Supply chain

Hamamatsu Photonics Group Supply chain Policy
Promotion Structure
Supply chain Overview
Identification of major suppliers
Basic Sales & Purchase Agreement
Supply chain Code of Conduct
Sustainable Procurement Survey
Education and raising awareness
Reporting system

Hamamatsu Photonics Group Supply chain Policy

As a responsible member of the global supply chain, the Hamamatsu Photonics Group promotes sustainable procurement that considers environmental protection, human rights and labor, safety and health, and corporate ethics. This commitment extends not only to our own companies or groups but throughout our entire supply chain, grounded in mutual trust with suppliers.

As part of our sustainability efforts, we have distributed the "Hamamatsu Photonics Supply Chain Code of Conduct" to our suppliers. This document helps them understand the "Hamamatsu Photonics Group Basic Policy of Sustainability" and supports the promotion of Corporate Social Responsibility activities. We believe that formulating and promoting activities for the Business Continuity Plan is essential to fulfilling our responsibility to provide consistent and reliable products to society.

To ensure alignment with these goals, we are conducting surveys to assess the current status of our suppliers in promoting ESG activities and the BCP.

Established: June 1, 2022
Revised: October 1, 2024

Promotion Structure

We established a supply chain management system headed by the Chief of Administration General Headquarters (Managing Executive Officer) and overseen by the Procurement Headquarters. Measures related to sustainable procurement are reported and discussed at the Sustainable Procurement Promotion Committee under the Procurement Headquarters, along with other committees, and progress on their activities is reviewed.

The Sustainability Office reports on important issues, targets, progress, and other items to the Board of Directors on a quarterly basis, which then provides direction and instruction.

Supply chain Overview

In terms of the amount spent on materials used in products by region, Japanese suppliers account for 82.3 % of the total, followed by North America (12.3 %) and Asia (excluding China) (3.9 %).

In terms of the number of suppliers by region, Japanese suppliers account for 94.3 % of the total.

Identification of major suppliers

We identify major suppliers by considering factors such as “procurement amount” and “availability of important materials that are difficult to replace.”

In the current fiscal year (ended September 2025), there are 229 major suppliers of materials used in our products. For the identified major suppliers, we request compliance with the “Hamamatsu Photonics Group Supply Chain Code of Conduct,” and conduct risk assessments, issue improvement requests, and provide support through sustainable procurement surveys and ESG audits.

Note that the procurement amount from major suppliers accounts for 90% of the procurement amount for materials used in our products (excluding the consolidated subsidiaries).

Basic Sales & Purchase Agreement

（Applicable to domestic supplier only）

We conclude basic sales ＆ purchase agreements with suppliers, stipulating compliance with laws and regulations, respect for human rights, and environmental protection, and require them to comply with these items. (94 % of major suppliers have signed the basic sales ＆ purchase agreement.)

The key articles of Basic Sales & Purchase Agreement

Article 36 Compliance with Supply chain Code of Conduct

Article 37 Environmental regulations

Article 38 Legal compliance

Article 39 Respect for Human rights

Article 40 Fair trading

Supply chain Code of Conduct

Supply Chain Code of Conduct [409 KB/PDF］

In October 2024, based on the Hamamatsu Photonics Group Code of Conduct, we have prepared the “Hamamatsu Photonics Supply Chain Code of Conduct” to include more articles related to respect for human rights, referring to the “Guidelines for Responsible Corporate Behavior” published by the Japan Electronics and Information Technology Industries Association (JEITA), to which we are involved.

We are requesting our major suppliers to understand and sign the Code of Conduct and submit a letter of agreement. As of June 2025, 223 major suppliers have signed. (Contract rate: 97.4 %)

Part I. Code of conduct

1. Compliance with Laws and Regulations and Respect for International norms

3. Health and safety

4. Environment

5. Fair trading and ethics

6. Quality and safety

7. Information security

8. Business continuity plan

9. Other

Part 2: Establishment of management system

A. Establishing a management system

B. Supplier management

C. Proper import/export control

D. Establishing a grievance mechanism

E. Disclosing the activities

We review the guidelines on a regular basis to keep them up-to-date with current conditions.

When any change is made to the guidelines, we disclose our suppliers and make them aware of the change.

Sustainable Procurement Survey

We regularly conduct sustainable procurement surveys to assess the status of sustainable procurement initiatives among our major suppliers and to confirm their compliance with the “Hamamatsu Photonics Supply Chain Code of Conduct”.

The survey items are based on the code of conduct and management system, with a particular focus on important issues such as human rights and labor ,and health and safety.

In particular, if the evaluation results of the supplier’s response are unsatisfactory, both parties will discuss improvement measures and request risk reduction in the future.

1. Dissemination of policy and Code of Conduct, and agreement

2. Identification of target suppliers (Major Suppliers)

3. Analysis/Result of Sustainable Procurement Survey

4. ESG Audit (Conduct on suppliers deemed to require corrective action based on the result.)

5. Request for development and validation of corrective plans

Rank	Result (FY2024)	Definition/Note
A	91 companies (40 ％)	Compliant with required items of the Code of Conduct.
B	59 companies (26 ％)	Almost compliant with the required items of the Code of Conduct, and request for voluntary corrective action.
C	40 companies (17 ％)	Does not comply with many of the required items of the Code of Conduct, and request for disclosure of Improvement plans.
D	39 companies (17 ％)	Does not comply with many of the required items of the Code of Conduct, and support and consultation are needed for improvement through ESG audits as needed. Then request for submission of improvement plan.

The items with high scores were “Quality and Safety”, “Environment” and “Health and Safety,” while “Human Rights and Labor”, “Business Continuity Plan” and “Information Security” showed room for improvement.

In addition, 39 companies (17 %) were Rank D, so we will hold discussions and consider ways to improve the situation with them in it .

Item	Scoring	Average score	Average score rate
1.Compliance with Laws and Regulations and Respect for International norms	15	11.4	76.0 %
2.Human Rights and Labor	148	97.8	66.1 %
3.Health and Safety	38	29.7	78.2 %
4.Environment	33	26.2	79.4 %
5.Fair Trade and Ethics	70	53.7	76.7 %
6.Quality and Safety	26	22.6	86.9 %
7.Information Security	26	17.5	67.3 %
8.Business Continuity Planning	5	3.4	68.0 %
Establishing a Management System	24	16.5	68.8 %
Total	385	278.7	72.4 %

Survey Period: Dec.2024 – Jan. 2025

Target: Major Suppliers 229 companies (Equivalent to approx..90 % of the procurement amount of materials for products.)

Responding Suppliers: 222 companies (Rate: approx.. 97 %)

Education and raising awareness

In-house education

In FY2024 (ended September 30, 2024), we provided in-house education for 524 procurement officers and related personnel regarding “promotion of sustainable procurement” and “procurement-related laws and regulations (e.g., Subcontract laws)”.

Educational Contents	Number of Participants
Promotion of sustainable procurement	99
Procurement-related laws and regulations (e.g., Subcontract laws)	425
Total number of partcipants	524

Suppliers Meeting

We hold Hamamatsu Photonics Cooperation Meetings (Suppliers Meetings) three times a year to share information and deepen mutual understanding with major suppliers.

In August 2024 we held Suppliers Meeting with 40 major suppliers (68 people) on the theme of health management.

Picture from Suppliers Meeting

The educational and awareness activities mentioned above will be held annually with different themes and educational participants.

Reporting system

We practice sustainable procurement in accordance with our "Hamamatsu Photonics Group Basic Policy of Sustainability". As part of these efforts, we have set up “Contact point for whistleblowing and reporting” for our suppliers.

Please contact us if you are aware of or have questions about misconduct or legal violations, ethical violations or similar conduct which may involve our business or employees.

Hamamatsu Photonics Group Compliance Hotline