June 11, 2024
Toshikazu Tajima
Board Director and CEO
TASAKI & Co., Ltd.
7-3-1, Minatojima Nakamachi, Chuo-ku, Kobe, Hyogo 650-0046, Japan

Re: Inquiry regarding TASAKI’s business partnership with sanctioned entity Myanmar Pearls
Enterprise.
We are civil society organizations from Japan and Myanmar that make policy proposals urging Japanesecompanies to consider the environment, society, and human rights in their overseas business
operations.
We are writing to you to express our concern regarding your company’s continued partnership withMyanmar Pearl Enterprise (MPE), a US, UK, and Canadian1 sanctioned state-owned enterprise under
the Ministry of Natural Resources and Environmental Conservation that is illegally controlled by theMyanmar military junta.
Since February 1, 2021 when the Myanmar military attempted a coup, it has been committing war
crimes and crimes against humanity with total impunity as it tries to take control of Myanmar. These
grave international crimes include deliberate killings, arbitrary arrests, torture, indiscriminate airstrikes,and destruction of civilian property, which have led to the displacement of more than 3 million peopleacross the country.2 There are grave concerns that the military is committing these crimes relying onrevenue from MPE and other junta-controlled entities.
We are aware that MYANMAR TASAKI Co., Ltd, a subsidiary of TASAKI & Co., Ltd, has been in a business
partnership with MPE since 1997 under a production sharing contract under a license granted by thenow junta-controlled Ministry of Natural Resources and Environmental Conservation (MONREC). The
military junta benefits from revenues generated through the pearl industry, including through aproduction sharing agreement under which MPE reportedly receives 20-25% of the pearls harvested.3
The junta also benefits from customs duties, other taxes and the transfer of technology that can support
further production.
Of the companies that have been granted permission for pearl farming, MYANMAR TASAKI was thelargest producer at over ten billion MMK (over US$8 million at the time) worth of pearls in 2017-2018,

the year with the most recently published data available. 4 We understand that your company has sold
Myanmar pearls around the world, with TASAKI’s website listing stores in Australia, China, France,
Japan, Hong Kong, South Korea, Singapore, Taiwan, UK and USA among others and that the junta hascontinued to earn revenue from pearls. According to a Myanmar junta run newspaper, 400 pearl lots
were up for sale this year during the 59th Myanmar Gems Emporium, which was attended by the junta
leader and commander-in-chief of the Myanmar military, Min Aung Hlaing. 5In April 2021, over three years ago, TASAKI’s business partner MPE was sanctioned by the US. In adding
MPE on the Specially Designated Nationals list, the US stated that “pearl industries are key economic
resources for the Burmese military regime that is violently repressing pro-democracy protests in thecountry and that is responsible for the ongoing violent and lethal attacks against the people of Burma,including the killing of children. 6” The UK also sanctioned MPE and a state-owned timber enterprise to“target the junta’s ability to profit from pearl and timber, 2 high-value natural commodities thatgenerate millions in revenue for the military regime. 7”
While TASAKI’s website states that pearls produced by the company’s own pearl farms “are ethically andsustainably sourced”, we are concerned that TASAKI’s continuing partnership with MPE contravenes
human rights responsibilities under the OECD Guidelines for Multinational Enterprises (OECDGuidelines) and the UN Guiding Principles on Business and Human Rights.8 Under the OECD Guidelines
and the UN Guiding Principles, all businesses have a responsibility to respect human rights and are
therefore required to exercise human rights due diligence to identify and prevent, mitigate and accountfor adverse human rights impacts.
We would like to reiterate our concern that by continuing its partnership with MPE, TASAKI is providing
the junta with a source of revenue that it can use to procure the very weapons and jet fuel that it needs
to continue to commit war crimes and crimes against humanity. We also believe that TASAKI’s
continued business with MPE undermines the effects of the sanctions imposed by the US, UK and
Canada against MPE, which are intended to block the junta’s access to revenue from the pearl sector.
Justice For Myanmar, together with another Japanese organization, Human Rights Now, has previously
issued a press release expressing concerns regarding TASAKI’s continuing business with MPE. 9
While we understand that an objective of TASAKI’s philosophy on sustainability is “harmonious coexistence with local communities'' inspired by a “spirit of sustainability, 10” we are further concerned byseveral Myanmar civil society reports on the situation of the indigenous Moken people of Myanmar,
which were submitted to the UN in 2020. 11 According to these reports, 12 TASAKI’s pearl farms inMyanmar, which are located in the Tanintharyi Region of southern Myanmar, could lead to furtherforced displacement of Moken people from their ancestral lands due to loss of water and land access.
In light of these concerns, we would like to know what human rights due diligence has been performed
since the military’s coup attempt, the results of that due diligence and what measures TASAKI has taken
in response.

We believe that by remaining in business with MPE, TASAKI may be in contravention of human rights
responsibilities under the UN Guiding Principles and the OECD Guidelines and risks complicity in themilitary junta’s international crimes. Therefore, we call on you to responsibly end all business with themilitary junta controlled MPE and fulfill your responsibilities to respect human rights. In addition, TASAKI
should publicly disclose its transactions with MPE and other junta-controlled entities since February 1,2021.
We would appreciate your timely reply to the contact address listed below by July 5, 2024 to share therequested data and to outline your course of action for addressing the issues raised. Furthermore, yourresponse will be published on our organization's website among other platforms (including the fact ofno response at the time of deadline). We look forward to receiving your response.
Sincerely,

Yuka Kiguchi
Executive Director, Mekong Watch
Yadanar Maung
Spokesperson, Justice For Myanmar
Contact address:
Mekong Watch
3F Aoki Bldg., Taito 1-12-11,
Taito-ku, Tokyo 110-0016,
Japan
TEL: +81-3-3832-5034
EMAIL: contact@mekongwatch.org

1

Office of Foreign Assets Control, “Burma-related Designations; Kingpin Act Designations Removals”, April 21, 2021
https://ofac.treasury.gov/recent-actions/20210421; Government of Canada, “Regulations Amending the Special EconomicMeasures (Burma) Regulations: SOR/2021-106”, May 14, 2021 https://gazette.gc.ca/rp-pr/p2/2021/2021-05-26/html/sordors106-eng.html; Office of Financial Sanctions Implementation, “Consolidated List of Financial Sanctions Targets in the UK”,
June 2, 2021 https://assets.publishing.service.gov.uk/media/65bb618927fccf000d4bd1b3/Myanmar.pdf.
2
UN Resident Humanitarian Coordinator a.i. for Myanmar, “Statement by the Resident and Humanitarian Coordinator a.i. forMyanmar”, May 3, 2024 https://myanmar.un.org/en/267754-statement-resident-and-humanitarian-coordinator-aimyanmar.
3

Frontier Myanmar, “Moken Fear a Sea Grab in the Myeik Archipelago”, December 29, 2019https://www.frontiermyanmar.net/en/moken-fear-a-sea-grab-in-the-myeik-archipelago/.
4Myanmar Extractive Industries Transparency Initiative, “Extractive Industries Transparency Initiative Myanmar, EITI Report2017-2018”, January 2019 https://eiti.org/sites/default/files/attachments/meiti_reconciliation_report_20172018_final_signed_31st_march_2020.pdf.

5The Global New Light of Myanmar, “400 Pearl, 160 Gem, and 4,550 Jade Lots Up for Sale”, May 2, 2024
https://cdn.myanmarseo.com/file/client-cdn/gnlm/wp-content/uploads/2024/05/4-5-2024.pdf.
6U.S. Department of the Treasury, “Treasury Sanctions Key Timber and Pearl Enterprises in Burma”, April 21, 2021
https://home.treasury.gov/news/press-releases/jy0138.
7
Foreign, Commonwealth & Development Office and The Rt Hon Dominic Raab MP, “Foreign Secretary Announces Further
Sanctions on Companies Linked to Myanmar’s Military Regime”, June 21, 2021 https://www.gov.uk/government/news/foreignsecretary-announces-further-sanctions-on-companies-linked-to-myanmars-military-regime.
8

Organisation for Economic Cooperation and Development (OECD), “OECD Guidelines for Multinational Enterprises on
Responsible Business Conduct”, June 8, 2023 https://www.oecd-ilibrary.org/finance-and-investment/oecd-guidelines-formultinational-enterprises-on-responsible-business-conduct_81f92357-en; United nations Office of the United Nations HighCommissioner for Human Rights, “Guiding Principles on Business and Human Rights : Implementing the United Nations‘Protect, Respect and Remedy’ Framework”, January 1, 2012https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf.
9

Human Rights Now and Justice For Myanmar “Human Rights Now and Justice For Myanmar call on TASAKI to end businesswith the Myanmar military junta, following US designation of Myanmar Pearl Enterprise for sanctions”, April 21, 2021
https://www.justiceformyanmar.org/press-releases/human-rights-now-and-justice-for-myanmar-call-on-tasaki-to-endbusiness-with-the-myanmar-military-junta-following-us-designation-of-myanmar-pearl-enterprise-for-sanctions.
10

TASAKI Website, “Our Sustainability”, accessed June 10, 2024. https://www.tasakiglobal.com/corporate/sustainability/about/.
11Burma Human Rights Network, “The Coming Extinction: The Moken People of Burma’s Mergui Archipelago”, December 12,
2020 https://www.bhrn.org.uk/en/component/edocman/bhrn-report/the-coming-extinction-the-moken-people-of-burma-smergui-archipelago.html; FIDH – International Federation for Human Rights and Myanmar Alliance for Transparency andAccountability, “Universal Periodic Review (UPR) 37th Session Myanmar: Joint Submission by FIDH and MATA”, July 2020,
https://www.fidh.org/IMG/pdf/fidh-mata_joint_upr_submission_july_2020.pdf; Coalition of Indigenous Peoples inBurma/Myanmar, “Joint submission to the UN Universal Periodic Review of Myanmar July 2020: 37th Session of the UPR
Working Group of the human Rights Council January/February 2021”,
https://uprdoc.ohchr.org/uprweb/downloadfile.aspx?filename=8278&file=EnglishTranslation.
12United Nations Working Group on the Universal Periodic Review, “Summary of Stakeholders’ submissions on Myanmar:
Report of the Office of the United Nations High Commissioner for Human Rights”, 12 November 2020,
https://digitallibrary.un.org/record/3893981?ln=en&v=pdf.