Basic Policy on Human Rights

In the spirit of the Company Creed of “Fairness, Innovation and Harmony,” the Marubeni Group is proudly committed to promoting social and economic development and safeguarding the global environment through fair and upright corporate activities. We recognize that respecting the human rights of persons affected by our business activities and endeavoring to take responsibility for doing so are of utmost importance, and to this end we have formulated our Basic Policy on Human Rights (“the Policy”), based on the UN’s Guiding Principles on Business and Human Rights.

Our Basic Stance on Human Rights

We support and respect all international rules on human rights, including the UN’s International Bill of Human Rights (Universal Declaration of Human Rights and International Covenant on Human Rights), the ILO’s Declaration on Fundamental Principles and Rights at Work and the 10 Principles of the UN Global Compact.

Scope of Application

This Policy applies to all executives and employees of the Marubeni Group. We also ask that stakeholders (vendors, service providers, contractors, third-party manufacturers, joint venture partners, outsourcing partners, customers and other business partners and local communities) and other related parties observe the intent of the Policy and take appropriate action if a negative effect on human rights caused by them is directly related to the business activities of the Marubeni Group.

Responsibility for Human Rights

We will carry out our responsibility to respect human rights by ensuring that we do not violate human rights. If it should come to light that any of our business activities are having a negative impact on human rights, we will take appropriate action to remedy the situation.

• Human Rights Due Diligence:
We will create and continue using a system for carrying out human rights due diligence.

• Redress:
We will create a system (complaint resolution mechanism) for reporting when our business activities have a negative effect on human rights or we have been involved in human rights violations. If such reports are received, appropriate procedures for redress will be taken once the facts are sufficiently ascertained.

• Dialogue and Discussion:
We will engage in sincere dialogue and discussion with relevant stakeholders in order to promote initiatives in line with this Policy.

• Compliance with Relevant Laws:
We will observe the laws and regulations of the countries or regions where we conduct business activities. If national laws are in contradiction with internationally recognized human rights, we will pursue solutions in which we can respect human rights principles.

• Education and Training:
We will conduct appropriate training and skill development for our executives and employees to ensure that this Policy is understood and effectively put into practice in all our business activities.

• Information Disclosure:
We will report on our initiatives, etc. for fulfilling our responsibilities to respect human rights through our official website and other avenues.

The above Policy includes the following policies with regard to those who are especially vulnerable to human rights abuses:

• Policy Regarding the Rights of Children:
In addition to supporting the Children’s Rights and Business Principles^*4, which are intended to protect children’s rights in the course of our business activities, we will undertake social contribution activities to strengthen children’s rights and by so doing will contribute to improving children’s rights.

• Policy Regarding the Rights of Indigenous Peoples:
When conducting our business activities in countries or regions with indigenous peoples, we will acknowledge the native culture and history of indigenous peoples, and we will give due consideration to the laws of the country or region in question and the rights of indigenous peoples set out in international rules.

• Policy Regarding Use of Security Services:
We are aware of the inherent risk to human rights related to the use of weapons for security. With regard to the use of security services when conducting business activities, we will observe the laws of the countries or regions where we operate, support international rules and related practices and endeavor to respect human rights.

• Children’s Rights and Business Principles: A comprehensive set of principles formulated by UNICEF, the UN Global Compact and Save the Children covering various actions that enterprises can take in the workplace, the marketplace and the community in order to promote respect for children’s rights.

Human Rights Due Diligence

We are continuously working to increase awareness of respect for human rights and enable early detection of, and remediation for, any adverse impacts on human rights, throughout our company and its group companies as well as our business counterparts, including our business partners and contractors, and our supply chain as a whole, based on the “Marubeni Group Basic Policy on Human Rights”, “Basic Supply Chain Sustainability Policy” and “Marubeni Group Basic Policy on Occupational Health and Safety”.

Specifically, we have established our human rights due diligence mechanism based on the UN Guiding Principles on Business and Human Rights, the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work (including the five core labor standards), and the OECD Guidelines for Multinational Enterprises and Due Diligence Guidance for Responsible Business Conduct, ISO 26000, SA 8000, etc. In order to identify areas to be prioritized for investigation, we conducted risk mapping, by considering the sector, product, geographic, and enterprise-level risks and the anticipated potential adverse impacts on human rights (as well as the severity (scale, scope and irremediability) and likelihood of occurrence).

In addition, during the process of establishing our mechanism, through dialogue (engagement) with various stakeholders and external experts (e.g. NGOs working towards respect for human rights, international organizations promoting protection of workers’ rights, experts on human rights, etc.) as well as our internal discussions, we made efforts to identify important and high priority initiatives in order to improve the effectiveness of our human rights due diligence.

Our human rights due diligence can be broadly divided into the following two approaches:

1. (1) Human rights due diligence related to business projects where we are investor and/or operator
2. (2) Human rights due diligence related to supply chains

(1) Human Rights Due Diligence Related to Business Projects where we are Investor and/or Operator

• For existing business projects, we conducted a written survey of all consolidated subsidiaries (and on-site inspections at some group companies), to assess the risk of human rights violations and confirm whether any human rights violations (incidents) had actually occurred (FYE 3/2021).
  For those entities assessed as high risk, we provide support and advice on how to prevent or mitigate the risks. However, the number of occurrences of human rights violations (incidents) was zero.
  After confirming the above (since FYE 3/2022), we have continued to conduct annual investigations to check whether any changes in business conditions and circumstances have occurred that affect the risk assessment, and for those entities where changes have been identified, we confirm whether additional controls have been implemented accordingly and provide support and advice for improvement if necessary.
• For new business projects, we have established internal procedures for new investment and financing projects in order to assess the risk of human rights violations and confirm whether or not any human rights issues exist.
  We maintained a coverage rate of 100% for the application of these internal procedures to new investment and financing projects in FYE 3/ 2022, FYE 3/2023 and FYE 3/2024.

(2) Human Rights Due Diligence Related to Supply Chains

• For existing supply chains, we identify important human rights issues to be prioritized and addressed, based on the various principles and external dialogues mentioned above, and conduct human rights due diligence using the following methods. In FYE 3/2023, we conducted desktop investigations (15 cases) and on-site investigations (additional investigations, 3 cases) regarding suppliers operating in specific countries or regions (parts of South America and Southeast Asia) where there is a high risk of human rights violations in the food industry, related to meat products. Furthermore, for the fiscal year ending March 2024, we expanded our investigation to suppliers in other high-risk industries, products, and regions that were identified through our mapping results. This includes suppliers across multiple industries and products such as vegetable oils, beverage ingredients, fruits, and grains, focusing primarily on countries and regions internationally recognized for high concerns of forced labor (including slave labor) and child labor. In total, 44 investigations were conducted (33 desktop investigations, 10 local peripheral investigations, and 1 direct site visit). Additionally, part of the investigation also included indirect suppliers beyond the secondary level. (No facts were found as a result of these investigations that would lead to a real suspicion of forced labor or child labor. The investigations were conducted in collaboration with an independent third-party specialist investigative body.)

  

• For new supply chains, we conduct checks on suppliers with whom we plan to start doing business (limited to certain high-risk sectors, products, and geographies) using specialist external databases, to confirm that they have not been designated as subject to human rights sanctions and that there have been no adverse media indicating significant human rights risks or incidents involving violations of human rights (these checks commenced at the beginning of FYE 3/2024). Going forward, we will consider the phased expansion of the sectors, products, and geographies covered by these checks.

Identification of Salient Human Rights Issues Specific to the Business

The Marubeni Group recognizes that forced labor (including slave labor) and child labor in its supply chain are salient human rights issues for its business. To address these issues, we conduct investigations and engage with stakeholders, including all employees and executives of the Marubeni Group, suppliers, and NGOs, to identify and address any concerns which may arise.

Development of Grievance Mechanism (Redress)

In FYE 3/2021, in line with our Basic Policy on Human Rights, we instituted an internal process that serves as a grievance mechanism for complaints relating to human rights (redress).
This is a formal mechanism that guarantees confidentiality and anonymity, and is available to and covers complaints about human rights violations from any stakeholders.
(A dedicated contact point for submission of complaints about human rights violations is also available on our website.)

Disclosure of Incidents of Human Rights Violations

In FYE 3/2021, FYE 3/2022, FYE 3/2023 and FYE 3/2024, no incidents of human rights violations in our business were reported.

Risks to Human Rights in the Supply Chain

Marubeni has established a Basic Supply Chain Sustainability Policy, which includes respect for human rights. We continue to work towards obtaining the understanding and cooperation of business partners.

Basic Supply Chain Sustainability Policy

Slavery and Human Trafficking Statement

Since the UK Modern Slavery Act came into force in October 2015, several Group companies (including corporate subsidiaries) that operate within the UK, as well as Marubeni Corporation, issue a statement each fiscal year.

FYE 3/2024 Slavery and Human Trafficking Statement[248KB]

FYE 3/2023 Slavery and Human Trafficking Statement[238KB]

FYE 3/2022 Slavery and Human Trafficking Statement[266KB]

FYE 3/2021 Slavery and Human Trafficking Statement[578KB]

FYE 3/2020 Slavery and Human Trafficking Statement[609KB]

FYE 3/2019 Slavery and Human Trafficking Statement[184KB]

FYE 3/2018 Slavery and Human Trafficking Statement[167KB]

FYE 3/2017 Slavery and Human Trafficking Statement[38KB]

FYE 3/2016 Slavery and Human Trafficking Statement[154KB]

Annual Report on Fighting Against Forced Labour and Child Labour

Since Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force in January 2024, several Group companies (including corporate subsidiaries) that operate within Canada, as well as Marubeni Corporation, issue an annual report each fiscal year.

FYE 3/2024 Annual Report on Fighting Against Forced Labour and Child Labour [265KB]

Compliance Manual

The first item in the Compliance Manual is “respect human rights and refrain from any form of discrimination, harassment and the like.” We support and respect all international rules on human rights, including the UN’s International Bill of Human Rights (Universal Declaration of Human Rights and International Covenant on Human Rights), the ILO’s Declaration on Fundamental Principles and Rights at Work^*5 and the 10 Principles of the UN Global Compact.

• The International Labor Organization founded fundamental principles and rights at work. The fundamental principles and rights are comprised of 10 conventions in 5 categories, namely: (a) freedom of association and the effective recognition of the right to collective bargaining; (b) the elimination of all forms of forced or compulsory labor; (c) the effective abolition of child labor; (d) the elimination of discrimination in respect of employment and occupation; and (e) a safe and healthy working environment.

Compliance Manual[12.4MB]

Marubeni Hotline _{(formerly, “Door of Courage”)}

For cases where circumstances warrant counseling and reporting to be carried out outside the regular reporting channels, the Marubeni Group has established the Marubeni Hotline _{(formerly, “Door of Courage”)} reporting and consultation hotline.

Compliance

Respect for Employees’ Right to Unionize and Bargain Collectively

Marubeni has declared its support for the 10 principles of the UN Global Compact, which calls for the support and practice of universal principles concerning human rights, labor, and other areas. Accordingly, Marubeni respects the right of employees to unionize and bargain collectively for the purpose of conducting negotiations between labor and management on working conditions, wage levels, and other matters.

Relationship with the Labor Union

Initiatives to Address Human Rights Issues

Human Rights and Discrimination Issues Committee

This committee (established in 1981) is chaired by the Chief Administrative Officer (CAO), and its members comprise the general managers of the corporate staff group and business groups, as well as the general managers of the domestic branches.

Selection of Officers for the Promotion of Fair Recruitment and Human Rights Awareness

At the Tokyo Head Office and the Osaka branch, Officers for the Promotion of Fair Recruitment and Human Rights Awareness are nominated and notification of their appointment is made. In this way, the company has established fair recruitment systems.

Human Rights Awareness and Training

In order to deepen understanding of respect for human rights, Marubeni holds webinars for executives and employees, as well as training programs for newly appointed executive officers, department general managers, section general managers, mid-career hires, and new graduates.
In particular, training for executives and managers includes lectures on respect for human rights and the prohibition of discrimination, sexual harassment, and work-related harassment, using real examples to draw attention to the importance of these issues and prevent such incidents from occurring. We will continue to implement this training every year, updating the contents as appropriate.
We conduct Overseas HR Management and Compliance Training for all employees who are scheduled to be stationed overseas, with the objective of learning how to prevent and deal with discrimination, bullying, harassment, etc. in their overseas locations.
In addition, through activities such as publishing our basic policies and training materials on human rights issues on the company intranet, and internal competitions to create slogans related to human rights, we continue to raise awareness among employees.

Concerning Our Group’s Initiatives to Respect Human Rights, and Claims Appearing in Certain Reports

The Marubeni Group has adopted the “Marubeni Group Basic Policy on Human Rights,” which lays out our commitment to respect the human rights of our stakeholders and address negative impacts that may arise from our business activities.
Our Group is aware of various reports and media coverage expressing concerns about human rights issues in the Xinjiang Uyghur Autonomous Region (XUAR) of China. Certain reports contain passages seeming to imply that our Group companies handle steel products made in XUAR, where human rights violations are a concern, leading some ESG rating agencies to report that our Group may be complicit in human rights violations.
However, our Group does not handle steel products made in the said region and has no involvement whatsoever.

Human Rights Training and Capacity Building for Group Company Employees

Marubeni seeks understanding of the Head Office’s efforts and provides training and capacity building opportunities with external human rights experts for Group companies involved in business in industry sectors, products, and regions that may be relevant to salient human rights issues, such as forced labor (including slave labor) and child labor.
In the fiscal year ending March 31, 2024, we held dialogues and engagements with Group companies that have both international procurement networks (in the nature of Buyer) and sales networks (in the nature of Seller) in apparel-related businesses, and as one of our joint efforts to ensure respect for human rights, we conducted the above training and capacity building.
A total of more than 170 participants learned about basic knowledge on human rights, international trends in business and human rights, accident cases, examples of advanced corporate initiatives, and the importance of dialogue and collaboration with customers and suppliers (stakeholder engagement).

The Human Rights Due Diligence Working Group

The Marubeni Group has declared its support for the UN Global Compact, the principles of which include support and respect for human rights.
Furthermore, we participate in the theme-based working groups of the Global Compact Network Japan. Through the Human Rights Due Diligence Working Group, we study due diligence best practices for preventing human rights violations and apply these in initiatives for ensuring respect for human rights within the Company and throughout our supply chain.

The Annual UN Forum on Business and Human Rights

Marubeni participates in the annual UN Forum on Business and Human Rights, and strives to share our experience and grasp the latest trends for promoting respect for human rights among corporations, based on the UN’s Guiding Principles on Business and Human Rights.