Respect and Consideration for Human Rights

Action Plan

Risks	Opportunities
Business delay or business continuity risk resulting from the occurrence of a human rights problem in business activities that expands (geographically). Decline in credibility that may result from defects in the social infrastructure services we provide. And others.	Stabilization of business or securing of excellent human resources resulting from harmonious coexistence with local communities. Establishment of safe, stable supply system for product enabled by the consideration of human rights and improvement of work environment in the supply chain. And others.

Materiality	Issues to address	Business area	Commitment	Specific approach	Performance indicators	Degree of Progress
Textile Company
Respect human rights	Establishing a supply chain reflecting consideration for human rights and the environment	Supply chain management	We will promote information-sharing in the overall Group and establish a safe, secure supply chain, thereby helping customers with risk reduction and contributing to sustainable economic development.	Make Group-wide efforts to review the social and environmental safety of the supply chain and make improvements as necessary, thereby promoting the establishment of a safe, secure commodity supply system.	FYE 2024: Establish and visualize the supply chain of the overall Group, from material procurement to sales, to ensure a responsible procurement policy.	In FYE 2019 we conducted an investigation of 50 of our suppliers from the standpoint of Environmental, Social and Governance (ESG) criteria. In FYE 2020 we plan to increase this to 80 companies, and continue to work to establish a healthy supply chain.
Machinery Company
Respect human rights	Improving water and hygiene infrastructures	Water and environmental projects	We will contribute to improving the hygiene environment, the development of economic activities, and the protection of the global environment through the appropriate treatment and effective use of water and waste.	Expand water and environment projects to promote the appropriate use and treatment of water and the effective utilization of resources, and reduce the environmental impact.	Expand and diversify the investment portfolio in the water and environment field.	Water Sector We are participating in Water Supply and Sewerage Treatment Companies in the UK and Spain, Seawater Desalination Projects in Australia and Oman. Our Project in Oman started commercial operation in 2018. We continue to invest in portfolio in the water sector. Environment Sector We invested in four Waste Management Projects in the UK and awarded a 25-year Waste Management and Resource Recovery Project in Belgrade, the republic of Serbia in 2017.
Respect human rights	Establishing a supply chain reflecting consideration for human rights and the environment	Overall electric power and plant projects	We will contribute to improving the quality of life of all stakeholders in the supply chain and business investment destinations.	Set rules on due diligence related to social and business environmental safety for suppliers and business investment destinations based on the distinctive characteristics of each business, implement due diligence, and strengthen monitoring continuously.	FYE 2020: Aim to implement the due diligence described on the left in all new development projects.	We observed ESG checklist for all new investment of development and also checked 7 main issues on guideline of social resposibility. (Organizational Governance, Human Rights, Labor Practices, The Environment, Fair Operating Practices, Consumer Issues, and Community participaion and Development.)
Metals & Minerals Company
Respect human rights	Sustainable mine development that reflects consideration of the risks in occupational safety and health and environmental risks, and that contributes to local communities	Mining business	We will promote sustainable development of natural resources by fully committing to EHS (environment, health, occupational safety) and harmonious coexistence with local communities in areas which we operate. We will improve local infrastructure such as medical care and education.	Ensure the thorough application of the EHS guidelines. Contribute to local communities through activities for improving medical care, education and infrastructure.	Implementation of annual internal seminars to ensure our employees are fully aware of the EHS guidelines. Donations to medical care, education and build infrastructure in local communities.	We held internal EHS (Environment, Health and Safety) training courses for supervisors and company employees belonging to sections engaged in resource development. The attendance rate of those subject to this training was 100%. In FYE 2019, we checked five existing projects and one new project under EHS guidelines using the check sheet, and set follow-up items. We carried out CSR activities that contribute to the local community as part of each project we invest in. As an original initiative, our Australian subsidiary, ITOCHU Minerals & Energy Australia Pty. Ltd., co-sponsored citizen awards in the communities surrounding the port of our iron ore projects.
Energy & Chemicals Company
Respect human rights	Establishment of an energy resources development system that goes well with local society and environment	Exploration & Production of Oil & Gas	Contributing in the development of local society by advancing exploration & production projects that accommodate social and environmental concern.	Implementation of projects in compliance with the laws and regulations of the respective government and internationally-recognized administrative body.	Be compliant with HSE (Health, Safety and Environment) standards in the respective government and the ones set by internationally-recognized administrative body. Reduction of HSE issues that involve serious damage to human beings and/or environment.	We are duly complying with the HSE management standards set by the governments and relevant authorities. In accordance with our internal regulations, we monitor the number of incidents, seriousness and contents of the cases on a monthly basis,. (In FYE 2019, no major operational incidents have been reported as of the end of February.)
Food Company
Respect human rights	Establishing a supply chain reflecting consideration for human rights and the environment	Provisions	We will establish a procurement system that conforms to third-party certification criteria and unique codes of conduct of manufacturers as our customers.	Start procuring coffee beans in Latin America in a way that conforms to the unique codes of conduct of manufacturers as our customers. Participate in conferences of RSPO, a third-party certification body on palm oil, and start supplying RSPO-certified oil.	Proceed with discussions of targets for the sustainable procurement of palm oil by collaborating with the trading industry organization based on customers' situations and industry trends.	By 2025 we aim to switch the palm oil we handle to sustainable palm oil (RSPO/MSPO/ISPO, etc.). On the basis of the industry trends and customers' circumstances, we are going to improve our procurement system to provide sustainable palm oil with industry groups.
General Products & Realty Company
Respect human rights	Providing an environment that enables the focus to be placed on stable production activities	Construction	We will operate industrial estates in a high-quality manner that will permit tenant companies to focus on stable production activities.	Establish a safe, secure, environmentally-friendly infrastructure, including facilities such as those for power supply ,industrial water/wastewater treatment, security and fire prevention systems, or improve the existing infrastructure to make it like the above. Create employment by inviting companies, and in addition, promote locally-based contribution activities.	Undertake further improvements of infrastructure facilities and the service system in industrial estates and continue diverse local contribution activities.	We continue to carry out the following initiatives at the Karawang International Industrial City Provide a service structure that takes into account safety, security and the environment. Activities that contribute to neighboring areas. 1) Support for establishment of a pediatric health contact center, supplying baby food, providing medical equipment to midwives. 2) Provision of scholarships to Jr. high and high school students. 3) Afforestation/donating saplings to local governments and establishing agricultural parks.

Policy and Basic Concept

Human Rights Policy of the ITOCHU Group

The ITOCHU Group has adopted the "ITOCHU Group Human Rights Policy" (hereinafter "the Policy"), drafted based on our Corporate Mission, Code of Ethical Conduct, and The Basic Policy on Promotion of Sustainability. This Policy iterates our commitment to respect the human rights of our stakeholders and address negative impacts that may arise from our business activities.

1. Policy scope and our expectations toward business partners: This Policy applies to all worldwide executives and employees of the ITOCHU Group, including contractors and temporary employees. The ITOCHU Group also expects business partners and other relevant stakeholders to comply with this Policy.
2. Endorsement of international agreement: The ITOCHU Group supports international agreements on human rights, including the Universal Declaration of Human Rights, the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, and the United Nations Global Compact, which we have been a signatory to since 2009. We will also implement measures aligning to the United Nations Guiding Principles on Business and Human Rights.
3. Legal compliance and respect for internationally recognized human rights: The ITOCHU Group will comply with the laws and regulations in the respective countries and regions where we perform our business activities in addition to Japan. If there is a contradiction between internationally recognized human rights and the laws and ordinances of a country or region, we will pursue a method to maximize respect for international human rights principles.
4. Management approach: The ITOCHU Group will build structures to realize this Policy. The Sustainability Officer will bear the responsibility to oversee the compliance and implementation situation of this Policy.
5. Human Rights Due Diligence: Based on the United Nations Guiding Principles on Business and Human Rights, the ITOCHU Group will implement human rights due diligence in order to identify, prevent and mitigate negative impacts on human rights and fulfill our commitment to accountability.
6. Remedy and Rectification: If the business activities of the ITOCHU Group induce a negative impact on human rights or if involvement in such becomes clear, we will strive to remedy and rectify that through appropriate procedures and dialogue.
7. Dialogue and consultations: The ITOCHU Group will leverage external human rights expertise in its implementation of human rights due diligence and will engage in dialogues and consultations with our stakeholders – especially those potentially subject to adverse impacts from our business activities.
8. Education and awareness: The ITOCHU Group will provide appropriate education to all executives and employees (including contractors and temporary employees) and strive to raise human rights awareness in order to incorporate and implement this Policy in our business activities.
9. Communication on this Policy and our relevant initiatives: This Policy will be approved by senior executive in charge of sustainability and be reported to our Board of Directors and we will widely publish it to the public. We will also report on our human rights efforts based on this Policy on the ITOCHU website and in our ESG Report.

April 2020
Fumihiko Kobayashi
Member of the Board
Senior Managing Executive Officer
Chief Administrative Officer

Individual Policy

Respect and consideration for human rights is an important issue for ITOCHU as we deploy our business activities in various regions around the world. ITOCHU also asks all our stakeholders to approve, understand and put into practice the human rights policy of ITOCHU in addition to education for employees to respond to this important issue.

Response to Modern Slavery and Human Trafficking

ITOCHU is committed to efforts 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. The existing principles of ITOCHU contain efforts to ensure that modern slavery and human trafficking do not occur in our sales activities and supply chain across the world.

Reference：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 next generation as one part of our Basic Activity Guidelines on Social Contribution. We perform activities to support the healthy development of the young people who will be responsible for the next generation.
Related activities can be found here.

Security Company Appointment Concept

The United Nations adopted the Code of Conduct for Law Enforcement Officials in December 1979. This aims to ensure that member states thoroughly implement and promote the appropriate roles of law enforcement officials (e.g., the police and military authorities) and respect and protect the dignity of humans while carrying out their duties. ITOCHU supports the Basic Principles on the Use of Force and Firearms by Law Enforcement Officials in which the United Nations has established the principles on the use of firearms by law enforcement officials under the above code of conduct. We select security companies according to the content of that.

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.

Structures and Systems

ITOCHU promotes the formulation and implementation of action plans with respect and consideration for human rights serving as one of our key issues. Under the sustainability promotion structure, the person responsible for this issue is the Sustainability Officer while the Sustainability Management Department serves as the secretariat. The secretariat performs a review every year together with the persons responsible for ESG in each division. This content is deliberated on and reported to the Sustainability Committee. Important matters are also discussed and reported to the Board of Directors.

Reference：Sustainability Promotion Structure Chart

Human Rights Due Diligence

ITOCHU's Understanding of Human Rights Due Diligence

Human rights due diligence as understood by ITOCHU is a mechanism in which the impact on human rights in the business of ITOCHU is identified and evaluated. Those evaluation results are then incorporated into risk management. Finally, the implantation and effectiveness of measures are tracked.
It is necessary to report externally how we are addressing the negative impact on human rights through due diligence.

New Business Investment Projects

For more details, please refer to "ESG Risk Assessment for New Business Investment Projects".

Existing Business

When entering into business with new suppliers, ITOCHU informs all applicable suppliers in advance of the Sustainability Action Guidelines for Supply Chains. If a matter in violation of the purpose of this policy is confirmed, we seek corrective measures from that supplier. At the same time, if it is judged that correction is difficult even though we have made continuous requests for correction, we deal with this under a stance of reviewing our business with that supplier.
We also perform due diligence with the seven core subjects of ISO26000 serving as the mandatory survey items (including modern slavery and human trafficking) when making new investments with major suppliers. We conduct additional due diligence with external specialist organizations for investment projects requiring a professional point of view.

Supply Chain Management

For more information see Sustainability in the Value Chain.

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.

Reference：Human Rights Audits in the Poultry Industry in Thailand

Consultation Desk

Employee Consultation Desk

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.

[Fig] — HR Help Guide Book on the Intranet

Career Counseling Center

ITOCHU established our Career Counseling Center ahead of other companies. This office accepts workplace culture, human relations, treatment and harassment related consultations in addition to consultations on the careers of individuals by telephone, fax, e-mail and the post. Full-time office employees deal with these consultations.

Employee Hotline

In addition to a direct hotline to those responsible for compliance in each division, we have also established a consultation desk to external lawyers and an external hotline.

Flow of report

Business Partner Consultation Desk and Hotline

ITOCHU accepts opinions, proposals and grievances from all our stakeholders.

Inquiries

Efforts

Implementation of Fair Recruitment

Human resources are the greatest management resources for ITOCHU - a general trading company deploying a variety of businesses around the world. ITOCHU conducts activities to recruit those newly graduating from universities and graduate schools every year. We also separately recruit those who have experience in the middle of their careers. Combining new graduate and mid-career hires, we recruit 150 to 160 employees a year. The table below gives our recruitment record over the last three years.

(Unit: persons)

Number of hires by gender★
	New-graduates			Mid-career			Total
	Male	Female	Total	Male	Female	Total	Total
FYE 2018	121	29	150	7	5	12	162
FYE 2019	103	35	138	11	4	15	153
FYE 2020*	96	31	127

The figures as of April 1st, 2019

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 age, gender, nationality 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

FYE 2019 Human Rights Training Record

(Unit: persons)

	No. of Participants
New employee training	131
Organization Manager Workshop	405
Pre-overseas appointment training	253

In addition to the above training, we made business and human rights one of the themes in our sustainability e-learning in FYE 2019. Please see the Spreading Sustainability at Itochu page for more details.

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 nationality, age and gender (including sexual minorities such as LGBTs) 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 efforts, 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 789 participants in our human rights training in FYE 2019.

Sustainability Seminars

We have continued to hold internal seminars since 2007 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 conducted awareness activities for business and human rights. The purpose of these was 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.
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.

We convey our basic concept on respect for human rights through the ITOCHU Group corporate code of ethical conduct and Human Rights Policy of the ITOCHU Group 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 prepared a handbook on communication with our suppliers. We deploy a check mechanism in which those in charge of surveys can understand the actual state of the management of human rights and labor practices in important suppliers more clearly and so that they can then offer advice on making improvements. At the same time, we utilize this in keeping our employees 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 desk to receive consultations from employees.
We have stipulated that discrimination due to race, gender, religion, creed, nationality, body, illness, age or other illogical reasons in relation to duties and sexual harassment (including discriminatory behavior and harassment concerning sexual orientation and gender identification) are clearly prohibited in the Human Rights Protection Violations in our work regulations. We have determined penalties against those who commit such acts.

Foreign Technical Intern Trainee Survey on Working Environment

[Photo] — Seminar on "sustainability promotion and foreign technical intern trainees" being held

ITOCHU Modepal, a subsidiary to ITOCHU under the Textile Company, conducted a survey on its domestic production contractors, which constitutes of 211 sewing factories. The survey inquired whether or not the contractors were employing foreign technical intern trainees, and if the contractor answered affirmatively, continued to ask how it manages legal compliance to labor standards and health and safety standards specifically regarding the foreign trainees. The latest survey results showed that there are no cases of non-compliance to relevant laws and regulations.

In order to facilitate the survey and enhance its results, ITOCHU's head office sustainability management department held a seminar for sales representatives and production managers prior to sending out the questionnaire. The seminar, entitled "sustainability promotion and foreign technical intern trainees", aimed to enhance participants' understandings of human rights risks and how to mitigate them.

ITOCHU will continue to make Group-wide efforts in identifying risks along the value chain that can potentially lead to human rights violations, and strive to uphold its commitment to respecting human rights.

Cooperation with Stakeholders

Participation in Workshops on Human Rights Issues

Business and Human Rights Training: Effective Stakeholder Engagement
Supply Chain Labor and Human Rights Audit (Practical) Training (Lloyds's Register Japan)
Caux Round Table
Human Rights Education Subcommittee (GCNJ)