Respect for Human Rights
Basic Concept
The Tsubaki Group considers respecting the human rights of all people involved in our business activities to be an important aspect of corporate social responsibility. We have established a Basic Human Rights Policy, which is based on international norms such as the United Nations’ Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights. We are striving to make this Policy well known and understood in the Tsubaki Group companies in Japan and overseas, and to promote respect for human rights throughout the entire Group.
Basic Human Rights Policy
As part of our commitment to corporate social responsibility and recognizing the importance of upholding human rights, the Tsubaki Group has formulated its Basic Human Rights Policy. This policy serves as a cornerstone for promoting and fulfilling our responsibility to respect human rights across the entire Tsubaki Group.
1. Compliance with Laws and Regulations
The Tsubaki Group respects international norms on human rights, such as the United Nations Bill of International Human Rights, which stipulates the fundamental human rights of all people, and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, which stipulates the fundamental rights at work of the ILO, and supports the Ten Principles of the United Nations Global Compact.
We will also promote initiatives for the respect of human rights, in line with the UN’s Guiding Principles on Business and Human Rights.
2. Scope of Application
This policy applies to all Tsubaki Group officials and employees. We will also encourage all business partners related to the Tsubaki Group’s business activities to support this policy.
3. Respect for Human Rights
The Tsubaki Group prohibits discrimination based on race, ethnic group, nationality, social status, origin, gender, disability, health status, thoughts and beliefs, sexual orientation, or differences in job type or employment status, as well as harassment that harms the dignity of individuals. We also promise to provide a safe working environment, secure minimum wages, labor practices including proper management of working hours, freedom of association, and respect for the right to collective bargaining. Moreover, we firmly condemn slave labor, human trafficking, forced labor, and child labor.
4. Implementation of Human Rights Due Diligence
We at the Tsubaki Group are aware of the negative impact that our business activities may have on human rights, and we conduct periodic risk assessments to identify this impact, while promoting initiatives to prevent and mitigate it.
We will endeavor to promptly take appropriate and effective action to remedy any negative impacts that occur.
5. Education
The Tsubaki Group will provide appropriate training to the officers and employees so that this policy is incorporated into all activities of the Group.
6. Information Disclosure
The Tsubaki Group will accurately share information regarding our endeavors to uphold human rights, as outlined in this policy, through our website and other relevant channels.
Established: April 1, 2020
Promotion System
Guided by the Sustainability Committee, which is chaired by the COO, the Tsubaki Group is promoting initiatives for the respect of human rights throughout the entire Group, based on the Basic Policy on Sustainability and Basic Human Rights Policy. The Sustainability Promotion Department, Human Resources Department, Legal Affairs Department, and departments in charge of procurement are all working together to roll out activities for promoting human rights across the supply chain.
Initiatives
Implementation of Due Diligence Regarding Human Rights
We are implementing human rights due diligence in order to identify human rights risks that concern our businesses, including in the Group’s supply chain.
(1) Applicable to the Tsubaki Group
In FY 2022, we began conducting a self-check survey about human rights and labor, targeting Group companies inside and outside Japan, and in FY 2023, we focused on supporting education and awareness. In the FY 2024 self-check survey, there were no serious points for concern in relation to human rights.
We will continue to support improvement efforts for areas in which it is necessary for each company to develop systems, for example, by promoting understanding, disseminating information, and taking remedial measures regarding respect for human rights.
(2) Applicable to Suppliers
In FY 2023, we began investigating human rights risks in the supply chain, targeting major suppliers in Japan, and it was confirmed that no human rights risks were found which required immediate correction. We subsequently visited two major suppliers which had been targets of the investigation, confirming the present status of initiatives for respecting human rights at the Tsubaki Group and each supplier, and exchanging information about the initiatives.
In FY 2024, the scope of the investigation was extended to include major suppliers of the Group in Japan. For items identified as needing improvement in the human rights risk assessment, we continue to work on improvements in cooperation with the suppliers.
Details of Implementing Human Rights Due Diligence
| The company and Group companies inside and outside Japan | Domestic suppliers | ||
|---|---|---|---|
| FY 2022 | Number of companies responding (response rate) | 32 (100%) | - |
| Incidents of corrective action | 1 | - | |
| FY 2023 | Number of companies responding (response rate) | - | 191 (77.6%) |
| Incidents of corrective action | - | 0 | |
| FY 2024 | Number of companies responding (response rate) | 31 (100%) | 349 (81.7%) |
| Incidents of corrective action | 0 | 0 | |
Setting Up a Consultation Desk and Reporting System for Human Rights-Related Issues
Through the Corporate Ethics Helpline consultation desk that we have set up within and outside the company, we are also responding to consultations on human rights and anonymous reporting on human rights incidents. Moreover, with the assignment of employees to engage in consultations on any topic, we are capable of handling not only risks related to compliance with laws and regulations but also routine matters. We will continue to advance the development of a positive work environment.
Human Rights-Related Education and Permeation
To ensure that nobody involved in its businesses is subject to any form of discrimination or harassment that violates individual dignity including on the grounds of race/ethnicity/nationality, social or economic status, gender, disability or health condition, personal beliefs, or employment type/status, the Tsubaki Group is implementing measures to enhance ethics awareness among all employees.
(1) Corporate Ethics Awareness Month
We have designated February of every year as Corporate Ethics Awareness Month while conducting activities designed to promote strict adherence to laws and rules in the Group’s countries of operation. In FY 2024, we conducted e-learning about respect for human rights on the theme of “Creating a better working environment.” All employees of the Group in Japan were eligible to participate.
(2) Training on Human Rights and Harassment
We are implementing training on human rights and harassment in new employee training and training for employees who are promoted.
The Tsubaki Group’s Basic Human Rights Policy has been established based on international human rights standards and the United Nations’ Guiding Principles on Business and Human Rights. Through our human rights-related training for employees, we have established an awareness that companies have a responsibility to promote appropriate initiatives to address human rights risks and the respect of human rights, and that addressing human rights-related issues with sincerity is linked to raising corporate value. In addition to these initiatives, in FY 2024, we welcomed an outside director as a lecturer to conduct training aimed at management.
(3) Provision of Human Rights Learning Materials to Group Companies and Suppliers
As a way of supporting awareness, we provided domestic Group companies and major suppliers with materials relating to business and human rights, thereby sharing our understanding of corporate responsibility for human rights violations in the supply chain and the importance of human rights due diligence. We also introduced human rights representatives from Group companies inside and outside Japan to an e-learning system provided by the United Nations Global Compact Academy, and we are enhancing the promotion and permeation of understanding human rights.
Planning and Participation in Initiatives
As a part of our expression of support and approval of the United Nations Global Compact, since FY 2022 we have been participating in human rights due diligence (HRDD) workshops and human rights education workshops sponsored by the Global Compact Network Japan (GCNJ). Through training and group work activities, the participants learned about positive examples of initiatives for respecting human rights and exchanged information with each other.
Additionally, we are also participating in the B+HR (Business and Human Rights) Academy, sponsored by the United Nations Development Programme (UNDP) together with the Japanese Government.


