• Basic Policy
• Tenant Engagement
• System Investment Utilizing ICT
• Effects of Introducing EGAO link at each property (July 2019 - September 2022)
• Initiatives in Collaboration with the Operators
• Operator Initiatives
• Contribution to Local Communities
• Positive Impact of Investing in Healthcare Facilities
• Initiatives at HAM

Basic Policy

Initiatives for Solving the Challenges of an Aged Society

Healthcare Asset Management Co., Ltd. (hereinafter, “HAM”) believes that Healthcare & Medical Investment Corporation (hereinafter, “HCM”)’s continuous investment in healthcare facilities and its stable management of assets will help towards solving the social challenges of an aged society. Therefore, we have cooperated with various internal and external stakeholders including unitholders, operators and hospital personnel, the sponsors, executives and employees.

Tenant Engagement

Healthcare facilities are assets that require special know-how and expertise to operate, so in order to properly evaluate an asset on its business characteristics, it is necessary to evaluate the operator's business capabilities and management stability.

Building a relationship of trust with the operator is essential for properly conducting due diligence prior to acquisition and monitoring after acquisition.

HAM actively works to build trust by visiting the healthcare facility and meeting with the facility manager and others in charge to gain an appropriate understanding of the facility's operations.

HCM has built a stable portfolio through business due diligence and monitoring.

System Investment Utilizing ICT

HCM paid 44.6 million yen, the initial cost of capital expenditure for 2 properties owned by HCM, in a lump sum, while the operator paid for the amount of increase in rent, thereby leveling the payment of introduction cost and realizing early introduction. (2019)

• ▪Targeted facilities and amount of capital expenditure
  ASHEIM Bunkyohakusan (completed introduction in July 2019, 20.9 million yen)
  ASHEIM Hikarigaoka (completed introduction in August 2019, 25.6 million yen)
  Total Amount of capital expenditure 46.5 million yen

System of EGAO link

A system enabling understanding of situation, record input and response to calls with smartphones possessed by the staff by linking sleep sensor, nurse call and electronic medical chart with nurse call gateway.

Effect of Introduction of EGAO link

The quality of nursing care services is expected to improve through the improvement of business efficiency of nursing care staff and the reduction of work burden through ICT investments.

Effects of Introducing EGAO link at each property (July 2019 - September 2022)

		Jul 31, 2019(1)	Sep 30, 2020	Sep 30, 2021	Sep 30, 2022(2)	(2)－(1)
1. Reduction of care staff
	①Number of residents	48 people	43 people	43 people	49 people	+1 people
	②Ratio of staff to residents	1.78：1	1.84：1	1.86：1	2.00：1	+0.22
	③Full-time employees	14.5 people	12.5 people	13.5 people	16.0 people	+1.5 people
	④Contract employees	2.0 people	2.0 people	1.0 people	0.0 people	▲2.0 people
	⑤Part-time employees	5.6 people	6.9 people	6.5 people	5.7 people	+0.1 people
	⑥Temporary workers	2.0 people	0.0 people	0.0 people	0.0 people	▲2.0 people
	⑦Nursing staff	2.8 people	2.0 people	2.0 people	2.8 people	+0.0 people
	⑧Staff per month	26.9 people	23.4 people	23.0 people	24.5 people	▲2.4 people
	⑨Total working hours	4,734 hours	4,118 hours	4,048 hours	4,312 hours	▲422 hours
2. Reducing burden of night-shift work for care satff
	①Number of night shifts	2.5 people	2.0 people	2.0 people	2.0 people	▲0.5 people
	②Total working hours/ month	40 hours	32 hours	32 hours	32 hours	▲8 hours
	③Regular inspection	4 times	0 times	0 times	0 times	▲4 times
3. Improving quality of nursing care services
	①Individual activities	20 hours	54 hours	117 hours	61 hours	+41 hours
	②Polypharmacy	7.2 medications	6.4 medications	6.1 medications	5.5 medications	▲1.7 medications
	③Hospitalization rate	5.2%	3.6%	7.8%	2.2%	▲3.0%

1. Reduction of care staff

Compared with initial introduction, staff per month decreased by 2.4 people, or 422 hours/month.
Since the facility is designed to operate with a 2:1 staffing ratio, 24.5 people is the minimum number of staff for the number of residents as of September 30, 2022.
As the COVID-19 pandemic has made it difficult to recruit and retain part-timers, our reform of the staffing structure will include increasing the ratio of full-time employees through our strength in hiring new graduates, aiming for a stable operation with a total of 24 to 25 people.

2. Reducing burden of night-shift work for care staff

The operator changed from a system with two night-shift positions and one semi-night-shift position to a system with two night-shift positions by eliminating the semi-night-shift position, and as of September 30, 2022, the operator continues to implement this system.
As of September 30, 2022, even after eliminating the semi-night shift, night-shift staff were able to take 2 hours of break time every day.
Regular inspections were terminated on October 1, 2019, but as of September 30, 2022, the operator had not received any complaints from clients or suggestions from the authorities.

3. Improving quality of nursing care services

The operator have worked to improve operations with the goal of securing 2 hours per day, or 60 hours per month, for the provision of individual activities (activities aimed at revitalizing each resident mentally and physically). When EGAO link was introduced, the number of hours was 20 per month, but as of September 30, 2022, it had increased by 41 hours. Although this is a significant decrease compared with the previous year, 60 hours is the basic amount for stable provision.
The operator has taken steps to improve polypharmacy (harmful effects due to combining multiple medications) by using sleep sensors and a medical records software database. With a target of 6.0 or less for the average number of medications used, the operator is promoting optimal use of medications in accordance with residents’ health condition in collaboration with partner medical institutions and pharmacies, based on sleep data and medical records data.
As a result, as of September 30, 2022, the operator has achieved our target with 0.5 medications below the target.
As an index measuring the results of the initiatives implemented to date, the operator has tracked “maintaining and increasing length of stay through improvement of the hospitalization rate.” From June to August 2022, the rate sometimes rose to 3.0% to 4.5% due to COVID-19 cases (1.6% in October 2022).

Future Initiatives

A database for the practice of science-based care is being completed. This is a phase in which the operator is identifying trends for the entire facility and issues for individual residents based on items such as cognitive function, nutritional status, food and water intake, activity level, sleep status, drug use and elimination status, and refine care services to effectively promote maintenance and improvement. The operator will also enhance education on using the data.

		Jul 31, 2019(1)	Sep 30, 2020	Sep 30, 2021	Sep 30, 2022(2)	(2)－(1)
1. Reduction of care staff
	①Number of residents	83 people	84 people	79 people	72 people	▲11 people
	②Ratio of staff to residents	2.04：1	2.17：1	2.04：1	1.76：1	▲0.28
	③Full-time employees	23.5 people	20.5 people	23.5 people	24.5 people	+1.0 people
	④Contract employees	0.0 people	1.0 people	0.0 people	0.0 people	±0.0 people
	⑤Part-time employees	11.6 people	13.7 people	12.2 people	12.4 people	+0.8 people
	⑥Temporary workers	1.0 people	0.0 people	0.0 people	0.0 people	▲1.0 people
	⑦Nursing staff	4.4 people	3.4 people	3.0 people	3.4 people	▲1.0people
	⑧Staff per month	40.5 people	38.6 people	38.7 people	40.3 people	▲0.2 people
	⑨Total working hours	7,128 hours	6,794 hours	6,811 hours	7,093 hours	▲35 hours
2. Reducing burden of night-shift work for care satff
	①Number of night shifts	3.5 people	3.0 people	3.0 people	3.0 people	▲0.5 people
	②Total working hours/ month	56 hours	48 hours	48 hours	48 hours	▲8 hours
	③Regular inspection	4 times	0 times	0 times	0 times	▲4 times
3. Improving quality of nursing care services
	①Individual activities	56 hours	63 hours	71 hours	121 hours	+65 hours
	②Polypharmacy	7.7 medications	6.9 medications	5.7 medications	5.6 medications	▲2.1 medications
	③Hospitalization rate	7.1%	2.2%	2.2%	4.3%	▲2.8%

1. Reduction of care staff

There was an decrease of 0.2 people or 35 hours/month compared with initial introduction.
As the COVID-19 has made it difficult to recruit and retain part-timers, our reform of the staffing structure will include increasing the ratio of full-time employees through our strength in hiring new graduates, aiming for a stable operation with a total of 37 to 38 people.

2. Reducing burden of night-shift work for care staff

The operator changed from a system with three night-shift positions and one semi-night-shift position to a system with two night-shift positions by eliminating the semi-night shift position, and as of September 30, 2022, the operator continues to implement this system.
As of September 30, 2022, even after eliminating the semi-night shift, night-shift staff were able to take 2 hours of break time every day.
Regular inspections were terminated on October 1, 2019, but as of September 30, 2022, the operator had not received any complaints from clients or suggestions from the authorities.

3. Improving quality of nursing care services

The operator has worked to improve operations with the goal of securing 2 hours per day, or 60 hours per month, for the provision of individual activities (activities aimed at revitalizing each resident mentally and physically). When EGAO link was introduced, the number of hours was 56 per month, but as of September 30, 2022, it had increased significantly to 121 hours. Note that in fiscal 2022, the average number of hours remained at approximately 70 hours due to the provision of individual activities such as long-distance outings in September 2022.
The operator has taken steps to improve polypharmacy (harmful effects due to combining multiple medications) by using sleep sensors and a medical records software database. With a target of 6.0 or less for the average number of medications used, the operator is promoting optimal use of medications in accordance with residents’ health condition in collaboration with partner medical institutions and pharmacies, based on sleep data and medical records data.
As a result, as of September 30, 2022, the operator has achieved our target with 0.4 medications below the target.
As an index measuring the results of the initiatives implemented to date, the operator has tracked “maintaining and increasing length of stay through improvement of the hospitalization rate.” April to July 2022 ranged from 1% to 2%, but the rate increased to 3.9% in August and 4.3% in September due to COVID-19 cases before returning to normalcy at 1% in October.

Future Initiatives

A database for the practice of science-based care is being completed. This is a phase in which the operator is identifying trends for the entire facility and issues for individual residents based on items such as cognitive function, nutritional status, food and water intake, activity level, sleep status, drug use and elimination status, and refine care services to effectively promote maintenance and improvement. The operator will also enhance education on using the data.

Initiatives in Collaboration with the Operators

HAM conducts a satisfaction survey of operators of its properties on a regular basis (in principle once a year), and shares the results of this survey (requests, issues, etc.) with the property management company to increase operator satisfaction.

As part of interior arrangements to isolate COVID-19-positive individuals or residents suspected of infection, a simple HEPA ceiling-embedded negative pressure ventilator was installed in short-term care rooms at Green Life Moriguchi.

Of the 48 properties owned by HCM as of the end of March 2023, 46 properties (about 95.8%) are equipped with in-house power generation facilities, forming a system prepared for emergencies.

ESG Workshops for Operators

HCM holds ESG workshops for operators of its properties to deepen their understanding and to introduce and promote initiatives to address issues based on HAM's Basic Policy on ESG.

Distribution of SDGs Promotion Leaflets

HCM distributes "SDGs promotion leaflets" to operators of properties it owns to promote the SDGs during facilities use.

Sponsorship of Music Concerts Organized by Operators

HAM sponsored the Nichii Home Autumn Music Festival 2022 organized by operator Nichii Carepalace Company in October 2022.

Operator Initiatives

Noah Konzer Co., Ltd. has developed a medication administration system called "Fukuyakkun" based on operation of its own facilities, to prevent medication errors by users and improve the work efficiency of facility staff.

1. Development Background

Medication errors (i.e., mistakenly given or forgotten medications) should never happen, but they do, mostly caused by human error, and checking to prevent medication errors has been a major burden for staff at facilities.

2. Mechanism of Medication Error Prevention

When facility staff hand out medication to a resident, they use a mobile terminal to read three QR codes: 1) for the resident, 2) for the staff and 3) for the medication bag in order to prevent errors by checking whether the medication is not for the wrong person, being administered at the wrong time, or a double dose.
In addition, three functions - 1) checking medication status on the computer, 2) checking the list of missed medications on the mobile terminal, and 3) an email notification of missed medication - can prevent forgotten medications.

3. Effects of Introducing Fukuyakkun

The development of Fukuyakkun has made it possible for one staff member and one mobile terminal to reliably check medications, improving operational efficiency at facilities where multiple staff members used to check medications multiple times.
It also enables centralized management of medication tasks, from medication receipt and inspection to distribution, support and completion checks, reducing time spent on medication preparation, administration checks and residual medication checks.
The system has been recognized to protect not only residents but also facility staff from medication errors, so as of November 15, 2022, it has been introduced at 520 facilities in Japan (according to the operator’s survey).

Contribution to Local Communities

Facilities owned by HCM are open to the community, not only to the residents of the facilities, but also to the local community.

At “Green Life Moriguchi” and “SHIP Senri Building,” hydroponic cultivation of vegetables is carried out as a job assistance project for people with disabilities.

Combining Facilities with Daycares for children

As of the end of March 2023, 4 of the 48 properties owned by HCM were contributing to the local community by housing daycare facilities.

Combined-Use Facilities

Property name	Contract area
AQUAMARINE Nishinomiyahama	1,769.00㎡
ASHEIM Bunkyohakusan
Kobe Gakuentoshi Building
SHIP Senri Building

Combining Facilities with Clinics, Pharmacies, and Day Centers

The properties owned by HCM include some in which part of the area is leased to businesses other than facilities/housing for seniors, such as clinics, pharmacies, and day centers.
These areas are open to not only residents of the facility but also the local community in general, providing it with necessary medical and care services.
As of the end of March 2023, 8 of the 48 properties owned by HCM were contributing to the local community by housing clinics or pharmacies.

Combined-Use Facilities (clinic, pharmacy)

Property name	Contract area
Kobe Gakuentoshi Building	2,900.46㎡
Smiling Home Medice Adachi
AIKOEN ICHIBANKAN Building
SOMPO CARE La vie Re Hama-Kawasaki
Hanakotoba Shin-Yokohama
Hanakotoba Shin-Yokohama II
Royal Kawaguchi
SHIP Senri Building

As of the end of March 2023, 9 of the 48 properties owned by HCM were contributing to the local community by housing day centers.

Combined-Use Facilities (Day Centers)

Property name
SAWAYAKA Tachibanakan
SAWAYAKA Mekarikan
SOMPO CARE La vie Re Hama-Kawasaki
Royal Kawaguchi
Heartland Kawaguchi Meiseien
NOAH GARDEN LEGEND
NOAH GARDEN L Grace
NOAH GARDEN CASA RICH
NOAH GARDEN Season Bell

ASHEIM Bunkyohakusan (Kids Harmony Hakusan)

Positive Impact of Investing in Healthcare Facilities

The scatter plots below show the monthly fees of HCM's main facilities on the horizontal axis and the deviation compared with surrounding facilities on the vertical axis. Our investments are diversified rather than skewing toward a high price range.
In particular, the facilities with reasonable monthly fees for their area (the lower-left shaded area) are not only price-competitive but also affordable to a wide range of elderly people. HCM defines these facilities as affordable facilities.
HCM and HAM believe that investing in these affordable facilities for the elderly can contribute to the development and revitalization of communities where people can continue to live.

Data source: Prepared by HAM based on "Paid Nursing Home Product Data: Average Monthly Cost for 60-month Nursing Care Residents" and "Average Monthly Cost for 120-month Independent Residents" by Tamura Planning & Operating.

The percentage of female facility managers at HCM-owned properties reached 31.9% in FY2022, and women are being actively promoted to managerial positions.

Proportion of Female Facility Managers at Properties Owned by HCM ^(Note1)

	End of fiscal 2019	End of fiscal 2020	End of fiscal 2021	End of fiscal 2022
Number of target properties (Note2)	34	35	36	47
Number of male	23	23	25	32
Male ratio	67.6%	65.7%	69.4%	68.1%
Number of female	11	12	11	15
Female ratio	32.4%	34.3%	30.6%	31.9%

(Note1)	Created based on the disclosure statement of important matters for each facility obtained by HAM every fiscal year.
(Note2)	Covers properties owned by HCM at the end of each year, excluding Niigata Rehabilitation Hospital. “SHIP Senri Building” covers Well House Senri-Chuo, a pay nursing home with care services.

Initiatives at HAM

Personnel Data (Diversity & Inclusion)

	Fiscal 2018	Fiscal 2019	Fiscal 2020	Fiscal 2021	Fiscal 2022
Number of executives and employees (Note1)	16	17	19	20	21
(Number of directly hired executives and employees)	9	10	11	15	19
(Number of assigned employees)	7	7	8	5	2
Number of male	14	15	17	19	17
Male ratio	93.8%	94.1%	94.7%	95.0%	81.0%
Number of female	1	1	1	1	4
Female ratio	6.3%	5.9%	5.3%	5.0%	19.0%
Number of manager	6	6	7	7	7
Number of male	6	6	7	7	7
Male ratio	100.0%	100.0%	100.0%	100.0%	100.0%
Number of female	0	0	0	0	0
Female ratio	0.0%	0.0%	0.0%	0.0%	0.0%
Number of new hires	2	2	1	4	7
Number of employees leaving the company	1	1	0	0	4
Annual turnover rate (Note2)	6.3%	5.9%	0.0%	0.0%	19.0%
Average monthly overtime hours	40.1 hours	27.5 hours	25.6 hours	35.9 hours	30.2 hours
Average employment	2 years and 5 months	3 years and 0 months	3 years and 4 months	3 years and 3 months	4 years and 11 months
Average paid leave acquired	11.7 days	16.3 days	10.9 days	11.2 days	13.7 days
Acquisition Rate	55.9%	71.1%	53.3%	56.1%	70.8%
Health examination / screening rate	100%	100%	100%	100%	100%
Occupational injury frequency (Note3)	0%	0%	0%	0%	0%

(Note1)	Numbers of employees are as of the end of each fiscal year (March 31).
(Note2)	The ratio of employees leaving the company to all executives and employees as of the end of each fiscal period (March 31) are indicated.
(Note3)	Occupational injury frequency = Number of occupational injury ÷ Total actual working hours × 1,000,000

Human Capital Development Initiatives / Framework for Ensuring that Executives and Employees Are Suitably Motivated

In order for all executives and employees to improve their professional skills, HAM recommends the acquisition of qualifications that are closely related to our business, such as a Real Estate Notary license or ARES Certified Master license.

Number of Employees Holding Qualifications as of March 2023，31 (including employees on temporary assignment from the sponsors, etc.)		Ratio
Real Estate Notary	13	61.9%
ARES Certified Master	9	42.9%
First-Class Architect	1	4.8%
Property Manager	3	14.3%
Real Estate Consulting Master	1	4.8%
Certified Building Administrator	3	14.3%
Small and Medium Enterprise Management Consultant	1	4.8%
Certified International Investment Analyst	1	4.8%
Chartered Member Analyst of the Securities Analysts Association of Japan	2	9.5%
Medical Management Specialist, Second Grade	1	4.8%
Medical Management Specialist, Third Grade	4	19.0%
Education and training expenses per person
Fiscal 2022	55,248 yen

In order to foster and improve self-directed compliance awareness, HAM holds monthly compliance workshops and rigorously implement customer-oriented business operations (fiduciary duty) for all executives and employees.

	Fiscal 2020	Fiscal 2021	Fiscal 2022
Number of compliance workshops	22	23	22
Number of participation in external compliance workshops	13	26	17

Main theme of compliance workshops	Fiscal 2020 (Number of participants/ Participation rate) (Note)	Fiscal 2021	Fiscal 2022
Compliance program of each fiscal year	20/100%	21/100%	22/100%
FSA Administrative Guidelines, Supervisory Guidelines, Basic Policy on Securities Monitoring, etc.	18/100%	21/100%	19/100%
Basic Policy on Customer-Oriented Business Operation	20/100%	-	19/100%
Exclusion of anti social force	19/100%	21/100%	21/100%
Insider Trading Regulations and Corporate Related Information Management System	20/100%	21/100%	20/100%
Information Management as an Asset Management Company	20/100%	21/100%	20/100%
Disclosure / Fair Disclosure	18/100%	20/100%	19/100%
Regulations on Conduct under the Financial Instruments and Exchange Act, Issuance Disclosure and Distribution Disclosure	19/100%	20/100%	18/100%
Appropriate Management of Related Party Transactions and Conflicts of Interest	18/100%	20/100%	19/100%
Accidents, Scandals and Clerical Errors	19/100%	21/100%	20/100%
Complaint Handling and Financial ADR System	21/100%	22/100%	18/100%
Prevention of Money Laundering and Confirmation at Time of Transaction	18/100%	20/100%	20/100%
FATCA	19/100%	20/100%	21/100%
Reporting Obligations to FSA, MLIT, etc., Statutory Ledgers and Licensing Matters	20/100%	20/100%	21/100%
Rules on Entertainment/Gifts and Prevention of Bribery	20/100%	20/100%	18/100%
Human rights	-	-	18/100%
Items of Special Note Regarding Real Estate Fund Managers	20/100%	20/100%	-
Confirmation Tests (first quarter)	16/100%	16/100%	16/100%
Confirmation Tests (second quarter)	16/100%	18/100%	14/100%
Confirmation Tests (third quarter)	16/100%	18/100%	15/100%
Confirmation Tests (fourth quarter)	16/100%	18/100%	19/100%

(Note)	The participation rate is calculated using the number of full-time directors and employees as the denominator and the number of participants as the numerator. Follow-up training is provided for those absent on the day of the workshop, and the number of participants includes those who attended the follow-up training. In addition, participants in Compliance Test exclude test creators.

Actions Aimed at Securing Human Resources

HAM has continued to consider new hires for the purpose of ensuring that HAM has sufficient human resources and to promote the development of an employee-friendly working environment, such as actively encouraging executives and employees to take paid leave (paid leave usage rate in FY2022: 70.8%), with the aim of improving the motivation of employees and executives and retaining them on a long-term basis.
In addition, as part of our human resources strategy, HAM is working to enhance our asset management operations by accepting highly specialized employees with diverse backgrounds from the sponsor companies.

Initiatives for Fair Personnel Evaluation

HAM has revised its personnel evaluation system, clarifying the roles and abilities required for each employee level, to evaluate job performance, base element, and comprehensive achievement of three performance targets which consist of single-year targets, medium-term targets and skill development. The final evaluation for the year for each employee is determined through regular interviews with and feedback from primary and secondary evaluators, making it a fair personnel evaluation process.

Benefits and work-life balance

Introduction of Cumulative Investment System
HAM has introduced a cumulative investment system that allows directly hired executives and employees to purchase HCM investment units. It is expected that the introduction of this system will assist executives and employees with asset-building and make them more conscious of improving business performance, which HAM believes will contribute to the continuous growth of HCM and improved unitholder value. Moreover, with the aim of promoting investment unit acquisition by employees and thereby enhancing the impact of the system, HAM began providing financial incentives in April 2021.

Introduction of Corporate Defined Contribution Pension Plan
HAM has introduced a corporate defined contribution pension plan as one of its benefit programs, with the aim of contributing to the lifelong stability and welfare of its executives and employees.

Vacation System
HAM provides a vacation system which includes leave for weddings, funerals, pregnancy, childbirth, childcare, sick or injured children and family care.

Premium Friday
As part of our efforts to reform the way we work, HAM encourages employees to leave the office early on "Premium Friday" (the last Friday of the month).

Health Examinations
Health examinations with items of inspection exceeding the legal requirement are conducted once every year.

Employee Satisfaction Survey
HAM conducted a questionnaire survey on employee satisfaction in and 2021 through a third-party investigation agency in order to understand employee’s perceptions of work as well as the conditions of the workspace and to realize an office environment that is conducive to work.
Employees were questioned anonymously on items such as resonance with the corporate philosophy, worthwhileness of work and personal relationship and atmosphere of the workplace. The results of the survey were shared with all employees. HAM will continue introducing measures that will further increase the satisfaction of employees.

Arrangement of the Office Environment

Digitization of Internal Meeting Materials

In September 2022, HAM implemented a paperless system for meeting materials at its officer meetings, Management Committee meetings and Board of Directors meetings in order to reduce environmental impact. As a result of this initiative, the total number of paper sheets used for approximately three months was reduced by 5,670 sheets (approx. 10.7%) year-on-year.

(Note)	Calculated based on the total for the three-month period from August 21 to November 20 of each fiscal year.

Initiatives for DEI (Diversity, Equity and Inclusion)

HAM respects diverse personality of each employee, and strives to establish and improve an employee-friendly working environment and equitable human resource support system that maximizes each employee's ability. These initiatives will not only increase job satisfaction of each employee but also enhance engagement between the company and employees. HAM believes that these initiatives will contribute to improving unitholder value over the long term.

Therefore, HAM has set targets as follows:

• ▪ Basic Targets:
  Achieve 100% participation rate of full-time executives and employees in training.
  Achieve 100％ employee satisfaction survey collection rate.
• ▪Long-term Targets:
  Deepen the understanding of DEI among executives and employees, thoroughly analyze current issues, and establish internal system to secure DEI by reviewing various rules and systems.