Respect for Human Rights

To implement the basic philosophy of Ishihara Sangyo Kaisha, Ltd. (ISK) from the standpoint of business and human rights, we formulated the ISK Group Policy on Human Rights in accordance with international standards related to human rights, including “International Bill of Human Rights”, “Declaration on Fundamental Principles and Rights at Work issued by the International Labour Organization (ILO)”, “Ten Principles of the UN Global Compact”, and “UN Guiding Principles on Business and Human Rights”. Recognizing that observance of the human rights of all people involved with its business activities is essential, the ISK Group acts in accordance with the Policy so that it will be able to continue contributing to better living environments through chemical technologies in the future. The Policy, which was formulated with advice from outside experts, was approved by the Board of Directors on April 8, 2022.

ISK Group Policy on Human Rights

The ISK Group’s corporate philosophy embodies the following principles:

• Contributing to a better society, life and environment through chemical technologies;
• Respecting shareholders, customers, suppliers, local communities and employees;
• Abiding by laws and regulations and maintaining transparency in business activities; and
• Respecting the human rights of ISK Group’s stakeholders.

In light of these principles, ISK Group adopts the following Policy on Human Rights (this “Policy”).

1. 1.
   Basic Commitment
2. 2.
   Scope of Application and Expectations for Suppliers and Contractors
3. 3.
   Respecting Human Rights through Business Activities
4. 4.
   Measures for Respecting Human Rights

• ISK Group Policy on Human Rights (Full text)

  1.Basic Commitment:

  ISK Group is committed to the protection and advancement of human rights throughout its global business operations. ISK Group’s Policy is guided by international human rights standards including the followings:

  • International Bill of Human Rights;
  • Declaration on Fundamental Principles and Rights at Work issued by the International Labour Organization (ILO);
  • Ten Principles of the UN Global Compact; and
  • UN Guiding Principles on Business and Human Rights.

  [In case of any conflict,] ISK Group tries to find a way to follow international human rights standards and remain in compliant with the local laws and regulations.

  2.Scope of Application and Expectations for Suppliers and Contractors:

  This Policy applies to all of ISK Group’s directors, officers, and employees, including both full and part-time. This Policy covers dispatched workers as stakeholders (collectively, the “Constituents”).
  ISK Group expects that its suppliers and contractors will commit to the same practices contained in this Policy.

  3.Respecting Human Rights through Business Activities:

  ISK Group recognizes its potential to impact human rights through its business activities. Through the principles set forth below, ISK Group will respect human rights by endeavoring to avoid human rights violations through its business operations and, should any adverse impact on human rights arise through its business operations, taking appropriate action to rectify such adverse impact and prevent any future violations.

  1. (1)
     Non-discrimination:
     ISK Group respects the diversity of its Constituents and, consistent with all applicable laws, does not discriminate based on race, religion, gender, age, national origin, form of employment, disability, sexual orientation, or gender identity.
  2. (2)
     Respect to Privacy:
     ISK Group respects privacy of individuals consistent with laws and regulations as well as privacy policy applicable in the countries and regions where ISK Group operates.
  3. (3)
     Anti-Harassment:
     ISK Group treats its Constituents with respect and promotes a work environment free of harassment.
  4. (4)
     Freedom of Association/Collective Bargaining:
     ISK respects its Constituents’ right to form, join, or not join a labour union in accordance with all applicable laws.
  5. (5)
     Health & Safety:
     ISK Group promotes the health and safety of its Constituents by maintaining a healthy work environment, promoting a culture of safety, and ensuring compliance with applicable safety practices and procedures.
  6. (6)
     Fair Wages/Compensation:
     ISK Group complies with the laws and regulations concerning working time and wages applicable in the countries and regions where ISK Group operates.
  7. (7)
     Forced Labour/Child Labour:
     ISK Group opposes any form of forced labour or harmful child labour. ISK Group prohibits the use of forced labour or child labour in all ISK Group facilities.
  8. (8)
     Coexist with Local Communities:
     We understand potential adverse impacts on local communities such as right to land, access to water, health and indigenous rights, and we will strive to coexist with local communities.

  4.Measures for Respecting Human Rights:

  1. (1)
     Education and Training:
     ISK Group will train its Constituents on this Policy and ensure that it is implemented throughout ISK Group’s operations.
  2. (2)
     Human Rights Due Diligence:
     ISK Group will work to identify, prevent and/or mitigate potential or actual violations of this Policy throughout ISK Group’s operations.
  3. (3)
     Response to Occurrence of Problems:
     ISK Group will investigate facts promptly upon receiving reports or whistleblowing from inside and outside our group companies. ISK Group is committed to providing prompt remedies through legitimate process based on the international standards if it has been identified that we have caused any adverse impact on human rights by our business activities.
  4. (4)
     Disclosure:
     ISK Group will publicize this Policy throughout ISK Group’s operations and through ISK Group’s website.
  5. (5)
     Review of This Policy:
     ISK Group will periodically review and update this Policy as necessary to maintain compliance with ISK Group’s corporate philosophy.

  Ishihara Sangyo Kaisha, Ltd.
  Executive Director and President
  Hiroshi Okubo

Message from an Outside Expert

Emi Omura
Attorney admitted in Japan and the state of New York
Officer, Steering Committee, Business and Human Rights Lawyers Network Japan

• Message from an Outside Expert (Full text)

  On the Formulation of ISK Group Policy on Human Rights

  March 23, 2022

  The ISK Group Policy on Human Rights, which explicitly draws on the International Bill of Human Rights, the ILO’s core labour standards, and other relevant documents, provides a detailed accounting of the ISK Group’s responsibilities concerning respect of human rights in its business activities. Its broad understanding of the foundations of prohibited discrimination and its acknowledgment of the need to coexist with the local community anticipate domestic laws, and as such, they deserve particular praise. In making clear its expectations for suppliers and business partners, the Policy aligns itself with the United Nations Guiding Principles on Business and Human Rights.
  The process itself, in which ISK conducted an exhaustive series of internal consultations so that it could ensure the new policy would permeate group companies’ operations and carefully sought input from outside experts concerning the latent negative impacts of its business activities on human rights (human rights risks), is also rich in meaning and significance.

  As if to embody your purpose of "To continue contributing to better living environments through chemical technologies," your businesses are closely related to the living environments of the individuals who make up society. In light of that orientation, I believe that focusing on people and undertaking initiatives that lead the industry in the area of human rights provide a foundation on which additional value can be created. Since ISK is also working to promote communication with residents living near its plant, I expect to see stepped-up dialog with an even broader range of stakeholders in the future.

  Now that the human rights policy has been adopted, ISK will presumably also do its utmost to carry out due diligence in the area of human rights, implement a hotline for human rights concerns from both inside and outside the company, and operate it in an effective manner. I will also pay attention to how ISK works to collaborate with the newly established Sustainability Promotion Committee; ensure consistency with supply chain management, which has been identified as a materiality; and enhance disclosure.
  Both in Japan and abroad, efforts to develop laws and formulate guidelines related to human rights due diligence and to strengthen disclosure of non-financial information are accelerating. I am confident that ISK, as a company with a global business, will take advantage of its human rights initiatives to become even more responsive to expectations from not only domestic investors, but also the international community.

  ＊Note: The above comments represent the views of Ms. Omura as an individual attorney. They do not reflect the views of any law offices or organizations to which she belongs, or of any organizations for which she serves as a director or officer.

  Profile of Attorney Omura

  

  • Partner, CLS Hibiya Tokyo Law Office
  • Officer, Steering Committee, Business and Human Rights Lawyers Network Japan
  • Member, Roundtable on Implementing Action Plan on Business and Human Rights (Ministry of Foreign Affairs)
  • Former manager, Office of International Affairs, Japan Federation of Bar Associations
  • Former employee, International Labour Standards Department, International Labour Organization (ILO)

Implementation of Human Rights Due Diligence

Sustainability Structures

To strengthen its ability to address sustainability issues, the ISK Group has established the Sustainability Promotion Committee, which reports directly to the president and oversees the Human Rights Due Diligence Promotion Team as it orchestrates initiatives to resolve human rights issues. The selection of plans to address human rights issues, the evaluation of activity results, improvements based on the evaluation, and issues to be considered are evaluated and managed by the Sustainability Promotion Committee, which reports to the Corporate Risk Management Committee as needed.

Human Rights Issues and Impact Assessment

The ISK Group is working to build mechanisms to identify and prevent or mitigate human rights issues negatively impacting society. In fiscal 2022, with the cooperation of outside experts, we examined our principal businesses and associated value chains, identified and evaluated human rights issues that could have a negative impact on human rights through our business activities, and then designated those human rights risks to be prioritized.

*You can see the entire image in the figure by scrolling horizontally.

●Identification of Human Rights Issues

●Evaluation

●Exchange of Views with Experts and Others

●Identification of Human Rights Risks to Be Prioritized

Human Rights Risks to Be Prioritized

Placing the highest priority on human life, the ISK Group has identified initiatives to address as priority human rights risks. These include responding to the fact that our major manufacturing sites are located in areas expected to be damaged by a Nankai Trough earthquake, enhancing our response to geopolitical risks, responding to workplace-specific risks like long working hours and harassment, and responding to increasingly sophisticated information security risks.
We also believe that it is necessary to understand the current state of human rights at suppliers and business partners and communicate with them in order to further increase transparency.

*You can see the entire image in the figure by scrolling horizontally.

Message from an Outside Expert

Emi Omura
Attorney admitted in Japan and the state of New York
Officer, Steering Committee, Business and Human Rights Lawyers Network Japan

• Message from an Outside Expert (Full text)

  Disclosure of Human Rights Risks to Be Prioritized

  February 13, 2023

  I welcome the fact that the ISK Group has begun to undertake human rights due diligence.
  The potential negative impact of business activities on human rights (human rights risks) is identified with a focus on stakeholders, who are rights holders of human rights, and is evaluated with the severity of the impact on human rights used as a priority indicator. Listing the health and safety of the ISK Group employees as a human rights risk to be prioritized is in line with the latest trends in the international community. The International Labour Organization adopted its core labor standards in 1998, and added “promoting safe and healthy working environments” to them in 2022. Thus, the importance of occupational safety and health was reaffirmed as fundamental human rights.

  Regarding long working hours and harassment, the protection of the lives and physical and mental health of workers is required by domestic laws and regulations. However, the United Nations Guiding Principles on Business and Human Rights require initiatives which go beyond compliance with domestic laws and regulations. For example, companies are required to confirm whether work style is being reformed or harassment countermeasures are taken among suppliers or business partners. In addition, I believe that it is necessary to deal with personal information and privacy in accordance with international standards in order to prevent serious situations that threaten the lives, bodies, and livelihoods of individuals, while taking into account differences in the privacy protection laws of the countries where your company operates.

  I have understood that the ISK Group will work on future initiatives to identify concrete human rights issues at suppliers and business partners and to promote dialogue with stakeholders in the process of human rights due diligence. The ISK Group promotes initiatives related to environmental impact, including waste disposal, and advocates process safety, disaster prevention, and environmental protection activities in the Multi-Stakeholder Policy that ISK formulated in 2023. A measure to be taken would be to reconsider environmental issues faced by suppliers and business partners from the perspective of human rights through dialogue with local communities.

  Initiatives on human rights that lead the chemical industry will help increase productivity and secure and maintain excellent human resources through the improved job satisfaction of employees, gain support from business partners and customers, and strengthen relationships of trust with them. I believe that such initiatives will bear fruit in the form of an increase in the evaluation of corporate value by domestic and foreign shareholders and investors, and will surely contribute to the further development of the ISK Group.
  I look forward to the progress of human rights due diligence in the future.

  ＊Note: The above comments represent the views of Ms. Omura as an individual attorney. They do not reflect the views of any law offices or organizations to which she belongs, or of any organizations for which she serves as a director or officer.

  Profile of Attorney Omura

  

  • Partner, CLS Hibiya Tokyo Law Office
  • Officer, Steering Committee, Business and Human Rights Lawyers Network Japan
  • Member, Roundtable on Implementing Action Plan on Business and Human Rights (Ministry of Foreign Affairs)
  • Former manager, Office of International Affairs, Japan Federation of Bar Associations
  • Former employee, International Labour Standards Department, International Labour Organization (ILO)

The ISK Group’s Major Initiatives to Ensure Respect for Human Rights

The ISK Group has been working on the following measures to ensure respect for human rights.
Since we have identified human rights risks to be prioritized, as described above, we will take further measures to promote respect for human rights.

• ●Occupational Health and Safety

  ISK’s health and safety policy is to ensure the safety and security of employees and local residents and maintain their health by complying with health and safety-related laws and regulations, working to prevent accidents and disasters and build a pleasant work environment and constantly raising the level of safety and health.

  Occupational Health and Safety

• ●Health and Productivity Management

  On October 11, 2021, we announced the ISK Health Management Declaration to help us think about and strategically put into practice employee health and productivity management from a business administration-informed perspective. We are moving forward with an effort to put in place an environment in which employees can do their jobs in an energetic manner while enjoying both mental and physical health, including a variety of initiatives to incorporate health considerations into the ISK's management as the key to sustained growth.

  Health and Productivity Management at ISK

• ●Diversity and Inclusion

  We recognize “Diversity and inclusion” as one of the Important issues (Materiality) and aim to use human resources with various backgrounds.

  Diversity and Inclusion

• ●Education and Training

  Once employees enter ISK, the company develops their capabilities by holding courses at each business location company-wide at certain points in their careers in order to make them aware of their roles in society and the company and to boost various skills. We also have courses to improve their global business skills, such as online courses they can take at home. They can also go to a language school to learn foreign languages, take part in overseas training, and attend a management school open to all employees to learn global communication skills and further leadership capabilities.

  Human Resource Development

• ●Responses to Mineral-Related Conflicts

  ISK Group Code of Conduct includes the following statement: “Together with our suppliers and subcontractors, we will engage in socially responsible procurement activities.” In keeping with that priority, we carry out purchasing and procurement activities in a way that takes CSR into account, for example by checking to be sure we do not purchase conflict minerals, while securing cooperation from suppliers.
  We make only limited use of tantalum, tin, tungsten, and gold (“3TG”), which are typically recognized as conflict minerals, in the manufacture of our Group’s products. Tin compounds, which we use as a raw material in electroconductive materials and other substances, and tantalum, which we use in vacuum deposition, fall under the definition.
  We require suppliers of tin compounds and tantalum to submit a report using the Conflict Minerals Reporting Template, a global standard for conflict mineral investigations developed by the Responsible Minerals Initiative. In this way, we verify the certification status of the refineries producing the tin and tantalum purchased by our suppliers. If necessary, we also confirm that the refineries have been certified as conflict-free by a third party.

• ●Coexistence with Local Communities

  The ISK Group aims to coexist with the local communities in which it operates. In particular, in countries with high geopolitical risks, pre- and post-conflict countries and countries with low awareness of human rights, we will collect information in a timely manner. We will consider how to coexist with local communities, as needed, which may include exercising our influence in some cases. The goal is to ensure that the rights of people in the local communities are not violated.

Corrective Mechanisms

Establishment of a Hotline

The ISK Group has established a hotline that can be used both inside and outside the company so that when there are fears or concerns that its business activities will have a negative impact on human rights, associated issues can be dealt with and corrected quickly. When it receives a report or tip from inside or outside the company, the ISK Group investigates immediately. If it finds that its business activities have had a negative impact on human rights, it will quickly undertake corrective action in an appropriate manner based on international standards. Callers can leave anonymous tips, but even if they give a name, we work to ensure that they will suffer no adverse treatment as a result of having used the hotline.