NAGASE Group Basic Human Rights Policy

Basic Principles

The aim of the management philosophy of the NAGASE Group is to contribute to society by maintaining the highest standards of integrity. To embody this philosophy today and in the future, we are committed to meeting our fundamental responsibility to respect the human rights of everyone who is affected by our business activities.

Based on this Policy, all the employees and directors of the NAGASE Group (defined as Nagase & Co., Ltd. (“Nagase”) as well as each entity in which Nagase has more than 50% of the voting rights, and any other entity wherein Nagase has approved the application of this Policy) are committed to fulfilling their responsibility to respect human rights. In addition, we will disclose this Policy to the customers and suppliers in our supply chain, business partners, and other concerned parties, who may be directly linked to the NAGASE Group’s business, products, and services, and expect them to gain a clear understanding of the Policy and comply with it.

This Policy was developed on the basis of the UN Guiding Principles on Business and Human Rights.

Responsibility to respect human rights

The NAGASE Group signed the UN Global Compact in December 2021. In addition, we support and respect the international rules on human rights, such as the UN Guiding Principles on Business and Human Rights and the UN’s International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the Children’s Rights and Business Principles, the principles of the Convention on the Elimination of All Forms of Discrimination against Women, and the National Action Plans (NAPs) on business and human rights of each country. If the laws, regulations, and other rules of countries and regions conflict with each other, we will endeavor to find a way that allows the international principles on human rights to be respected.

We not only prohibit human trafficking, forced labor, and child labor but also respect the history, culture, and customs of each country and region and the personality and individuality of each person and promote initiatives to respect human rights, such as prohibiting discrimination and physical and psychological harassment on the basis of race, beliefs, gender, sexual orientation and gender identity, age, religion, nationality, language, physical features, disabilities, property, and birthplace. Our aim is the creation of a safe and pleasant working environment, protection of the rights to freedom of association and collective bargaining, and the provision of fair compensation.

We strive to improve our business, products, and services by strengthening mutual understanding of the potential impact of our business activities with the relevant stakeholders, such as customers and members of local communities, through dialogues and discussions with them. We aim to contribute to and operate in harmony with society.

Human Rights Due Diligence

We will establish a system for human rights due diligence based on the UN Guiding Principles on Business and Human Rights to identify any adverse impacts on human rights caused by our activities in society at large and to prevent and reduce such impacts.

Contact Center

We have established a contact center and hotline that can be used by the employees and directors and employees of the NAGASE Group. We also provide an inquiry form on the website so that all the stakeholders, including the customers and suppliers in our supply chain, business partners, and other concerned parties, who are directly linked to the NAGASE Group’s business, products, and services, can make inquiries or report on issues related to human rights. When we receive inquiries or reports, we immediately conduct the necessary investigations.

Remedy and Remediation

When we identify any adverse impacts to human rights that Nagase caused or contributed to, we make every effort to remedy and/or remediate such impacts by immediately implementing appropriate countermeasures.

Education

The NAGASE Group endeavors to raise awareness among all employees and directors through effective educational initiatives so that this Policy can be appropriately implemented and incorporated into all business activities.

Information Disclosure

The NAGASE Group monitors the initiative to respect human rights based on this Policy on a continuous basis and discloses the progress and results on the website and in other places.

Governance

The board member in charge of Corporate Administration Division is responsible for managing and supervising the implementation of this Policy. In addition, Corporate Administration Division shall collaborates with the relevant departments at each affiliate in the Nagase Group, and promote daily initiatives designed to reinforce respect for human rights.

System

The board member in charge of the Corporate Administration Division of Nagase & Co., Ltd., is responsible for managing and supervising the implementation of the initiatives taken to support respect for human rights based on the NAGASE Group Basic Human Rights Policy. The data on the status of risks identified in the Group is compiled by the Risk Management & Compliance Committee and reported to the Board of Directors on a regular basis.

Whistleblowing/ Inquiries from Stakeholders

The NAGASE Group has introduced a whistleblowing system and established the Compliance Hotline that can be used to seek advice on or report systematic or individual compliance violations with the aim of preventing, detecting in the early stage, and remediating violations. In addition, the NAGASE Group has also established the Contact Center for External Parties where stakeholders, including service providers and clients, can seek advice on human rights violations, such as various types of harassment, and express their opinions on human rights.

Compliance problems may bring discredit to the NAGASE Group and severely interfere with the NAGASE Group’s operations. We make it absolutely clear to everyone that they should immediately seek advice or report any issues that are detected, even small issues, which may betray the trust and expectations of society.

Training / Awareness-raising Activities

We not only specify our responsibilities regarding respect for human rights in the Code of Conduct for Risk Management & Compliance, but we also make sure that all NAGASE Group employees and directors both inside and outside Japan fulfill their responsibilities by distributing leaflets and providing information on the Intranet. We also request that our stakeholders understand and cooperate in meeting these responsibilities by providing information on our website.

At Nagase, we require our employees to take a monthly e-learning training course on the prevention of various types of harassment and implement other measures to prevent harassing behaviors (sexual harassment, power harassment, etc.) at work that have become social problems regardless of whether or not they are aware of such issues. Each NAGASE Group affiliate is required to regularly implement similar initiatives.