CUC Group Human Rights Policy

The CUC Group believes that respect for human rights forms the foundation for realizing a society in which every individual can live true to themselves and receive healthcare with peace of mind.

We understand and strive to follow, as a minimum standard, the human rights ethics expressed in the International Bill of Human Rights (Note 1) (Note 2) and the principles concerning fundamental rights set forth in the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work (Note 3). We also endeavor to respect and promote human rights in accordance with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

Furthermore, through our business activities, we respect the human rights of people who may face barriers in accessing medical and nursing care services. These include, older adults, people with disabilities, individuals with chronic or intractable diseases, pregnant and postpartum women, children, people living in areas that are geographically or economically isolated from medical institutions, and foreign nationals or those with different linguistic or cultural backgrounds. We strive to improve their circumstances.

In each country or region where we operate, we comply with applicable laws and regulations. When there is a difference in the level of requirements between domestic laws and internationally recognized human rights standards — or when the two conflict — we seek ways to respect international human rights standards. We also strive to respond to the evolving expectations of stakeholders regarding respect for human rights in healthcare as times change.

(Note 1) Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights

(Note 2) Fundamental rights of all people, including the rights of children, youth, men, and women

(Note 3) Freedom of association and the right to collective bargaining; the elimination of all forms of forced or compulsory labor; the effective abolition of child labor; the elimination of discrimination in respect of employment and occupation.

This policy serves as a standard that all officers and employees of the CUC Group (CUC Inc. and its consolidated subsidiaries) must adhere to, and also functions as a guideline for protecting the human rights of all rights holders involved in our Group’s services.

We communicate this policy in a manner that is easy for all parties involved to understand, and take the utmost care to ensure that no human rights violations are caused or facilitated under it across the entire value chain of the CUC Group.

The Board of Directors has approved this policy and bears ultimate responsibility for overseeing its implementation. Acting through advisory bodies, such as the Risk & Compliance Committee, the Board enacts policies to ensure the dissemination of our sustainability principles and compliance culture, and continuously supervises activities related to human rights. Dialogue with healthcare stakeholders is also an important element. The Board ensures the implementation of reasonable measures to avoid direct or indirect involvement in human rights violations.

Responsibility for executing this policy lies with the Executive Officer in charge of Sustainability, while the Sustainability Department of CUC Inc. is responsible for operational execution. The Executive Officer for Sustainability and the Sustainability Department take the lead in promoting this policy and report its implementation status to the Board of Directors on a regular basis.

All employees working in the CUC Group are protected from any human rights violations in the course of their duties. We strive to avoid both direct and indirect involvement in human rights violations in the provision of medical services, and we expect all employees to respect this policy. We establish appropriate mechanisms, including consultation, remedy, and corrective measures, and continuously work on improvements.

We seek ways to further respect the human rights of patients and to advance medical services. We also expect our business partners — including medical institutions, nursing care facilities, client companies and suppliers, and contractors — to act in accordance with this policy. Furthermore, we endeavor to establish mechanisms and exert influence to address any negative impacts on human rights caused by our business partners.

1. (1) Respect for International Standards

   We support the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, and we respect these principles within the healthcare setting.

2. (2) Prevention of Discrimination and Harassment

   We aim to maintain an environment in which patients and their families, our employees and officers, and all rights holders involved in our business activities are mutually respected and feel secure. To this end, we prohibit all forms of discrimination, harassment, and violence.
   In our corporate activities, we do not tolerate discrimination based on class, race, color, gender, language, ethnicity, religion, gender identity or expression, age, political or other opinions, nationality, property, sexual orientation, disability, birth, or disease.

3. (3) Elimination of Forced and Child Labor

   To protect the rights of all individuals involved in healthcare, we do not tolerate any form of forced labor, excessive working hours, human trafficking, child labor, bullying, or unfair treatment. We also strive to improve the working environment and ensure a safe and healthy workplace.

4. (4) Improvement of the Working Environment

   We create an environment where people can take pride in their work and continue to thrive with peace of mind. We endeavor to provide appropriate working conditions, ensure a safe and healthy workplace, and support the achievement of a good work-life balance.
   We also respect the principle of equal pay for equal work and ensure a fair and transparent compensation system.

5. (5)Land Rights and Health & Safety of Local Residents

   We recognize that the operation of medical-related facilities may affect land rights and the health and safety of local residents. In addition to complying with relevant laws and regulations, when opening or expanding facilities, we conduct appropriate explanations and consultations with municipalities and communities in advance, aiming to coexist with local society. We operate our business with the highest priority placed on the health and safety of local residents.

1. (1) Human Rights Due Diligence

   We assess the impacts of our business activities on human rights and strive to ensure that if any adverse human rights impacts occur through the activities of the CUC Group, we can respond appropriately with fair and equitable remedies. To this end, we continuously endeavor to:
   1. ①　Identify and assess adverse human rights impacts
   2. ②　Prevent or mitigate adverse human rights impacts
   3. ③　Monitor the effectiveness of responses
   4. ④　Disclose relevant information

2. (2) Consultation and Remedy Mechanisms

   The CUC Group has established a publicly accessible internal reporting channels (the “Hotlines”), through which patients, employees, healthcare workers, and other stakeholders can anonymously report concerns related to human rights.

   We aim to handle potential human rights issues comprehensively — from fact-finding and problem resolution to the consideration of preventive measures and post-incident follow-up. We take sufficient care to ensure that no retaliation occurs when issues are raised in good faith, and we respond sincerely to ensure that victims of human rights violations receive appropriate remedies.

   As a forum for reviewing human rights risk assessments and responses in a healthcare setting, the Risk & Compliance Committee of CUC Inc. regularly reviews the number of human rights violation reports received through the Hotlines and any trends related to them. For cases with the potential to lead to serious violations, we have established a system to discuss countermeasures under the supervision of the Board of Directors.

3. (3) Education and Awareness

   The CUC Group has formulated the CUC Partners Promise as a pledge between management and employees: To create an environment where every individual feels a sense of purpose in their work and can take on challenges toward their dreams and ideals.

   As a corporate group that brings together diverse professionals — from healthcare workers to business professionals — and expands teamwork both domestically and internationally, we provide an environment where each person can continue to pursue their ideals without giving up. We respect the decent work and individuality of all people working within the CUC Group.


   We also provide human rights-related training and awareness activities for all officers and employees, continuously enhancing understanding and action across the organization.

We regularly disclose information on our human rights initiatives and progress, ensuring transparency in our communications.

We strive to publish the implementation status of this policy on our corporate website. By disclosing such information, we create opportunities to receive feedback from society, which we aim to use to further enhance our initiatives.

This policy will be implemented under the leadership of senior management and executed by the Executive Officer in charge of Sustainability, with the entire CUC Group organization working together to contribute to the creation of a better society.

To realize this commitment to the human rights of rights holders in our business activities — including patients, their families, healthcare professionals, officers, employees, business partners, and local communities — we will work to ensure this policy is understood by all stakeholders, including our officers, employees and business partners, and actively promote activities that raise awareness of human rights among them.