Respecting human rights
Our human

Our approachrights strategy

and progress

Governance andHuman Rights

stakeholder

Impactengagement

Assessments

We operate in parts of the world where
human rights are at risk, and are therefore
exposed to human rights-related issues,
such as forced labor, child labor, bribery, andcorruption.
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 human rights strategy
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 thegrievances 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 the
JT Group Responsible Procurement Policy, JT Group Supplier Standards, and Agricultural Labor
Practices (ALP)
Our human rights strategy is based on five pillars:
1 Embed2 Identify and Prioritize
3 Respond
4 Measure
5 Report
This circular approach provides a systematic way of conducting ongoing due diligence and is in linewith the UN Guiding Principles, the Organisation for Economic Co-operation and Development(OECD) guidelines, and the Food and Agriculture Organization (FAO) guidance on responsible
agricultural supply chains.

Our human rights due diligenceIn 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. As
part of this program, we are committed to assessing 100% of our high-risk countries by 2025, in our
tobacco business.

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 to respecthuman rights andconduct due diligence
never wavered during
the COVID-19 crisis. As acompany, we haveembraced our obligation
to respect human rights
and are committed totackling the challenges
this will bring.

Charlie Watson,
Director, Human Rights, JT
International

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Our approach

Embed
Approach
We are working hard to embed human rights thinking in our Company culture, and to improve
employees’ understanding of the human rights implications of business decisions. To do this, we
provide regular training and continuously share information about human rights and the JT Group
Human Rights Policy.

Our progress
In the digital world, where attention spans are short and content easily disregarded, we have taken adifferent approach to e-learning. In 2020, we laid the groundwork to launch a digital human rights elearning campaign which focuses on behavioral change. The objective is to increase awareness andunderstanding of human rights risks and to empower our employees to do the right thing withregards to ethical behaviors. The campaign will be launched in 2021 ahead of the tenth anniversary

of the UN Guiding Principles. It will offer employees bite-sized training modules via a new humanrights e-learning platform.
Employees in our Japanese operations have completed an online human rights e-learning module,
which was offered in Japanese, English, and Chinese with a completion rate of 92% (*C). The scopeof the training included our subsidiary companies in China and Thailand (processed food business)and the U.S. (pharmaceutical business). In addition, we provide reader-friendly printed
communication materials to over 25,000 employees (*C). The goal is to enhance our employees’
awareness and understanding of human rights.

Identify and prioritize
Our approach
There are a variety of ways in which we identify and understand human rights impacts. Our
approach and methodology is tailored to match exactly what we are assessing. Thanks to thisflexibility, and our unwavering commitment to protecting human rights, we continued to conduct
human rights due diligence throughout the pandemic. For the highest risk human rights countries
within our prioritization matrix, we conduct Human Rights Impact Assessments, while for the lower
ranked high-risk countries, we conduct self-assessment questionnaires.
In line with the UN Guiding Principles, our Human Rights Impact Assessments and self-assessment
questionnaires focus on the greatest risk to people, both within our own Company and throughbusiness relationships with our suppliers, from farm to store. Both tools allow us to address theidentified risks of rights-holders, meet our stakeholder expectations on respecting human rights,
and mitigate the overall risks to people and the business.

Our progress
As part of our commitment to assess 100% of high-risk countries by 2025 in our tobacco business,
we have completed ten Human Rights Impact Assessments across our entire value chain in the last
two years: Bangladesh, Dominican Republic, Egypt, Ethiopia, Kazakhstan, Kyrgyzstan, Malaysia,
Mexico, Myanmar, and Tanzania. This demonstrates our approach to prioritizing, which involves
considering where our 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.
In 2019, we also conducted Human Rights Impact Assessments in our tobacco leaf supply chain invarious markets, including Ethiopia and India. These assessments provide a more comprehensive

understanding of the human rights impacts within one specific part of our value chain – ourtobacco supply chain and tobacco growing business – and the challenges that tobacco growers
face in their communities.
In 2019, we introduced a self-assessment questionnaire to evaluate the human rights profile ofmore countries, to increase the scope and impact of our human rights due diligence. Following thesame methodology as our Human Rights Impact Assessments, this smartly designed survey
targets our lower ranked high-risk countries that have not been prioritized for a full assessment in
the short term.
Piloted in Morocco and Colombia, the questionnaire is designed to identify human rights risks topeople, so that we can act on that information and meet our responsibility to respect human rights.
Effectively assessing human rights impact requires building the know-how of the colleagues
involved in the assessment.
In 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 have done this is by expanding the human rights
self-assessment questionnaires. After the successful roll-out of the self-assessment questionnairein Morocco and Colombia, we launched this tool in a further 10 countries in 2020: Brazil, Guatemala,Indonesia, Lebanon, Russia, South Africa, Thailand, Tunisia, Vietnam, and the United Arab Emirates.
Each self-assessment questionnaire is reviewed by a third party, who assess the findings and any
supporting documentation.
To further increase our human rights due diligence work, we integrated human rights into existingrisk identification tools such as our internal audit procedure. We adapted the methodology toinclude a greater focus on risks to people, rather than simply risks to the business, and trained ourinternal auditors accordingly. This means that our internal audit procedure is now able to identify
and understand risks to people on top of standard audit methodology.
The findings of the internal audit are then shared with our human rights team, helping build a wider
picture of potential risks to people and allowing for more targeted and effective human rights
assessments.
Outside of our international tobacco business, we started conducting due diligence in our
processed food business in China and Thailand in 2019, with the support of KPMG AZSA
Sustainability. This followed the Human Rights Impact Assessment of three of our business
operations – our Japanese domestic tobacco business, pharmaceutical business, and processedfood business – in 2016 and 2018, supported by Ernst & Young. In those three business operationsin Japan, we identified the risks unique to migrant workers as key. Read more about
how we addressed the risks concerning this group.
To identify the most important current and potential risks, we have also applied a smart mix of selfassessment questionnaires and on-site Human Rights Impact Assessments since 2016. The

questionnaires cover a broad spectrum of human rights issues and aim to identify the greatest
potential risks in our operations. Topics include child labor, forced labor, occupational health andsafety, working conditions, social security, discrimination, and grievances, and there is also a special
focus on vulnerable groups such as migrant workers. The questionnaires are followed by on-site
assessments where needed.
In 2019, based on the results of the questionnaires, three out of seven of our subsidiary companies
in China and Thailand were identified as potentially high-risk. We therefore decided to carry out onsite assessments in these three companies to examine the risk in more detail. As a result, we
identified occupational health and safety, working conditions, and social security as risks, and weput robust action plans in place to address these. The plans were agreed between the top
management of these companies, our human rights team, and KPMG Azusa Sustainability. The
necessary improvements have either already been confirmed, or progress is still being monitored.

RespondOur approach

Human Rights Impact Assessments andself-assessment questionnaires are ameans to an end, not an end in themselves.
It’s vital that we act on the information
generated by the assessments in order tomeet our responsibility to respect humanrights.
We develop action plans, with input from thelocal business, employees and communities,
to address issues identified through Human
Rights Impact Assessments and selfassessment questionnaires. These plans
enable us to drive improvements andintegrate human rights into our existing
management processes in a consistent way.
The plans have defined responsibilities, clear
timelines for implementation, and key
performance indicators to monitor progress.

Our progress
We develop human rights action plans for each country that has undertaken an assessment, eachwith an agreed timeline. A total of 32 Human Rights Champions were appointed within thesecountries, as part of a network. The responsibility of this network is to ensure that action plans aremanaged and implemented by each country, and respect for human rights is firmly established in
the business.
The Human Rights Champions are selected by the local management, typically from departments
where human rights risks are relevant. The Champions manage the implementation of the actionplans locally, on top of their usual roles. Our head office provides the Champions with training
materials on the UN Guiding Principles on Business and Human Rights, as well as support withspecific points within the action plans.
In 2019, we carried out a review of our high-risk countries, including a more detailed analysis onwhich countries have the greatest risk to people. Previously, we identified our high-risk countries
using publicly available geopolitical data on human rights. We decided to improve this process by
integrating additional criteria regarding our international tobacco business' operations and impact
into our overall matrix.
The criteria included the number and type of our international tobacco business' operations in eachcountry, historical data from our operational grievance mechanism or Agricultural Labor Practices
program, the health and safety performance of our international tobacco business' operations ineach country, and our salient issues. This improvement to the process ensures we have a much
more accurate picture of our potential risks in each country, and that we are able to prioritize ouractions where they are needed most.

Our progress in Asia including Japan
Since 2018, we have established action plans for 21 key sites in Japan*C, covering the head officesof subsidiary companies in our Japanese operations. We have also agreed action plans for seven of
our subsidiary companies in the processed food business in China and Thailand, as high-riskcountries outside of Japan.
In addition to local efforts, our Japanese headquarters has improved our corporate guidelines toaddress the potential risks relating to migrant workers, identified as the most vulnerable groupthrough our Human Rights Impact Assessments. The number of migrant workers in Japan has
increased rapidly in the past few years accelerated by the revised immigration law. Consequently,
there was a need for common, Group-wide guidelines regarding the hiring and labor management of
migrant workers, aligned with the international norm, the UN Guiding Principles.

We now offer our external Reporting Concerns Mechanism in five languages – Japanese, English,
Chinese, Vietnamese, and Nepali – to give migrant workers easier access to reporting channels.
In addition, we launched a new scheme, in which central management regularly checks theemployment status of migrant workers across our entire Japanese operations. By making sure wehave the most up-to-date information, we can better protect this vulnerable group and address any
potential and actual risks.

Identifying our salient 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.

What is a salient issue?
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. The risks that are viewed as most salient arelikely to converge as a risk to the business.
To identify the salient human rights issues in our value chain, in 2019 we conducted an assessmentwith the support of auditing firm Mazars. This exercise included a review of relevant internal
policies and procedures, and a workshop with internal stakeholders.
A total of 16 human rights issues important to our international tobacco business were presented
and discussed. The idea was to understand which specific activities associated with our businessmay put human rights at risk, so that we can proactively identify those issues to prioritize. Forced &Bonded Labor, Child Labor, and Living Wage were among the seven human rights issues identified
as salient.
To ensure that our ongoing human rights program and due diligence processes already target thesesalient issues, we have integrated them into our Human Rights Impact Assessment methodology
and self-assessment questionnaires. These issues are now also included in our methodology for
identifying high-risk countries, which helps us to prioritize our due diligence process based onwhere our greatest potential impacts lie.

In 2020, with the support of external experts, we undertook a new project to identify salient humanrights issues for the JT Group. Once finalized, these salient human rights issues will be disclosed
and reflected in our human rights reporting, as per the UN Guiding Principles Reporting Framework.
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Governance and stakeholder engagement
Given the breadth of the JT Group’s operations around the world, it was critical to establish an
appropriate governance structure. We believe it is important to embed respect for human rights
throughout our entire organizational structure. This is driven by our dedicated human rights team,which is responsible for raising awareness and improving engagement internally. JT Group’s top
management is committed to respecting human rights. The senior management of all JT Groupbusinesses attend a regular forum, our Business Ethics Committee*E, to discuss key agendas forsustainability, including human rights.
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. For this reason, theestablishment of a Human Rights Champions Network was central to our governance structure in
2018. This network comprises employees from the countries in which we have conducted Human
Rights Impact Assessments, and facilitates the sharing of guidance and best practice on humanrights by those closest to the issues on the ground.
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.
To further strengthen our external engagement, we have partnered with Business for Social
Responsibility (BSR) and (until 2019) KPMG Azusa Sustainability. These organizations provide
technical support with our ongoing human rights due diligence approach and overall human rights
strategy.

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
implementation of our human rights strategy. The panel of experts guides us with their expertiseand challenges us where they believe we need to improve, helping to strengthen our efforts todeliver on our human rights 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 (Paul Hastings)■

Richard Karmel (Mazars)

Protecting and respecting employee rights during
the pandemic
The 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 human rights standpoint,
which we will reflect upon in the next phase of implementation.
To ensure our response followed human rights best practice, we are completing the ‘United Nations
Development Program Human Rights Due Diligence and COVID-19: Rapid Self-Assessment for
Business’. This provides a structure for our response and ensures that we make rights-respecting
decisions across the business.
From the start of the pandemic, we made decisions that helped protect and respect our employees’rights.

Guidelines for vulnerable employees
In June 2020, we created guidelines for vulnerable employees providing comprehensive guidanceon how to protect our personnel. We also ensured that staff from third-party contractors (hygiene,catering, security, etc.) would receive salaries in full, even if they were requested not to come to our
premises or their shifts were reduced.

Inclusive decision-making
In our international tobacco business, we involved relevant stakeholders in critical decision-making
processes. This included debating and deliberating on return-to-work scenarios, ensuring we
considered everything from our employees’ point of view. Returning to the office is currently
voluntary, with a survey held every two weeks to gauge feedback from employees working at theheadquarters of our international tobacco business. Based on their knowledge of the changes andadaptations made in their workspace, employees have the freedom to decide whether it is be safefor them to return to work.

Strict health and safety measures
For many of our employees and contractors, working-from-home is not an option, because theywork in factories, sales distribution, and other field-based jobs. To ensure they can work safely, we
put in place stringent measures, using a risk-based approach that puts people first.

Clear communication
Finally, we provided scientifically accurate information – using clear, easy-to-understand language –to staff on a regular basis. This included the multiple steps taken to protect employees, as well as
data relating to those impacted by COVID-19 both globally and locally.
Read more about how we have responded to the pandemic from the perspective ofCommunity Investment, Health & Safety and Supply Chain.

MeasureWe are committed to continually measuring the effectiveness of, and improving where possible, ourapproach to respecting human rights.
Since we started our Human Rights Impact Assessments in 2016, we have been measuring theeffectiveness of our Action Plans. Each Action Plan we develop includes an individual set of key
performance indicators to measure the effectiveness of our improvements over time. For ourHuman Rights Champions, we track the implementation of each action item and report on aquarterly basis to the human rights team. All human rights action plans are discussed on a quarterly
basis with selected Management to measure progress.
There are various ways to measure the effectiveness of our responses in our leaf supply chain. Oneof them is the number of issues which we observe during subsequent crop cycles. Read more on
our approach.

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 weare taking 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.
Read more on our individual assessments and action plans.
In 2019, we published our human rights correspondencewith Human Rights Watch, the UN

Human Rights Council, and The Guardian on our website.

Programs
To address our human rights issues, markets put in place their own customized corrective
measures through 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

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

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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 and used different tools where necessary.
Unable to conduct on-site assessments due to the pandemic, we quickly introduced remote Human
Rights Impact Assessments and expanded the roll-out of our human rights self-assessment
questionnaires. These consist of around 100 questions based on our human rights due diligence
methodology. Focusing on procedures and processes, the questionnaires help us to assess theeffectiveness of our work on the ground and identify any ‘blind spots’.
As the year progressed, we added specific COVID-19 risk-related questions. These covered subjects
such as personal protective equipment, working from home, and procedures for returning to theoffice.
Rightsholder involvement and consultation is a fundamental component of effective due diligence,so we plan to include this element in our self-assessment questionnaire in 2021.

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
Bangladesh (2019)

Kazakhstan &Colombia (2020)

Kyrgyzstan (2019)

Dominican Republic(2018)

Malaysia (2018)

China (2019)

Myanmar (2018)

India (2019)

Vietnam (2020)

Japan (2016/2017)

Thailand (2019)

Mexico (2018)

Africa, Middle

EuropeEast

Switzerland (2017)

Egypt (2019)
Ethiopia (2019)
Lebanon (2020)
Malawi (2019)
Morocco (2020)
South-Africa (2020)
Tanzania (2018)
Tunisia (2020)
Zimbabwe (2019)

Case study

Using leverage with our leaf merchants
The UN Guiding Principles recommend the following:

UN Guiding Principle 13 (b):The responsibility to respect human rights requires that business enterprises seek toprevent or mitigate adverse impacts that are directly linked to their operations, products orservices by their business relationships, even if they have not contributed to those impacts.
UN Guiding Principle 19 (b) (ii):
In order to prevent and mitigate adverse human rights impacts, business enterprises should
integrate the findings from their impact assessments (…) and take appropriate action.
Appropriate action will vary according to (…) the extent of its leverage in addressing theadverse impact.
With this in mind, we have been receiving Agricultural Labor Practices reports from major
suppliers since 2016. Through these, we recognized Crop Protection Agent management
challenges in Zimbabwe. We have been looking for solutions beyond providing PersonalProtective Equipment, which led us to initiate a Highly Hazardous Pesticide response.
In May 2018, we received a letter from the United Nations Office of the High Commissioner
for Human Rights that highlighted several alleged human rights violations such as childlabor, health and safety, and a variety of labor rights abuses in tobacco growing in
Zimbabwe.
Although we have no operations in Zimbabwe and only purchase tobacco leaf through leaf
merchants (third-party suppliers), we were still connected through our business relationship.
The purchasing entity of our international tobacco business used its commercial leveragewith the suppliers to reduce the risk of harm occurring. The local entity of our international
tobacco business worked alongside some of our biggest leaf merchants – Alliance One
International, Inc. (AOI), Premium Tobacco International DMCC (Premium), and Universal
Leaf Tobacco Company, Inc., CONTRAF-NICOTEX-TOBACCO GmbH – to encourage
suppliers to adopt and implement the UN Guiding Principles on Business and Human Rights.
Where necessary, we also recommended changes to their business practices, not just in
Zimbabwe but globally.
All of our suppliers engaged positively and made the following commitments:

■Eliminate the use of the most hazardous pesticides to human health – Highly Hazardous
Pesticides Criteria 1 – by the end of 2021■

Develop a human rights policy approved at the most senior level of their organization andmake it publicly available■

Develop an industry-wide grievance mechanism■

Focus efforts on six key issues identified as having the potential to cause the most
severe harm and that are most likely to occur: exposure of workers to hazardous
substances, land rights, child labor, gender discrimination, freedom of association, andenvironmental impacts

We also engaged in open dialogue with the Zimbabwe Ministry of Labor, the Tobacco
Industry and Marketing Board, the Tobacco Research Board, and the National Employment
Council for Agriculture and Tobacco.
We will monitor the commitments our suppliers have made and continue to work with themto ensure the best possible outcome for those impacted.
Read our full correspondence
for Human Rights.

with the United Nations Office of the High Commissioner

Case study

Eliminating Highly Hazardous Pesticides Criteria
1 in our supply chain
To protect people and the environment, our objective is to phase out the use of Highly Hazardous
Pesticides (HHPs) Criteria 1 from our leaf supply chain by the end of 2021.
HHPs Criteria 1 are pesticide formulations that meet the criteria of hazard classes 1a and 1b of theWorld Health Organization Recommended Classification of Pesticides by Hazard.
Our suppliers have committed to an assessment by country to identify any HHPs Criteria 1 which
are still registered, recommended, or used in tobacco production. They will also identify available
alternatives, prioritizing Bio Crop Protection Agents. There will be a special focus on eliminating
HHPs Criteria 1 Pyrethroids insecticides as part of our 2021 commitment.

External recognition
We were categorized as a ‘leader’ by the Global Child Forum in their latest study, conducted incollaboration with the Boston Consulting Group. This benchmark report analyses just under 700 of
the world’s largest companies and how they are safeguarding children’s rights as part of theirbusiness value chain.
We are proud that the study recognizes the concrete actions we have taken to embed respect forchildren’s rights in our supply chain, notably through our flagship child labor elimination program
ARISE.

Going forward
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 isongoing, 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.
In our international tobacco business for 2021, we will continue to prioritize countries based on aset of risk-based criteria in order to assess our most high-risk countries first. Going forward, we arecommitted to assessing actual and potential human rights risks in at least six countries each year
and will continue to embed respect for human rights within the business.
In our Japanese operations, we will carry on monitoring the progress of our Human Rights Impact
Assessment action plans and provide the necessary support to ensure that they are implemented.
Given the increase in migrant workers since Japan’s immigration policy was revised in April 2019 we
made minor changes to the Group-wide guidelines for migrant workers, in line with Japan’s revised
immigration law. Unfortunately, due to COVID-related travel restrictions, we had to postpone thefollow-up of the Human Rights Impact Assessments we conducted in 2017 in our processed foodbusiness, focusing on migrant workers. However, we conducted self-assessment questionnaires inthe subsidiaries of our processed food business which relate to labor management, targeting not
only migrant workers but all employees.

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

Read more

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