Human Rights

Basic Approach

As a corporate group with global business operations, the ENEOS Group believes that an important element in striving for sustainable development is respect for the human rights of all stakeholders, including employees.
The Group supports international norms such as the United Nations Guiding Principles on Business and Human Rights and the fundamental labor rights of the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work (freedom of association and the effective recognition of the right to collective bargaining, the elimination of all forms of forced or compulsory labor, the effective abolition of child labor, the elimination of discrimination in respect of employment and occupation).
We conduct our business activities with respect for the human rights not only of our employees, but of all stakeholders, including our suppliers, customers, business partners and members of local communities.

ENEOS Group Code of Conduct (excerpt)
  1. 5.Respect for human rights
    1. (1)We shall not infringe on human rights through our business activities. We respect internationally accepted human rights standards and diversity, acknowledging differences pertaining to gender, age, nationality, race, ethnicity, skin color, culture, thought, religion, belief, political opinions, sexual orientation, and the presence or absence of disability.
    2. (2)We shall not engage in any type of discrimination or harassment.
    3. (3)We shall not engage in any forms of forced labor or child labor.
    4. (4)We shall not engage in business transactions which may lead to the prolongation of conflicts, human rights violations, or inhumane acts.

Human Rights Policy

We have stipulated respect for human rights as a basic principle in the ENEOS Group Code of Conduct, and we have supplemented this principle with the Human Rights Policy. The Group asks all business partners involved in its business activities to understand and cooperate with this policy, and strives to ensure thorough awareness and compliance.

ENEOS Group Human Rights Policy

The ENEOS Group conducts its business activities under the ENEOS Group Philosophy, which states that we will contribute to the development of our communities and help to ensure a vibrant future through creation and innovation in energy, resources, and materials.
This policy was formulated as a guideline for promoting respect for human rights across the entire Group and fulfilling related obligations pursuant to the United Nations Guiding Principles on Business and Human Rights.

1.Basic Approach
The ENEOS Group fully recognizes that human rights must be respected in all of the countries and regions where it conducts its business activities.
2.Compliance with Applicable Laws and Regulations
The ENEOS Group complies with the laws, ordinances and regulations applicable in the countries and regions where it conducts its business activities. In addition, the ENEOS Group will pursue a method for respecting international principles on human rights in case of a contradiction between internationally recognized human rights and the laws and regulations of each country and region.
3.Respect for International Norms on Human Rights
The ENEOS Group supports and respects the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights), which stipulates the fundamental human rights of all people, along with international norms on human rights such as the ILO Declaration on the Fundamental Principles and Rights at Work of the International Labor Organization, which sets forth fundamental labor rights, other conventions relating to the human rights of workers on wages and working hours, the Declaration on the Rights of Indigenous Peoples, and the Children’s Rights and Business Principles. As a participant in the UN Global Compact, we support and respect the 10 principles of the UN Global Compact.
4.Fulfillment of Responsibility to Respect Human Rights
The ENEOS Group is committed to upholding human rights. If it is determined that our business activities cause or have caused adverse impacts on human rights, we will take appropriate action to remedy such impacts in accordance with our responsibility to respect human rights. As part of our efforts, the ENEOS Group will promote the following initiatives.
Human Rights Due Diligence
The ENEOS Group will establish and continually implement a mechanism for human rights due diligence. Human rights due diligence refers to the continuous process of conducting preventive surveys and investigations, rectifying issues using appropriate means, and disclosing the progress and results of such externally, in order to prevent or mitigate possible adverse impacts on human rights caused by the company.
Dialogue and Discussions
The ENEOS Group conducts in earnest dialogue and discussions with relevant stakeholders to ensure that it comprehends and addresses the impacts it has on human rights from the perspective of those affected.
5.Training
The ENEOS Group will provide appropriate training to its officers and employees to ensure that this policy is incorporated into the business activities of all companies belonging to the ENEOS Group.
6.Information Disclosure
The progress and results of initiatives for respect for human rights under this policy will be disclosed on our website and in reports, among other media.
7.Applicable Scope
This policy applies to all officers and employees of the ENEOS Group. All business partners involved in the ENEOS Group’s business activities will be asked to cooperate with this policy.
8.Positioning
This policy supplements the provisions of the ENEOS Group Philosophy and the ENEOS Group Code of Conduct.

Structure

For information about our structure, see ESG Management Structure.

Internal Structure for Business and Human Rights

Based on the third-party opinion received in human rights due diligence and the assessment results of the Corporate Human Rights Benchmark (CHRB), the Corporate Planning Department and the Human Resources Department of ENEOS Holdings are taking the lead in strengthening human rights initiatives across the Group.
An overview of these efforts is presented below.

Operations Departments in charge (breakdown)
Human rights due diligence planning Corporate Planning Department
1 general manager, 1 deputy general manager, 6 in group responsible
Various consultation contact points (human rights, people with disabilities, sexual minorities), human rights awareness (in-house training) Human Resources Department
1 general manager, 1 deputy general manager, 11 in group responsible

Material Issues, Plans and Results

Fiscal 2023 Targets, Results and Progress

Evaluation:Achieved/Steady progressNot achieved

Material ESG Issue Initiative Target (KPI) Results/Progress
Compliance with international principles on human rights Human rights due diligence Implement human rights due diligence

Conducted third round of human rights due diligence
Human rights awareness Implement human rights training

Implemented

Major Initiatives

Participation in the UN Global Compact

The Group supports the UN Global Compact and works to realize its 10 principles in four areas, including human rights.
We also support the Japanese government’s National Action Plan on Business and Human Rights (2020–2025), established in 2020, and are working to promote responsible corporate actions involving respect for human rights through its implementation.

Corporate Human Rights Benchmark(CHRB)

The ENEOS Group became subject to Corporate Human Rights Benchmark (CHRB) assessment* in 2019, and regularly engages in dialogue with CHRB to exchange opinions on business and human rights.
Since fiscal 2020, based on the assessment and dialogue with CHRB, we have been focusing our efforts on the consideration of human rights factors in supply chain management (see Human Rights Due Diligence).
Going forward, in order to sufficiently address the questions posed by CHRB, we will carry out initiatives on business and human rights and proactively disclose relevant information.

  • *See the CHRB website for assessment results.

Raising Awareness of Human Rights through Training and e-Learning

At our Group companies, we continue to provide human rights awareness training and e-learning for all officers and employees to raise awareness of human rights and prevent human rights violations in the workplace. The training promotes understanding of human rights violation risks specified in the National Action Plan on Business and Human Rights (2020-2025).
In fiscal 2023, ENEOS Holdings and ENEOS Corporation conducted a total of 5,828 hours of training on business and human rights and harassment prevention.

Policies, Principles, and Norms on the Rights of Indigenous Peoples

The Group supports and respects international norms on human rights with regard to the rights of indigenous peoples.

Main international norms on human rights that we support and respect

  • United Nations International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights)
  • 10 principles of the UN Global Compact
  • International Labour Organization (ILO) Declaration on the Fundamental Principles and Rights at Work
  • ILO conventions relating to human rights of workers on wages and working hours
  • United Nations Declaration on the Rights of Indigenous Peoples
  • United Nations Children’s Rights and Business Principles

Response to the UK Modern Slavery Act 2015

ENEOS Group company ENEOS Europe Limited has released a statement in response to the United Kingdom Modern Slavery Act 2015, which came into effect in October 2015.

  • *See the following for more information.

Initiatives for Business and Human Rights

Human Rights Due Diligence

The Group has three procedures to comprehensively identify and address human rights risks: human rights due diligence, CSR procurement surveys in the supply chain, and a response flowchart for suspected human rights violations.

1. Human Rights Due Diligence for ENEOS Holdings and Group Companies

The ENEOS Group began carrying out human rights due diligence in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGP) in fiscal 2019. The due diligence in fiscal 2019 and fiscal 2021, conducted with the cooperation of a third party, involved identifying and assessing the scope of human rights violation risks in our business activities, formulating improvement measures, and developing a training system. We received third-party verification for the due diligence conducted in these two fiscal years.
The third round of human rights due diligence, conducted in fiscal 2023, included several new Group businesses and identified human rights risks and issues in the associated businesses and supply chains. The due diligence was conducted with assistance from the Global Alliance for Sustainable Supply Chain (ASSC), a third party with a wealth of knowledge, and included desk surveys as well as interviews with suppliers and contractor companies. The results were used to assess and verify Group human rights risks, and we identified priority human rights risks and considered response measures. We will make improvements prior to the scheduled fourth round of human rights due diligence.

Human Rights Due Diligence Cycle

1. Conduct scoping of stakeholders and human rights risks

In the course of human rights due diligence, in which we reference Guidance on Human Rights Due Diligence of the Japan Federation of Bar Associations, Reference Material on Practical Approaches for Business Enterprises to Respect Human Rights in Responsible Supply Chains of the Ministry of Economy, Trade and Industry, and the opinions of NGOs, in addition to the UNGP, we conduct scoping of human rights risks to be assessed and verified (see table below).

Human Rights Due Diligence Issues for Confirmation

Stakeholders Human rights issues
Employees Harassment Management of working hours
Discrimination Health
Safety Work-life balance
Freedom of association (right to organize, right to collective bargaining) Fair and sound labor standards
Suppliers Human rights violations by suppliers
Customers/
Business partners
Quality defects (including contamination) Inadequate provision of product information
Improper management of chemical substances used in products Information security (privacy)
Local communities Environment (including environmental degradation, health impacts, and damage in local areas)
2. Assess and verify human rights risks

For the human rights risks identified through scoping conducted in step 1, conduct self-assessments in each company/department to determine whether human rights violations have occurred through business operations. After self-assessments, request confirmation by outside experts and identify human rights risks requiring priority response.

22 Risk Areas Where Rights are Verified in Due Diligence

  • Employment conditions
  • Work hours and wages
  • Discrimination in the workplace
  • Forced labor
  • Youth and child labor
  • Occupational health and safety
  • Environmental pollution
  • Land use and property rights
  • Freedom of association and the right to collective bargaining
  • Local communities
  • Employee privacy
  • The rights of women and sexual minorities
  • Harassment
  • Corruption and bribery
  • Security
  • Migrant worker rights
  • Freedom of expression
  • Education and training
  • Poverty
  • Governance
  • Product development/advertising/use of products and services
  • Ethical sourcing

Business Areas Covered by Human Rights Due Diligence

  • Oil and gas (including the upstream areas of ENEOS Xplora)
  • Lubricants
  • Renewable energy (Japan Renewable Energy, currently ENEOS Renewable Energy)
  • High performance materials (ENEOS Materials)
  • Metals (JX Advanced Metals)

Risk Selection Process in Human Rights Due Diligence

3. Consider response measures
4. Implement response measures

Based on the results of the self-assessment and the opinions of outside experts, we considered and introduced response measures for priority human rights risks.

Priority Human Rights Risks and Response Measures

Human rights risk Response measures and initiatives
  1. 1)Insufficient right to access to remedies at suppliers
  • Increase awareness of the supplier-related human rights contact points
Issue guidance through the company contact department about the supplier-related human rights contact points established in fiscal 2022 to ensure easy accessibility.
  1. 2)Potential human rights risks concerning foreign workers in the supply chain
  • Understand actual conditions for foreign workers and formulate response measures
Although no specific issues were detected in the third round of human rights due diligence, efforts will be made to understand actual conditions in order to identify potential risks. If a possibility of a human rights risk exists, we will take action, such as conducting on-site audits, and formulate response measures.
  1. 3)Potential human rights risks concerning forced labor in the supply chain
  • Continue investigating actual conditions concerning forced labor in the supply chain
Questions on the presence or absence of forced labor were included in the fiscal 2022 CSR procurement surveys. We will continue to assess conditions and conduct follow-up fact-finding if survey responses are not satisfactory.
Situation in Fiscal 2023 and Future Plan

As of November 2024, there have been no serious human rights violations in the value chains of our main businesses. If a human rights violation occurs in the course of our business activities, we will take corrective steps and promptly implement remedy measures pursuant to laws and regulations and following the instructions of the relevant authorities, while also working to prevent recurrence.
Based on the results of the third round of human rights due diligence conducted in fiscal 2023, we plan to examine possible countermeasures, including for potential human rights risks, as part of our efforts to prevent human rights violations.

Third-Party Opinion

The Group has asked an international human rights NGO to conduct desk research for third-party verification of its human rights risk assessments.
For the third round of human rights due diligence, we commissioned the Global Alliance for Sustainable Supply Chain (ASSC) and received the following third-party opinion.

A portion of the third-party opinion

Human rights risk mapping has identified human rights issues (potential risks) with high likelihood of occurrence and severity in each business. However, since the current survey is based on desktop research, we suggest that the following initiatives be taken in the future to assess risks and locate issues with a high degree of accuracy.
It is also desirable to expand the scope of human rights due diligence in the future and confirm the status of human rights in new business and business processes.

  • Interviews with each department and reflection of information obtained
  • Implementation of self-checks
  • On-site interviews, etc.

Risk Management
The company-wide risk management (ERM) system operated by the Group (see Risk Management) identifies various risks in the Group’s operations, including those pertaining to human rights. In addition to our implementation of human rights due diligence, this serves as a framework for continuously assessing impacts on human rights.

2. CSR Procurement Surveys in the Supply Chain

We began conducting CSR procurement surveys in cooperation with our suppliers in fiscal 2018. By including the Group’s human rights due diligence verification items in the surveys, we conduct similar human rights due diligence for our suppliers. Although no serious human rights risks have been identified to date, we have urged suppliers who need improvement to take corrective action. We will continue to monitor the status of improvements with regular checks every two years. For details, see Supply Chain Management.

The Group’s CSR procurement surveys have targeted primary suppliers and have been expanded to include suppliers selected based on importance to our business and ESG risks. We are also developing a mechanism for even more effective identification and response to human rights risks through such means as positioning the CSR procurement survey as part of our broader human rights due diligence and subsequently enhancing the human rights risk survey process.
In addition to these initiatives, the JX Advanced Metals Group is taking measures against conflict minerals. For details, see Confronting the Issue of Conflict Minerals.

3. Response to Suspected Negative Impacts on Human Rights

In fiscal 2021, upon the directive of the Board of Directors, we developed the Human Rights Response Flowchart to facilitate timely identification and analysis of and measures to avoid and mitigate the impact of human rights violations involving the Group. The flowchart, which is aligned with the human rights due diligence framework of the UNGP, is used to determine responses in terms of the impacts of our business operations on human rights violations, mainly those committed by third parties.
To supplement the flowchart, in fiscal 2023 we added eight new points to confirm at the time of assessment and items to check concerning human rights.
We use the flowchart to determine appropriate responses whenever human rights risks are detected, and we report to the Board of Directors on the status of those responses twice a year. We will continue our earnest response to human rights risks in our business activities.

Overview of Human Rights Response Flowchart

  • Identification of human rights risks
    Use desktop research, media reports, external findings, engagement with outside parties, etc., to determine whether there are any human rights violations by third parties and complicity in such violations.
  • Examination of response measures
    In the event of complicity in human rights violations, consider urging the party to remedy the situation or terminating the business relationship.
    Even in cases without complicity, the eight assessment and human-rights-related check items, including the severity of human rights violations, are used to ascertain risks from multiple perspectives, and subsequent preventive measures are discussed.

Based on this flowchart, we determined the following responses.

ENEOS Xplora completed the withdrawal from the Yetagun gas field project in the Republic of the Union of Myanmar
Upon careful consideration and discussion of the situation in the country, including its response to social issues, and project economics based on evaluation of the gas field, the company decided to withdraw from the project in April 2022. The withdrawal process was initiated and subsequently completed with the approval of the Myanmar government in April 2023.

Consultation Contact Points (Remedy Measures)

If it is confirmed that human rights have been impacted in our business activities, the Group will provide remedy to the affected parties in accordance with the ENEOS Group Code of Conduct and Human Rights Policy.
The Group has established whistleblower systems, human rights consultation contact points, and human rights consultation contact points for suppliers as internal contact points for consultation and reporting of issues, including human rights violations. These contact points accept anonymous reports and provide consultation on issues ranging from human rights issues that may occur in the course of day-to-day operations to serious human rights violations. The contact points are available in Japanese, English and other languages for employees in Japan and overseas.
Whistleblower systems of the Company and ENEOS, reports received are reported to officers by email once the investigation of a report begins, and the status of response is explained to the Audit and Supervisory Committee and corporate auditors regularly. We inform employees of this system through the Company intranet, and in e-learning training sessions held by the Legal & Corporate Affairs Department, we encourage employees to use the system.
Persons who contact the contact points are not in any way subjected to unfavorable treatment for seeking consultation or making reports. Retaliation against persons who make reports is strictly prohibited, and their privacy is rigorously protected. Employees who report matters to whistleblower systems and the human rights consultation contact points are not restricted from seeking remediation outside the company for those matters. Therefore, employees are also free to seek other remedies using the legal systems of their respective countries (Whistleblower Protection Act, etc.).
At the Company and ENEOS, generally, investigation of all reports are completed within one year.
See Compliance for the internal reporting workflow of compliance hotlines. See Procurement(Available in Japanese only) on our corporate website for the human rights consultation contact points for suppliers.

Labor-Management Negotiations on Appropriate Labor Conditions

At least once every year, Group representatives meet with employee representatives (labor unions) to negotiate overall working conditions, including wages. The wages of newly hired employees greatly exceed the minimum wage in Japan. The percentage of employees covered by the collective bargaining agreement is 88.4%. (Refer to Data for the labor union participation rate of each Group company).
The Group respects the ILO’s fundamental labor rights (freedom of association and the effective recognition of the right to collective bargaining, elimination of all forms of forced or compulsory labor, effective abolition of child labor, elimination of discrimination in respect of employment and occupation). Workers who exercise their rights are protected by the laws and regulations of each country.
In accordance with labor agreements, ENEOS discusses criteria with the labor union in advance in the event that a large number of union members are transferred due to the closure or downsizing equivalent to closure of a business site. Union members are officially notified at the time of external announcement of the closure or downsizing equivalent to closure of the business site. In addition, the content of discussions with the labor union and items to be notified in advance are mutually determined by labor and management.
The Company and ENEOS have established an overtime work limit of 35 hours per month and 360 hours per year at the head office, and 80 hours per month (up to six times per year) and 480 hours per year by concluding a separate agreement. We also take the health of employees into consideration by having them conduct self-checks if they work overtime in excess of 45 hours per month and by providing an interview with an industrial physician for those who have worked overtime in excess of 80 hours per month. Overtime work is monetarily compensated with an overtime work stipend and employees who work on holidays are compensated with a holiday work stipend. Those who work late at night between 10 p.m. and 5 a.m. the next day are compensated with a late-night work stipend.

Preventing Forced Labor and Child Labor

From a standpoint of completely eliminating forced labor and child labor, the Group supports and respects not only the laws of each country, but also international norms on human rights such as the United Nations International Bill of Human Rights, the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, conventions relating to human rights of workers on wages and working hours, and the Children’s Rights and Business Principles. As a signatory, we support and respect the 10 principles of the United Nations Global Compact—a point that is clearly stated in the ENEOS Group Human Rights Policy.
In addition, the ENEOS Group Code of Conduct clearly states that we will not use forced labor or child labor, and we are making thorough efforts to eliminate forced labor and child labor by conducting our business in accordance with this Code of Conduct.
Furthermore, in order to promote compliance with the Group Code of Conduct in the supply chain, we have established Group procurement policies and procurement guidelines that reflect the content of the Code of Conduct, and request suppliers to implement initiatives based on these policies. In order to ensure the effectiveness of our requests, the Group clearly states to suppliers that it emphasizes compliance with these policies and may review the details of transactions in some cases.
Additionally, we conduct CSR procurement surveys for suppliers, in which we have established survey items including child labor and forced labor, and urge suppliers to implement improvement measures as needed. We conduct these surveys every two years so that we can continue to monitor the progress of improvements.