provide mental support to employees who have suffered customer harassment.

5. Employee Education and Awareness

We will continue to inform our employees, spread awareness among them and provide them with education about the basic knowledge relating to customer harassment and the method of dealing with it when it occurs to prevent harm caused by customer harassment and to respond it quickly and appropriately.

Enacted on January 1, 2024
Hiroshi Kajiwara
President, CEO and Representative Director
BELLSYSTEM24 Holdings, Inc.

3. Initiatives

Respect for the Rights of Children (Nurturing the Next Generation)

• We opened a call center pavilion in KidZania Tokyo in 2016. It provides children with a wide range of experiences of working in a call center. This initiative allows children to learn the rules and manners of society and the fun and hardships of working. We will continue to work to provide these valuable experiences in the future.

  

  

Fair Recruitment and Recruitment of Local Human Resources

• We basically recruit people in each region with our approximately 40 contact centers across Japan. The following is our recruitment record by region below.
• FY2022 Number of Employees by Region(Fixed-term Contract Employees) ★

  	Men	Women	Total
  Hokkaido	602	1,609	2,211
  Tohoku	60	137	197
  Kanto	1,051	1,958	3,009
  Chubu	65	225	290
  Kinki	464	1,095	1,559
  Chugoku	240	955	1,195
  Shikoku	64	222	286
  Kyushu	517	1,158	1,675
  Okinawa	159	493	652
  Other	6	14	20
  Grand Total	3,228	7,866	11,094

  ＊ SGS Japan Inc. has conducted a third-party verification on the results data marked with a ★ .
• Number of Employees (By Country on a Consolidated Basis)

  	Number of Employees
  	FY2021			FY2022★
  	Men	Women	Total	Men	Women	Total
  Japan	2,740	7,670	10,410	2,887	7,948	10,835
  Taiwan	10	41	51	26	52	78

  ＊ SGS Japan Inc. has conducted a third-party verification on the results data marked with a ★ .
  * The number of employees indicates the total number of full-time employees and indefinite-term employees.
• Record of Hiring People with Disabilities

  	Number of Employees with Disabilities
  	FY2021	FY2022
  Japan	519	605
  Taiwan	0	1
  Total	519	606

Training

• We have introduced human rights training on a mandatory basis for all our employees. We also change the content of the training in a timely manner to respond to changes in social issues based on the unique challenges faced by our company.
• In addition to human rights training, we have also introduced compliance training (basic and operational), compliance case briefings, compliance seminars with external lawyers, and In-house case study training.

Awareness Activities

• We provide all our employees with the Code of Conduct Guidebook both in booklet form and online. We engage in awareness activities by widely disseminating various themes relating to human rights.

  

Amount of Investment in Social Contribution

• Amount Donated (NPOs and NGOs) in FY2022: 256 Million Yen

  	FY2020	FY2021	FY2022
  Amount of Investment in Social Contribution (millions of yen)	236	226	256

  * The amount of investment in social contribution includes creches to support the work-life balance, cafes and farms run by people with disabilities, and support for occupational education to children through KidZania.

Charity Activities

• Volunteer Cleanup Activities at Contact Centers

  

  

  

• Other Volunteer Activities
  • Operational Volunteers at the Hokkaido Marathon
  • Operational Volunteers at the Mita International Marathon
  • Participation in the NIPPON Charity Ekiden in Odaiba, Tokyo