• Tokyo Metro Group Human Rights Policy
• Holding Dialog with Experts

• Implementation of Impact Studies
• Initiatives Against Customer Harassment
• Tokyo Metro Group Customer Harassment Response Policy
• Framework for Promoting Respect for Human Rights

• Compliance Reporting Hotline for Business Partners
• Customer Center

In March 2023, we established the Tokyo Metro Group Human Rights Policy to respect the human rights of all people affected by the Group's business activities.
As part of its efforts to contribute to the realization of a sustainable society through ESG initiatives, the Group respects the human rights of each and every employee and implements various initiatives through dialogue with stakeholders. Our aim is to create a workplace which creates job satisfaction where diverse employees can thrive, and also to promote sustainability management.
The Policy represents the commitment of the Group to respecting human rights and applies to all our executives and employees. We will also seek the understanding and support of our suppliers, partners, etc. for the Policy, working with them to promote respect for human rights together.
In addition, our Sustainability Management Vision defines "Respect for Human Rights" as a materiality (key challenge). Additionally, in the new mid-term management plan "Tokyo Metro Plan 2024," we have set relevant indicators as KPIs, and will promote various initiatives, including human rights due diligence.
Based on the Policy, we will respect the human rights of all people, including customers, suppliers, employees, and local communities and societies, and conduct our business activities in a manner that makes the most of diverse values, aiming to create a sustainable society that offers peace of mind.

The Tokyo Metro Group has established the Tokyo Metro Group Human Rights Policy (the "Policy") to respect the human rights of all people affected by the Group's business activities as we work to "Create a Sustainable Society that Offers Peace of Mind" based on the Group Ideal of "Keeping Tokyo on the Move." Based on the Group Ideal, our Resolution, Sustainability Management Vision, and Code of Conduct and Behavior Standards, the Policy represents our commitment to respecting human rights.

In addition to Japanese laws on human rights, based on the Guiding Principles on Business and Human Rights (United Nations), the Tokyo Metro Group supports and respects international norms on human rights such as the International Bill of Human Rights (United Nations) and the ILO Declaration on Fundamental Principles and Rights at Work (International Labour Organization), as well as the likes of the Children's Rights and Business Principles (UNICEF, UN Global Compact, Save the Children).
In addition, based on these international human rights norms, we will respect the human rights of all people, including customers, suppliers, employees, local communities and society, as well as conduct our business activities in a manner that makes the most of diverse values.

The Policy applies to all executives and employees (regardless of employment status) of the Tokyo Metro Group. We will also seek the understanding and support of our suppliers, partners, etc. for the Policy, working with them to promote respect for human rights together.

The Tokyo Metro Group will fulfill our responsibility to respect human rights by avoiding causing or contributing to negative impacts on human rights in our business activities, and by taking appropriate action to remediate any such impacts that do occur. We will also comply with the human rights and labor laws and regulations of each country, and work to prevent human rights violations. Even if the Tokyo Metro Group is not directly contributing to a negative impact on human rights, if our suppliers, partners, or other parties in the supply chain are causing negative impacts on human rights, the Tokyo Metro Group will work with such parties to encourage them to not violate human rights.

The Tokyo Metro Group will comply with international norms on human rights, and will not commit or be complicit in discrimination on the basis of race, religion, gender, age, sexual orientation, gender identity, disability, nationality, or any other grounds. We also prohibit human trafficking, forced labor, and child labor, and guarantee the likes of freedom of association, the right to collective bargaining, and equal remuneration.
In addition, the Tokyo Metro Group recognizes the following as human rights issues that should be addressed as a priority. We will review this list from time to time in light of social changes, business trends, etc.

• Violation of the right to receive goods and services safely
• Violation of the right to enjoy a safe and healthy working environment and standard of living
• Occurrence of overwork and therefore violation of the right to rest and leisure
• Occurrence of harassment
• Invasion of privacy
• Discrimination in terms and conditions of employment and remuneration
• Discrimination in opportunity and evaluation

In order to implement the Policy, the Tokyo Metro Group has established a Sustainability Promotion Committee and will - under the supervision of the Board of Directors - promote initiatives to respect human rights.

(1) Human rights due diligence
In order to fulfill its responsibility to respect human rights, the Tokyo Metro Group will identify negative human rights impacts through a human rights due diligence mechanism, and work to prevent or mitigate those impacts.
When it is necessary to prioritize response measures, priority will be given to addressing the most serious negative impacts on human rights, taking into account scale, scope, and remediability.

(2) Remediation and remedy
The Tokyo Metro Group will work to remediate and remedy any negative human rights impacts - be they direct or indirect - through appropriate procedures.

(3) Dialog and consultation with stakeholders
The Tokyo Metro Group will strive to enhance and improve its efforts to respect human rights through sincere dialogue and consultation with relevant stakeholders.

(4) Education and training
The Tokyo Metro Group will provide education and training to its executives and employees to ensure that the Policy is understood, that the human rights of all people are respected, and that correct knowledge and awareness of human rights issues are embedded throughout the organization. We will also strive to ensure that suppliers and partners of the Tokyo Metro Group understand that they should not infringe on human rights.

(5) Disclosure of information
The Tokyo Metro Group will appropriately disclose information on the progress of its efforts to respect human rights based on the Policy through its website and other means.

The Policy was adopted by the Board of Directors on March 24, 2023.

Date of enactment March 24, 2023
President and Representative Director

In January 2023, we conducted dialogue with external experts to verify the appropriateness of our Human Rights Policy content, including the process of policy identification. We engaged in an internal re-examination based on the wide range of opinions we received, and reflected in our Policy.

Key opinions

• Tokyo Metro is a company with a large social impact, so society's expectations regarding sustainability are high.
• We would expect the company to actively disseminate information on human rights both internally and externally, and also to serve as a model for railway companies.
• Ensuring safety in rail transportation should be treated as an important human rights issue, as it guarantees the most fundamental of human rights, namely the right to life.
• There is no problem with the number of human rights issues related to employees increasing in terms of their relevance to business activities.
• It is important to be aware of rights holders, including minorities, when identifying priority action issues.
• It is important to set the order of priority with proper awareness of remediability as well.

We identify, prevent, and mitigate adverse human rights impacts through mechanisms to identify human rights risks to stakeholders and to eliminate, prevent, mitigate, and correct such risks.

We conduct impact studies to identify adverse human rights impacts on our various stakeholders as well as to work to prevent and mitigate them.
For business partners, we requested corrective measures to the companies that needed to take action, and those measures have been carried out. In addition, interviews were conducted with five selected companies to obtain their understanding of their efforts to respect human rights as well as to request cooperation for risk prevention and mitigation. In FY2024/3, we expanded the scope of respect for human rights in the Tokyo Metro Co., Ltd. Procurement Guidelines, which are to be observed by our procurement business partners.
For customers, the FY2025/3 survey findings indicated - similar to in FY2024/3 - a sense of inadequacy in terms of safety and hygiene of facilities provided and providing an environment that can be used by a diverse range of customers, which may be recognized as a human rights issue. However, the percentage of such concerns voiced was lower than in FY2024/3. We will continue to conduct impact assessments, steadily clean facilities, and further publicize the Tokyo Metro app and Barrier-­Free Handbook, which provide information on fully-accessible routes. We will also proceed with installing elevators, escalators, and fully-accessible toilets so that all customers, including those with disabilities, can rest assured when using our services.
For employees, issues such as lack of understanding of the Human Rights Policy, lack of awareness of consultation points and concerns about their use, and harassment were identified. Through DE&I training^*1 and sustainability training^*2, we will continue to promote the embedding of our Human Rights Policy as well as knowledge about and the enhancement of trust in consultation points.

• 1. 10,178 participants
• 2. 10,188 participants

With the publication of a manual by the Ministry of Health, Labour and Welfare and a basic policy by the Japan Private Railway Association, there is growing momentum in society at large - including the railway industry - to strengthen measures against customer harassment. In light of serious incidents that constitute customer harassment also occurring at Tokyo Metro, we are taking measures against customer harassment.
With this background, to prevent harassment by customers and ensure a safe working environment for Group employees, we established the Tokyo Metro Group Customer Harassment Response Policy in March 2024.
In the event that Tokyo Metro Group determines that a request or behavior from a customer toward an employee constitutes customer harassment based on this policy, the company will, in principle, refuse to provide any further service to that customer. Additionally, it will take appropriate measures, including making a police report and taking criminal and legal action, if necessary, to respond firmly to such customer harassment.
We seek the understanding of our customers and others about this policy, and in addition aim to respect human rights together, promote the building of an ever-more sound relationship between our customers and our company, and become a corporate group chosen by all stakeholders.

Based on the Tokyo Metro Group Human Rights Policy established on March 24, 2023, the Tokyo Metro Group (hereafter "the Group") has established the Tokyo Metro Group Customer Harassment Response Policy (hereafter "the Policy") . The Policy lays out the Group's stance on customer harassment against the Group’s employees (hereafter "Employees").

(1) Response to customer harassment
In the event that Tokyo Metro Group determines that a request or behavior from a customer constitutes customer harassment, the Group will, in principle, refuse to provide any further service to that customer. Additionally, it will take appropriate measures, including making a police report and taking criminal and legal action, if necessary, to respond firmly toward such customer harassment.
(2) Efforts within the Group
The Company will respond to customer harassment by utilizing the Response Manual and the reporting and consultation system formulated based on the Policy. We will also work to raise awareness so that employees do not themselves engage in customer harassment regarding business partners etc.

Any request or behavior by a customer etc. in which carrying out the content of the request would necessitate inappropriate behavior in light of social conventions, threaten the safety or mental and physical health of employees, or unreasonably hinder the Group's operations.

• Violence
• Abusive language, intimidation, threats, or discriminatory speech or behavior
• Excessive or unreasonable demands exercising authority
• Occupying employee time for an extended period, or repeated unreasonable demands
• Defamatory statements on social media or other parts of the internet
• Sexual harassment
• Other acts of harassment

Enacted March 21, 2024
(Revised March 25, 2025)
President and Representative Director Akiyoshi Yamamura

We have established a promotion system centered on the Sustainability Promotion Committee, chaired by the chief sustainability affairs officer appointed by resolution of the Board of Directors, and we have also set up a Human Rights Promotion Working Group, led by the executive officer in charge of the Sustainability Promotion Department, to advance efforts to respect human rights throughout the Tokyo Metro Group.

To further enhance compliance, the Tokyo Metro Group is working to establish a mechanism for redress in relation to human rights.

To further enhance compliance, the Tokyo Metro Group has established a reporting hotline that can be used by all our business partners. Please notify us if Tokyo Metro Group officers or employees are found to have engaged in activities which are or may be non-compliant.

Tokyo Metro Group business partners, their officers, and employees

Acts in violation of laws and regulations, human rights violations, and other acts which are or may be contrary to compliance by Tokyo Metro Group officers and employees
* We will not respond to comments, inquiries, advertisements, solicitations, or reports for the purpose of defaming the Tokyo Metro Group that are unrelated to the above.

• The Tokyo Metro Group will not treat a person making a whistleblowing report in a disadvantageous manner. However, this protection does not apply to false reports or reports for other improper purposes.
• We will maintain confidentiality and will not use the personal information of whistleblowers or the contents of their reports for any purpose other than investigation and response to the content of the report.

• Please provide specific details (such as the date, time, place, perpetrator, and details of the act) to enable prompt investigation and corrective action.
• Please indicate your name, department name, workplace name, and contact information to the extent possible. We accept anonymous reports, but please note that we may not be able to conduct sufficient investigations in such cases.

Whistleblowing form

User ID: TokyoMetro Password: partner
* After opening the whistleblowing form, please log in with the above user ID and password (common to all suppliers).

The Customer Center also accepts inquiries about human rights.

Inquiry form