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Respect for Human Rights

Toyo Seikan Group Human Rights Policy

The Toyo Seikan Group’s Management Philosophy, launched in 2016, states that the Group will aspire to achieve a sustainable society and contribute as a group to people’s happiness. We understand that respect for human rights across our business activities is a prerequisite for realizing this philosophy.
Accordingly, we have formulated the Toyo Seikan Group Human Rights Policy (the “Policy”) as our guide to promote respect for human rights and to fulfill our responsibility. The policy is in accordance with the United Nations Guiding Principles on Business and Human Rights.
In preparing the Policy, we conducted a “quantitative survey on human rights issues” based on the human rights risk database of Verisk Maplecroft, a global risk assessment and analysis firm. We performed quantitative impact assessments by business domains and by countries across ten human rights issues closely related to our operations. As a result, we confirmed that the industry risk levels in the business domains in which the Toyo Seikan Group operates are generally medium to low. In addition, we conducted surveys—mainly interviews with stakeholders within the Group—to identify potential human rights issues in the supply chain and stakeholders closely related to those issues, and used the findings to formulate the Policy.
At the same time, however, we acknowledge that it is not possible to completely eliminate the risk that our business activities may have adverse impacts on human rights. With this understanding, we will earnestly address such issues and work to ensure greater respect for human rights.
Each company within the Toyo Seikan Group will conduct impact analysis and evaluation on human rights and translate them into specific initiatives.

Toyo Seikan Group Human Rights Policy

1.  Scope of Application

The Policy applies to all directors, auditors, officers and employees working within the Group. We also expect all business partners who are associated with the Group’s products, systems and services to comply with the Policy.

2.  Basic Perspective

We promote our commitment to respecting human rights based on the United Nations Guiding Principles on Business and Human Rights, with our support and high regard for the following international rules and agreements related to human rights.

  • The United Nations International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Covenant on Civil and Political Rights)
  • The International Labour Organization’s Declaration on Fundamental Principles and Rights at Work
  • The United Nations Declaration on the Rights of Indigenous Peoples

3.  Responsibility to Respect Human Rights

We will not infringe on the human rights of those affected by our business activities, and if an adverse human rights impact occurs through our operations, we will take appropriate action to remedy the situation. This is the way we fulfill our responsibility to respect human rights and build a responsible supply chain.

4.  Human Rights Due Diligence

We establish a human rights due diligence process to identify, prevent and mitigate actual or potential adverse impacts on human rights.

5.  Communication and Consultation

While implementing the Policy, we have honest communication and consultation with our stakeholders, drawing on independent external expertise in human rights.

6.  Education and Training

We provide appropriate education and training so that the Policy is embedded throughout our business operations and effectively implemented across the Group.

7.  Remediation

If our own activities cause adverse human rights impacts, or if it becomes clear that we are involved with adverse human rights impacts through our business relationships, we will provide remedies to redress the harm through communication and appropriate procedures based on international standards.

8.  Director in Charge of Policy Implementation

We officially designate a director in charge of the Policy implementation and oversee the progress of the implementation.

9.  Disclosure

We disclose the information on the progress and results of our human rights-related activities on our website and through other media.

10.  Applicable Laws

We comply with laws and regulations of countries and regions where we operate. If there is any conflict between internationally recognized human rights and laws and regulations of a country or region, we will seek ways to honor international human rights principles to the greatest extent possible.

Toyo Seikan Group Human Rights Policy

Japanese, Thai and Chinese versions are also available for employees of foreign group companies to understand and comply with the Human Rights Policy.

Major Human Rights Risks in Toyo Seikan Group

The Toyo Seikan Group's Code of Conduct explicitly states: "We will understand and respect the laws and regulations of the countries where we do business and international standards for human rights and will never violate human rights in every aspect of our business." It further states: "We promise to understand the Toyo Seikan Group Human Rights Policy and to always pay attention to whether or not we negatively impact human rights in all the business activities we are engaged in."
The typical human rights risks recognized by the Toyo Seikan Group include the following:

    • Forced labor
    • Child labor
    • Freedom of association and the right to collective bargaining
    • Any form of discrimination in employment and occupation
    • Safe and healthy working conditions
    • Wages (preventing unpaid wages, ensuring fair wages above the legal minimum wage, and promoting equal pay for equal work)
    • Proper working hours
    • Human rights in the supply chain
    • Rights of foreign workers
    • Human rights of indigenous peoples and local communities

Promotion Structure

The Toyo Seikan Group has established the "Group Sustainability Committee" to promote sustainability management across the group. 
From fiscal year 2023, the Group set up subcommittees for each element of ESG (Environment, Social, Governance). One of these is the Human Rights and DE&I (Diversity, Equity, and Inclusion) Subcommittee which serves as the central coordinating body to address social issues such as human rights promotion and DE&I.  Through this Subcommittee, departments and Group companies collaborate across organizational boundaries to promote sustainability-related activities. The Human Rights and DE&I Subcommittee held two meetings in each of fiscal year 2023 and 2024.

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Activities of Toyo Seikan Group

Group Level Human Rights Due Diligence

Risk assessment using supplier platforms

Using Sedex, we conducted risk self-assessments at 82 sites across all 39 domestic consolidated Group companies (excluding Toyo Seikan Group Holdings). As a result of the risk assessment, No cases of serious human rights violations, such as child labor or forced labor, were identified. 

The Survey on the Actual Situation of Foreign Workers

With the increase in the employment of foreign workers, the Toyo Seikan Group further recognizes the importance of respecting their human rights as well as providing them with a comfortable working environment. 
As a part of these efforts, surveys have been conducted at some business sites where foreign workers are working, in collaboration with designated third-party investigators (ASSC*) to have document reviews, on-site inspections of factory premises, and interviews with workers. Through the thorough examine of labor contracts, wages, working hours, and living conditions, we strived to identify the issues and corrective actions to be taken.

  • ASSC (The Global Alliance for Sustainable Supply Chain) is a non-governmental organization that provides support to companies in addressing expected social issues from a sustainability perspective.

Dates of Surveys

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Year Date Survey destination
FY2022 March 1, 2023 Mebius Packaging Ibaraki Factory
FY2023 April 28, 2023 Toyo Aerosol Industry Mie Factory
February 20, 2024 Tokan Kogyo Komaki Factory
February 21, 2024 Japan Bottled Water
FY2024 March 12, 2025 Nippon Closures Ishioka Factory

Summary and Process of a Fact-finding Investigation

Document Review Confirmation of documents such as employment regulations, employment contracts, payroll statements, and attendance records. Comparison with conventions and guidelines of International Labour Organization (ILO) to investigate the actual situation regarding long working hours, forced labor, harassment, and other issues
On-site Factory Inspection Confirmation of Occupational Health and Safety, Evacuation Routes, and Notices on Board
On-site Dormitory Facilities Inspection Conducted at the sites where dormitory facilities are set up
Worker Interviews Interviewing Workers, with the assistance of an interpreter, regarding their employment history, reasons for working in Japan, Japanese language proficiency level, current income, shifts, holidays, utilization of paid leave, housing, transportation, and other related topics.

Main Investigation Items and Checking Contents

Through the investigation, we received feedback on the following items in particular. In addition, many of the interviewed employees reported being satisfied with their working environment.

Employment Contracts Discrepancies in working conditions
Wage-related Matters Minute-by-minute calculation of working hours
Working Hours Placement of time recorders
Overtime Work Persistent excessive overtime
Employment Regulations Punitive provisions (e.g., salary reductions)
Exercise of Rights Grievance mechanisms
Living Environment
    • Room locks and valuables boxes
    • Fire extinguishers installed
    • Emergency reporting drills
    • Appropriateness of housing cost burden
    • Pre-arrival cost burden
Understanding of the Situation Understanding of working and living conditions
Harassment Intimidation (behaviors intended to intimidate)
Debt Bondage Worker debt (personal loans)
Discrimination Discrimination (e.g., pre‑travel pregnancy tests)

Supply‑chain human rights due diligence

Managing environmental and social risks across the entire value chain is essential for sustainable corporate growth. The Toyo Seikan Group discloses sustainability information using supplier sustainability platforms such as Sedex and EcoVadis*.

  • EcoVadis is a France‑based company established to support improvement of suppliers’ environmental and social sustainability performance. It evaluates companies across four themes: environment; labor practices and human rights; ethics; and sustainable procurement.

Supplier CSR Guidelines Self-Assessment (SAQ)

In addition to incorporating each item of "Toyo Seikan Group Procurement Policy" into the Group's common basic transaction agreement, we have also established the "Supplier CSR Guidelines," which outline the importance of CSR in the supply chain, our Group's approach to CSR, and the basic matters we expect our business partners to observe (compliance, quality and safety, human rights, occupational health and safety, the environment, and information management).We confirm that business partners of each operating company within the Group agree to the guidelines, and we also ask them to cooperate with us in completing a self-assessment questionnaire (SAQ), which serves as a communication tool to ensure compliance.
In fiscal 2025, we sent the common SAQ developed by GCNJ to 774 suppliers of 10 major Group companies and received responses from 588. We sent feedback sheets to all respondents and discussed current conditions and future improvements in the priority areas of human rights and labor with some suppliers.

Participation in the Supply‑chain Working Group of the Global Compact Network Japan

The Toyo Seikan Group became a signatory to the United Nations Global Compact (UNGC) and is a member of the Global Compact Network Japan (GCNJ). We participate in various GCNJ working groups, including the supply‑chain working group, through which we collaborate with other participating companies to promote sustainable procurement across supply chains.

Education on Human Rights Issues for Deeper Understanding

e-Learning on Human Rights

Toyo Seikan Group promotes understanding of human rights issues through activities to raise awareness of the Toyo Seikan Group Code of Conduct, which prohibits all forms of discrimination and harassment, among all employees of the group both in Japan and overseas.
As part of our human rights awareness activities, we have been providing e-learning materials on business and human rights, "Cherish People: Essential e-Learning Edition" (produced by the Asia-Pacific Human Rights Information Center (HuRights Osaka) and Amnesty International Japan), with a total of 5,806 people taking the course over the three years from fiscal 2019 to fiscal 2021. They have learned about the connection between business activities and human rights, as well as international norms such as the Universal Declaration of Human Rights and the Guiding Principles on Business and Human Rights.
In fiscal 2022, we created our own e-learning materials and conducted study sessions to promote understanding of Toyo Seikan Group 's human rights policy and issues facing foreign workers at the company.
In fiscal 2023, we provided 4,599 executives and employees with the Business and Human Rights e-learning material, "Cherish People" e-learning version (produced by the Asia-Pacific Human Rights Information Center [HuRights Osaka]), with a completion rate of 99%. In fiscal 2024, we provided e-learning using materials based on the United Nations Guiding Principles on Business and Human Rights and other standards at all 41 applicable Group companies in Japan. We also provided similar e-learning at 14 overseas Group companies, primarily in Thailand and Malaysia. In FY2025, the program was conducted at 26 overseas Group companies. Including those that had already provided the training by FY2025, all consolidated companies have now conducted internal education on human rights.
We will continue to foster a culture of respect for human rights within the Group by diversifying our training materials and methods beyond e-learning.

Access to Remedies

The Toyo Seikan Group is a member of Japan Center for Engagement and Remedy on Business and Human Rights (JaCER), which provides a non-judicial platform for grievance redress known as the "Engagement and Remedy Platform". Utilizing this platform, the Group addresses grievances and reports related to human rights from all stakeholders, including those in the value chain.
Reports through the platform can be made in Japanese, English, or other languages and submitted anonymously.
We ensure that no disadvantages are imposed on whistleblowers will not be disadvantaged as a result of reporting, and we strive to protect the privacy of whistleblowers and maintain confidentiality. In addition, we disclose responses and progress of the redress on grievance in a format that ensures anonymity through JaCER's “List of Grievance Redress Cases”.

JaCER Grievance Form

Human Rights in Labor-Management Relations

At the Toyo Seikan Group, we actively engage in information sharing with labor unions and hold discussions with labor and management working as one to solve various issues related to our corporate activities. Labor unions are organized in some group companies (the union membership rate across the entire consolidated group is 47.6% as of March 31, 2026).
Specifically, we conduct proactive labor-management consultations on themes such as “work style reforms,” “health and safety,” and “welfare,” striving to build and maintain healthy labor-management relations through communication among management, labor unions, and employees.