Human Rights Policy

The Cosmo Energy Group Management Vision is, “Striving for an infinite tomorrow, developing sustainably in harmony with humanity, society, and our planet.” True to our Vision, we recognize our responsibility to ensure that the human rights of every stakeholder are fully respected, and we expect every officer and employee of the Group to act according to high ethical standards. The Cosmo Energy Group Code of Conduct expresses the requirement to respect human rights, while stressing their importance and our responsibility to respect them. This Human Rights Policy is based on our Management Vision and Code of Conduct and outlines our basic approach to respecting human rights.

a) Respect for international norms

We support and respect the Ten Principles of the UN Global Compact as a signatory to the United Nations Global Compact, as well as the United Nations International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and International Covenant on Economic, Social and Cultural Rights), the United Nations Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, United Nations Declaration on the Rights of Indigenous Peoples, and Children’s Rights and Business Principles.

b) Legal compliance

We comply with all human rights laws and regulations in the countries and regions where we conduct business. In addition, if there is a difference between internationally recognized human rights norms and the laws and regulations of a particular country or region, we seek ways to honor international human rights principles, using this policy as a guideline.

c) Scope of application

This policy applies to all officers and employees of the Cosmo Energy Group. All external partners involved in the Group’s business activities are also expected to understand and comply with this policy.

We especially focus on respect for human rights in the following areas, where our business activities have particular impact.

a) Supply chain

• Respecting fundamental human rights
• Prohibiting discrimination
• Prohibiting forced and child labor
• Respecting the lands and rights of indigenous peoples
• Taking a careful approach to business in countries with human rights issues
• Taking security measures with respect for human rights

b) Employees

• Ensuring assessments are fair and equitable and prohibiting discrimination, etc.
• Promoting a healthy work/life balance
• Respecting diversity
• Prohibiting harassment
• Ensuring stable employment
• Maintaining healthy employee/management relations

We build and continually operate a human rights due diligence system. Whenever the Group’s business activities or any activities pertaining to its business transactions have or could have a negative impact on human rights, directly or indirectly, we take appropriate measures for prevention and remediation in order to fulfill our responsibility to respect human rights. This human rights due diligence system includes a framework for human rights assessment and remediation processes, as well as effective mitigation.

We actively share this policy with officers, employees, business partners and other stakeholders. We fully educate all of our officers and employees on this policy to ensure that it is properly integrated into the business activities of the entire Group.

We maintain dialogue and engage in discussion with relevant stakeholders to address potential and actual impacts on human rights.

We disclose the progress and results of our efforts to respect human rights in accordance with this policy on our website and in reports.

Established: December 21, 2021