Introduction

We are committed to reviewing and, where necessary, improving our practices to combat slavery and human trafficking.

In recent months we have been reviewing our supply chains as well as our practices and policies to ensure that we are doing all we can to combat the problem. This statement sets out the steps we have taken.

Our business and its structure

Our mission is to create, innovate and facilitate exciting and engaging experiences for artists and audiences alike.

Avex Classics International Inc. is a Japanese company, part of Avex Inc. located in Avex Building, 3-1-30 Minami Aoyama, Minato-ku, Tokyo 107-8577, Japan. The London Branch was founded in February 2014 to cover the territories of Europe and the Americas.

For information on the activities of the London Branch, please visit the following website:

www.avexclassicsinternational.co.uk

The Avex Group has an annual turnover in excess of £36m.

Our supply chains

Avex Classics International Inc. expects all suppliers in its supply chains to take appropriate steps based on the relevant policies stated below.

Our policies on slavery and human trafficking

We have recently developed the Anti-Slavery Policy which expresses our commitment to acting ethically and with integrity and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our company and supply chains.

Our efforts on slavery and human trafficking

We are committed to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and supply chains.

We have in place systems to:

Provide education and training on our policies to employees and executives of Avex Classics International Inc. Monitor compliance by requiring every employee and executive to regularly review and confirm their compliance with our policies.

Encourage the reporting of concerns and the protection of whistle blowers.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

Further steps

We intend to review every year the steps we have taken to combat slavery and human trafficking.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking disclosure for the financial year ending March 31, 2017.

Hiroyuki Nakashima, Representative Director

Avex Classics International Inc.

1. Policy statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners.

1.3 This Policy is applied to our employees (except for part-timers) and executives.

1.4 This Policy does not form part of any employee’s contract of employment and we may amend this Policy at any time.

2. Responsibility for this Policy

2.1 The Representative Director has overall responsibility for ensuring this Policy complies with our legal and ethical obligations, and that all individuals under this Policy comply with it.

2.2 The Policy Manager has primary and day-to-day responsibility for all matters regarding this Policy, including monitoring its effectiveness and dealing with any queries about this Policy.

2.3 Managerial persons at all levels are responsible for ensuring those reporting to them understand and comply with this Policy (ensuring that they are given adequate and regular training on this Policy and the issue of modern slavery in supply chains).

2.4 You are invited to comment on this Policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Policy Manager.

3. Compliance with this Policy

3.1 You must ensure that you read, understand and comply with this Policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those under this Policy. You are required to avoid any activity that might lead to, or suggest, a breach of this Policy.

3.3 You must notify the Policy Manager as soon as possible if you believe or suspect that a conflict with this Policy has occurred or may occur.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

3.5 If you believe or suspect a breach of this Policy has occurred or may occur, you are encouraged to notify the​ whistle-blowing hotline of Avex Group Holdings Inc., our parent company.

3.6 If you are unsure about whether a particular act, the general treatment of workers, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise concerns with the Policy Manager.

3.7 We aim to encourage openness. We shall ensure no one suffers any detrimental treatment as a result of genuine and good faith reporting or concerns based on this Policy. Detrimental treatment includes dismissal, demotions and salary reductions.

4. Communication and awareness of this Policy

4.1 Training on this Policy forms part of the training for all individuals under this Policy, and regular training will be provided as necessary.

5. Breaches of this Policy

5.1 Any employee who breaches this Policy may face disciplinary action (including dismissal).

* Currently, Hiroko Porter and Naoto Ozawa are the Policy Manager.