1. Human Rights Due Diligence at the Toyo Tanso Group

2. Governance and Due Diligence Framework

At Toyo Tanso, the human rights due diligence process is led by its Human Rights Working Group, established under the People and Organizational Vitalization Group, one of three groups within the Sustainability Committee, under the supervision of the Board of Directors. The Working Group labors in tandem with human rights officers appointed from each of the departments in the company to promote the process. Significant human rights risks are also shared with the Risk & Compliance Committee and incorporated into groupwide risk management.

3. Human Rights Risk Surveys

Toyo Tanso conducts human rights risk surveys to identify human rights risks within the Group. These surveys are formulated in reference to the UN Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the Japanese Ministry of Justice Human Rights Bureau Areas of Human Rights to be Respected by Companies, and similar guidelines.

●Human Rights Risk Surveys Conducted in 2024

• 1. Scope of Coverage

  All Toyo Tanso Co., Ltd. business sites in Japan

• 2. Survey Method

  (1) Questionnaire to ascertain systemic conditions

  Toyo Tanso conducted a questionnaire survey of relevant departments to identify ways in which our human rights-related systems should be improved and to ascertain the status of activities designed to prevent human rights violations.

  (2) Questionnaire to ascertain situation for employees

  All employees were anonymously surveyed about the occurrence of human rights violations, workplace safety conditions, and similar issues.

  (3) Employee interviews

  Based on the responses to the questionnaire distributed in (2) above, a sample of employees from a sampling of departments were interviewed by outside experts to confirm the validity of the survey results and verify the possibility of human rights violations that could be inferred from the survey findings.

4. Assessing and Identifying Human Rights Risks

We assessed and identified risks for each human rights risk area based on the human rights risk survey. Risk is assessed in terms of two components: severity and probability. Severity is further assessed from three perspectives: degree of violation, scope, and reparability. Probability is further assessed from two perspectives: likelihood/potential and preventive measures. Our evaluation process includes outside experts to ensure that risks are objectively assessed and identified. The surveys we conducted identified the following human rights risks.

5. Preventing and Mitigating Human Rights Risks

We will expand our efforts to prevent and mitigate identified human rights risks to include the entire Toyo Tanso Group, beginning with measures that can be immediately deployed.

• (1) Understanding/instilling human rights policy

  In order to help all employees understand the intention and content of our efforts to respect human rights and create a workplace free of human rights violations, it is essential that our human rights policy, which is the foundation of these efforts, is instilled as part of our corporate culture. For this reason, we regularly explain our human rights policy to employees and provide them with training to ensure that all employees know and understand the policy contents. We focus particularly on making plain our human rights policy to newly hired employees during their orientation training.

• (2) Understanding/instilling whistleblowing system

  Some employees may not understand how to use the whistleblowing system or fear negative repercussions if they utilize the system. We therefore strive to dispel concerns by providing employees with a proper understanding of how the whistleblowing system works and how to use it, so that our employees are able to consult with hotline staff without concern.

• (3) Treatment of non-fulltime employees

  Although we have not faced any systemic issues related to wages or other aspects of the actual treatment of non-fulltime employees, we continually review how these employees are treated in practice to ensure the tenet of equal pay for equal work, including the balance between work content and wages. If any issues are identified, we work to improve the situation.

• (4) Preventing harassment

  Training on various types of harassment and discrimination has been, and will continue to be, provided to all employees. As an area for improvement in the future, we have found that there are cases where it is difficult for employees to distinguish between what is and what is not deemed harassment in the context of power or sexual harassment. We are therefore focused on improving our training program to include specific examples of harassment to clarify this matter for employees.

• (5) Ensuring safety in the workplace

  In our factories, warehouses, and transportation-related workplaces, we continually work to identify dangers and conduct improvement and hazard avoidance activities. Information on hazards and improvements related to specific departments are shared widely within the Group to alert other departments and help them in implementing safety measures.

• (6) Responding to climate change and instilling awareness within the Group

  We continue to conduct in-house training on climate change responses to ensure that awareness of this issue is deeply instilled within the Group. We are also working on formulating more detailed plans for initiatives to reduce GHG emissions so that employees are able to consider and work on these initiatives by incorporating them into their own tasks.

6. Monitoring and Disclosing Information

We conduct annual employee satisfaction surveys to ascertain the opinions of our employees and their situations in the workplace. Our Human Rights Working Group monitors progress on actions to address human rights risks through correction and prevention and reports its findings to the Sustainability Committee. In addition, we plan to conduct human rights risk status surveys approximately every three years on each survey area, monitoring the effectiveness of preventive and corrective measures taken to address human rights risks.
The content of these reports will be disclosed externally on our website or in our Integrated Report.