• Policy
• Structure
• Human Rights Due Diligence
• Hotline for Consultation and Reporting about Human Rights Issues
• 2023 Human rights due diligence results
• 2022 Human rights due diligence results
• Key Issues and Initiatives on Human Rights
• Education and Dissemination
• Data
• Oji Group Basic Policy on Customer Harassment

Policy

The Oji Group believes that the responsibility to respect human rights is an important element of the global code of conduct. We have established the Oji Group Human Rights Policy in line with the United Nations Guiding Principles on Business and Human Rights and other similar works to further strengthen and implement our initiatives regarding respecting human rights. In January 2025, we partially revised our policy in line with joining a non-judicial grievance mechanism platform in accordance with the United Nations Human Rights Council's "Guiding Principles on Business and Human Rights."
Guided by this policy, the Oji Group will continue its effort to uniformly introduce measures related to human rights and ensure that all domestic and overseas Group companies are thoroughly aware of the basic policies.
(Please see the translations of the Oji Group Human Rights Policy below.)

Translation of Oji Group Human Rights Policy

Structure

We deliberate matters that are material to fulfilling our commitment to respecting human rights through the Sustainability Committee (chairperson: CEO, members: all Company Presidents and others) which is monitored and supervised by our Board of Directors.

Human Rights Due Diligence

To fulfill our responsibility of respecting human rights in accordance with the procedures described in the United Nations Guiding Principles on Business and Human Rights endorsed by the UN Human Rights Council, we are conducting human rights due diligence by taking into account the perspectives of our stakeholders. Through such due diligence, we will identify, prevent, and mitigate adverse effects on human rights that may be caused or contributed to by our business activities or which may be directly related to our business operations, products, and services through business relationships, by conducting an ongoing dialogue with stakeholders. We also will continually verify the effects of these actions.

If it becomes evident that we are causing or contributing to adverse effects on human rights, we will engage in dialogue with those concerned and strive to provide remedies through appropriate procedures. Additionally, in the event that our business operations, products, or services are directly related to adverse effects on human rights through our business partners or other related parties, we will consider encouraging these parties to provide remedies.

Regarding the establishment of a grievance mechanism, we have joined a non-judicial grievance platform in accordance with the United Nations Human Rights Council's "Guiding Principles on Business and Human Rights," and have set up a grievance window accessible to all stakeholders, including employees, the supply chain, local communities, and indigenous people. This ensures that we have a system in place to appropriately address negative impacts on human rights and the environment that may arise throughout the entire value chain of the Oji Group, both domestically and internationally.

Furthermore, we have established a consultation window on our company website for consumers and external stakeholders.

Throughout these consultation and reporting processes, we ensure the anonymity of those seeking consultation or making reports, protect the confidentiality of the information shared, and take measures so that those involved are not subjected to disadvantageous treatment.

In dialogue with stakeholders, in the FY2024, we conducted interviews targeting migrant workers at business locations in Malaysia, where the proportion of migrant workers is high and the number of our group's production sites is significant.

Hotline for Consultation and Reporting about Human Rights Issues

At the Oji Group, we have introduced a hotline that all stakeholders can consult regarding human rights issues or report issues to. 
At the Oji Group, we receive reports and requests for consultation via a non-judicial engagement and remedy platform conforming to the United Nations Guiding Principles on Business and Human Rights. This platform is provided by the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER), an organization that supports and facilitates member companies' redress of grievances in a professional capacity.
This platform also receives requests for consultation regarding not only human rights issues but also responsible business conduct as a whole (including conduct and ethics related to the environment and nature). Therefore, we are able to receive anonymous reports from all of our stakeholders in Japan and other countries, including suppliers, people from local communities, indigenous people and immigrant workers. 

Process of the grievance mechanism using JaCER

The Oji Group examines the content of the matters reported via JaCER. When it has been determined that consultation is necessary regarding a matter, JaCER exchanges information with the whistleblower and analyzes the matter. The Oji Group receives information about the matter, engages in a dialogue with the whistleblower and strives to resolve the matter. 

2023 Human rights due diligence results

1. Implementation of human rights assessments

The suppliers that would be assessed in the FY2023 were determined by defining the scope of high-risk operations and then evaluating the suppliers using scores calculated using METI data. The rationality and legitimacy of this selection method was confirmed by a third-party organization. 

Target

• 62 suppliers (response rate 80.6%)
• After discussion, the target industries selected for this fiscal year were wood chips, wood fuel, starch/corn, wood products, PKS and hemp.
• The target companies were selected referencing their Human Rights Risk by Product and Human Rights Risk by Region scores in the Practical Reference Materials for Respecting Human Rights in Responsible Supply Chains, etc. published by Japan’s Ministry of Economy, Trade and Industry.

Human rights issues covered by this assessment

• Prohibition of discrimination
• Respect for indigenous peoples and customs
• Prohibition of forced labor
• Prohibition of child labor
• Fair application of working hours and leave
• Wages
• Freedom of association and the right to collective bargaining
• Employee health and safety

Assessment Results

• Human rights risk cases that have materialized: None
• Examples of potential human rights risks: Seven items
  (1) Dissemination of human rights policy
  (2) Clarification of human rights protection system
  (3) Remedial measures
  (4) Prohibition of child labor and forced labor
  (5) Fair wages
  (6) Freedom of association
  (7) Workplace health and safety
• Corrective actions taken: Three suppliers that were found to be deficient in the above key human rights items were asked to make improvements, the implementation of the improvements was confirmed and letters of intent were submitted.
• Potential risk identification ratio: 6.0% (3/50 companies)
• Potential risk mitigation implementation ratio (implementation of improvement requests): 100% (3/3 companies)

2. Integration into own management

To understand the working environment of foreign workers in Japan, we checked the employment status of foreign employee workers (including technical interns and temporary employees) and compliance with related laws and regulations at the three*³ newly consolidated companies in Japan in FY2023. The results of this examination indicated no problems were found in terms of legal compliance or treatment. 

• *3A survey of 92 domestic consolidated companies was conducted in FY2022.

3. Monitoring (implementation of human rights assessments in conflict-affected areas) 

In the course of conducting human rights assessments, we exchanged opinions with local management companies regarding the implementation of human rights assessments of suppliers in conflict-affected areas in Southeast Asia. Referencing the opinions of a third-party organization, we conducted assessments through Group companies in the region in FY2023 (scope: three companies). We will continue to gather information and closely monitor developments in the region concerned.

4. Dialogue and consultation

The Oji Group participated in the Human Rights Due Diligence Subcommittee and the ESG Subcommittee of the Global Compact Network Japan (GCNJ) and exchanged information with experts from other companies and NPOs. In addition, one person in charge participated in and completed the first phase (October 2023-February 2024) of the Program for the Development of In-house Experts for Respect for International Human Rights and Labor Standards jointly sponsored by the ILO Office in Japan and the GCNJ.

2022 Human rights due diligence results

1. Implementation of human rights assessments

In FY2022, we conducted human rights assessments to check human rights and labor practices at consolidated companies and overseas suppliers of wood raw materials that were included within the scope of the Supplier Sustainability Survey. No serious human rights risks were identified, but we requested improvements at sites with organizational problems that could be potential human rights risks (e.g., it was unclear which departments or personnel were responsible for human rights-related issues).

Target 

• Domestic and foreign consolidated companies (157 companies,*⁴ 96.8% response rate) 
• Overseas suppliers of wood raw materials (39 companies, response rate 100%)

• *4Excludes a small number of employees, common administrative departments, etc.

Human rights issues covered by this assessment

• Prohibition of discrimination
• Respect for indigenous peoples and customs
• Prohibition of forced labor
• Prohibition of child labor
• Fair application of working time and leave
• Wages
• Freedom of association and the right to collective bargaining
• Employee health and safety

Assessment results

Consolidated companies

• Examples of identified human rights risks: none.
• Potential human rights risks: 5
  • The system for respecting human rights and the person responsible for human rights are unclear: 3 companies
  • The system for informing the public about consultation services and the person responsible for the system are unclear: 2 companies
• Improvement examples
  • Clarification of the system for respecting human rights and the person responsible for human rights: 3 companies
  • Clarification of the system for notifying people of consultation counters and the person responsible for the system: 2 companies

Suppliers

• Ratio of potential risks identified: 5.1% (2/39 companies)
• Potential risk mitigation implementation ratio (implementation of improvement requests): 100% (2/2 companies)

2. Integration into own management (Assessing the working environment of foreign national workers)

To ascertain the working environment of foreign workers in Japan, a survey was conducted on the employment situation of foreign employee workers (including technical interns and temporary workers) and compliance with relevant laws and regulations, targeting 92 domestic consolidated companies. No problems were found in terms of compliance with laws and regulations or treatment in 23 companies employing foreign national workers.

3. Monitoring (Investigation of potential human rights risks and sharing of case studies) 

Although no serious risks were identified in the human rights assessment, as the Ministry of Economy, Trade and Industry's Guidelines for Respect for Human Rights state that foreigners, women and children, people with disabilities, indigenous people, etc. are often placed in vulnerable positions, this year's potential human rights risk survey targeted foreign nationals, including technical interns Workplace employing foreign nationals, including technical trainees, and an interview survey was conducted by external experts (Caux Round Table Japan (CRT Japan)) at Oji Packaging, a Group company. 

Target

Foreign technical interns of Oji Packaging Co., Ltd.: 8

Results

Case study sharing

On the advice of the CRT, the results of this interview were shared within the Group as best practice examples, and the status of labor practices, etc. was checked at the four companies that hire technical interns. The results were generally good, but it was found that there were some businesses where pay slips and signs to prevent accidents in the workplace were written only in Japanese, so points to be improved were shared and the intent to implement further improvements were confirmed. 

4. Dialogue and consultation

We participated in the Human Rights Education Subcommittee and the Human Rights Due Diligence Subcommittee of the Global Compact Network Japan and exchanged information with experts from other companies and NPOs.

Key Issues and Initiatives on Human Rights

The Oji Group supports and respects international norms such as the International Bill of Human Rights. It recognizes the following items as important human rights issues and is working on them.

Fair treatment 

As detailed in its Oji Group Human Rights Policy, the Oji Group adheres to and respects core labor standards, including the elimination of discrimination in employment and work. In the Oji Group's Behavior Standard, the Oji Group stipulates that it will conduct its business activities while respecting the human rights of all stakeholders, including employees.

• Regarding employee wages, the company has established wages that exceed the minimum wage standards set in the individual countries in which it operates and it strives to maintain and improve the living standards of its employees.
• We comply with all applicable wage laws (e.g., equal pay for equal work) and pay employees fair and equitable compensation.
• We regularly conduct internal audits to ensure that the employment regulations of our affiliates in Japan and overseas are in compliance with the law and that they are being followed.
• To ensure sustainable growth together with the local communities in which we operate, we actively recruit locally at each of our bases.

Safe and healthy work environment

In its Oji Group Human Rights Policy, the Oji Group adhere to and respect core labor standards, including maintaining a safe and healthy workplace environment. In the Oji Group Code of Conduct, the Oji Group states that it will ensure the health and safety of all parties involved in its business by ensuring health and safety in the workplace and practicing safe behaviors.

In October 2020, we established the Oji Group Health Declaration, and under the leadership of our Chief Health Officer (Group CEO), we have been working to ensure the health of our employees. Since FY2021, the company has been certified as a Corporation with Excellent Health Management (Large Corporation Category).

Examples for activities

For domestic employees, we conduct regular health check-ups and actively encourage secondary examinations and specific health check-ups to prevent, detect early, and treat lifestyle-related diseases and other illnesses. Additionally, we promote mental health measures, conduct stress checks, reduce total working hours, improve the utilization rate of annual leave, and prevent health issues caused by excessive workloads through workplace reforms and improvements.

For overseas expatriates, we conduct health check-ups, vaccinations, mental health assessments before assignment, and regular check-ups during their assignment, along with appropriate guidance.

In some countries, HIV/AIDS, tuberculosis, and malaria are significant issues. To actively contribute to solving these global health problems, our group implements various health and hygiene improvement programs for the community at our overseas business locations. 

Additionally, our overseas afforestation companies provide medical support in regions with limited access to public services, including health check-ups, the establishment of clinics, and emergency transportation assistance for the local communities.

Occupational health and safety (harassment prevention)

The Oji Group's Behavior Standard stipulates that we will not engage in any acts of harassment, including power harassment and sexual harassment, or invasion of privacy, and that we will not allow others to do so. We have also established the Harassment Prevention Regulations as a part of our employment regulations, and we are working to prevent harassment, which is a familiar violation of human rights. 

Freedom of association and collective bargaining

As stated in its Oji Group Human Rights Policy, the Oji Group adheres to and respects core labor standards, including the recognition of freedom of association and collective bargaining rights. There are labor unions organized by employees in the Group, mainly at major Group companies including Oji Materia, Oji Container, Morishigyo Group, Oji Nepia, Oji F-Tex, Oji Imaging Media, Oji Green Resources, Oji Paper, Oji Management Office and Oji Logistics, and labor-management agreements are created and entered into through collective bargaining and consultations between labor and management.

The Oji Group’s management and the Oji Paper New Labor Union, the labor union with the largest number of members (total membership of 2,287 as of June 1, 2024 with a union enrollment rate of 97.6%) have confirmed in the preamble to their labor-management agreement that they “recognize the social responsibilities and missions of the company and that the improvement of employees’ labor conditions and the prosperity of the company are basically dependent on each other, and strive to cooperate to establish a stable labor relationship built on a foundation of mutual trust and understanding.” Both of the parties negotiate labor conditions such as salaries, bonuses and benefit packages on an equal footing.

In addition, the company has established forums for sharing management information and discussing various management issues, such as the Labour-Management Committee, a forum for  appropriate communication between labor and management, to establish sound labor-management relations. 

Prohibition of child labor and forced labor

As stated in its Oji Group Human Rights Policy, the Oji Group adheres to and respects core labor standards, including the prohibition of child labor and forced labor. The Oji Group's Behavior Standard stipulates that child labor and forced labor are strictly prohibited.
We believe that children's rights are vulnerable to infringement and that special consideration should be given to their human rights.

The Oji Group endorses the United Nations and ILO conventions on children’s rights and takes steps in each region to ensure that children’s right are respected.

Examples of our activities

Celulose Nipo-Brasileira S.A. in Brazil carries out awareness-raising activities and initiatives, including initiatives regarding health, for the students of local communities (mainly junior high school students).

• Adolescent pregnancy and prevention of sexually transmitted diseases such as AIDS, syphilis and gonorrhea
• Domestic violence
• Sexual harassment
• Bullying
• Prevention of dengue fever and yellow fever
• Drugs, etc.

Rights of Indigenous peoples (Respect for local culture)

In its Oji Group Human Rights Policy, the Oji Group clearly states its support for and respect of international human rights, including the United Nations Declaration on the Rights of Indigenous Peoples and free, prior, and informed consent. In the Oji Group's Behavior Standard, the Oji Group stipulates that, as a member of the international community, we shall respect the culture, customs, and values of each country and region, and shall work in good faith and in concert with the people of each country to develop our businesses.

In the pursuit of global activities, as part of respecting human rights, we will understand and consider the unique cultures and histories of indigenous peoples in our business operations in areas where indigenous communities exist. This includes taking into account the local laws and internationally mandated rights of the respective regions.

Examples of our activities

1. The company-owned forest in Biratori-cho, Hokkaido has a holy rocky hill, which is a sacred place (chinomishiri) of the Ainu, and places for preserving the view of nature and traditional cultures of the local people. To maximize the value of this area, we engaged in dialogue with the Ainu association of Biratori and the Biratori-cho municipal government to concluded the three-party Agreement Aimed at Protecting the Forest, Preserving the Ainu Culture, Taking Advantage of the Culture for the Revitalization of the Area, and Thereby Ensuring Harmonious Co-Existence in the Company-Owned Forest with a Cultural Landscape in 2017.
2. We respect the cemeteries, traditional events and other cultural elements of the Aboriginal people in the forests of Albany Plantation Forest Company of Australia Pty Ltd. and also the forests that general timber is purchased from, by ensuring that people have access to these places. In addition, before we implement a plan to log trees in an area, we contact the relevant administrative body to confirm that the area is not registered as a reserve.

Engagement with the local community

CENIBRA provides support for agriculture, tree planting, beekeeping, and other activities to support the stable income of farmers in the vicinity of its afforestation areas. In addition, CENIBRA works with the city and local NPOs to support young entrepreneurs by providing free lectures and training, textbooks, meals, and transportation. Furthermore, CENIBRA is actively working towards local procurement of materials and goods to stimulate the local economy.

• Harmonious coexistence with local communities

Education and Dissemination

The Oji Group respects human rights. To ensure that each and every employee has a correct understanding and awareness of human rights, we will enhance internal education by incorporating education on human rights into diversity training, position-based training at each company, and other training programs to raise the awareness of human rights among all employees. 

Human rights education

The Oji Group continues to conduct human rights education to deepen understanding of the policy and enhance awareness of human rights.
As part of our preparations for implementing human rights due diligence in FY2023, we held preliminary training for the procurement department, which serves as the point of contact with suppliers, to deepen their understanding of business and human rights. In addition, the Human rights initiatives directly related to corporate value and The basics of business- and human rights-related risk management: What is required of the corporate sector today? Training programs provided to 2,547 participating Oji Group managers.
Additionally, we utilize the portal site for human rights education within the group by publishing the "Oji Group Human Rights Policy Handbook" and various other materials.
We will continue to make efforts to improve awareness of human rights, such as by continuing to provide training and education.

Compliance awareness surveys of all Oji Group officers and employees are conducted periodically in Japan to monitor the status of compliance awareness, including awareness related to harassment and other improper conduct, and compliance issues at each worksite. In addition, the Internal Audit Department regularly audits the status of compliance, including that of overseas Group companies. Moreover, we dispatch instructors and conduct compliance seminars, including on harassment and other improper conduct, at the domestic and overseas Group companies to ensure that an awareness of compliance is entrenched throughout the Group.

Data

• ESG Data

Oji Group Basic Policy on Customer Harassment

1. Introduction

Oji Group, with the corporate slogan " Beyond the Boundaries," aims to "Grow and manage the sustainable forest,　Develop and deliver the products from renewable forest　And　Oji will bring this world a brighter future filled with hope." We are committed to providing "useful and safe products and services" to our customers.
While we sincerely accept and respond to customer opinions and requests regarding the use of our group's products and services, if any actions from customers are identified as customer harassment, we will respond firmly in accordance with our Corporate Behavior Charter, which includes "compliance with laws and fair business activities," "creating a safe and healthy workplace environment," and "respect for human rights." We strive to ensure a healthy working environment and protect the human rights of each employee, aiming to continuously provide high-quality products and services and contribute to the realization of a truly prosperous society.

2. Definition of Customer Harassment

Customer harassment is defined as actions by customers^* that exceed the socially acceptable range, considering the nature of the work and other circumstances, and harm the working environment of the employees involved.

• * Customers include clients, business partners, facility users, and others related to the business activities of Oji Group.

Examples of Customer Harassment The following examples are illustrative and not exhaustive:

• When there are no defects or faults recognized in the provided products or services.
• When the demands are unrelated to the products or services provided by the company.
• Physical attacks (assault, injury).
• Mental attacks (threats, slander, defamation, insults, abusive language, nitpicking).

3. Stance on Responding to Customer Harassment

If customer harassment is confirmed, we may unfortunately refuse to conduct business or respond to the customer. In severe cases, we will collaborate with external experts such as police and lawyers to address the situation appropriately.

4. Initiatives within Oji Group

• Clarifying the corporate stance through this policy and raising awareness among employees working at Oji Group.
• Formulating methods and procedures for responding to customer harassment.
• Conducting education and training for employees.
• Establishing a consultation and reporting system for employees.

Oji Holdings Corporation
Representative Director of the Board
President and Group CEO
Hiroyuki Isono

Established: April 1, 2025