Respect for Human Rights

Toyo Seikan Group Human Rights Policy

The Toyo Seikan Group’s Management Philosophy, which was 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 throughout our business operations is a prerequisite for all endeavors to accomplish the intention of the management philosophy.
We have now formulated the Toyo Seikan Group Human Rights Policy (the “Policy”), which serves as a guide for us to drive our commitment to respecting human rights and to fulfill our responsibility, in accordance with the United Nations Guiding Principles on Business and Human Rights.
At the same time, however, we admit that we cannot completely eliminate the risk of adverse impacts that business activities may have on human rights. With this fact in mind, we will seriously address this issue to ensure greater respect for human rights.

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

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

The Process of Formulating a Human Rights Policy

In order to narrow down the focus areas for the formulation of our human rights 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 conducted quantitative impact assessments by business domains and countries upon 10 human rights issues that are closely related to our business. As a result, we identified that risks in the industry where the Toyo Seikan Group operates were generally at a medium to low level, and the highest priorities among the potential human rights issues were identified as "occupational health and safety," "fair wages and working hours," and "rights of indigenous peoples" in the "packaging industry" and "iron and steel production industry".

Furthermore, we conducted surveys mainly by interviewing related parties within the Group to identify the potential human rights issues in the supply chain as well as stakeholders closely related to the issues. As a result, we found that there could be concerns related to "occupational health and safety," "fair wages and working hours," and "rights of indigenous peoples" throughout the supply chain. In addition, in the areas of "procurement" and "manufacturing", the importance of addressing "occupational health and safety," "fair wages and working hours," and "rights of indigenous peoples" was emphasized. Stakeholders that are generally considered to be potentially impacted by the food industry include "workers" and "indigenous communities and local residents".
Each company within the Toyo Seikan Group will conduct impact analysis and evaluation on human rights and translate them into specific initiatives.

Major Human Rights Risks in the 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." and "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 are as follows:

    • 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 (unpaid wages, fair wages above the statutory minimum wage)
    • 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" with the aim of conducting sustainability management across the group. Starting from the fiscal year 2023, subcommittees have been established for each ESG (environment, social, governance) category, one of which includes Human Rights and DE&I (Diversity, Equity, and Inclusion) Subcommittee to coordinate activities related to human rights and DE&I across the departments and group companies as the central axis, in order to promote sustainability-related activities. The Human Rights and DE&I Subcommittee held two meetings in the fiscal year 2023.

* The table can be scrolled left or right.

Activities of Toyo Seikan Group

Education on Human Rights Issues for Deeper Understanding

e-Learning on Human Rights

To improve understanding of human rights issues, all employees in the Group are provided with opportunities to learn about the Toyo Seikan Group Code of Conduct, which prohibit any discrimination, harassment or abuse.
For the three years from fiscal 2019, the program was attended by a total of 5,806 members, who learned about the relationship 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 year 2022, the Toyo Seikan Group created its own e-learning materials and conducted training sessions in order to deepen understanding of the Group's human rights policy and issues related to foreign workers in the Group.
In fiscal year 2023, we held an e-learning session on "Taking Care of People" (produced by the Asia-Pacific Human Rights Information Center (HURIGHTS OSAKA)) for 4,599 directors and employees (99% completion rate).
We will continue to engage in human rights education to ensure that respect for human rights becomes an integral part of our corporate culture.

Group companies joining the program

  • Toyo Seikan Group Holdings
    • Tokan Trading Corporation
    • Tokan Kyoei Kaisha
  • Toyo Seikan
    • Honshu Seikan
    • Nippon National Seikan
    • Ryukyu Seikan Kaisha
    • Toyo Seihan
    • Fukuoka Packing
    • Japan Bottled Water
    • Toyo Seikan Group Engineering
    • TM Pack
    • TOYO PACK KIYAMA Co., Ltd.
    • Toyo Mebius
  • Toyo Kohan
    • KOHAN SHOJI
    • TOYO PACKS
    • KYODO KAIUN
    • TOYO PARTNER
    • KOHAN KOGYO
    • Fuji Technica & Miyazu
    • Kudamatsu Unyu
  • Tokan Kogyo
    • Nippon Tokan Package
    • Tokan Kosan
    • Tokan Takayama
    • Tokan Logitech
    • Sunnap
    • Shosando
  • Nippon Closures
    • Shin-Sankyo-Pd.
  • Mebius Packaging
  • TOYO GLASS
    • TOYO - SASAKI GLASS
    • Toyo Glass Machinery
    • TOHOKU KEISYA
    • TOSHO GLASS
    • TOYO GLASS LOGISTICS
    • ICHINOSE-TRADING
  • Toyo Aerosol Industry
  • TOMATEC

Utilization of Information Sharing Platforms in the Supply Chain

For sustainable growth of a company, it is crucial to manage environmental and social risks throughout the entire value chain. The Toyo Seikan Group utilizes sustainability information sharing platforms (Sedex*1, EcoVadis*2) to disclose sustainability-related information.
We also use Sedex as a tool for the group’s risk assessment to conduct self-checks. In the fiscal year 2024, it was implemented across 21 group companies and 62 business sites. No serious human rights violations such as child labor and forced labor were found through the risk evaluation.

  • Sedex is a London-based non-profit organization to promote ethical and responsible business practices in the global supply chain. It conducts surveys by questionnaire on labor, health and safety, environment, and business ethics and publishes the results on its web platform.
  • EcoVadis is a French company aimed at improving environmental and social sustainability performance of suppliers and vendors. It provides ratings in four themes: environment, labor and human rights, ethics, and sustainable procurement.

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 were 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.

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 specifically regarding the following items. In addition, it was concluded that many of the interviewed employees are satisfied with their working environment.

Employment Contracts Existence of Discrepancies in Working Conditions
Wage-related Matters Existence of Calculation of Working Hours on a Minute-by-Minute Basis
Working Hours Validity of Locations of Time Recorders
Overtime Work Existence of Constant Overtime Work
Employment Regulations Existence of Punitive Provisions such as Salary Reduction
Exercise of Rights Existence of Grievance Handling Channels
Living Environment
    • Installation of Room Locks and Valuables Boxes
    • Installation of Fire Extinguishers
    • Implementation of Emergency Reporting Drills
    • Appropriateness of the Burden of Housing Expenses
    • Existence of Cost Burden Prior to the Arrival of Japan
Understanding of the Situation Understanding of the Working Environment and Living Environment
Harassment Existence of Behavior to Incite Fears
Debt Bondage Existence of Borrowed Money
Discrimination Existence of Discrimination Based on Pre-Travel Pregnancy Tests, etc.

Future Actions/Responses

Through these fact-finding surveys, we have identified human rights and labor-related audit points and proceeds reviews on the key checking items to be implemented in each company. Furthermore, we aim to establish a framework in which each company can voluntarily implement the PDCA (Plan-Do-Check-Act) cycle of human rights due diligence.

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 called "Engagement and Remedy Platform". Through this platform, the Toyo Seikan Group accepts grievances and reports related to human rights from all stakeholders, including those in the value chain.
It is ensured that no disadvantages are imposed on whistleblowers regarding the reported cases, and it is also strived to protect the privacy of whistleblowers and maintain confidentiality. Additionally, the results and progress of the redress of grievance are disclosed in a format that ensures anonymity through JaCER's “List of Grievance Redress Cases”.

Human Rights in Labor-Management Relations

The Toyo Seikan Group is actively working on sharing information and discussing solutions to various issues with the labor union. Some of the group companies have organized labor unions, and the union membership rate is 51.9% across all consolidated subsidiaries.
At labor-management meetings, we actively discuss various themes, such as work style reform, health and safety, and welfare, to build and maintain sound labor-management relations through communication among management, the union and employees.