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)
- 5.Respect for human rights
- （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）We shall not engage in any type of discrimination or harassment.
- （3）We shall not engage in any forms of forced labor or child labor.
- （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) |
|---|---|
| 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 |
| Human rights due diligence planning | Corporate Planning Department 1 general manager, 1 deputy general manager, 7 in group responsible |
Material Issues, Plans and Results
Fiscal 2022 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 | Conduct survey of technical intern trainees at suppliers and formulate responses |
|
|
| Human rights awareness | Implement human rights training | Some companies have not completed the training because the implementation date was extended to the first half of fiscal 2023 due to revisions to the training content | ||
Major Initiatives
Participation in the UN Global Compact
ENEOS Holdings, ENEOS, JX Nippon Oil & Gas Exploration and JX Metals support the UN Global Compact and work 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）
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).
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
Mine Development and Respecting the Human Rights of Local Residents
The development and operation of mines can have a particularly significant impact on the surrounding environment. It is therefore essential to give due consideration to the human rights of local residents.
SCM Minera Lumina Copper Chile, the operator of the Caserones Copper Mine, applies a basic three-point policy for supporting local communities: respect for life, protection of the community and environment, and compliance with laws and regulations. In keeping with this policy, after the project launch in 2007, the operator began holding briefings and engaging in dialogue with the Collas, the indigenous people who live in the area around the mine site, in an effort to build trust.
There were no cases of infringement of residents’ rights in fiscal 2022.
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. We implement the due diligence process every two years. Human rights due diligence consists of identifying and assessing the scope of human rights violation risks in our business activities, formulating improvement measures, and developing a training system.
In the second round of human rights due diligence, conducted in fiscal 2021, we followed suit from the first round in assessing and verifying whether the Group had committed any human rights violations involving employees, customers, residents living near refineries or smelters, residents living near service stations, or suppliers. In addition, in this second round of human rights due diligence, we carried out engagement with NGO Human Rights Now and the ENEOS and the JX Metals labor unions, and used the results to assess and verify human rights risks in the Group. We identified human rights risks to be addressed and formulated responses.
Scoping for Human Rights Risk Survey
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 and the opinions of NGOs in addition to the UNGP, we conduct scoping of human rights risks to be evaluated 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) | |
- *Additional human rights risks included in the second round of human rights due diligence, conducted in fiscal 2021.
Rights Verified in Human Rights Due Diligence
- 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 and elimination of discrimination in respect of employment and occupation)
- Three labor rights (right to organize, right to collective bargaining, freedom of association)
- Freedom from forced or compulsory labor
- Freedom from all forms of harassment
- Right to work in a safe and healthy work environment
- Freedom from discrimination
- Rights of foreign workers
- Rights of immigrants
- Rights of persons with disabilities
- Rights of women
- Rights of sexual minorities
- Right to access to remedies
- Social security
- Prohibition of child labor
- Access rights to resources
- Rights concerning health
Human Rights Risks to Be Addressed
- 1）Latent human rights risks concerning technical intern trainees in the supply chain
- 2）Insufficient right to access to remedies at suppliers
Response Measures and Initiatives
- 1）Conduct survey of technical intern trainees and formulate responses
The fiscal 2022 CSR procurement survey included indicating the presence of foreign technical intern trainees. For suppliers who indicated the presence of foreign trainees, we will conduct surveys of the actual conditions and if the results indicate any potential human rights risks, we will follow up with on-site audits and other measures. - 2）Expand grievance mechanisms
In fiscal 2022, we established human rights consultation contact points for suppliers.
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 harassment, child labor, and forced labor. In addition to our implementation of human rights due diligence, this serves as a framework for continuously assessing impacts on human rights.
Human Rights Due Diligence Cycle
- 1. Scoping of stakeholders and human rights risks subject to human rights risks survey
-
- Stakeholders: Employees, customers, local residents living around refineries/smelters, local residents living around service stations, suppliers, etc.
- Human rights risks: See Human Rights Due Diligence Issues for Confirmation
- 2. Assess and verify human rights risks
- For the human rights risks identified through scoping conducted in step 1, conduct self-assessments in each 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
- 3. Consider response measures
- Based on the results of the self-assessments and the opinions of outside experts, consider response measures for human rights risks requiring priority response
- 4. Implement response measures
- Introduce response measures based on consideration of measures in step 3
Fiscal 2023 (plan):
Incorporating the opinions of third parties, identify human rights risks in the value chains of our main businesses
- 5. Disclosure
- Report on response
Situation in Fiscal 2022 and Future Plan
As of November 2023, 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.
In fiscal 2023, we plan to conduct the third round of human rights due diligence, which will incorporate third-party opinions, as we seek to identify potential human rights risks in the value chains of our main businesses. As in fiscal 2021, we plan to receive third-party verification of our third round of human rights due diligence, which we will conduct in fiscal 2023.
We will continue our pursuit of more highly effective human rights due diligence through efforts such as identifying high-risk countries and businesses, for which we will prioritize human rights due diligence.
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. As in fiscal 2021, we plan to receive third-party verification of our third round of human rights due diligence, which we will conduct in fiscal 2023.
A portion of the fiscal 2021 third-party opinion is summarized as follows.
A portion of the third-party opinion (★ denotes observations from fiscal 2019)
Initiatives for supply chain management implemented in fiscal 2020 were deemed to have achieved steady progress, while further issues to be addressed were also indicated.
- Right to access to remedies ★
- Further dissemination and promotion of the use of the whistleblower systems (hotlines)
- Discrimination and harassment ★
- Advanced efforts for discrimination and harassment prevention training
- Supply chain management ★
- Effective implementation of the Group Code of Conduct among Group companies and suppliers in Japan and overseas, and response to human rights risks across the entire value chain, including overseas
- Just Transition
- Implementation of human rights due diligence based on potential human rights risks due to global warming initiatives
- Human rights in conflict-affected areas
- Implementation of appropriate measures to avoid contributing to human rights harm in areas where serious human rights violations occur, and implementation of engagement with stakeholders
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.
To date, our CSR procurement surveys have targeted primary suppliers. Going forward, we will select suppliers in terms of importance to our business and ESG risks. We also plan to develop 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 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.
We will continue to use the flowchart to determine appropriate responses whenever human rights risks are detected, and we will report to the Board of Directors on the status of those responses twice a year. In this way, 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
Based on this flowchart, we determined the following responses.
JX Nippon Oil & Gas Exploration 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 compliance hotlines, human rights/harassment consultation contact points, and supplier-related human rights contact points 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 and English for employees in Japan and overseas.
Under our compliance hotline system, all reports received are reported to officers by email, and the status of response is explained to Audit and Supervisory Committee members and corporate auditors semi-annually. We inform employees of this system through the company intranet, and in 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 compliance hotlines and the human rights/harassment 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.).
Each report received by the Group is investigated and addressed. Generally, all reports are resolved within one year. See Compliance for the internal reporting workflow of these hotlines.
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 70.9%. Refer to Data for the labor union participation rate).
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.
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, and obtains written consent from suppliers who have agreed to comply with these policies. 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. This survey will be conducted every two years so that we can continue to monitor the progress of improvements.