Lumens Human Rights Policy

1. Policy Statement 

Lumens Digital Optics Inc. (hereinafter referred to as "Lumens" or "the Company") respects internationally recognized human rights and protects the fundamental rights of employees, suppliers, contractors, customers, and other stakeholders in all regions where it operates. In addition to complying with the laws of each jurisdiction, Lumens manages human rights matters in line with the United Nations Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights (UNGPs), the United Nations Global Compact, the International Labour Organization Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. 
Lumens also follows the Responsible Business Alliance (RBA) Code of Conduct and integrates human rights considerations into its corporate governance, daily operations, and supply chain management. The Company is committed to building a fair, inclusive, safe, and respectful workplace, and to reducing human rights risks through prevention, mitigation, and remediation mechanisms, thereby fulfilling its corporate responsibility to protect human rights. 

2. Scope of Application 

This Policy applies to all operating activities of Lumens Digital Optics Inc. and its subsidiaries in which Lumens holds more than 50% of the shares. It covers all employees, including full-time employees, contract employees, dispatched workers, interns, and other workers under the Company's management. Through the Supplier Code of Conduct and related management mechanisms, Lumens also encourages suppliers, contractors, and business partners to pay attention to human rights issues and to help reduce human rights risks and adverse impacts. 

3. Human Rights Commitments

• Labor Rights and Freely Chosen Employment: Lumens prohibits any form of forced labor, human trafficking, bonded labor, and child labor, and respects employees' employment rights and the principle of fair recruitment. 
• Wages, Working Hours, and Benefits: Lumens complies with applicable laws on working hours, wages, and benefits in each jurisdiction where it operates. The Company provides fair working conditions and prohibits unlawful wage deductions and unfair treatment. 
• Diversity, Inclusion, and Non-Discrimination: Lumens prohibits inhumane treatment and does not tolerate any tangible or intangible form of sexual harassment, workplace violence, abuse, corporal punishment, mental or physical coercion, verbal abuse, or other discriminatory behavior in the workplace. 
• Occupational Health and Safety: Lumens provides a safe and healthy workplace and reduces occupational injuries and health risks through effective management, training, and preventive measures. 
• Freedom of Association and Communication: Lumens respects employees rights to freedom of association, collective bargaining, and peaceful assembly. The Company maintains open and fair communication channels and protects employees' right to express their views and to participate in trade unions. 
• Supply Chain and Responsible Sourcing: Through supplier management, social responsibility audits, responsible minerals management, and related communication mechanisms, Lumens encourages its supply chain partners to pay greater attention to human rights and labor standards. 
• Privacy, Product Responsibility, and Social Responsibility: Lumens attaches importance to the protection of personal data and customers' confidential information, product safety, and hazardous substance management, and pays attention to the impacts of its operations on local communities, Indigenous Peoples, the environment, and other stakeholders. 

4. Human Rights Governance and Management Mechanisms 
4.1 Human Rights Risk Management 

Lumens regularly reviews the human rights risks that may be involved in its operations and value chain, covering labor rights, occupational health and safety, discrimination and harassment, the rights of migrant workers and other vulnerable groups, privacy and data protection, supply chain impacts, and community impacts. Priorities are determined based on the results of the risk assessment, and the Company continues to strengthen the related management actions and improvement measures. 

4.2 Grievance and Remediation Mechanisms 

Lumens has established diverse and confidential grievance channels for employees and other stakeholders to raise human rights concerns or report suspected violations. Upholding the principles of confidentiality and non-retaliation, the Company investigates and handles reports in accordance with established procedures and takes necessary remedial and improvement actions, so that human rights cases are properly addressed and the risk of recurrence is reduced. 

5. Training and Awareness 

Through training, internal awareness activities, and communication mechanisms, Lumens enhances employees' awareness of human rights, covering human and labor rights, workplace equality and non-discrimination, occupational health and safety, and grievance channels and preventive mechanisms, so as to integrate human rights principles into the corporate culture and day-to-day operations. 

6. Stakeholder Engagement and Disclosure  

Through its sustainability report and related disclosure mechanisms, Lumens regularly explains its human rights policy and management framework, risk assessment results, improvement measures, and implementation performance. The Company also maintains ongoing communication with employees, suppliers, communities, and other stakeholders, and responds to the issues of concern they raise.