Respecting human rights
Commitment

Strategy

GovernanceSalient issues

ImpactDue diligenceassessments

Stakeholder

andengagement

Going forward

questionnaires

We operate in parts of the world where
human rights are at risk, and we are
therefore exposed to human rights-related
issues, such as forced labor, child labor,
bribery, and corruption.
Our sustainability strategy is driven by threeabsolute requirements that are at the heartof everything we do. One of theserequirements is respecting human rights.

JT Group Human Rights Report

To coincide with the 10th anniversary of theUnited Nations Guiding Principles on
Business and Human Rights, we are
publishing our first standalone Human
Rights Report which examines the potential
human rights risks arising from ourworldwide operations. The report identifies
nine salient human rights issues and thesteps we are taking to remedy them.
JT Group Human Rights Report

Our commitment

JT Group Human Rights Policy
We respect human rights across our value chain and recognize the Universal Declaration of Human
Rights, the International Bill of Human Rights, and the International Labor Organization’s Declaration
on Fundamental Principles and Rights at Work. Our JT Group Human Rights Policy, which wasapproved by the JT Board of Directors, follows the framework provided by the UN Guiding Principles
on Business and Human Rights. This means working to avoid infringing the rights of others andaddressing any adverse impacts of our global operations.
Our commitment to human rights is reinforced by our Board of Directors through our
Code of Conduct. Our Reporting Concerns Mechanism helps us ensure that we listen to and act on
the grievances of those whose human rights might be impacted by our activities. Through thislegitimate, fair, and accessible mechanism, we encourage employees and suppliers to speak up on
human rights, without fear of retribution, about any concerns they may have.
Our suppliers and growers throughout the world are obliged to respect human rights by adopting
and maintaining internationally recognized labor standards regarding child labor, rights of workers,
and workplace health and safety. They do this in line with:■

JT Group Responsible Procurement Policy■

JT Group Supplier Standards■

Agricultural Labor Practices (ALP)

To address our human rights issues, markets put in place their own customized corrective measuresthrough human rights action plans. We also have global programs that can be applied by the local

markets to ensure a consistent approach across the Group. Read more:
Code of Conduct
JT Group health and safety
Agricultural Labor Practices
Our ARISE (Achieving Reduction of Child Labor in Support of Education) program
Community Investment
Diversity and inclusion

UK Modern Slavery Act
JTI UK, the JT Group’s U.K. subsidiary, has been publishing a Modern Slavery Act Statement yearly
since 2017.
JTI UK Modern Slavery Statement (JTI UK Website)

The UN Guiding
Principles on Businessand Human Rights makethe pathway clear:companies have a
responsibility to respect
the rights of those they
impact through theirbusiness operations andsupply chains. That is
especially importantduring a global
pandemic. Ourcommitment torespecting human rights
and to conducting due
diligence never wavered
during the COVID-19
crisis. Our people, oursuppliers, and ourcommunities make us
who we are, and it is vitalthat we continue to carefor them, hear their voice,and respect their humanrights.

Charlie Watson,
Director, Human Rights, JT
International

Our human rights strategy

Our approach
Our human rights strategy is based on fivepillars. This circular approach provides asystematic way of conducting ongoing due
diligence and is in line with the UN Guiding
Principles on Business and Human Rights,
the Organisation for Economic Co-operation
and Development (OECD) guidelines, and the
Food and Agriculture Organization (FAO)
guidance on responsible agricultural supply
chains.

1 Embed2 Identify and Prioritize
3 Respond
4 Measure5 Report

Read more on ‘Strategy’ in our Human Rights
report.

Our progress
Embed
Since 2016 we have been continuously providing trainings in the entire group. The contents of ourvery first e-learning on respecting human rights was totally aligned to the UN Guiding Principles, andwas implemented from 2016 to 2019. The e-learning has been provided in 25 languages to all our
employees, regardless of their employment status, such as directly or indirectly employed, and full orpart-timers.
In the digital world, where attention spans are short and content easily disregarded, we have taken adifferent approach to e-learning.
In 2021, we laid the groundwork to launch a digital human rights e-learning campaign which focuseson behavioral change. The objective is to increase awareness and understanding of human rights
risks and to empower our employees to do the right thing with regards to ethical behaviors. It offers
employees bite-sized training modules via a new human rights e-learning platform.
For our most recent approach, please read more on ‘Culture change through training’ in our
Human Rights report.

Identify and prioritize
From 2020, with our ability to conduct in-person Human Rights Impact Assessments disrupted by
the pandemic, we had to adapt. One of the ways we did this is by expanding the human rights selfassessment questionnaires.
We applied a smart mix of self-assessment questionnaires and on-site Human Rights Impact
Assessments. The questionnaires cover a broad spectrum of human rights issues and aim to
identify the greatest potential risks in our operations, which include

our nine salient human rights issues.
In 2021, we upgraded the self-assessment questionnaire by enhancing its focus on the newly
established salient issues. We also included questions related to how our markets were
implementing new COVID-related guidelines and controls.
In 2021, the self-assessment questionnaire was launched in five new markets: Angola, Cambodia,
Jordan, Nigeria, and Romania.
Read more:■‘Our assessments’ in our Human Rights report■

Human rights impact assessments: key findings

Respond
We develop human rights action plans for each country that has undertaken an assessment, eachwith an agreed timeline. Human Rights Champions were appointed within these countries, as part ofa network. The responsibility of this network is to ensure that action plans are managed andimplemented by each country, and respect for human rights is firmly established in the business.
The Human Rights Champions manage the implementation of the action plans locally. Our head
office provides the Champions with training materials on the UN Guiding Principles on Business andHuman Rights, as well as support with specific points within the action plans.
Read more:■‘Role of local governance’ in our Human Rights report■

Human rights impact assessments: key findings

MeasureWe have been measuring the effectiveness of our Action Plans, which includes an individual set of
key performance indicators to measure the effectiveness of our improvements over time. Our
Human Rights Champions track the implementation of each action item and report on a quarterly
basis to the human rights team to measure progress.
There are various ways to measure the effectiveness of our responses in our leaf supply chain. One

of them is the number of issues which we observe during subsequent crop cycles. Read more on
our approach.
Read more on Progress toward quantitative target

ReportOur understanding of our obligations under the UN Guiding Principles is to ‘know and show’ that weare aware of the potential human rights related risks to which we may be connected, and that we aretaking appropriate steps to manage those that occur. The UN Guiding Principles encourage
corporate transparency to the benefit of a broad set of stakeholders. We are committed to this levelof transparency and disclosure.
■

JT Group Human Rights Report■

Integrated Report■

Our human rights correspondenceswith Human Rights Watch, the UN Human Rights Council,

and The Guardian.

Governance
Our CEO and the Board of Directors play a key role in formulating the JT Group Sustainability
Strategy, which has respect for human rights at its core. They oversee and are accountable for theeffectiveness of this strategy, as they are committed to the Group achieving its sustainability
targets. The Chief Sustainability Officer is responsible for driving sustainability across the Group,
including respect for human rights.
While our CEO and Board of Directors are accountable for the strategy, governance, and reporting ofadherence to the JT Group Human Rights Policy, each local business unit is responsible for
operational implementation and has an appropriate management system to apply human rights
initiatives. This is driven by our dedicated human rights team, which is also responsible for raisingawareness and improving engagement internally.
To secure an effective due diligence system, it is critical to link impact assessments to effective
governance structures that ensure accountability for acting on the findings. The Human Rights
Champions Network plays a vital role to facilitate the sharing of guidance and best practice onhuman rights by those closest to the issues on the ground.
Read more on ‘Board oversight and governance’ in our Human Rights report.

To advance the rights of our stakeholders, it is important that we listen to the advice, concerns, andcriticisms of people outside the JT Group. Therefore, we have continued to take counsel from our
Human Rights External Advisory Board.

Human rights external advisory board*E

Our Human Rights External Advisory Board plays a vital role in providing us with a broad external
perspective in the human rights area. Made up of international experts on business and humanrights, the Board advises us on all issues that the members consider relevant for the implementationof our human rights strategy. The panel of experts guides us with their expertise and challenges us
where they believe we need to improve, helping to strengthen our efforts to deliver on our humanrights commitments.
Board members include:■

Paul Bowden (Professor of Law, The Nottingham Law School)■

Donna L. Westerman (Sustainable Purchasing Leadership Council)■

Rona Starr (Association for Professional Social Compliance Auditors)■

Jonathan Drimmer (Partner, Paul Hastings (a leading international law firm))■

Richard Karmel (London Managing Partner, Global Sustainability, Mazars (a leading international
audit, tax and advisory firm))

Salient human rights issues
To strengthen the focus of our policies and programs on human rights areas that matter most, it is
crucial to have an understanding of our respective salient human rights issues.
According to the UN Guiding Principles Reporting Framework, “a company’s salient human rights
issues are those human rights that stand out because they are at risk of the most severe negative
impact through the company’s activities or business relationships.”
The concept of salience focuses on the risk to people, not to the business, and impacts areprioritized according to their severity and likelihood.

We created our first group human rights risk maps to assist us in developing JT Group Human
Rights Policy in 2016. As external and internal environments have evolved, we have reviewed ourgroup salient issues in 2021. This resulted in the identification of nine salient issues associated with
our own operations, value chain and new business relationships.
Going forward, our plan is to corroborate these salient issues with rights-holders on the ground. This
will enable us to better understand and focus our efforts and resources on those issues perceived
most at risk in each market. We will do this by integrating them into our Human Rights Impact
Assessment methodology and self-assessment questionnaires.

Our nine salient issues
Identification of salient issues
In order to identify the salient human rights issues for the JT Group, the assessment was conductedin two aspects, Severity and Likelihood, in line with the UN Guiding Principles on Business andHuman Rights. Firstly, we identified the full range of human rights that could potentially be
negatively impacted by our activities or through its business relationships. We then prioritized
potential negative impacts by using severity and likelihood framework.

Severity assessment
Severity of human rights impacts were assessed by their scale, scope, and irremediability, whichmeans how grave the impact would be, how widespread the impact would be, and how hard it would
be to put right the resulting harm. Based on that framework, we identified the severity of eachhuman rights issue using a scoring system for risk mapping.

Likelihood assessment
In assessing the likelihood of human rights issues in the JT Group, the following steps were taken.
We analyzed the operations of our entire value chain (in over 130 countries) across five categories;
Leaf sourcing, Processing, Manufacturing, Office, and Sales and Marketing. We determinedmagnitudes of risk for each operational category in each country. We then quantified each risk using
environmental and social country indices published by a leading global risk analytics company, andusing country indices published by international organizations.

Risk mapping
These mapping exercises were carried out for all three of our businesses; tobacco, pharmaceuticals,
and processed food. In the consolidated map of those businesses, the issues of high severity andhigh likelihood were finally identified as salient in the JT Group.
■Child labor■

Environmental impacts■

Fair wage■

Forced labor■

Harassment and gender impacts■

Health and safety■

Health risk■

Non-discrimination and equality■

Working hours

Read more on ‘Salient issues’ in our Human Rights report.

Our human rights due diligenceIn line with the UN Guiding Principles, we have made human rights due diligence an essential andintegrated part of our business. This enables us to identify and assess actual and potential humanrights risks, as stated in our JT Group Human Rights Policy.
Embedding human rights due diligence – which is in part informed by our widely applied Human
Rights Impact Assessments – is our responsibility. It helps us to prevent adverse impacts on people
and ensure the highest standards of behavior are upheld within our business and value chain.

Progress toward quantitative targetWe have committed to assessing 100% of high-risk countries by 2025.
In addition to the high-risk countries identified, we completed the assessment in Japan where ourheadquarters and many subsidiary companies are located, given its scale of businesses; tobacco,
pharmaceuticals, and processed food. We also conducted the assessment in Switzerland,
headquarters of our international tobacco business, and also in China and Thailand for our
processed food business.
In our tobacco business, we assessed five new markets in 2021: Angola, Cambodia, Jordan, Nigeria,
and Romania. In total, we completed 10 Human Rights Impact Assessments and 17 selfassessment questionnaires across our entire value chain. We also conducted one
Supply Chain Impact Assessment (SCIA) one Grower Livelihoods Assessment and used ourleverage to conduct a supplier human rights workshop. By the end of the year, 30 out of 67 (45%)
high-risk countries had been assessed. This reflects our commitment to prioritizing assessments incountries where the greatest risks to people lie. It also shows our willingness to go into countries
with histories of human rights allegations and assess the on-the-ground reality.
Read more:■‘Our assessments’ in our Human Rights report■

Human rights impact assessments: key findings

Human rights impact assessments and selfassessment questionnaires

Our Human Rights Impact Assessments focus on impacts to people within our main operations andvalue streams. Key activities during an impact assessment include visiting and observing farming,
processing, manufacturing, and sales and distribution operations. During the assessments, we
conduct a series of interviews with employees and workers, as well as representatives of suppliers,
clients, and partners.
At the end of the assessment, we report on the findings and discuss recommendations for
improvement with local management. Our head office then works closely with the local team toaddress any issues raised and improve the situation.

Adapting our approach to ensure continuity
Our commitment to conducting human rights due diligence as part of our Human Rights Policy
never wavered during the pandemic. To ensure continuity and protect everyone involved, we tailored
our approach in our assessments.
Read more on our new approach on COVID-19 human rights response.

Human rights impact assessments: key findings
The following list of key findings includes one human rights risk identified in each of ourassessments, to demonstrate the wide range of issues our stakeholders may face.

Read more about key findings and how we are
addressing them by selecting a country
Asia, Americas

Africa, Middle EastEurope

Bangladesh (2019)

Kazakhstan &Egypt (2019)

Brazil (2020)

Kyrgyzstan (2019)

Ethiopia (2019)

China (2019)

Malaysia (2018)

Lebanon (2020)

Colombia (2020)

Mexico (2018)

Malawi (2019)

Dominican Republic(2018)

Myanmar (2018)

Morocco (2020)

Thailand (2019)

South-Africa (2020)

India (2019)

Thailand (2020)

Tanzania (2018)

Indonesia (2020)

Vietnam (2020)

Tunisia (2020)

Japan (2016/2017)

Turkey (2020)
UAE (2020)
Zimbabwe (2019)

Switzerland (2017)

Case study

Using leverage with our leaf merchants in
Zimbabwe

Case study

Eliminating highly hazardous pesticides criteria 1
in our supply chain

Case study

Migrant Workers in Japan
Japan’s Technical Intern Training Program was further sensitized to the risk of forced labor by arecent US Trafficking in Persons Report. Since we started Human Rights Impact Assessments in ourJapan operation (tobacco, pharma, and processed food businesses - including China and Thailand),migrant workers have been identified as the most vulnerable stakeholders who need our special
attention.
Read more on how we have addressed a focus on migrant workers in our Human Rights report.

Stakeholder engagement
To further strengthen our external engagement, we have partnered with Business for Social
Responsibility (BSR) and Mazars. These organizations provide technical support with our ongoing
human rights due diligence approach and overall human rights strategy.
Read more on ‘Engagement’ in our Human Rights report.

Protecting and respecting employee rights during
the pandemic
Our human rights external advisory board was very positive about our response to COVID-19. The
Board has provided feedback and recommendations to our response to the pandemic from a humanrights standpoint, which we will reflect upon in the next phase of implementation.
Read more on how we have responded to the pandemic in our Human Rights report.

Read more about how we have responded to the pandemic from the perspective ofCommunity Investment and Health & Safety.

Going forward
In terms of our global sustainability strategy, we have identified priority areas for each businesssegment. Moreover, we have defined a set of targets we aim to achieve by 2030. Our targets are a
key component of our commitment to conduct our business in a responsible manner and mitigate
our nine human rights salient issues. We keep our existing targets under review with an intention tostrengthen these commitments over time.
Read more on our strategy, targets, and progress in our Human Rights Report.

Our work to promote and respect human rights will evolve and adapt to the changing economic andpolitical context of the countries where we operate. Our approach to human rights due diligence isongoing, as the risks to human rights may change over time. We will continue to act where actions
are necessary and focus on our human rights priority areas.
We will continue to prioritize countries based on a set of risk-based criteria in order to assess ourmost high-risk countries first. Going forward, we are committed to assessing actual and potential
human rights risks in at least six countries each year and will continue to embed respect for humanrights within the business.

About our reporting
Our referenced guidelines(GRI), notes
on data (BoR), and scope of our data(*A-E).

Read more

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