Response to Modern Slavery and Human Trafficking

ITOCHU is committed to initiatives to ensure that there is no modern slavery or human trafficking in our supply chain and business activities. We are participating in the United Nations Global Compact. Together with this, we are reflecting the concept of the United Nations Guiding Principles on Business and Human Rights in our business activities. Our existing principles contain initiatives to ensure that modern slavery and human trafficking do not occur in our sales activities and supply chain across the world.

Refer to：Status of Initiatives at ITOCHU Europe PLC. (Slavery and Human Trafficking Statement)

Consideration for Foreigners

If foreign workers, interns and trainees are accepted in our supply chain, we pay full attention so that we comply with the labor related laws and ordinances in the country concerned and so that we do not commit acts contrary to the purpose of that acceptance system. We do this from the point of view of respect for human rights and relief because such people are liable to become the target of illegal acts due to their low social and economic status.

Respect for the Rights of Children

ITOCHU supports the United Nations Convention on the Rights of the Child and Children's Rights and Business Principles. We respect the four pillars of the United Nations Convention on the Rights of the Child - a child's right to life, development, protection and participation.

ITOCHU has adopted the development of the future generation as one of the ITOCHU Group Basic Activity Guidelines on Social Contribution. We perform activities to support the healthy development of the young people who will be responsible for the future generation.

Refer to：Growth of Future Generations

Policy on the Use of Security Guards

In order to ensure the safety of our business operations in various parts of the world, ITOCHU uses security personnel. When necessary, we may employ armed security personnel. We are aware of the potential risk of human rights violations that may accompany the handling of weapons, and employ personnel in each country based not only on adherence to local law but also on international standards.^*

• United Nations Global Compact, Voluntary Principles on Security and Human Rights, Code of Conduct for Law Enforcement Officials, Basic Principles on the Use of Force and Firearms by Law Enforcement Officials, etc.

Respect for the Rights of Indigenous People

We recognize that indigenous people have their own culture and history when we conduct business activities in regions where indigenous people live as part of our commitment to respect human rights. We respect and take into consideration the rights of indigenous people established in the laws of the countries and regions where we perform our business activities and international agreements (e.g., the Declaration on the Rights of Indigenous Peoples and the International Labour Organization (ILO) Convention 169). When examining new business investment projects, we also strictly enforce prior checks concerning the impact on the rights of indigenous people by that business.

Job Creation and Employment Concept

The ITOCHU Group works to make local contributions by local hiring during the diverse business activities we engage in around the world. We strive for coexistence with the local regions in which we operate and to contribute to the development of international society. We comply with the statutory minimum wage and strive to pay at least a living wage when we hire local employees. Doing so leads to human resource development in the region and helps stimulate local economies. Moreover, we believe this contributes to sustainable development. When an ITOCHU Group company in Japan or overseas engages in business activities in a particular region, as the parent company, ITOCHU supports to formation of a management structure for ensuring that the company complies with relevant laws and provides an optimal labor environment for its employees. (Group companies report to division companies based on their operating domain and the division company provides direct support.) The ITOCHU Group is comprised of some 300 companies in Japan and overseas, and works to balance business and regional development by hiring and training local staff.

Policy on Decommissioning of Mining Operations

Mining projects can have adverse impacts on the environment and society in the area where the development is to take place, including water, air, land and soil, landscape, and local residents. We believe it is important to minimize any effects on the environment and society, including biodiversity and human rights. It is therefore important to have a long-term plan in advance that takes into account the impacts during the project study and development stage, the operational stage, and also after the mine decommissioning and closure in the future. When decommissioning mining operations, the ITOCHU Group undertakes appropriate measures based on laws and regulations as well as a mine decommissioning plan. In our mineral resource development and operational business, we have prepared Environment, Health, Safety (EHS) guidelines based on international standards such as the International Finance Corporation (IFC)’s Environment, Health, Safety (EHS) guidelines. In accordance with these guidelines, we have developed a rehabilitation and mine closure plan that takes various stakeholders into account, and we undertake long-term monitoring after closure to minimize the negative impacts of mining business and maximize social benefits.

Oaky Creek Coal Mine Rehabilitation

Depression from Mine Development

Completed Rehabilitation

Through ITOCHU Minerals & Energy of Australia Pty Ltd, our wholly owned subsidiary, we are participating in the active Oaky Creek coking coal mine in Queensland, Australia. The Oaky Creek project has developed a rehabilitation plan for the mine area in advance of its closure based on the decommissioning policy mentioned above and reviewed and assessed by experts for environmental and social impacts that might occur prior to or after the mine closure. Decommissioning and rehabilitation costs are periodically re-evaluated and reflected in the business plan. By conducting rehabilitation according to the closure plan, the project prevents soil and water pollution, promotes the restoration of the ecosystem, and ensures the health and safety of local residents.

For example, pits created by coal mining are backfilled using topsoil excavated during the mining process, and are then rehabilitated back to a level suitable for final land use. It is also important to conduct appropriate management of wastewater quality to prevent water pollution caused by chemical residues. In addition, appropriate management for waterway are taken. Regarding underground mining areas, detailed geological surveys are undertaken at the time of decommissioning, and measures are undertaken to prevent land subsidence and manage mine affected water.
After decommissioning, coal-washing equipment, pipelines, conveyor belts, and other surface equipment are completely removed, and ground-leveling operations are undertaken.

After backfilling and levelling are completed, planting begins. Following restoration, long-term monitoring is undertaken on land stability and plant growth.

Human Rights Due Diligence

The ITOCHU Group is fulfilling our responsibility to respect human rights based on The ITOCHU Group Human Rights Policy established in April 2019. Specifically, we continuously identify and assesses the negative impact from the corporate activities of the ITOCHU Group on human rights that may affect society. We then work to prevent and mitigate such impact by taking the appropriate steps. Therefore, following the procedures detailed in the UN Guiding Principles on Business and Human Rights, we establish a human rights due diligence mechanism to assess a wide range of human rights issues, including five core labor standards (Freedom of Association and Collective Bargaining, Forced Labor, Child Labor, Discrimination, Occupational Safety and Health) set out in “The ILO Declaration on Fundamental Principles and Rights at Work.” In addition, we disclose information on the progress and results of our action.

Human Rights Due Diligence Procedure

Supply Chain Management

For more details, please refer to Sustainability in the Value Chain (Structures and Systems） and Response to Suppliers in Violation of this Policy.

Risk Assessments

We conduct risk assessment on human rights including modern slavery and human trafficking. We do this through group company fact-finding surveys in which we visit sites together with external experts as appropriate. This is in addition to our supplier surveys in due diligence. We have also established policies and responses for procurement by product in regards to products with a significant impact on society and the global environment. This is an attempt to reduce the risks in our supply chain.

Refer to：Human Rights Audits in the Poultry Industry in Thailand

Grievance Mechanism

The ITOCHU Group has multiple points of contact for receiving concerns and complaints from stakeholders. In case that we are found to be involved in a negative impact on human rights, we take appropriate measures to remedy the situation.

Consultation Desk for Employees

We have established an employee consultation desk called 7830 (Nayami Zero) to respond to worries and consultations from each individual employee. We have also posted the HR Help Guide Book on the Intranet and have widely informed employees about the consultation desk. This means we have established a structure in which it is possible for employees to consult with us.

Hotline

In addition to a direct hotline to those responsible for compliance in each division, we have also established multiple whistleblowing contacts both in Japan and overseas (including external whistleblowing contacts that utilize specialized company and external lawyers). We accept reports from employees who have an employment relationship with ITOCHU, those who have been dispatched to ITOCHU under a worker dispatch contract from a company that has entered into that contract with ITOCHU (temporary employees), and employees of group companies. It prohibits the unfavorable treatment (e.g., retaliation) of whistleblowers and allows whistleblowers to provide information anonymously.

Flow When Received a Report by the Japanese External Report Reception Desk (Integrex Inc.)

ITOCHU Corporation applied for recognition under the Whistleblowing Compliance Management System (Phase 1: self-declaration of conformity), which was newly introduced by the Consumer Affairs Agency of Japan. Our conformity with certification standards was confirmed and our registration was accepted as of April 10, 2019 (first to be registered in this system in Japan).

Consultation Desk for the General Public (including Stakeholders)

ITOCHU Corporation has established a system to accept opinions, proposals, and grievances and to accept inquiries from the general public and all our stakeholders, as described below.

Refer to: Inquiries

Implementation of Fair Recruitment

Human resources are the greatest management resources for ITOCHU – a company deploying a variety of businesses globally. ITOCHU conducts activities to recruit those newly graduating from universities and graduate schools every year.

We also offer internships (work experience workshop) every year separate to our recruitment activities. The aim of these internships is to provide support to university and graduate school students in forming their careers. We provide opportunities to deepen knowledge about the business of trading companies and about working in a trading company.

ITOCHU recruits employees chiefly on the basis of their personal character. We recruit employees fairly and impartially without concern for their race, gender (including sexual minorities such as LGBTQs), religion, nationality, age or otherwise. We have provided human rights education with lecturers from the Tokyo Metropolitan Human Rights Promotion Center and have also reflected that content in our interviewer education. We have also established a watchdog system in which employees are selected and notified to serve as watchdogs to establish a fair recruitment screening system.

Training Programs

We raise awareness about the relationship between our corporate activities and human rights in our various internal training programs. We develop the mind to respect human rights that should be possessed as an ITOCHU person in our new employee training. For example, we hold training to acquire consideration for race, gender (including sexual minorities such as LGBTQs), religion, nationality and age from the basic concept of human rights and points of concern. We raise the problem of sexual harassment (including discriminatory behavior and harassment toward sexual orientation and gender identity) and abuse of authority in internal training aimed at organizational heads. We provide education and instruction for measures when harassment has actually occurred and when we have received reports of such. We strive to create an environment that does not allow harassment on a daily basis. Through these initiatives, we are aiming for a thorough understanding toward human rights. We are also striving to raise awareness in various regions by looking at consideration for human rights in our supply chain in pre-overseas assignment training. There were 1,402 participants in our human rights training in FYE 2024.

In addition to the above training, we provide opportunities for officers and employees of ITOCHU all over the world to learn about business and human rights with online general sustainability education.

Refer to: Sustainability Awareness Activities at ITOCHU

Sustainability Seminars

We have continued to hold internal seminars since FYE 2008 on human rights issues. The aim of this is to adopt insight and opinions from those outside the company. We made business and human rights (in the supply chain) a theme in FYE 2019. We then looked at the fact consideration for human rights is becoming even more important as a trend in society surrounding sustainability in FYE 2020 and FYE 2021.
We are continuing to conduct awareness activities for business and human rights. The purpose of these is to learn about the latest trends concerning corporate activities and human rights problems and to make use of that in our business as a general trading company which deploys various businesses across the world and which plays an important role in the supply chain.

Refer to: Seminar Details

Various Publications

We are endeavoring to raise awareness of human rights. The aim of this is to ensure that human rights violations do not occur in the workplace. We are doing this through various publications that we distribute to all our employees and publish on the Intranet.

• We convey our basic concept on respect for human rights through The ITOCHU Group Code of Ethical Conduct and The ITOCHU Group Human Rights Policy to all our employees.
• We call on our employees not to induce human rights violations in business in our compliance handbook. We do this by establishing pages on respect for human rights and harassment with concrete examples.
• We have described checkpoints in a handbook on communication with our suppliers. This is so that those in charge of surveys can understand the actual state of the management of human rights and labor practices in suppliers even more clearly and so that they can then offer advice on making improvements. This ensures that the supply chain sustainability survey mechanism functions. At the same time, we utilize this in keeping those in our company informed.

Countermeasures against Harassment

ITOCHU is raising awareness on the importance of making systems well-known and engaging in communication through organizational head training. We are doing this so that pregnant employees and employees persevering with their work while being engaged in childcare and nursing care can also contribute to their workplaces with a sense of their work being worthwhile. This is without employees in the workplace being subjected to abuse of authority or sexual harassment (including disadvantaging and harassing employees who are applicable to sexual minorities). Superiors encourage employees with restrictions due to balancing their work with childcare or nursing care to make use of the related systems appropriately. In addition to this, we are also ensuring employees are fully informed about the importance of reviewing work content, work division and work styles over the entire workplace. Furthermore, we have thoroughly established a workplace environment which does not allow discriminatory remarks relating to sexual orientation or gender identification and remarks made under unconscious assumptions of gender segregation. We have also established a consultation desk where employees can safely seek advice regarding harassment from both internal and external parties, including business partners and clients.
The following are clearly defined as prohibited acts in human rights violations under the work regulations: discrimination relating to work by race, gender, religion, creed, nationality, body, illness, age or any other irrational reason; sexual harassment (including discriminatory behavior and harassment relating to sexual orientation and gender identity); and workplace bullying. The regulations stipulate disciplinary action to be taken against such behavior.

In FYE 2024, we conducted “Harassment Prevention Training” targeting all manager level employees including those seconded from the company and assigned in overseas (approx. 1,800 individuals). During the training, there were lectures from experts on the causes and mechanism behind harassment and shared lessons learned from cases studies. We are striving for the elimination of any kind of harassment from all workplaces.

Human Rights Training for Ready-made Meal Manufacturers

FamilyMart, a group company, holds a regular (approximately once a year) Information-sharing Meeting on Human Rights Issues in the Supply Chain for managers involved in the hiring of ready-made meal manufacturers who supply products to FamilyMart stores and the formulation and implementation of labor-related policies. The aim of these meetings is to promote understanding of and prevent human rights risks.

The ITOCHU Group will continue to work to reduce human rights risks across our entire value chain.

Pineapple Production Business Promoting Local Employment, Supporting Living Infrastructure, and Improving Productivity

For more details, please refer to Community Contribution in Social Contribution Activities.

An Oil Project in the Caspian Sea, which Ensures a Stable Resource Supply and Contributes to Local Communities for Harmonious Cooperation

For more details, please refer to Community Contribution in Social Contribution Activities.

Cooperation with Stakeholders