21st December 2018

Human rights concerns in the Japanese apparel industry
A majority of companies fail to implement mechanisms to either prevent or addresshuman rights abuses
Human Rights Now
Business & Human Rights Resource Centre

Human Rights Now, an international human rights NGO based in Tokyo,, and theBusiness & Human Rights Resource Centre, an international human rights NGO
headquartered in London, have published the findings of a joint survey of the human rights
policies and practices of 62 top apparel companies in Japan. The survey was based on aquestionnaire sent to companies.
The results illustrate that, aside from a small group of leading companies, most apparelcompanies in Japan have yet to address human rights concerns adequately. The keyfindings include:1) The response rate was low, with nearly two thirds of companies, including leading
domestic Japanese companies, failing to respond to the questionnaire. 2) The mechanisms
in place within most companies to implement human rights remain in the very early stages ofdevelopment. 3) There was a distinct difference between the foreign companies and theJapanese companies. The Japanese companies, in general, lag behind .
This is a grave concern andneeds to be addressed. We urge the apparel industry inJapan to effect a significant improvement, in particular by the Tokyo 2020 Olympics.
1The response rate
The questionnaire was sent to 62 companies. 21 companies responded, amounting a
response rate of just over one third (33.8 percent). The companies chosen forinvestigation included the top fourglobal industry leaders Inditex (Spain), H&M(Sweden), FAST RETAILING (Japan) and Gap (USA), as well as the top 30 domestic
Japanese companies, and further additional companies with brand recognition for
sports, outdoor, and children’s clothing. The questionnaire was sent individually to eachcompany via post or e-mail in July 2018.

Of these top companies, those that did not respond included Shimamura, World,Aoyama Trading, United Arrows, Gunze, Nishimatsuya Chain, Pal Group Holdings,
Right-on, Aoki Holdings, Atsugi, and other well known names. Half of the top 10companies (as listed in table 1) ; 37 percent of the top 30 companies responded. Somecompanies, such as Aoyama Holdings and United Arrows, flatly declined to answer any
human rights-related questions. Others were not even aware which department within
the company were responsible for responding, or had no department for this matter atall. The results are detailed in table 1.
2

Insufficient human rights policy/mechanisms in many companies that didrespondOf the 21 companies which did respond, 12 companies had a human rights policy orprocurement guidelines in line with international standards: Fast Retailing, Wacoal
Holdings, Honeys Holdings, Daidoh, Gap, H&M, Aeon, Ito-Yokado, adidas, Asics,Mizuno, Sankisyoko (Mikihouse) and Patagonia. The remainder either had no humanrights policies at all, insufficient policies (including human rights policies that did notrefer to the Universal Declaration of Human Rights or ILO standards), or only generalprinciples. Nevertheless, the number of companies which have established CSR
procurement guidelines seems to be increasing – a positive trend. 3 companies out of
the 21 that responded had no procurement guidelines for their suppliers, nor any
implementation mechanism for their human rights policies.
Notably, 8 companies stated they did not conduct human rights due diligence. Whilst
H&M, adidas, Gap, Patagonia, Fast Retailing, Asics, and Mizuno stated they conduct
human rights due diligence , only 6 of the remaining 14 domestic Japanese companies
had a process in place. Only 14 companies carry out regular human rights audits of
their suppliers.

3

Traceability and disclosure of supply chain
Traceability also remains a challenge. 6 companies stated they could track products totier 1 suppliers, 9 companies to tier 2, and 5 companies to tier 3. Companies need tohave a better grasp further down their supply chain, given the many human rights
issues reported in connection with the cotton harvest, such as child labour,environmental pollution and public health repercussions from certain agricultural and2

chemical substances.
Only 3 companies, all non-Japanese companies (GAO, adidas and Patagonia) havedisclosed their full supplier list. 5 companies (Fast Retailing, Wacol Holdings, H&M,
Asics and Mizuno) have partially disclosed their suppliers. The remainder answered ashaving no disclosure. This is a great challenge for the Japanese apparel industry.
4

Technical intern trainees
The Technical Intern Training Program (TITP) has been a hotbed of human rightabuses in Japan. Despite the longstanding reports of abuse, 6 companies had noknowledge of whether their suppliers employed foreign labourers through the TITP. 13
companies responded that their suppliers did use foreign labour through the TITP, and2 companies responded that there were no TITP ‘trainees’ in their supply chain.
Measures taken to prevent abuses within the TITP framework varies dramatically,ranging from companies that commit to audit suppliers that employ foeign labour
through the TITP to companies that merely distribute information sheets. As a whole,
the measures taken by most companies appear inadequate. The popular domestic
clothing chain CECIL McBEE, which was reported in December 2017 as having forced
labour of TITP ‘trainees’ in its supply chain, did not respond to the survey.
The multitude of human rights abuses associated with the TTIP has received
increasing attention in recent months, within the context of the planned expansion ofthe foreign labour programme in Japan . Given that many apparel companies employ
foreign labour through the TITP, urgent measures are necessary.

5Remedy Procedure
Renown, Yamato International, and Ryohin Keikaku have no remedy procedure forhuman rights abuses, and stated they had no knowledge of any abuses in the past.
Onward Holdings and Sankisyoko (Mikihouse) also stated they had no remedy
procedure. Adastria and TSI holdings did not respond to this part of the survey. Notably,
though many companies do have a remedy procedure, most are only open to workers
in Japan, or are accessible only in Japanese: Wacol holdings, Sanyo Shokai, Honeys
holdings, Dido, Aeon, Mizuno and Stripe International. In contrast, some companies
have remedy procedures that workers in their supply chains can also access: Fast3

Retailing, GAP, H&M, adidas, Ito-Yokado, Patagonia and Asics (though not for localresidents). Among those, only 4 companies (Fast Retailing, GAP, adidas andPatagonia) provide multi-language hotlines that workers in their supply chain can use.
6Improvement in recent years.
It is notable that many companies have started to deal with human rights concerns.
Honeys holdings answered to have created a human rights policy upon receiving thissurvey, and stated they were considering conducting human rights audits of suppliers.
Wacoal holdings stated that they adopted CSR procurement guidelines in 2017 on theoccasion of this survey, and that the guidelines include ‘trainees’ under the TITP.
Wacoal holdings has also started human rights due diligence, and has partiallydisclosed their suppliers.
Sankisyoko (Mikihouse) also adopted the company’s human rights policy and CSR
procurement guidelines in 2017, and is currently establishing a human rights due
diligence and audit process.
TSI holdings started auditing their supply chain.
Ryohin Keikaku has started a third-party audit on a trial basis in 2018, and plans tofirm up the process in 2019.
AEON conducted human rights due diligence for the first time in 2018.
Daidoh commented that, in recent years, it made a point of ensuring that their
suppliers were adequately informed about its code of conduct for suppliers. It also
stated that it conducted third party assessments on their suppliers.
We welcome other improvement reported, for instance, according to recent media
reports, Shimamura issued a notice to all their suppliers to protect the rights of foreignlabourers under the TITP. Nevertheless, as Shimamura did not respond to our survey,we are unaware of the details of this.
We urge the apparel industry to accelerate their measures to strengthen humanrights due diligence.

7Conclusion
There is a distinct gap between, on the one hand, the small number of global apparelcompanies that have human rights policies and implementation mechanisms; and, on
the other, the bulk of Japanese companies. Some Japanese companies have madeprogress in recent years, a trend which we welcome. However, concerns remain thatpeople may be facing serious human rights abuses stemming from the businesspractices of the apparel industry - especially with regard to the companies that did not4

participate the survey.
Media and other reports show that serious human rights abuses in the apparelindustry is not limited to suppliers outside of Japan, but also take place within thecountry, in particular with regard to the TITP. Given that even some major Japanesecompanies did not respond to the survey, there remains a high risk of negative impacts
on human rights within the Japanese apparel industry.
Human Rights Now and Business & Human Rights Resource Centre urge all apparelcompanies and the Japan apparel industry association to commit to implementing thefollowing recommendations.
1

Adopt human rights policies with clear reference to international human rights standards,and communicate to all suppliers and business partners the expectation that they also
respect human rights;.

2

Conduct human rights due diligence, through a transparent process;3

Conduct regular human rights audits;

4

Track and disclose all suppliers;

5

Create detailed codes of conduct in regard to discrimination, harassment, forced labour,child labour, human trafficking, and ensure a living wage for all workers.

6

Investigate as a matter of urgency whether any TITP foreign labourers are employed in
the supply chain. Disclose the results, address any human rights issues, and establish
mechanisms to prevent any abuse;

7

Establish remedy systems accessible to workers and local residents throughout thesupply chain, such as a multi-language hotline.

5