Guidelines for Preventing Harassment of Job Applicants and Other Candidates
ENECHANGE Ltd. (the “Company”) is committed to conducting fair and appropriate recruitment activities so that everyone who participates in our recruitment and selection processes, company information sessions, internships, or other job-seeking activities (collectively, “Recruitment Activities”) can do so safely and with confidence.
In light of the purpose of the amended Act on Equal Opportunity and Treatment between Men and Women in Employment, effective October 1, 2026, and the related guidelines (Ministry of Health, Labour and Welfare Notice No. 52, “Guidelines on Measures to Be Taken by Employers in Employment Management Concerning Problems Caused by Sexual Conduct in Job-Seeking Activities, etc.”), the Company establishes the following fundamental policy to prevent harassment of job applicants and other candidates.
1. Fundamental Policy
The Company does not tolerate sexual harassment or any other form of harassment in connection with Recruitment Activities. The Company’s directors and employees, regardless of employment status (collectively, “Personnel”), must respect the dignity and individuality of Applicants and strive to ensure a fair recruitment and selection process.
2. Scope
These Guidelines apply to all conduct and communications between Personnel and individuals seeking employment with the Company, whether as new graduates or experienced professionals, as well as internship participants and prospective employees who have received offers (collectively, “Applicants”), in connection with any Recruitment Activity conducted by the Company. This includes company information sessions, internships, application screening, interviews, informal meetings, one-on-one contact in referral recruiting, alumni visits, casual interviews, social events for prospective employees, and all related settings.
3. Definition of Harassment of Applicants
For purposes of these Guidelines, “Harassment of Applicants” means sexual conduct or other inappropriate conduct by Personnel in the course of Recruitment Activities that interferes with or impedes an Applicant’s job-seeking activities. Examples include, but are not limited to:
・Sexual jokes or unnecessary questions about physical characteristics, dating history, or similar personal matters
・Persistent invitations to meals or private meetings, or demands for a sexual relationship
・Inviting an Applicant, under the guise of an interview or meeting and without a legitimate reason, to a private room or a setting involving alcohol
・Sexual remarks or conduct that make it difficult for an Applicant to continue their job-seeking activities
・Inappropriate remarks or conduct concerning pregnancy, childbirth, or related matters, or seriously offensive conduct arising from a position of superiority
・Any other conduct that disadvantages an Applicant or causes significant discomfort
4. Standards of Conduct in Recruitment Activities
Personnel must comply with the following standards when engaging in Recruitment Activities:
（１）In-person interviews and meetings with Applicants should, in principle, be conducted at the Company’s offices or another public location, and situations involving a high degree of isolation or privacy should be avoided. Online interviews and meetings must use the web-conferencing systems used by the Company for business purposes, in order to avoid the exchange of personal accounts or closed communications through unofficial tools.
（２）When dining with Applicants as part of Recruitment Activities, Personnel must not use private, enclosed spaces on a one-to-one basis, pressure anyone to consume alcohol, or engage in excessively inappropriate conduct. If a dinner, social gathering, or exchange of views takes place at night or involves alcohol, it must be conducted appropriately and with full respect for the Applicant’s preferences.
（３）Communications with Applicants should, in principle, be made through the Company’s applicant tracking system, a Company-issued email address, or another business communication channel. This does not apply where the nature of the activity—such as referral recruiting, direct recruiting, or an alumni visit—makes it appropriate to use an individual employee’s social media account or personal means of communication. Even in such cases, Personnel must fully understand the purpose of these Guidelines and refrain from overly personal communications or inappropriate contact.
（４）The Company will provide regular harassment-prevention training to all employees and ensure that these Guidelines are thoroughly communicated.
（５）Personnel who engage in harassment will be dealt with strictly in accordance with the Company’s Rules of Employment and other applicable rules.
5. Consultation and Reporting
The Company has established the following consultation channel so that Applicants can feel safe and confident in seeking advice if they experience harassment—or believe that harassment may occur—in connection with Recruitment Activities. Raising a concern will have no effect whatsoever on the outcome of the recruitment and selection process. Upon receiving a report or consultation, a designated representative will promptly and carefully ascertain the facts and take appropriate action.
Contact and Consultation Form
6. Protection of Privacy and Prohibition of Retaliation
（１）The Company will give due consideration to the privacy of all parties concerned, including the person making the report and the person alleged to have engaged in the conduct, and will strictly safeguard confidential information learned in the course of handling a consultation or report.
（２）The Company will not subject an Applicant to any disadvantage in the recruitment and selection process—including rejection—on the grounds that the Applicant consulted this channel or cooperated in confirming the facts.
7. Response When Harassment Is Confirmed
If, after reviewing a report or consultation, the Company confirms that harassment occurred, it will take appropriate measures to support and protect the affected Applicant and will deal strictly with the responsible Personnel in accordance with the Company’s Rules of Employment and other applicable rules.
8. Review of These Guidelines
The Company will review these Guidelines as necessary in light of amendments to applicable laws and regulations, changes in social conditions, and other relevant developments.
Established: October 1, 2026
ENECHANGE Ltd.