Respect for Human Rights
Human Rights Policy
We are working to resolve various social issues to realize sustainable societies. We recognize that as a prerequisite for this, it is important to respect human rights of people who are affected by our business activities, and that it is essential to continuously fulfill such responsibilities in truly contributing to the realization of sustainable societies. To this end, we respect human rights set out in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, and make our best efforts to protect the dignity of these people based on the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises.
Action Guidelines
- We comply with the laws and regulations of all countries and regions in which we conduct our business activities. If where national laws and international human rights differ, we seek ways to respect internationally recognized human rights wherever possible.
- We identify negative impacts that we could have on human rights through our business activities, and strive to prevent, mitigate, or eliminate the causes of such impacts.
- We establish a scheme for our employees and suppliers to access or report, and accept consultations and notifications concerning human rights. Upon receiving consultations or notifications, we investigate the facts, and if any problem is identified, we remedy it through appropriate response.
- We disclose efforts and progress promptly on human rights actions and keep updating ones through discussions and dialogues with various internal and external stakeholders.
- This policy applies to all Corporate Officers and employees of the Group. We provide appropriate education and trainings to ensure that all Corporate Officers and employees understand and act with this policy.
- We consistently require all of our business partners, including suppliers, to understand the Policy and join our efforts to respect human rights.
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The Policy is top-ranked guideline on human rights actions and had been confirmed by our CSR and Sustainability Committee and approved by Board of Directors’ meeting. The Policy shows the Group’s approach on human rights and complements our Corporate Philosophy, CSR and Sustainability Charter, and Corporate Code of Conduct.
The Policy will be periodically updated in response to changing social and business environment and human right issues, through discussions and dialogues with stakeholders. We keep adequate management system and reflect updates on relevant business policies and procedures to integrate in entire business activities.
The human rights that the Group respects in its corporate activities include the following:
[Prohibition of forced labor]
We do not tolerate forced labor and human trafficking, and we employ employees on their own volition.
[Prohibition of inhumane treatment]
We do not engage in inhumane treatment such as abuse, corporal punishment, sexual harassment, or power abuse, and we respect the human rights of our employees.
[Prohibition of child labor]
We respect rights of children and do not employ them under the minimum age for employment in the country or region. Workers under the age of 18 shall not perform work that is likely jeopardize the healthy development.
[Prohibition of discrimination]
We prohibit discrimination of any kind, irrespective of race, color, age, gender, sexual orientation, gender identity, ethnicity, nationality, disability, pregnancy, religion, union membership, protected genetic information, or marital status.
[Working conditions and equal opportunities]
We comply with the laws and regulations of each country and region, such as minimum wages, overtime wages, equal pay for equal work, working hours, etc., offer working conditions for a better life for our employees, and do not unreasonably reduce wages. We also ensure equal opportunities and equity in hiring, promotion, and compensation.
[Freedom of association and collective bargaining]
We respect freedom of association and the right to collective bargaining in accordance with the laws and regulations of each country and region.
[Responsible procurement of resources and materials]
We promote responsible procurement of resources and materials, taking into consideration human rights issues, including those relating to conflict minerals. If any use of such minerals is found, we will take appropriate measures.
[Respect for privacy]
We respect and do not infringe on the privacy of individuals.
[Comfortable workplace environment]
We comply with the laws and regulations concerning safety, hygiene and health in each country and region, strive to reduce long working hours and create a safe, healthy and comfortable workplace environment.
[Respect for the rights of Indigenous Peoples and local communities]
In business activities in areas where indigenous peoples reside, we recognize that indigenous peoples have their own unique cultures and histories, and we respect the rights of indigenous peoples as stipulated in international agreements. We also respect the rights of local communities, including Indigenous Peoples, to land, forests, and water, and we will not engage in environmental pollution, development that leads to environmental destruction, forced evictions, or illegal land grabs.
[Respect for Human Rights in Security Operations]
We comply with the laws and regulations of each country and region in security operations. We also support international guidelines, such as the Voluntary Principles on Security and Human Rights.
Basic Philosophy
We are aware that a wide range of people are affected by the business activities of our Group, including not only employees of our Group but also employees in the supply chain and local residents. Based on the United Nations Guiding Principles on Business and Human Rights, we are committed to respecting human rights through the establishment of a mechanism to identify, assess, prevent, mitigate, and remedy negative impacts of our business activities on human rights.

Promotion System
Since human rights issues are wide-ranging, each department is depending on the issue. The progress of work and problems are checked by each department and each relevant specialized committee.
In addition, in response to the recent global trend toward legislation on business and human rights, discussions on human rights have begun in FY2022 in the divisions involved in the implementation of human rights due diligence (Business Management Dept., Sustainability Strategy Dept., Human Resources Strategy Dept., Environment & Safety Management Dept., and Procurement Dept.) and are continuing.
All initiatives for respect for human rights are supervised by the Human Rights Subcommittee of the CSR and Sustainability Committee (chaired by an outside director), an advisory body to the Board of Directors.

Formulation and Publication of Human Rights Policy
We established the Human Rights Policy in 2020 as part of the CSR Basic Policy. Subsequently, we revised the Human Rights Policy in January 2023 in response to the increasing importance of and expectations for corporate human rights initiatives and the increasing need for companies to promote human rights not only within our Group but throughout the entire value chain.
In making revisions, the Human Rights Working Group, with the advice of external experts in the field of human rights, prepared a draft revision, taking into consideration our Group’s issues, human rights risks, global standards, etc. The draft was then reviewed by the CSR and Sustainability Committee and approved by the Board of Directors.
<Process of revision of the Human Rights Policy>

Human Rights Due Diligence
We are working to identify, assess, prevent and mitigate human rights risks related to the business operations of our Group.
In identifying human rights risks, we organized the Group’s major value chains and related stakeholders and extracted commonly assumed human rights risks for each value chain. We then organized the Group’s human rights risks by referring to reports from international organizations, media databases, and other surveys, as well as benchmarks from other companies. We then conducted a simplified human rights impact assessment and mapped them and identified priority human rights risks.
<Identified Priority Human Rights Risks>
Our Group | Supply Chain |
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Based on these results, we are now promoting human rights due diligence initiatives depends on risk assessments, primarily within our group and supply chain.
We also recognize that the human rights risks we have identified may change depending on social conditions, the progress of our group's business, the development of new business relations, etc.
In order to increase the effectiveness of our efforts, we will conduct periodic reviews of the risk mapping.
【Our Group】
We conduct compliance awareness surveys of employees and human rights and labor surveys of Group companies to identify human rights violations and potential human rights risks.
- Compliance awareness survey for employees
A compliance awareness survey is conducted for all Group employees in Japan to identify risks related to compliance (including harassment), the level of awareness and understanding, and the status of the organization, etc. The survey includes an open-ended section that allows respondents to anonymously write their opinions about compliance. Issues and potential human rights risks identified through the surveys are reported to heads of respective divisions to prevent them and make improvements. - Human rights and labor survey for Group companies
We also conduct annual surveys on our group companies about human rights and labor issues to check for potential human rights risks.
【Supply Chain】
To promote CSR and sustainability efforts throughout our supply chain, we issued the CSR and Sustainability Procurement Guidelines, which have been deployed to suppliers. The guidelines include compliance matters related to human rights, including labor, safety, and health.
To monitor the status of implementation by suppliers, we conduct surveys every two years using a checklist and provide feedback on the results. For suppliers that require follow-up activities, we visit them to check the situation. We also provide support as appropriate when improvements are needed.
In FY2023, we revised the guidelines and checklist and conducted a supplier survey using the new checklist.
Our Group | Compliance Awareness Survey |
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Human Rights and Labor Survey |
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Supply Chain | Survey using the CSR and Sustainable Procurement Guidelines check sheet |
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Complaint Handling Mechanism
We have contact points in place to accept opinions, questions, requests, etc. from stakeholders, including customers, suppliers, and employees.
Reports and consultation requests related to human rights from suppliers and employees are accepted by contact points for the whistle-blowing system.
For consultations and reports we receive, we investigate the facts with utmost care to ensure that the person who reports or consults is not identified or does not feel uneasy, and if any problem is identified, we deal with it promptly. In addition, we prohibit disadvantageous treatment of persons for reasons of having reported or consulted. We also confirm with the persons whether they are treated disadvantageously.
【Japan】
- Contact points for the Corporate Ethics Helpline (a whistle-blowing system) are in place internally and externally.
- External contact points offer consultation services and accept reports outside working hours and on holidays. Consultation requests are also accepted anonymously.
- The helpline is available for suppliers and our group employees.
【Outside Japan】
- Respective group companies have contact points for whistle-blowing.
Dialogue with Stakeholders
We hold regular labor-management meetings with the labor union, which represents employees, to discuss working hour management and work styles. In FY2023, we also held a dialogue on the theme of human rights.
For our suppliers, we receive consultations through the consultation desks, etc., and we sincerely listen to their problems and concerns and discuss with them to help them solve problems and improve the situation while deepening mutual understanding.
In addition, we hold roundtable meetings with representatives of residents living near our plants to exchange opinions on various matters, including whether there are any issues that could threaten their living environment.

Human Rights Education and Awareness Raising
Compliance Guidebook
We distribute the Compliance Guidebook to employees at our group.
The Compliance Guidebook is a booklet that compiles corporate and social rules. It is used to check correct action to be taken as a member of the Niterra Group when it is difficult to make judgments. This guidebook also stipulates compliance matters related to human rights, including respect for human rights and prohibition of various types of harassment (e.g., harassment related to pregnancy, childbirth, childcare leave and long-term care leave, bullying, and mobbing, as well as sexual harassment, including that directed against people of the same gender and in relation to sexual orientation or identity). The guidebook is also used in daily awareness-raising activities, such as read-through at the workplace.
Human Rights Training
In human rights training for all employees, employees watch a video on the necessity of respect for human rights, the Group’s human rights policy, human rights due diligence and remedies, and they take a check test to confirm their level of understanding. In addition, we also hold human rights seminars for management to provide them with the opportunity to consider global trends, business and human rights, etc. We are working to raise awareness of human rights among management and employees through increased education and information provision.
We have been recently increasing opportunities to raise awareness about gender equality and LGBTQ+-related issues through our human-rights-related training and e-mail newsletters. We are also monitoring human rights problems around the world.
Showing Support to the “My Declaration of Human Rights” Project under the Auspices of the Ministry of Justice
In July 2021, we publicized “My Declaration of Human Rights” to show support for the “My Declaration of Human Rights” project promoted by the Ministry of Justice.

