Asahi Group
Responsible Procurement Supplier Guidelines

Please email your relevant Asahi procurement
relationship owner if you have any concerns,
queries or need additional assistance inunderstanding or implementing the Guidelines.

1. The Program

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. AppendicesContents
1–3

Introduction
Objective
Scope and applicability
How to use the Guidelines

1. Responsible Procurement Program

4 – 13

2. Grievance mechanisms

14 – 15

3. Implementation guidance

16 – 34

4. Questions

35 – 36

5. Glossary of terms

37 – 40

6. Appendices

41 – 43

6.1 Related Asahi Responsible Procurement frameworks,
policies and guidance material
6.2 Additional resources for Supplier Code of Conduct implementation
6.3 Policy review

Asahi Group Responsible Procurement – Supplier Guidelines | 2

1. The Program

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Introduction
At the Asahi Group (also ‘Asahi’, ‘we’, ‘our’), we source products and services from across the world. Dueto the nature and scale of our business, we have significant potential to drive positive social andenvironmental outcomes through our procurement activity. We expect strong social and environmental
standards from our suppliers and aim to support our suppliers to implement more sustainable practices.

Scope and applicability

We have developed our Asahi Responsible Procurement Program (the ‘Program’) to operationalize ourambition to protect the human rights of workers and communities in our supply chains and safeguard
nature.

The Guidelines apply to all prospective suppliers interested in participating inan Asahi sourcing tender, and all existing suppliers with active sourcing
contracts. Existing and prospective suppliers receive the Guidelines, thePolicy and Code of Conduct when they become registered suppliers via theregistration link to Asahi’s supplier management system.

The Program is supported by a set of policies which are designed to assist Asahi’s suppliers to uplift theirbusiness practices:

How to use the Guidelines•

Asahi Group Responsible Procurement Policy (the ‘Policy’)•

Asahi Group Global Supplier Code of Conduct (the ‘Supplier Code of Conduct’)•Asahi Group Responsible Procurement - Supplier Guidelines (the ‘Guidelines’)•

Asahi Group Human Rights Principles•

Asahi Group Environmental Principles

The Guidelines are for use by all registered suppliers as guidance material forunderstanding how to interact with the Program and conform with therequirements set out in the Policy and Code of Conduct.
Interested suppliers may also refer to the Guidelines to understand Asahi’s
Responsible Procurement expectations prior to registration.

These Guidelines outline the process by which Asahi’s suppliers are to engage with the Program andcommunicate evidence of compliance with the requirements set out in the Policy.

Our focus areas
The Asahi Group is committed to respecting internationally recognized human rights. Asahi has
determined the following as key focus areas to inform our Responsible Procurement (Human Rights)
strategy and roadmap.
Child labor
Safe and decent work conditions

Responsible recruitment

Fair wages

Working hours

Treat workers equitably

The Guidelines are publicly available and shared with suppliers during supplierregistration.
Bolded terms indicate that the relevant definition is outlined in the Glossary ofTerms.

Asahi Group Responsible Procurement – Supplier Guidelines | 3

Responsible Procurement Program1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Responsible Procurement Program
The Program outlines Asahi’s process for monitoring, verifying and managing supplier performance in line with the requirements set out in the Supplier Code of Conduct, the Policy and supporting
Guidelines. This approach is designed to formalise a continuous improvement approach and integrate broader stakeholder feedback into the Program. Our approach to addressing supplier risk forsuppliers in scope of the Program is detailed throughout the following sections.
The below diagram outlines the process by which prospective suppliers will interact with the Program.

Click on each sub-heading to jump to the relevant section of the Guidelines.

1. Supplier
Registration

2. Source to Contract

Request for Proposal

Risk checkpoints

3. Ongoing Management

Contracting

Ongoingmanagement SAQs

Third-party audits

Supplier
management
plan monitoring

Suppliers are assigned risk ratings throughout the process (risk checkpoints), which determines requirements for further due diligence activities. Specificdue diligence requirements will be communicated to suppliers at each stage of the process based on their risk outcome.

Asahi Group Responsible Procurement – Supplier Guidelines | 5

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. AppendicesStage 1 - Supplier registration
All prospective suppliers are required to register on Asahi’s suppliermanagement system (SAP Ariba) and attest to relevant Asahi policies
to become registered suppliers.

1. Supplier Registration

Prospective suppliercompletes registrationquestionnaire, including
attestation to the Supplier
Code of Conduct and
the Policy.

Supplier confirmation of compliance•

All prospective suppliers and existing suppliers are required to attest to thefollowing policies during the registration stage:•

Asahi Group Supplier Code of Conduct (the ‘Supplier Code of Conduct’);and•Asahi Group Responsible Procurement Policy (the ‘Policy’).

2. Source to Contract

Supplier enters Source toContract stage as a registeredsupplier.

•

The Supplier Code of Conduct, Policy and the Guidelines are shared with
suppliers via SAP Ariba upon registration to the platform.

•

Acceptance of the Policy and the Supplier Code of Conduct by attestation
results in Asahi approval to progress to the Source to Contract stage.

Asahi Group Responsible Procurement – Supplier Guidelines | 6

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. AppendicesStage 2 - Source to contract
3. Ongoing
Management

2. Source to Contract

Suppliers are assigned a risk grouping during these stages
Qualified suppliersubmits information
relating to category
and country of goods
or services procured,and prospective
spend

Supplier completes
pre-screening
questionnaire andoptionally, uploads
any third-party
product certifications

Who is subject to Asahi’s
due diligence activities?
•

Active management suppliers aresuppliers within scope of the Program’s
due diligence activities.

•

Active management suppliers will be
subject to pre-screening due diligence
activities prior to contract signing toassess the suitability of the supplierbased on their risk profile and thematurity of their controls.

Supplier
becomes eligible
to participate inan RfP

Specific to the risk grouping,supplier may be required toundergo a qualification audit orprovide a valid third-party
product certification

Supplierawarded andaccepts Asahi
sourcing
contract

Supplier may besubject to ongoing
management which
may include due
diligence, based on
assigned risk grouping

Pre-screening
Registered suppliers are required to undergo pre-screening due diligence activities aimed at determining the high-level existence of controls
for managing human rights risks in their own operations and supply chain. The outcome of these pre-screening due diligence activities
determines whether a supplier qualifies to participate in an Asahi sourcing Request for Proposal (RfP) and if additional pre-screening due
diligence activities are required.

Pre-screening questionnaire•

Suppliers may be required to complete a pre-screening questionnaire. The pre-screening questionnaire is designed to identify risk factors
present in the supplier’s operations and supply chain and assess the existence of controls at a high level. Completion of the pre-screening
questionnaire, where relevant, is a pre-requisite to participating in an RfP.

•

The supplier’s assigned risk grouping determines which, if any, additional pre-screening due diligence activities are required prior toawarding an Asahi sourcing contract or purchase order.
Asahi Group Responsible Procurement – Supplier Guidelines | 7

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. AppendicesQualification audit•

Qualified suppliers may be required to undergo aqualification audit and/or develop and implement a
Responsible Procurement Supplier Management Plan (SMP).

•

As an alternative to undergoing a qualification audit,
qualified suppliers may submit and confirm the validityof one of the following:•

Being responsible for the cost of the third-party audit, relevant suppliers may select an audit company of their choice,which must, at a minimum, satisfy the criteria set out in Table 1: Third-party auditor selection criteria. Any exceptions tothis requirement will be assessed on a case-by-case basis.
Table 1: Third-party auditor selection criteria✓ Demonstrate the capability to deliver the planned auditing activities, given the location, scale and scopeof audit activities

1. A third-party product certification from the list of
approved certifications in section Third-party productcertification assessment; or•

2. A third-party audit report conducted at least 12 months
prior to the supplier’s notification of the need to undergo
a qualification audit.

✓ Have the capacity to apply one or more of the approved audit programs in delivering the audit

Where audits are required, they must be booked within 30 daysof the supplier being notified, and follow the same methodology
as detailed in section Third-party audits.

✓ Have systems and processes in place to enable delivery of transparent, accurate and complete audit findingssuch as an audit quality program✓ Audit companies/auditors are registered and/or preferably certified to the Association of Professional Social
Auditors (APSCA)✓ Have not been the subject of allegations relating to fraud, corruption, and deception••

Asahi reserves the right to disqualify any certification body/auditor.
Asahi may choose to develop and implement a Supplier Management Plan as a result of pre-screening due
diligence activities. Asahi will notify and consult with the supplier through this process, where required.

Asahi Group Responsible Procurement – Supplier Guidelines | 8

1. The Program
DRAFT

2. Grievance mechanisms

Third-party product certification assessment

3. Implementation guidance

Therefore, when deciding the extent and cadence ofoversight required in the ongoing management
phase, Asahi views a supplier's third-party productcertification as a key factor. Asahi gives preference
to buying products that have been independently
certified and prioritizes sourcing the following
commodities that are certified under the schemes
set out in Table 2: Third-party product certifications.

5. Glossary of terms

Paperproducts

Prioritised certification schemes

Tea

Certification type•

Paper certified by the Forest Stewardship Council (FSC) or Programme for theEndorsement of Forest Certification (PEFC).

•

Coffee product suppliers who are able to provide evidence of coffee productionthat generates positive and mitigates negative social and environmental outcomesthroughout the value chain. Asahi may accept Fairtrade International andRainforest Alliance certified products.

•

Fairtrade International and Rainforest Alliance independently certified tea
products.

CoffeeCocoa•

Fairtrade International and Rainforest Alliance independently certified cocoa
products.

Third-party product certification –What do I need to do as a supplier?

All types

Relating to Rainforest Alliance:• Rainforest Alliance Sustainable
Agriculture Supply Chain
Certification• Rainforest Alliance Sustainable
Agriculture Farm Certification

Relating to Fairtrade:• Fairtrade Product Certification• Fairtrade Trader Certification•
Palm oil•Roundtable on Sustainable Palm Oil (RSPO) independently certified palm oil
products, derivatives, and fractions.

•

Bonsucro and Fairtrade International independently certified sugarcane
products.

•

Recognised farm-level assessments include SAI Platform’s Farm Sustainability
Assessment (FSA) Gold and Silver performance level sites.

☐ Confirm which third-party productcertification is applicable☐ Provide a copy of the valid certification☐ Notify Asahi if the certification has beensuspended/expired. In case of expiry,
the supplier is required to provide themost up to date certification to Asahi.

6. Appendices

Table 2: Third-party product certifications

Commodity

Asahi views third-party product certification
as a component of its risk management approach,supplementing our own due diligence processes.
Asahi recognizes that certification programs often
carry out continuous checks and confirmations.

4. Questions

Sugarcane

Barley/Malt••

RSPO Principles and Criteria(P&C) Certificate
RSPO Supply Chain Certificate
RSPO Independent Smallholder(ISH) Certificate••

Bonsucro Production Certificate
Bonsucro Chain of Custody
Certificate•

FSA SAI Letter of Attestation –Gold and Silver performance levels

Asahi Group Responsible Procurement – Supplier Guidelines | 9

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Following the contracting stage, active management suppliers will be subject to ongoing management due diligence activities.

The nature of these ongoing management due diligence activities differs according to the outcome of the supplier’s pre-screening questionnaire, and whether the supplier holds valid andapproved third-party product certifications.

Stage 3 - Ongoing management
Diagram 1: Ongoing management SAQ and audit requirements

Ongoing management self-assessment
questionnaires (SAQs)•

Depending on assigned risk level

SAQs are used as a risk monitoring tool to determine an active
management supplier’s baseline level of compliance toAsahi’s standards.

Submit completed SAQ within 12 months of signing contract

Who is required to complete an SAQs?
•

•

•

•

Active management suppliers will be required to complete an
ongoing management SAQ within 12 months of signing theircontract based on Diagram 1: Ongoing management SAQ andaudit requirements. Asahi will notify relevant suppliers when
SAQs require completion.

Low risk
SAQ outcome

Medium risk
SAQ outcome

Option 1 : Confirm
validity of approved thirdparty product certification

Asahi will preferentially accept the following third-party
SAQ schemes as equivalent to Asahi’s SAQ requirements:•

Supplier Ethical Data Exchange (SEDEX) SAQ•

EcoVadis questionnaire and scorecard

Alternatively, and by exception, suppliers not affiliated to eitherof the above schemes will receive a link to the Asahi
customised SAQ, either online or manually.
All SAQs will be reviewed by Asahi and suppliers will receive
an Asahi-equivalent SAQ risk outcome.

High risk SAQ outcome

Option 2:
Submit a valid approved
third-party audit program
report dated within thelast 12 months
Option 3: Participate inan approved third-party
audit and submit audit
reportDevelop, implement and monitor SMP
No ongoing management activities
requiredUpdate SAQ every 24 months
Update SAQ every 12 months

Asahi Group Responsible Procurement – Supplier Guidelines | 10

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

AuditsApproved third-party audit programs

Audits are used to verify compliance with our
Supplier Code of Conduct and require the auditor
to conduct verification activities such as, but notlimited to, viewing and evaluating worker records,
and engaging directly with workers.

•

4. Questions

5. Glossary of terms

6. AppendicesAsahi will accept the following third-party audit formats:Approved third-party audit programs•

Supplier Ethical Data Exchange (SEDEX) Sedex members
Ethical Trade Audit (SMETA)•

Amfori Business Social Compliance Initiative (BSCI)•

Social Accountability (SA) 8000

Third-party audits•

The requirement for a supplier to participate in
an ongoing management third-party audit
is based on the SAQ risk outcome asoutlined in Diagram 1: Ongoing management
SAQ and audit requirements.
•

Suppliers are required to participate in all pre-audit activities
required by the third-party audit scheme, including the completionof any applicable SAQs.

•

The approved third-party audit schemes will be reviewed as
required and any major changes, including the addition of new
schemes will be communicated to suppliers. Additional third-party
audit schemes may also be recognised at Asahi’s discretion.

•

As an alternative to undergoing an ongoing management thirdparty audit, active management suppliers may submit andconfirm the validity of one of the following:

Third-party audits are to bebooked within 30 days of a
supplier being notified of their SAQ risk
outcome, and to be conducted within 90
days of the same notification. These
timeframes may be adjusted on a caseby-case basis as determined byseasonality, availability of auditors andother relevant factors to be discussed
and agreed upon between Asahi and the
supplier.

1. A third-party product certification from the list of approved
certifications in section Third-party product certificationassessment; or
2. A third-party audit report dated no more than 12 months prior
to the supplier’s notification of the need to undergo an
ongoing management third-party audit.

Asahi Group Responsible Procurement – Supplier Guidelines | 11

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

The following steps should be followed for program selection and sharing third-part audit reports.
Any concerns relating to audit scheduling and costs should be directed to the relevant Asahi contact.

••

Step 1:

Step 2a:

Step 2b:

Selecting an approved third-party audit scheme

Submitting a valid approved
third-party audit

Sharing your third-party audit
with Asahi

Suppliers that are not part of an existing audit scheme
are able to choose a scheme from Asahi’s list of
approved audit programs based on industry and location.
Asahi’s preferred audit format is SEDEX SMETA 4-pillar
audit, however due consideration will be given to othersupplier requirements.
Asahi does not mandate audit scheme selection; however
once selected, suppliers must not change schemes until
all non-minor non-conformances (NC) identified by thescheme are closed.

•

Suppliers are encouraged to stay with the same scheme
to demonstrate continuous improvement over time.

•

Suppliers are responsible for:••

Selecting and engaging their approved third-party
audit scheme.

•

Bearing the cost of audits and other required fees.

•

Arranging and participating in necessary preliminary
and follow-up audits (as required).

•

Implementing the prescribed corrective actions fromthe approved third-party audit scheme of choice.

•

Participating in training programs (as required) by
the selected approved third-party audit scheme.

•

Maintaining accreditation.

Failure by the supplier to meet the above requirements
may result in suspension or termination ofcontract/purchase order with Asahi.

•

For third-party audits to beconsidered valid, they must:•❑ Be less than 12 months old.

❑ Include the full audit report,
including comprehensive
findings and associateddetailed data points and be
unredacted (except confidential
information concerning
production or the supplierbuyer relationship).
❑ Include the audit firm andauditor name to facilitate
verification.
❑ Be conducted by certification
bodies recognized by theapproved third-party audit
scheme’s governance.

•

Audit checklist– what timeframes do I
need to be aware of?

Where a supplier participatesin a new third-party audit at
Asahi’s request:•

Suppliers must submit complete
audit reports and outcomes
within 7 business days of theaudit report being available
to the supplier.

•Suppliers not registered to SAP
Ariba are required to share theirreport via email according to thesame timeline above.

☐ Third-party audits must be
less than 12 months old☐ For new third-party audits:
Suppliers must submit
complete audit reports andoutcomes within 7 businessdays of the audit report being
available to the supplier

Where a supplier intends to submit avalid audit report completed within thelast 12 months:•

Suppliers must share audit
reports within 7 business days of
being notified of their SAQ risk
outcome by uploading to theaccreditations field under SAP
Ariba.

•

Suppliers not registered to SAP
Ariba are required to share theirreport via email to their relevant
Asahi contact within 7 businessdays of being notified of their
SAQ risk outcome.

☐ Audits not undertaken within
the last 12 months: Audits areto be booked within 30 days ofa supplier being notified of their
SAQ risk outcome☐ Audits undertaken within thelast 12 months: Suppliers must
share audit reports within 7
business days of being notifiedof their SAQ risk outcome

Asahi Group Responsible Procurement – Supplier Guidelines | 12

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Responsible Procurement Supplier Management Plan (SMP) Monitoring
Third-party audit reports will be reviewed by Asahi and graded according to Asahi’s internal Non-Conformance (NC)grading guidance.

Supplier Management Plan (SMP) development andmonitoring

Table 3: Audit grading and outcomes•

Asahi may require suppliers to develop a set of specific,
timebound actions that will be developed in consultation
with the supplier, and recorded in an SMP.

•

Suppliers are required to implement their SMP in accordancewith the timeframes of each specific action and will be
periodically engaged by Asahi on the status of the SMP’s
implementation.

•

SMPs are likely to be developed as a result of the Program’s
third-party audit requirements, however they may also be
developed based on any of, but not limited to, the following:

Asahi audit
grading

Green

Amber

Red

Outcome•Approved to trade•

NC must be closed out according to the approved third-party audit program’s
requirements•

Approved to trade – conditional on the agreement of an SMP•

NC must be closed out according to the approved third-party audit program’s
requirements•

May lead to temporary suspension, pending investigation and the agreementof an SMP•

NC must be closed out according to the approved third-party audit program’s
requirements•

Supplier may be selected for an Asahi led site visit•

Supplier may be required to participate in training or capacity building at theirown expense
If the supplier is unable or unwilling to remedy a NC or complete an SMP within
the required timeframe, Asahi may suspend and/or terminate the supplier relationship.
A decision to terminate a supplier will be made in accordance with Asahi’s internal
responsible exit process

•

•

SAQs

•

Asahi led site visits•

Substantiated grievances identified from both the Asahi
Speak Up Policy and the supplier’s grievance mechanism•

Substantiated NCs identified from media, NGOor other reports•

Communication from human rights defenders

Responsible exit•

Where a supplier fails to comply with the SMP within theagreed timeframe, Asahi will prioritise working with the
supplier collaboratively to close out NCs. Failure to comply
with the SMP within the agreed and reasonable timeframes
shall result in escalating consequences up to and including
possible termination in the most severe circumstances. This
will be conducted in line with Asahi’s internal responsible exit
guidelines and in consultation with the supplier.

Asahi Group Responsible Procurement – Supplier Guidelines | 13

Grievance and remediation mechanisms

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Grievance and remediation
mechanisms•

As required in the Supplier Code of Conduct, we expect our suppliers to havea formal grievance mechanism in place that should be made available to all
workers in its operations (including contractors and workers not covered bya formal contract of employment).

•

The grievance mechanism must be accessible, easy to understand, legitimate
and safe, equitable and rights-compatible, predictable, transparent, confidential
and improvement-based.

•

Where a substantiated adverse impact is identified, we expect our suppliers
to provide remediation to all impacted workers in their operations and supply
chains. Adverse impacts may be substantiated by evidence that is identified andverified by investigation through avenues such as, but not limited to, Asahi or the
supplier’s grievance mechanism.

•

If any person becomes aware of a breach of this Supplier Code of Conduct, either in
its own organization or Asahi’s supply chain, reports can be made to Asahi’s Speak
Up channel. This channel is independently operated by an external party and isavailable 24/7, 365 days a year, in various local languages of the countries/regions
which we operate in. The Speak Up channel can be used anonymously and isintended to be confidential. Users may access the Speak Up channel through one of
the following methods:•

Web browser form: asahigroup.ethicspoint.com•

Mobile form: asahigroupmobile.ethicspoint.com•

Free of charge telephone hotline in designated countries/regions (seeAsahi Speak Up Policy – Annex 1 for hotline numbers)

Asahi Group Responsible Procurement – Supplier Guidelines | 15

Implementation guidance1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Implementation guidance
We appreciate that our suppliers may need additional support and guidance in adhering to
our Supplier Code of Conduct and Responsible Procurement Policy.
This section of the Guidelines outlines:
1.

Potential issues that suppliers may encounter when implementing the requirements;
and2.

Examples of effective management systems, policies and procedures that may
enable suppliers to meet the requirements set out in the Supplier Code of Conduct.

The potential issues and examples are not exhaustive and intended to be indicative only.

Tip: Download this implementation guidance and use it as a checklist.

Asahi Group Responsible Procurement – Supplier Guidelines | 17

1. The Program
DRAFT

2. Grievance mechanisms

Child labor

3. Implementation guidance✕ Insufficient process for verifying
the age of job applicants.
✕ Young employees are allocatedto night shifts, risky jobs, or working
overtime.

✕ Children working on the family farm
handling hazardous materials andworking significant hours that limits
attendance to school throughout theyear.
✕ The corrective action for a childdiscovered working in the workplace
only involves their removal, which
could potentially expose thechild to even greater risks.
✕ On-site service providers are
employing children.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ The supplier establishes sufficientfinancial (or other) resources toensure children in their communities
can continue schooling until they are
no longer minors. If necessary, they
provide support and give access totransitional schools that prepare
previously out-of-school kids forenrolment into a state-run school.
☐ The supplier ensures that the child
who has been withdrawn from workattends school rather than returning
to work elsewhere.
☐ Management and employees receive
adequate training on the policy andprocedures concerning child labor,
including age verification for job
applicants.
☐ The supplier maintains records of allprocedures that ensure the safety ofyoung workers.

Policies

Procedures☐ The supplier has a comprehensive
and explicit policy against child labor.
The policy explicitly describes the
supplier’s responsibility for ensuring
adherence to the applicable childlabor laws and regulations.
☐ Only applicants who meet or exceed
the minimum age requirement for
employment are recruited.
☐ Ensure compliance and adherence
to relevant child labor laws
regarding pay, work conditions,and working hours.
☐ Young employees will not beallocated to night shifts, overtime
tasks, or any job that poses mental,
physical, social, or moral harm.
☐ The policy specifies the minimum
age requirements for all employees
and outlines corrective actions if
there is any instance of child labor
identified.
☐ Maintain accurate recordsof employees hired byservice providers, including
documentation that verifies
their age.

☐ Legitimate and objective processes
to confirm the age of all job
applicants, using officiallyrecognized government
documents when possible.
☐ Methods to categorise
workplace jobs with health andsafety risks, deemed unsuitablefor young workers.
☐ A system in place to ensure thatstudent employees are allocatedonly to positions that align with theiracademic studies.
☐ Evaluate whether all relevant
employees have education, ensuring
adherence to the requirements foryoung workers, including those inapprenticeships and internships.
☐ Remediation and corrective
measures include immediate careprovision, instant withdrawal of thechild from all work-related activities,
and a guarantee of a secureenvironment where the child does
not feel threatened or frightenedby the circumstances.

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1. The Program
DRAFT

2. Grievance mechanisms

Forced andcompulsory labor

3. Implementation guidance✕ Employees incurring substantial debts,
resulting from paying fees to recruitment
agents or sub-agents.
✕ Labor brokers or employers keep
worker identification documents
including their passports, restricting
their ability to leave their jobs and theirfreedom of movement.
✕ Workers are required to sign revised
contracts potentially applicable fordiffering jobs with lower wages andbenefits, after arriving in theirdestination country.
✕ The workers are compulsorily registeredin obligatory savings schemes where
their access to their wages is restricteduntil the end of their employment period.
✕ For the same jobs, foreign immigrants
and contract laborers usually retain
fewer benefits and less earnings incomparison to local full-time employees.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Ethical recruitment and forced labor
policy trainings are accessible toboth management and employees.
☐ Forced and bonded labor prohibited
through extensive policy and legal
requirements, with sufficient
protocols to ensure compliance.
☐ Adequate documentation of methods
to track recruitment and placement
fees charged to job seekers andemployees.
☐ Oversight on workers’ willingengagement in their employment
contract, upholding their right toresign without facing
any repercussions, given that they
provide appropriate notice.

Policies

Procedures☐ The supplier should only partner withrecruitment agencies with a proventrack record of ethical hiring andfulfilling the supplier's policy
requisites.
☐ Every worker is given
comprehensive and precise
employment conditions prior to being
requested to sign an employment
agreement.
☐ Workers contract terms should not
be altered without written agreement.
☐ Employees will always retain their
passports and be given their own
safe storage facilities.
☐ All workers can terminate theiremployment contracts during any
period if given within the appropriate
notice period, without consequenceor retaliation.
☐ Migrant workers identified as victimsof trafficking or provided withcounterfeit immigration documents
will be granted remedies within thescope of the law.

☐ Employees constantly hold theirpersonal identification documents,
travel papers, and bank payment
cards. The agent, broker, or
employer can only keep these for theduration needed to renew thenecessary paperwork, such as visas
and work permits. Where documents
are held centrally, employees havefree access to all documents.
☐ Workers should not be subjected toany fees that would result in them
being placed in situations of forcedlabor, to be confirmed through theofficial contracts with recruitment
agencies and labor contractors.

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1. The Program
DRAFT

2. Grievance mechanisms

Discriminationand harassment

3. Implementation guidance✕ Individuals applying for jobs who were
rejected due to their personal belief
systems and attributes.
✕ The flawed use of medical examinations
to assess a worker’s job skills andabilities.
✕ Factors including gender, age, ethnicity
restricting employee ability to receive
overtime, bonuses, promotions, or job
training.
✕ Differential treatment of union members
and representatives compared to other
employees.
✕ Women workers are put at risk of losing
their jobs, their position, or get
penalized with wage cuts if they fall
pregnant.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Hiring and promotion decisions areto be solely dependent on skills,
merit, and job performance.
☐ Instead of using disciplinary based
incentives, employers should opt for
behavioural incentives.
☐ Appropriate preventative measures
to address discrimination, allowing
for equal and harassment-freeopportunities.

Policies

Procedures☐ The prohibition of discriminatory
workplace practices in relation to job
promotions, compensations, benefits,
and other risk areas.
☐ Policies which restrict any inhumantreatment including verbal andphysical abuse, harassment, andthreats.
☐ Applying progressive disciplinary
systems to all workers fairly.

☐ Reassess the processes used toprevent discriminatory behaviour
across recruitment stages, training,
promotion, and employment
termination periods.
☐ Altering communication styles,
through adapting language to begender neutral and including
representative images of diverse
individuals.
☐ Programs recognising andaddressing discrimination risks tovulnerable groups including women,
migrant communities, and disabledindividuals. These programs should
increase awareness of flexible
working arrangements, childcare andother relevant areas.
☐ Diversity criteria included in theselection of new suppliers.
☐ Liability to ensure adherence to antidiscrimination laws.

✕ Unconscious bias and systemic
discrimination concerns.
Asahi Group Responsible Procurement – Supplier Guidelines | 20

1. The Program
DRAFT

2. Grievance mechanisms

Safe and decent
work conditions

3. Implementation guidance✕ Exit aisles and doors are not accessible toworkers, as they are either locked or haveblocked entries.
✕ Employees dissuaded from reporting
workplace-related health & safety concerns
and injuries.
✕ The maintenance of machine safetymeasures is either neglected or deliberately
avoided.
✕ Employees requiring permission fromsupervisors to drink water or use therestroom.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ The establishment of a safe andhealthy work environment.
☐ Management and employees receive
sufficient workplace health andsafety policies, addressing the
primary hazards and challenges ofvarious job tasks.
☐ Guaranteeing that health and safety
policies and procedures are
effectively communicated acrossworkplace channels, ensuring all
visitors are provided with thenecessary information.

Policies

Procedures☐ Sustaining a safe and healthy
workplace, encompassing any
employer-provided housing,transportation, and food services.
☐ Medical treatments and additional
services are provided to workers
dealing with work-related injuries orillnesses, ensuring they can safely
recover and return to work.
☐ Employees obtain rights to accessnecessities including clean toilets
and drinking water.
☐ Policies clearly declare theirworkplace health and safety risks,
which is easily accessible for all
workers.

☐ Enabling proactive measures forhazard controls including machine
guarding and exhaust ventilation.
☐ Implementing the minimum
requirements of safe and healthy
workspaces include having adequate
lighting, controlled temperatures, andsanitation, also applying to any
company living spaces.

✕ Routine evacuation practice drills are notcarried out.

✕ Storage facilities not aligned with the local
health and safety requirements.
✕ Implications associated with harsh working
conditions and demanding job tasks.
Asahi Group Responsible Procurement – Supplier Guidelines | 21

1. The Program
DRAFT

2. Grievance mechanisms

Safe and decent
accommodation

3. Implementation guidance✕ Worker accommodations have limitedaccess to clean and drinkable water,
sanitation, food, ventilation and/or cleanbathrooms.

✕ No easily accessible exits are available
to workers in their accommodations.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Liability to create safe and clean
accommodation for employees,
meeting their fundamental needs,
while guaranteeing workers canselect their own living arrangements.
☐ Rental fees should not exceed areasonable percentage of
employee’s wages, by ensuring noloan repayment programs are
imposed on employees.

Policies

Procedures☐ All worker accommodations should
abide by the relevant health andsafety regulations.
☐ Employees will not face any
unjustifiable constraints on their
movement from theiraccommodation/workplace during
their non-working hours.

☐ Labour agency or employer provided
accommodation require periodic
assessments to ensure it remains
clean, safe and is structurally upheld.
☐ Workers obtain the freedom of
choice to decide to live in any
workplace accommodation such as
dormitories offered.

Asahi Group Responsible Procurement – Supplier Guidelines | 22

1. The Program
DRAFT

2. Grievance mechanisms

Hazardous materials

3. Implementation guidance✕ Environmental implications resulting fromany potential chemical spills, or any
uncontrolled emissions from hazardous
materials.
✕ Inadequate applications of monitoringand documentation procedures that track
the storage and handling of hazardous
materials.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Detailed policy guidelines that outline
strategies to safeguard workers fromhazardous material exposure.
☐ Enabling the protection of workers
who are in contact with hazardous
materials, through the provision of
resources and training to both
workers and management.
☐ Creating effective monitoringprocesses to assess strategies used
to prevent harms associated withworker’s exposure to any hazardous
materials and waste.

Policies

Procedures☐ Emergency procedures that allow forpreventative measures to address
challenges in cases of hazardous
material leaks and spills, as well asother potential environmental
incidents.
☐ Relevant documentation provided toassess procedures involving
worker’s handling and storing of
hazardous waste and chemical
process equipment.

☐ The development of a workplace
Health and Safety committee, whereselected personnel receive training
on environmental issues concerning
waste management and theappropriate disposal of hazardous
materials.
☐ Routine inspections of facilities toensure emissions controls are
effective and functioning correctly.
☐ Hazardous materials handling andstorage requires employees to use
personal protective equipment (PPE).

✕ Unregulated vendors discarding of any
unsafe and hazardous waste materials.

Asahi Group Responsible Procurement – Supplier Guidelines | 23

1. The Program
DRAFT

2. Grievance mechanisms

Responsible
recruitment

3. Implementation guidance

4. Questions

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Policies

Procedures

Examples of potential issues✕ Hazards of worker abuse, such as debt
bondage where employees must keep
working to repay
a debt to a labor broker, their employer, or
another third party, usually due torecruitment fees or loans.
✕ Chances the employee might be paying fortheir job, even if the labor costs are being
covered. For instance, a labor agency may
be collecting charges from both you and theworkers, or employees might be paying fees
to anotherparty involved in the recruitment process,apart from the agency.

☐ Conducting pre-screening ofrecruitment agencies used.
☐ Bearing the responsibility forcovering all costs and expenses
related to a worker securing a jobor those incurred during theirperformance of duties. If workers
have paid any fees, they mustreceive reimbursements.
☐ Engaging in industry-wide programs
that advocate ethical hiring practices
that help to foster demand for
responsible recruitment byhighlighting the advantagesof ethical practices.

☐ Addresses specific concerns likerecruitment fees, wage advances
and worker loans and withholding
wages.
☐ Outlines the necessary diligence andcontinuous management proceduresto effectively address issues likerecruitment fees when employing
recruitment agencies or brokers.

☐ Implementing procedures to avert,
detect, and rectify any potential
instances of recruitment fees being
paid by employees, including throughthe oversight of recruitment agencies
or labor brokers.

✕ Upon arrival in the destination country,
workers are asked to sign new contracts that
may be for a different job, with different
terms and conditions, with lower pay andbenefits.
✕ Regardless of whether the recruitment fees
are minimal, or paid to several people,
workers may accumulate substantial debts,
potentially leading to debt bondage.
Asahi Group Responsible Procurement – Supplier Guidelines | 24

1. The Program
DRAFT

2. Grievance mechanisms

Fair wages

3. Implementation guidance✕ Workers not receiving pay promptly
or in accordance with minimum wage
regulations.
✕ The overtime pay does not comply withthe rate specified by the relevant laws
and regulations.

✕ Regardless of the hours worked by piece
rate workers, they do not earn minimum
wage.
✕ Unlawful wage deduction imposed
as a disciplinary action.
✕ The pay slip data and information does
not align with the associated payroll
records.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Documenting and tracking all work
hours in the timekeeping system andemployee pay slips to ensure they do
not surpass legal limits andguaranteeing that workers receive a
day off every week.
☐ Documentation of all wage and social
benefits payments.
☐ Monitoring that workers receive
remuneration accordingly to the legal
minimum wage requirements,
including consideration of legally
mandated social benefits.
☐ The supplier’s policy demonstrates
an explicit commitment to providing
legal wages and benefits.

Policies

Procedures☐ Unless specified differently by local
laws, there must not be any wage
deductions used as a disciplinary
action (this does not negate the rightto damages on a contractual or legal
basis).
☐ The basic wages, including approved
overtime, always comply withcollective bargaining or legal
agreements, and wages should be
paid in full and promptly on time.
☐ Full time wage earnings are sufficient
to meet the necessities of workers,
covering their fundamental living
expenses.
☐ Employees pay slip clearly specify
the main components of theircompensation, exact wages,
benefits, incentives,and any deductions made.

☐ Employees receive equitable andcompetitive remuneration andbenefits, upholding the principle ofequal pay for equal work.

✕ Failure to pay allowances, bonuses,
or benefits as mandated by law.

Asahi Group Responsible Procurement – Supplier Guidelines | 25

1. The Program
DRAFT

2. Grievance mechanisms

Working hours

3. Implementation guidance

4. Questions✕ Workers are engaged for more working
hours each week or month than thelegal requirements permit.
✕ Employees are unable to decline
overtime work without facing
repercussions, such as not receiving
consideration for overtime work in the
future.

✕ Employees working for several weeks
without a day off, leading to a rise injob-related injuries and diminishedproductivity.
✕ Workers do not receive the daily rest
periods mandated by law.

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

5. Glossary of terms☐ An explicit commitment in the
supplier's policy to restrict work
hours, comply with legal
requirements, and prioritize
employee safety.
☐ Accountability in procedures
ensuring compliance to working
hours laws and regulations.
☐ Training provided for management
and employees on working hours,
and strategies on managing themwithin legal constraints.
☐ Documenting and tracking all work
hours in the timekeeping system andemployee pay slips to ensure they do
not surpass legal limits andguaranteeing that workers receive a
day off every week.
☐ Management ensures the workforce
meets the staffing requirements, areskilled and resourced to prevent
overtime,
whereby peak periods exist to avoid
excessive overtime.
☐ Suppliers must be transparent
regarding the need for overtime
work, and any associatedcompensation provided for it.

Policies
☐

☐

☐

☐

Procedures

Adherence to national and local laws
related to working hours and rest
periods.
Regulations mandate that rest breaks andmeal breaks should be given during theworking day.
Every seven days, 24 consecutive hours
of rest will be given, or every 14 days, 48
consecutive hours of rest will be given.
All overtime is voluntary, and workers do
not work in excess of 60 hours per week(including overtime).

☐ Methods for employees to log theirwork hours, ideally through anelectronic timekeeping system.
☐ Sufficient management procedures
to ensure working hours do notsurpass the legal limits.
☐ Procedures so employers canrequest overtime work from
employees’ overtime whilst allowing
them to reject these requests.
☐ Work scheduling procedures which
can guarantees at least one rest day(24 consecutive hours) every sevendays worked for all employees.
☐ Employees must receive equitable
and competitive remuneration andbenefits, upholding the principle ofequal pay for equal work.

Asahi Group Responsible Procurement – Supplier Guidelines | 26

1. The Program
DRAFT

2. Grievance mechanisms

Women’s rights

3. Implementation guidance✕ Challenges in gathering genderdisaggregated data to address
any risks.
✕ Unlawful discrimination in hiring
processes.
✕ Female workers face threats oftermination, seniority loss or wage
cuts if they fell pregnant.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Establishing a committee dedicatedto dealing with gender-related
matters in the workplace, comprisedof several employees which aids thecompany in pinpointing risks
associated with gender in thecompany's policies, operations,and initiatives.
☐ Ensuring that the gender-related
committee serves as crucial resource
to enhance women workers' safety,
security, and empowerment.

Policies

Procedures☐ Reviewing workplace policies toensure they specify how operations
can affect women workers versus
men workers differently, for example
in relation to workplace, health, andsafety concerns.

☐ Adapting communication methods tosuit audiences is important, forinstance when women may possess
limited literacy skills, utilizing
cartoons, images, and infographics
could be useful.
☐ Regularly assessing gender-related
and diversity policies and themeasurable targets set for achieving
equitable gender equality outcomes.
☐ Implementing a gender-based
perspective in workplace procedures
and carefully examining them toensure the presence of genderresponsive policies, such as
evaluating the anti-harassment
policy.
☐ Encourage clear communication
about the measures taken to bridge
gender disparities, underlining adefinite commitment towards
achieving gender equality targets.

Asahi Group Responsible Procurement – Supplier Guidelines | 27

1. The Program
DRAFT

2. Grievance mechanisms

Freedom of associationand collective bargaining

3. Implementation guidance✕ Applicants do not receive job opportunities
due to their affiliations with trade unions
or other worker groups.
✕ Worker representatives do not receive anycompensation for their time allocated towards theirrepresentative responsibilities.
✕ Union representatives and members are treateddifferently than other workers.
✕ Workers discouraged to join unions and/or
representative employer organisations.
✕ Worker representatives selected by management
rather than being democratically elected.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ The supplier’s policy explicitly
details their responsibility torespect the rights of collective
bargaining and forming
associations.
☐ Protocols which uphold compliancewith laws and regulations that
support freedom of association.
☐ Management and workers are
given training on the freedom of
association policy, including
relevant guidance on how unions
and other worker organizations canoperate without disruption.

Policies

Procedures☐ Workers have the right topeacefully gather and deliberate on
workplace-related issues.
☐ Workers have the right to either
join or abstain from joining tradeunions or other representative
worker organizations of theirpreference.
☐ Employment decisions included
within hiring processes,
promotions, wage increases andaccess to training should notaccount for workers association
with trade unions.
☐ Methods for workers to collectively
voice any concerns or requests tomanagement in situations where a
trade union is not present.

☐ Building a thorough understandingof risks which can impede freedomof association rights across thewhole supply chain of thebusiness.
☐ Utilising risk assessments whenrequired to evaluate potential
limitations of worker’s freedom of
association rights.
☐ Facilitating collaborative training
initiatives with trade union orworker representatives to foster
positive labor relations, including
health and safety training, andsexual harassment prevention.

✕ Freedom of Association laws-local law restrictions.
✕ Temporary and contract workers can pose risks tothe business at precarious times, including duringindustrial unrest or strikes.
✕ Workers face adverse consequences suchas risks to their wages, working hours, employment
status, promotional opportunities, and grievances
resulting from them joining or creating trade unions.

Asahi Group Responsible Procurement – Supplier Guidelines | 28

DRAFT
1. The Program

2. Grievance mechanisms

Rights to land andnatural resources

3. Implementation guidance✕ No regular evaluation processes toassess compliance with regulations
and laws.
✕ The principle of free, prior, andinformed consent not followed before
the land becomes acquired.
✕ Unauthorised vendors used in thedisposal of hazardous materials
and waste.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Policies on land use andacquisition are comprehensive
and clearly outlined.
☐ Procedures that adhere to therelevant regulations,international standards, andlaws on the rights to land,acquisition of land and natural
resources.
☐ Sufficient training provided to
management and workers
engaging with community
members on procedures for
obtaining free, prior, andinformed consent.
☐ Keeping detailed records of allproperty or land use rights
pertaining to all lands owned,
acquired, or under the controlof the supplier.

Policies☐ Ensure adherence to therelevant regulations, laws, andinternational standards,
concerning land use,acquisition, and natural
resources.
☐ Engagement with Indigenous
Peoples and local communities
must uphold transparency forthe lease or purchase of land.

Procedures
☐

☐

☐

☐

☐

☐
☐

☐

☐

☐

Procedures regarding land rights should include: humanrights and environmental impact assessments, community
engagement, free, prior, and informed consent process
and grievance process.
Processes to regularly identify, monitor and apply
applicable laws, regulations and international standards
relating to land use and acquisition and natural resources.
Adequate procedures to attain the free, prior, and fully
informed consent of Indigenous Peoples or impacted
communities, concerning all land acquisitions.
Community members can access training on their rightto free, prior and informed consent, in regard suppliers’
land acquisitions or transfers .
Maintains records of all relevant land use laws, regulations,international standards, and customer requirements.
Facilitating outreach with individuals, communities, andIndigenous Peoples, with records of meeting minutes.
Documentation of community grievance reports whichmust involve their investigation and resolution processes,
and if applicable any remediation outcomes.
Regular feedback mechanisms enabled through ongoingsurveys of community members, concerning any relevant
supplier land use policies and procedures.
Routine audit procedures conducted on the supplier’s land
use processes and procedures are undertaken by internal
staff and external auditors who are qualified and trained.
Conducting assessments of any grievances from
community members about land use issues on aregular basis.

Asahi Group Responsible Procurement – Supplier Guidelines | 29

1. The Program
DRAFT

2. Grievance mechanisms

Human rights
defenders

3. Implementation guidance✕ Connection to intimidation, threats,
or attacks against human rights
defenders, whether by the organizationor any affiliated third parties.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Human rights defenders or humanrights policy must be comprehensive
and clearly outlined.
☐ Ensure adherence to the relevant
regulations, laws, and international
standards, concerning the protectionof human rights defenders.
☐ Sufficient training provided to
management and workers engaging
with human rights defenders, ensuring
the protection of their human rights.

Policies

Procedures☐ Recorded protocols detailing theprohibition of all threats, any form ofabuse, intimidation, or retaliation
against human rights defenders.

☐ Applying and monitoring therelevant regulatory standards,
laws, and international standards,
corresponding with the protectionof human rights defenders.
☐ The provision of safe, accessible andanonymous grievance mechanisms
to human rights defenders.

Asahi Group Responsible Procurement – Supplier Guidelines | 30

1. The Program
DRAFT

2. Grievance mechanisms

Grievance mechanism
and remediation

3. Implementation guidance

4. Questions✕ Employees fail to use the provided grievance mechanisms,
due to their lack trust in its confidentiality, and beliefs they
are ineffective in resolving their concerns.

✕ The reported problems are not being addressed promptly.
✕ Workers lack awareness on processes to reporta grievance anonymously.
✕ Workers who report any complaints or grievances
face harassment and retaliation.
✕ Grievance processes are not procedural and standardised.
✕ Parties lack sufficient access to the required advice,resources, and expertise to participate in the grievanceprocess in a fair, informed, and respectful manner.
✕ Dissatisfied parties cannot contest the outcomes ofgrievance investigation procedures due to no appeals
processes.
✕ Workers do not have access to any progress madeon their grievances lodged, nor are they consulted
on the mechanism’s performance capability and design.

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

5. Glossary of terms☐ Grievance mechanism policy is to be comprehensive
and clearly outlined.
☐ Efficient processes for establishing a confidential andtrustworthy grievance procedure, that effectively
investigates and resolves any reported issues.
☐ Sufficient training provided to management and workers
on the grievance mechanism policies and procedures.
This includes detailed steps on ways to reportgrievances, and processes on grievance resolutions.
☐ Records of grievance reports and resolutions should bereadily available.
☐ Procedures to ensure the appropriate steps are followed
for grievance mechanisms, allowing for an easierprocess for impacted parties to use.
☐ Grievance processes should allow for clear resolutionsof issues regarding the application of relevant policies
and procedures.
☐ Regular reviews by senior management of the overall
performance of the grievance system.
☐ Developing a grievance mechanism committee including
the relevant personnel such as workers, managers, andother affected parties.

Policies☐ Retaining confidentiality in grievance procedures, also
allowing the impacted parties to raise any concerns
anonymously.
☐ Several channels to report grievances that can be either
formal or informal.
☐ Not allowing any retaliation or harassment of theaffected parties involved in grievance procedures.

✕ The outcomes and solutions of grievance procedures
do not adhere to the international human rights standards.
✕ No monitoring or assessments on the effectivenessof grievance processes.
Asahi Group Responsible Procurement – Supplier Guidelines | 31

1. The Program
DRAFT

2. Grievance mechanisms

Grievance mechanism
and remediation cont.

3. Implementation guidance

4. Questions

5. Glossary of terms

6. AppendicesPotential implementation actions
Procedures☐ The supplier has ways that workers can report a grievance against their supervising manager to a different individual who is not in thesame reporting channel.
☐ Time efficient investigations and resolutions of grievance reports, communicating to the worker who originally reported their concerns.
☐ Methods allowing the affected parties to monitor the progress of their grievance report, and appeal any resolutions they disagree with.
☐ Clearly outline the instructions on various approaches to report grievances, in the languages that relevant parties can understand.
☐ Training provided to managers and other parties who uphold a clear responsibility to respond to grievances.
☐ Convey the deadlines for management to address grievances through written communications. If the resolution is postponed, thesupervisor or manager should provide the cause of delay in writing.
☐ Workers receive sufficient training on the appeals processes for grievance mechanisms.
☐ There is robust governance of grievance mechanisms to ensure they are managed in the correct manner.

Documentation procedures

☐
☐
☐

☐
☐

Maintaining records of any of the grievance reporting,investigation, resolution, and appeal processes.
Logging and classification of all reported issues.
The grievance records should obtain clear details about theissue, the reporting date, the person assigned to investigate
and resolve it, how it was handled, and when feedback wasprovided to the complainant.
Grievance records should be maintained confidentially, withaccess restricted to the selected personnel.
Summaries of the key issues reported in grievance procedures,
including supervisor’s responses, accessible to any impacted
parties.

Monitoring procedures

☐
☐

☐
☐

Routine assessments of the use of reporting channels provided,
to review if the intended goals are met.
Regularly evaluate the effectiveness of the establishedprocedure used by managers and other responsible individuals
for investigating and resolving complaints. This can be done byexamining complaint records and conducting interviews with therelevant staff to gauge their understanding of the procedure.
Ongoing monitoring procedures to evaluate the KPIs, and tomeasure the effectiveness of the program.
Regularly surveying employees and other impacted parties todevelop a comprehensive understanding of their trustin the grievance mechanism.

Asahi Group Responsible Procurement – Supplier Guidelines | 32

1. The Program
DRAFT

2. Grievance mechanisms

Sub-contracting

3. Implementation guidance✕ Engaging sub-contractors to carry out
some or all of the services under acontract, when Asahi has expressly
prohibited sub-contracting of thoseservices.
✕ Significant reliance on the use of subcontractors to perform businessactivities, particularly those which arelabor intensive.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Reasoned decision-making
processes for evaluating the need forusing sub-contractors with the
purpose of eliminating, or minimising
their use where required.
☐ Efficient processes for notifying andobtaining approval from Asahi if theuse of sub-contractors is required.
☐ Processes for engaging with subcontractors to ensure compliancewith the supplier’s human rightsrelated policies.

Policies

Procedures☐ Human rights-related policies mustclearly outline their applicability to
sub-contractors and describe thesupplier’s processes for ensuring
compliance.
☐ Explicit description of Asahi approvalbeing a pre-requisite for any use of
sub-contractors.

☐ Standardised procedures forrecording the use of all subcontractors and the justification for
their use, including a description of
why their non-use is not possible.
☐ Documentation of procedures for
obtaining prior approval from Asahi
for any use of sub-contractors.
☐ Due diligence procedures for
identifying, managing, monitoring
and remedying the human rightsrelated practices of sub-contractors.

✕ Absence of controls or processes for
identifying, managing, monitoring andremedying the human rights-related
practices of sub-contractors.

Asahi Group Responsible Procurement – Supplier Guidelines | 33

1. The Program
DRAFT

2. Grievance mechanisms

Climate Change

3. Implementation guidance✕ Inadequate or incomplete carbon
accounting procedures to track
greenhouse gases (GHG) emissions.

✕ Inadequate monitoring anddocumentation processes that track andaudit carbon reduction.
✕ Lack of ambition of climate targets andgoals to reach 1.5 degrees of global
warming, the limit defined according to
the Paris Agreement.

✕ Insufficient action plan to decarbonize
operations, and no risks andopportunities assessment in place.
✕ No regular follow up on carbon-related
regulations and protocols that might
affect operations.

5. Glossary of terms

6. AppendicesPotential implementation actions
Management systems

Examples of potential issues

4. Questions☐ Greenhouse gases (GHG)
accounting is up to date, covering all
the necessary segments of thecompany, and coherent to guidelines
set by the GHG Protocol.
☐ Emission reductions targets areambitious; and their evolution isreviewed regularly.
☐ Sufficient training provided to
management and workers engaging
with GHG accounting, reporting, andtarget setting and follow up.
☐ Ensure that auditing or third-party
verification of the inventory is carriedout at least on a yearly-basis.
☐ Maintaining records and evidences ofdata for external audit purposes.
☐ Net Zero target is approved by the
SBTi and the decarbonization
roadmap is regularly updated.
☐ Risks and opportunities assessmentin place to tackle increased climate
resilience.

Policies

Procedures☐ Ensure adherence to relevant local
regulations, laws, and to international
standards, concerning carbon
reporting, climate risk analysis,
carbon reductions, and similar.
☐ Follow up on new developments andnegotiation of climate-related policies
arising in different countries andregions, such as the CSRD for
Europe.
☐ For publicly traded companies, beaware of regulations on reporting
climate and sustainability-related
matters at different stock exchangeorganizations.
☐ Increasing anti-greenwashing actions
from civil society, non-governmental
and governmental organizations.
☐ Carbon markets and carbon taxes
are being created and updated indifferent regions and countries. Stayup to date with these changes, andaware of risks and opportunities foryour business.

☐ Adequate and frequent capacity
building of teams in carbon
accounting, climate change,sustainability risks and opportunities,
and similar.
☐ Creating effective accountability andexternal reporting of carbon data androadmaps.
☐ Routine audit procedures conductedby internal teams and externalorganizations.
☐ Processes to regularly identify, monitor
and apply upcoming and applicablelaws, regulations and international
standards relating to GHG emissions,climate strategy and reporting.
☐ Leadership within the organization is
accountable for climate and carbon
targets.
☐ Establish close collaboration withgovernment and corporate affairs
teams to advocate for public policies
and incentives towards
decarbonization and green innovation.

Asahi Global Responsible Procurement – Supplier Guidelines | 34

Questions

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Questions
Please email your relevant
Asahi procurement relationshipowner if you have any concerns,
queries or need additional
assistance in understanding or
implementing the Guidelines.

Asahi Global
AsahiResponsible
Group Responsible
Procurement
Procurement– Supplier– Supplier
Guidelines
Guidelines
| 36
| 36

Glossary of terms

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Glossary of terms
Key terms

Definition

Active management

All inherently high-risk suppliers that the business has a contractual relationship with regardless of spend, in addition to suppliers with whom Asahi has a contractual relationship andspends more than $100,000 USD per annum.

Bonsucro

Bonsucro offers a credible, metric certification process to demonstrate commitment to environmental and social sustainability in sugarcane1.

CDP Questionnaire2

CDP is a global non-profit that runs the world’s environmental disclosure system for organizations including capital markets, companies, cities and governments to assess theirimpact. CDP offers a multi-environmental issue questionnaire for large organizations, focused on climate change, forests and water security.

Activities conducted to exercise reasonable care, investigate, verify and assess all potential risks of adverse impacts associated with a business’ supply chain
or a specific business transaction or decision.
Due diligenceDue diligence may involve examination of financial records, legal documents, operational mechanisms, and other relevant factors. For human rights this could involve suppliers
answering SAQs to identify risks. The standard and scope of due diligence may vary based on a business’s size and nature of the business agreement.

Fairtrade

Fairtrade supports and challenges businesses and governments and connects farmers and workers with the people who buy their products3.

Forest Stewardship Council(FSC)

FSC forest management certification confirms that the forest is being managed in a way that preserves biological diversity and benefits the lives of local people
and workers, while ensuring it sustains economic viability 4.

Greenhouse gases (GHG)

Any gas that absorbs infrared radiation in the atmosphere. Greenhouse gases include, but are not limited to, water vapor, carbon dioxide (CO2), methane (CH4), nitrous oxide(N2O), hydrochlorofluorocarbons (HCFCs), ozone (O3), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulfur hexafluoride (SF6).

GHG Protocol

Greenhouse Gas Protocol provides standards, guidance, tools and training for business and government to measure and manage climate-warming emissions5.

Grievance mechanism

Any routinized process through which grievances concerning business-related negative impacts can be raised and remedy can be sought6.

Non-conformance (NC)

An instance where the supplier’s practices do not meet the requirements of the Program.

Ongoing management

Set of due diligence activities applied to active management suppliers to verify and manage their performance relating to the requirements of the Program.

Ongoing management thirdparty audit

Third-party audits provided under an approved third-party audit scheme that is conducted as part of the Program’s ongoing management requirements.

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1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Key terms

Definition

Pre-screening due diligence

Set of due diligence activities subject to suppliers prior to being awarded an Asahi sourcing contract or purchase order.

Programme for theEndorsement of Forest
Certification (PEFC)

PEFC, the Programme for the Endorsement of Forest Certification, is a leading global alliance of national forest certification systems. As an international non-profit,
non-governmental organization, we are dedicated to promoting sustainable forest management through independent third-party certification7.

Prospective supplierSuppliers who have expressed interest in becoming an Asahi supplier but have yet to participate in the Program.

Qualification audit

Third-party audits provided under an approved third-party audit scheme that is scheduled and/or conducted prior to being awarded an Asahi sourcing contract or purchase order.

Qualified supplierSuppliers who are eligible to participate in an Asahi tender or RfP.

Rainforest Alliance

The Rainforest Alliance is an international non-profit organization building an alliance to protect forests, improve the livelihoods of farmers and forest communities,
promote their human rights and help them mitigate and adapt to the climate crisis 8.

Registered supplierSuppliers who have registered to Asahi’s supplier management system (SAP Ariba) and attested to the Policy and Supplier Code of Conduct.

Remediation

The process of providing remedy for an adverse impact and the substantive outcomes that can counteract, or make good, the adverse impact. These outcomes may takea range of forms such as apologies, restitution, rehabilitation, financial or non-financial compensation, and punitive sanctions (whether criminal or administrative, such as fines),
as well as the prevention of harm through, for example, injunctions or guarantees of non-repetition9.

Request for Proposal (RfP)

The process whereby qualified suppliers participate in a tender process for an Asahi sourcing contract.

Roundtable on Sustainable
Palm Oil (RSPO)RSPO Certification assures individuals that RSPO Members who produce or physically handle RSPO Certified Sustainable Palm Oil (CSPO) have obtained RSPO Certification. It
includes the assurance that the member has committed to and complied with sustainability requirements, and can make a claim on their certification status and communicate thisthroughout the supply chain10.

SAI Platform’s Farm
Sustainability Assessment(FSA)

The Farm Sustainability Assessment (FSA) enables food and drink businesses to assess, improve, and validate on-farm sustainability in their supply chains.
Built around a simple set of questions to farmers, the FSA standardizes farm assessment 11.

Self-Assessment
Questionnaire (SAQ)

A series of questions to be completed by active management suppliers that assesses the existence of risk management controls.

Self-Assessment
Questionnaire (SAQ) risk
outcomeRisk outcome determine based on the self-assessed existence and quality of controls, as identified from the Self-Assessment Questionnaire (SAQ).

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1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Key terms

Definition

SBTi

SBTi is a global body enabling businesses to set ambitious emissions reductions targets in line with the latest climate science. The SBTi defines and promotes best practice inscience-based target setting, offers resources and guidance to reduce barriers to adoption, and independently assesses and approves companies’ targets12.

Scopes 1 and 2

Scope 1 emissions refer to direct greenhouse gas (GHG) emissions that occur from sources that are controlled or owned by an organization. This includes all land-use emissions
from companies that own or control land to produce agricultural and forest-risk commodities.
Scope 2 emissions refer to indirect GHG emissions associated with any purchases of electricity, steam, heat, or cooling.

Scope 3

Scope 3 emissions are the result of activities from assets not owned or controlled by the reporting organization, but that the organization indirectly impacts its value chain. This
includes the emissions linked to downstream companies where sourced commodities are being produced, through, for example, packaging, logistics, raw materials, cooling etc.

Site visit

An in-person activity conducted by Asahi to verify, by examination and evaluation of objective evidence, that applicable elements of a supplier’s management systems
are approved, effective and conform with the requirements of the Program.

Supplier Management Plan
(SMP)

A set of specific, timebound actions for suppliers to implement to raise their performance relating to the requirements of the Program. The SMP will be developed by Asahi inconsultation with the supplier and is informed by a combination of inputs such as, but not limited to, the pre-screening questionnaire, self-assessment questionnaire, third-party audits
and Asahi site visits.

Third-party audit

A means of evaluating sufficient evidential matter to assess performance relative to a set of standards set by a third-party program13.
A procedure by which a third-party scheme:

Third-party productcertification•

Establishes standards or similar tools focused on one or more sustainability issues;•

Measures, monitors, or verifies performance or progress against these tools; and•Allows for claims to be made by the organisation with reference to these tools 14.

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Appendices1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Appendices
Related Asahi Responsible Procurement
frameworks, policies and guidancematerial

Additional resources for Supplier Codeof Conduct implementation•

International Bill of Human Rights International Bill of Human Rights which consists of the Universal
Declaration of Human Rights (UDHR), International Covenant on Economic, Social and Cultural Rights(ICESCR) and the International Covenant on Civil and Political Rights (ICCPR)•

Asahi Group Responsible Procurement Policy•

Asahi Group Supplier Code of Conduct•

United Nations (UN) Guiding Principles on Business and Human Rights•

Asahi Speak Up Policy•

International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work•

Asahi Group Human Rights Principles•

OECD Guidelines for Multinational Enterprises on Responsible Business Conduct•

UN Women’s Empowerment Principles•

UN Convention on the Right of the Child•ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy•

UN Global Compact•

Children’s Rights and Business Principles•

Convention on the Elimination of All Forms of Discrimination against Women•International Convention on the Protection of the Rights of All Migrant Workers and Members of Their
Families•

United Nations Declaration on the Rights of Indigenous Peoples

Asahi Group Responsible Procurement – Supplier Guidelines | 42

1. The Program
DRAFT

2. Grievance mechanisms

3. Implementation guidance

4. Questions

5. Glossary of terms

6. Appendices

Policy review
Policy review
Owner:

Approver/Issued by:Documentation Administrator:

Effective from:Tomas Veit – CEO Asahi Global
Procurement

Kaoru Sakita - Group CFO Asahi Group
Holdings

Morgan Cleland – Global Sustainability Lead
(Responsible Procurement)

AUG-08-2024

Revision
No.

Date:

1.

AUG-08-2026

Description:

Revised by:

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