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.
Overview of Human Rights InitiativesBased on our Human Rights Policy, each department and specialized committee within our Group is driving initiatives to address human rights issues in their respective areas.
In response to the globally accelerating focus on 'Business and Human Rights,' relevant departments—including Risk Management, Compliance, Human Resources, Procurement, and Sustainability—have engaged in continuous discussions since FY2022 to ensure the ongoing implementation and enhance the effectiveness of our human rights due diligence.
Starting in FY2026, the Human Rights Subcommittee, established under the Compliance Committee, will continuously monitor our human rights due diligence processes, as well as deliberate and evaluate related issues. Important matters identified through this process are reported and submitted to the Board of Directors via the Management Meeting. Through these structured procedures, we have established an effective promotion system under the strict supervision of the Board of Directors.
Human Rights Promotion SystemSince establishing our Human Rights Policy in 2020 as part of our CSR Basic Policy, we have reviewed its content annually and as needed.
In January 2023, recognizing the growing importance of corporate initiatives to respect human rights and the need for such efforts not only within our Group but throughout the entire value chain, we fully revised the Human Rights Policy to align with international norms and other standards. At the same time, we specified examples of human rights to be respected in an Appendix to the policy. The revision was made based on advice from external human rights experts and after extensive discussions among departments involved in implementing human rights due diligence. The revised policy was then reviewed by the CSR and Sustainability Committee and approved by the Board of Directors. Furthermore, in December 2024, we revised the Appendix to the Human Rights Policy to include items concerning "the rights of Indigenous peoples and local communities" and "respect for human rights in security operations."

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 human rights impact assessment and mapping, and identified priority human rights risks.
Impact on Human Rights: Assessed based on severity (scale, scope, and irremediable character) and likelihood.| Our Group | Supply Chain |
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Based on these results, we are currently advancing our initiatives to respect human rights, focusing on our Group and supply chain where we can exert direct influence, and prioritizing the human rights risks identified as key areas.
We also recognize that the identified human rights risks can change due to shifts in social conditions, the progress of our Group's business, and the development of new business partners. Therefore, to enhance the effectiveness of our initiatives, the departments involved in implementing human rights due diligence take the lead in periodically reviewing the risk map.
We periodically monitor the status of respect for human rights within our Group and supply chain by conducting surveys.
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.
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.
| 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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For any issues or potential human rights risks identified through these surveys, we implement corrective measures as necessary and work to prevent their occurrence.
For instance, in fiscal year 2024, we discovered that a Group company in Thailand was conducting pre-employment pregnancy and infectious disease tests, citing workplace safety considerations. As this could potentially lead to discrimination, we abolished these tests in accordance with international standards. We also confirmed that no other Group companies were conducting similar tests.
Risks related to human rights cannot be completely eliminated and will continue to exist, even with systems such as human rights due diligence in place. This is because such risks often stem from the limitations of these systems, unforeseen events, and the complexity of the issues themselves; furthermore, human rights standards vary by country, region, and era. To mitigate these risks, we are committed to continuous improvement, dialogue with stakeholders, transparent disclosure, and educational and awareness-raising activities aimed at embedding respect for human rights into our corporate culture.
| Human Rights Issue | Initiative | Specific Action |
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| Conflict Minerals | Commitment to Responsible Minerals Sourcing | We established the "Niterra Group Responsible Mineral Procurement Guideline." |
| Forced Labor | Abolition of Pay Reduction as a Disciplinary Measure | We abolished pay reduction as a disciplinary action, in accordance with international standards. We plan to extend this policy to our Group companies. |
| Discrimination | Support for Same-sex Partnerships | Employees in registered same-sex partnerships are now eligible for welfare and benefits programs on the same basis as employees in heterosexual marriages. We will extend this policy to Group companies where it is not yet implemented. |
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.
We hold regular labor-management meetings with the labor union, which represents employees, to discuss working hour management and work styles. In FY2024, 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.
Dialogue with the labor unionsWe 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.
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 are increasing educational and information opportunities to raise awareness among management and employees. For our management team, we addressed topics such as global trends in human rights and business and human rights in expert lectures on sustainability management.
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.
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.
President Kawai (at the time) holding a declaration card
“My Declaration of Human Rights”