Tokyo Century Group Human Rights Policy

We are mindful of corporate social responsibility, offer high expertise and a wide range of unique financial services by leveraging our flexible business domain, and have set out in our management philosophy that we will contribute to the creation of an environmentally sound, sustainable economy and society that enables economic development through the effective use of resources.

We have formulated this Human Rights Policy in accordance with our management philosophy and promote respect for human rights throughout our business activities.

Recognizing respect for human rights as a key issue, we will cultivate a corporate culture that allows diverse human resources to fully demonstrate their skills and individual characteristics to become a company where all officers and employees can hone their expertise and experience growth as well as a sense of pride.

1. Scope

This Human Rights Policy applies to all officers and employees of the Tokyo Century Group.

We expect all of our stakeholders, including customers and suppliers of Group companies, to also respect human rights.

2. Affirmed international standards

We endorse and have signed the United Nations Global Compact. We also refer to the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights), the UN Guiding Principles on Business and Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work* in implementing initiatives for respecting human rights.

*Freedom of association and the right to collective bargaining, elimination of all forms of forced or compulsory labor, the effective abolition of child labor, elimination of discrimination in respect of employment and occupation, and equal remuneration for work of equal value.

3. Legal compliance

We comply with the relevant laws and regulations in each country or region where we operate. Where there is a conflict between internationally recognized standards and regional laws or regulations, we will find a way to respect international standards.

4. Where the policy stands

This Human Rights Policy was established after deliberation by the Management Meeting followed by approval by the Board of Directors.

5. Human rights of all officers and employees

We respect the human rights of all officers and employees and strive to create a vibrant, rewarding working environment where everyone’s human rights and human dignity is respected. Furthermore, we promote diversity and inclusion in accordance with the separately established Basic Diversity Policy and foster a corporate culture that enables diverse talent to thrive in an environment free from discrimination based on race, religion, gender, age, sexual orientation, disability, and nationality.

6. Human rights due diligence

We recognize that our businesses and services have the potential to cause or contribute to adverse impacts on human rights in any domain, and we conduct appropriate due diligence to prevent or mitigate such impacts associated with our business activities.

7. Remedy

If we find that our business has caused or contributed to adverse impacts on human rights, we will strive to provide a remedy to those affected.

8. Dialogues with stakeholders

We will conduct dialogues with stakeholders on our human rights initiatives.

9. Communication and education

We engage in communication and education to ensure that all officers and employees understand the importance of respecting human rights and that the Human Rights Policy is incorporated in all aspects of our business activities. Additionally, we will conduct compliance-related training to confirm that we will not tolerate any discrimination or harassment and that our officers and employees will fully comply with related laws.

10. Information disclosure

We strive to ensure that stakeholders understand our initiatives based on the Human Rights Policy by disclosing information on our website and other media.

Human Rights Initiatives

1. Position on Human Rights

The Tokyo Century Group’s position on human rights is expressed in its Human Rights Policy as well as its Corporate Code of Conduct (4. Respect for Human Rights) and Our Action Guidelines (3. We will respect human rights and human dignity and create a rewarding working environment). We have declared our commitment to promoting respect for human rights in our business activities and expect our customers, suppliers, and other stakeholders to do so as well.

In Credit Policy, which defines our basic approach to assessing transactions, we strive to uphold the Public Good Principles and examine whether or not providing credit in a specific case contributes to resolving social issues, such as respect for human rights, as a condition for doing business, and we require confirmation on this point for each transaction.

2. Managing Human Rights Risks

Tokyo Century controls its human rights risks under comprehensive risk management as a system for understanding and evaluating risks associated with the Group as a whole, including human rights risks, and responding appropriately from both a qualitative and quantitative perspective as needed. The system is implemented by the Comprehensive Risk Management Committee, which periodically reports on the status of its activities to the Management Meeting and Board of Directors.

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We monitor human rights risks under this system by classifying them as “human rights and workplace environment risks” under “operational risks” and verify the appropriateness of our response.

3. Training and Education on Human Rights

We conduct the following training and educational activities to foster awareness of respect for human rights.

In addition, all officers and employees submit a Compliance Confirmation Form each year, pledging their commitment to the Corporate Code of Conduct and Our Action Guidelines, which include our human rights policies.

Target Major Themes
All officers and employees
  • Human rights risks in business activities, business and human rights, and human rights initiatives
  • Prohibition of harassment, including sexual harassment; power harassment; harassment related to pregnancy, childbirth, childcare leave, or nursing care leave; and remote harassment
Members of each division and branch office (individual workplaces)
  • Prohibition of harassment, related laws and regulations, prevention guidelines, basic stance on prevention of occurrence, etc.
Staff responsible for human rights at Group companies
  • Basic knowledge of human rights

4. System for Addressing Human Rights Violations (Relief Mechanism)

(1) Officers and employees of Group companies

As a means of addressing actual compliance violations, including harassment and human rights violations, or concerns over possible compliance violations, the Group operates an internal reporting system available to all officers and employees at Group companies in Japan and overseas (directors, executive officers, employees, contract employees, temporary employees, loaned employees, part-time employees, and others), as well as former employees within a year after their resignation.

We make the utmost effort to ensure the anonymity of whistleblowers and maintain the confidentiality of their reports, and we will take remedial measures for victims in cases where human rights violations are found as a result of investigations into the cases reported.

We conduct an annual compliance survey of all officers and employees, with questions regarding compliance concerns including about human rights violations, and conduct hearings depending on the content of the response to prevent problems from occurring.

(2) Customers and other external stakeholders

As part of our efforts to promote respect for human rights in our business activities, we have established contact points for human rights consultation for customers and other external stakeholders.

Regardless of whether you do business with our Group or not, if you have noticed any human rights violations by Group companies or their officers or employees, please notify the following contact points. We will look into the matter and reply to you with the results of our investigation.

Contact Point for Human Rights Consultation

Compliance Office in the Risk Management Division Tokyo Century Corporation

5. Human Rights Due Diligence

We conduct PDCA cycles to effectively analyze, identify, and assess the negative human rights impacts associated with the Tokyo Century Group’s business activities and take corrective action to prevent or mitigate such impacts.

In fiscal 2022, Tokyo Century Corporation and all of its consolidated subsidiaries in Japan implemented human rights due diligence.

Our Due Diligence Process

With third-party assistance, we began by generating a long list of human rights risks, and after considering the nature of our business and our stakeholders, we identified our key risks in this area.

To understand the current status of these key risks, we conducted a survey and interview at Tokyo Century Corporation and its consolidated subsidiaries in Japan in addition to analyzing the content of consultations and reported cases as well as the results of the employee awareness and compliance surveys.

Identified issues

No material risks emerged during this process of risk identification, which confirmed that Tokyo Century has properly established and maintained its human rights policies, the operation of its internal reporting system as a relief mechanism, and its reporting systems for compliance violations during contingencies as well as incidents and accidents, and its educational system including e-learning.

On the other hand, we did note some room for improvement as a parent company, in the way we sought to grasp the standard operations of each Group company with regard to their awareness of harassment and human rights risks, such as for occupational health and safety and working hours. There is also room for improvement in how we disseminate our policies across the Group and the frequency with which we monitor each Group company.

Future Actions

In fiscal 2023, we will conduct human rights due diligence at our consolidated subsidiaries overseas and begin doing the same at investee companies on a trial basis toward developing a mechanism for evaluating the human rights risks associated with our business partners.

Tokyo Century will continue its efforts to ensure respect for human rights and to realize sustainable businesses by verifying human rights issues as they arise in the course of our corporate operations and consistently implementing PDCA cycles to prevent or mitigate any negative impacts to human rights, with the guidance of expert consulting organizations.

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Sustainability

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