Anti-Harassment Policy
Effective: March 27, 2025
FIRSTLIGHT Capital, Inc. (hereinafter referred to as “the Company”) values mutual respect and recognition of each individual, regardless of differences in values, race, religion, gender, sexual orientation, and so on, among its officers, employees, contractors, entrepreneurs we meet, investment targets (including candidates), investors, business partners, and prospective hires, as well as all those who are associated with the Company. To this end, the Company will take strict action against any human rights violations, including discrimination, violent behavior, sexual harassment, power harassment, and other such misconduct in the workplace. In this policy, the Company clarifies the definition of harassment, the reasons and objectives for preventing harassment, and establishes a complaint and consultation desk, procedures for handling complaints and consultations, as well as training programs for harassment prevention. The Company is committed to preventing and eliminating harassment in the workplace.
Article 1 (Definition)
- The definitions of terms used in this policy are as follows:
(1)”Workplace”
Refers to the locations where the individuals to whom this policy applies (hereinafter referred to as “Applicable Persons”) are engaged in work, including business trip destinations, client sites, vehicles used for work, restaurants used for meetings and business dinners, and places such as social gatherings held within the workplace context.
(2)”Sexual Harassment”
A) Any act that discriminates against Applicable Persons in terms of their working conditions or contract terms, such as dismissal, demotion, salary reduction, transfer, or termination of contract, based on their rejection or protest against sexual remarks or behavior in the workplace.
Alternatively, or
B) Any act that makes the work environment uncomfortable for Applicable Persons due to sexual remarks or behavior in the workplace.
The following are examples of, but are not limited to, forms of sexual harassment:
ⅰ. Asking about sexual facts or matter
ⅱ. Intentionally spreading information of a sexual nature
ⅲ. Forcing or coercing someone into a sexual relationship
ⅳ. Unnecessarily touching someone’s body
ⅴ. Distributing or posting obscene images or drawings
ⅵ. Engaging in following, stalking or similar
ⅶ. Any other acts prohibited by law, or behavior similar to those listed above
(3)”Power Harassment”
Any behavior in the workplace based on a superior-subordinate relationship that harms the work environment of Applicable Persons, beyond what is necessary and reasonable for work-related purposes.
The following are examples of, but are not limited to, forms of power harassment:
ⅰ. Threatening someone by slamming a desk, throwing documents, etc.
ⅱ. Unilaterally intimidating someone in front of other Applicable Persons.
ⅲ. Arbitrarily rejecting or ignoring consultations, etc. from subordinates.
ⅳ. Repeatedly making statements that deny someone’s personality or dignity.
ⅴ. Forcing subordinates to adopt one’s own methods or ways of thinking, regardless of company policy.
ⅵ. Shifting responsibility onto subordinates while avoiding one’s own responsibility.
ⅶ. Forcing unreasonable transfers or resignations, or threatening dismissal.
ⅷ. Withholding necessary information or advice for work-related matters.
ⅸ. Any other acts prohibited by law, or behavior similar to those listed above.
(4)”Maternity Harassment”
A) Any act of discriminating against Applicable Persons in terms of their working conditions or contract conditions due to reasons related to their pregnancy, childbirth, or other matters concerning pregnancy or childbirth.
B) Any act of discriminating against Applicable Persons in terms of their working conditions or contract terms due to their request for or taking of parental leave.
The following are examples of, but are not limited to, forms of “Discrimination” as defined in A) and B) above:
ⅰ. Dismissing the person.
ⅱ. Not renewing the contract of a fixed-term employee.
ⅲ. Forcing an employee to resign or forcing a change in labor contract terms, such as making a full-time employee or a non-regular employee.
ⅳ. Terminating a business contract.
ⅴ. Damaging the work environment.
ⅵ. Ordering an employee to remain at home.
ⅶ. Demoting, reducing salary, or giving an unfair evaluation in performance reviews.
ⅷ. Making disadvantageous changes in an employee’s job assignment.
(5)”Customer Harassment”
Among complaints, speech or behavior from customers or business partners, any request or demand that, when considered in light of its reasonableness of the request or demand regarding such complaints, speech or behavior, involves methods or approaches for achieving such request or demand that are socially inappropriate, and where such methods or approaches harm the work environment of the Applicable Persons.
(6)”Harassment Behavior”
The behaviors defined in sections (2) to (5) above are collectively referred to as “Harassment Behavior.”
A) Notwithstanding the previous paragraph, any act that infringes upon a person’s dignity or personality and causes mental distress, even if it does not involve a position of authority or a superior-subordinate relationship in business dealings, is considered a violation of human rights and will be treated as Harassment Behavior under this policy.
B) Regardless of the definition of Harassment Behavior, any act defined by the laws of each country as harassment will also be treated as Harassment Behavior, and this policy will apply.
Article 2 (Scope of Application)
This policy applies to all individuals associated with the Company, including its officers, employees, contractors, entrepreneurs the Company meets, investment targets (including candidates), investors, business partners, and prospective hires. If Harassment Behavior by the Company’s officers, employees or contractors, or by external Applicable Persons toward the Company’s officers, employees or contractors, is recognized, the Company will take appropriate action in accordance with the spirit of this policy.
Article 3 (Prohibition of Harassment Behavior)
The Company does not tolerate any Harassment Behavior by its officers, employees, or contractors. If any harassment is committed by the Company’s officers, employees or contractors, the Company will take appropriate action, including disciplinary measures, in accordance with the employment regulations or contracts. Furthermore, the Company does not tolerate any Harassment Behavior by individuals other than its officers, employees or contractors towards the Company’s officers, employees or contractors.
Article 4 (Responsibilities of Managers and Supervisors)
- Those in positions of management or supervision over the Company’s officers, employees, and contractors will make efforts to prevent and eliminate Harassment Behavior through daily guidance and supervision to ensure a positive work environment. In the event that issues arise due to Harassment Behavior, they will take prompt and appropriate action to address the situation.
Article 5 (Consultation and Complaints)
- Any internal or external stakeholders who have experienced Harassment Behavior may freely report their concerns or complaints about the Harassment Behavior to the designated consultation contact person. This applies not only when harassment has actually occurred but also when there is a risk of such behavior occurring.
- If any internal or external stakeholders witness Harassment Behavior and feel uncomfortable, they may also report their concerns or complaints to the designated consultation contact person.
Article 6 (Establishment of Consultation Desk)
The Company will establish a consultation desk to handle concerns and complaints related to Harassment Behavior.
[Consultation Desk]
Company Auditor’s Office
Email address: compliance@firstlight-cap.com
Article 7 (Response to Consultations and Complaints)
Upon receiving a consultation or complaint, the consultation desk personnel will consider the privacy of the person making the report and, if necessary, will hear the facts from the alleged perpetrator, the victim, and relevant parties.
Article 8 (Prohibition of Disadvantageous Treatment)
The Company promises not to engage in any disadvantageous treatment based on the filing of complaints or consultations regarding harassment.
Article 9 (Training and Awareness for Harassment Prevention)
The Company will provide training and awareness activities to ensure that its officers, employees, and contractors gain a thorough understanding of the causes and issues related to harassment, in order to maintain a positive workplace environment and prevent and eliminate harassment.