Basic Approach to Respect for Human Rights
黑料网 recognizes that respect for human rights is our corporate responsibility, and one of the most important, fundamental requirements of our business activities. 黑料网 established the Charter of Business Conduct as our global code for conducting business activities to realize our corporate concept of human health care (hhc). The Charter of Business Conduct states that we will respect human rights wherever we do business.
We enacted the 黑料网 Human Rights Policy to complement the Charter of Business Conduct and to demonstrate the specific policies that underpin our corporate responsibility for respecting human rights.
Human Rights Policy and Our Commitment
黑料网’s Human Rights Policy was formulated based on the international norms on human rights* which are recognized globally. It was issued in March 2019 with the approval of the (former) Executive Committee, which is the highest decision-making body for business execution, and the consent of the Board of Directors. As stated in the policy, we are committed to respecting internationally recognized human rights, supporting the 10 Principles as a signatory of the United Nations (UN) Global Compact, and implementing initiatives in accordance with the UN Guiding Principles on Business and Human Rights. In addition, this Policy stipulates that all business partners, including suppliers, should respect and not infringe on human rights.
* The international norms on human rights:
- International Bill of Human Rights (Universal Declaration of Human Rights, International Convention on Civil and Political Rights, International Convention on Economic, Social and Cultural Rights)
- ILO Declaration on Fundamental Principles and Rights at Work
- UN Guiding Principles on Business and Human Rights
- OECD Guidelines for Multinational Enterprises
Governance System
In 2018, we established a cross-organizational "Business and Human Rights" Project in order to carry out activities that respect human rights based on the Human Rights Policy. This project consists of working groups that practice activities in each organization and the “Business and Human Rights Steering Committee”, consisting of the Chief Human Resource Officer, who is the chairman and responsible for the implementation and management of the Human Rights Policy, as well as the Corporate Officer for Sustainability, the Chief Compliance Officer, and the President of 黑料网 Demand Chain Systems (EDCS). The project secretariat responsible for promoting the project activities includes representation from the Sustainability Department, General Affairs Department, Global Human Resource Strategy & Planning Department, Compliance Department, and EDCS Partnership Management Unit.
In 1980, we established the Human Rights Awareness Committee within 黑料网, which mainly deals with awareness raising activities to eliminate various kinds of discrimination and harassment at workplaces at 黑料网 and its network companies in Japan. The “Business and Human Rights” Project is a newly established project to quickly respond to international trends and legislation on respect for human rights in each country based on the UN Guiding Principles on Business and Human Rights. The project and the “Human Rights Awareness Committee” are working together to promote respect for human rights.
Human Rights Due Diligence
In accordance with the Human Rights Policy, we perform human rights due diligence for rights holders related to our business such as "patients and the people in the daily living domain (including clinical trial participants)", "employees" and "business partners (including suppliers)". Human rights issues for these key rights holders were assessed based on magnitude of potential impact and likelihood, through analyzing case studies from the pharmaceutical industry to date. This analysis highlighted which human rights issues could present the most material risk to our business.
The identified eight significant human rights-related areas are access to medicines, human rights of patients, human rights of clinical trial participants, product safety and quality, ethical marketing, health and safety of employees, workplace environment, and human rights of business partners including suppliers. In addition, global warming caused by greenhouse gas has a negative impact on consumers, and environmental pollution by business partners causes health hazards to local residents. Therefore, "environmental impact" related to our business was added as one of the important human rights issues.
Based on the analysis of interviews with relevant departments on these important human rights issues and the human rights impact assessment, "human rights among business partners, including suppliers" was identified as an issue that should be addressed as a priority.. Since fiscal 2019, we have prioritized preventing and mitigating potential human rights risks in the supply chain, and have been working to establish a responsible supply chain management system while engaging with our business partners.
For key human rights issues of major stakeholders, we are continuously working to prevent and reduce negative impacts on human rights through the following activities:
Human rights of patients and the people in the daily living domain
黑料网 recognizes that improving "access to medicines" in developing and emerging countries is an important human rights issue that must be addressed and is actively promoting initiatives to address the issue in partnership with governments, international organizations, non-profit private organizations, and others. For more information, please refer to the "Initiatives for Improving Access to Medicines" section of our website.
Human rights of clinical trial participants
Clinical trials are an indispensable process for assessing the safety and efficacy of new drugs and delivering superior novel drugs to the world. It is the responsibility of pharmaceutical companies to respect the human rights of those who participate in such clinical trials and give the utmost consideration to safety. Therefore, before we begin clinical trials, we perform due diligence to identify all possible potential safety risks and take measures for them in advance. We strictly adhere to compliance and ethics based on the guidelines of ICH (International Council for Harmonization of Pharmaceutical Regulations) and regulatory authorities in each country. In addition, in all clinical trials, it is stipulated as a guideline to comply with regulations such as ICH-GCP (Good Clinical Practice) and the Pharmaceutical Affairs Law and to carry out activities with high ethical standards. In particular, when conducting the first clinical trial in humans, we have established a system in which a committee independent of the new drug development project evaluates the entire proposed clinical trial in advance. The committee evaluates the clinical trial implementation plan, the clinical trial implementation system, and the quality of investigational drugs and risk management from an ethical and scientific point of view, and then decides whether we conduct clinical trials of new drugs or not.
Furthermore, in order to provide comprehensive and equitable access to treatment options, we have made “Diversity in Clinical Trials” one of our core commitments and are committed to maximizing clinical trial access for all patients regardless of ethnicity, race, sex, age, socio-economic status, gender identity, geographic location, or physical ability.
Human rights of employees
黑料网 recognizes the importance of creating Employee-Friendly Environment where human rights and diversity are respected in order for employees to work in a healthy and rewarding manner. Therefore, we are committed to prohibiting all discrimination related to race, sex, disability, age, sexual orientation and gender identity, preventing harassment, facilitating the participation and advancement of female employees in the workplace, and developing a work environment and systems for decent work.
For details, please refer to the pages on Diversity Equity and Inclusion (DE&I), Employee-Friendly Environment, Health Management, and Occupational Safety and Health in the "Relationship with Our Employees" section of our website.
We have also signed the United Nations Global Compact, which states that “businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining” of employees and we engage in ongoing labor-management consultations with labor unions in an effort to resolve various issues between labor and management.
Human rights of business partners
We have created "Code of Conduct for Business Partners" that summarizes sustainability-related matters that we would like our business partners to comply with. Human rights-related items in the Code of Conduct require business partners to prohibit forced labor and child labor, provide a workplace free from discrimination and harassment, respect freedom of association, comply with regulations on working hours and minimum wage, and provide a safe and healthy working environment. The process of action is introduced in the "Human Rights in the Supply Chain" section.
The table below summarizes the risks identified and the actions for major rights holders in fiscal 2023.
Initiatives to address human rights issues in FY2023
*You can scroll to the left or right here
| Rights Holders | Priority Issues | Actions and Achievements |
|---|---|---|
| Patients and consumers | Improving access to medicines*1 |
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| Employee | Discrimination and harassment prevention |
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| Promotion of decent work |
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| Promotion of health maintenance and improvement activities*3 |
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| Labor-management cooperation |
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| Creating Value through Integrated HR Strategies |
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| Suppliers | Respect for human rights in the supply chain |
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*1
Please see “Initiatives for Improving Access to Medicines” on our website.
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*2
Please see “Initiatives for Lymphatic Filariasis” on our website.
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*3
Please see “Health Management” on our website.
/sustainability/society/employee/health_management/index.html
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*4
Ecovadis' global platform that provides enterprises with sustainability assessments for their business partners.
Preventing and Mitigating Human Rights Risks in the Supply Chain
Child labor, forced labor, and human trafficking
Child labor, forced labor, and human trafficking in the supply chain are internationally considered human rights violations for which there should be zero tolerance. We are conducting risk assessments of purchased raw materials from the perspective of the geographic location of the country of origin and the industry in order to verify the potential negative impact on human rights indirectly through the purchase of pharmaceutical raw materials.
Raw materials with high risk
Carnauba wax, which is used to coat銆�tablets, was the subject of a purchased raw materials traceability survey due to concern about the risk of forced labor and the working environment in its place of origin. As a result, we were able to identify the company of origin in Brazil and confirmed that the raw materials were certified by a certification organization (Fair for life). For pharmaceutical raw materials where there are concerns about human rights risks at the most upstream tier of the supply chain, we have continued to conduct traceability surveys and to confirm the local situation regarding human rights.
Japanese Technical Intern Training Program
It has been pointed out that the Japanese Technical Intern Training program has human rights risks such as wage, working hours and sexual harassment, and has been cited by the US Department of State as constituting forced labor. We consider this to be one of the important human rights issues in Japan, and in interviews with our business partners for feedback on sustainability evaluation, we request confirmation of the employment of foreign technical intern trainees and a report on their employment status.
Measures to mitigate potential negative impacts on human rights in the supply chain
By implementing a sustainable procurement program, we are working to prevent potential negative impacts on human rights, labor and other issues in the supply chain. In the program, we require our major suppliers to respect human rights to the same standard as 黑料网, by agreement to comply with the 黑料网 Global Code of Conduct for Business Partners (hereinafter referred to as the "Code of Conduct"). The labor and human rights requirements in the Code of Conduct include prohibition of forced labor, prohibition of child labor, compliance with laws and regulations in the employment of young workers, prohibition of discrimination, fair treatment, prohibition of harassment and other inhumane treatment, strict adherence to minimum wages, observance of legal working hours, and freedom of association. In addition, to monitor compliance with the Code of Conduct, we conduct on human rights, labor, and environmental risk assessments using the EcoVadis platform. We strive to prevent potential human rights risks by engaging individually with suppliers whose assessment results indicate risk concerns and seeking corrective measures based on mutual agreement.
Results of efforts to mitigate potential human rights risk
Supply chain of production sites in Japan
As one of our objectives to prevent potential negative impacts on human rights in the supply chain, we have implemented sustainable procurement targeting direct material suppliers, including contract manufacturers, of our plants in Japan. We request our Tier-1 and major Tier-2 suppliers, both domestic and overseas, to submit a signed agreement to the Code of Conduct and to participate in a sustainability performance assessment by EcoVadis. At the end of FY2023, no companies were considered high risk based on the labor, human rights and environmental assessment results. We strive to improve the level of sustainability performance throughout our supply chain by engaging individually with suppliers.
Every year we hold a supplier briefing session to explain our policies addressing social issues such as human rights and the environment, as well as our expectations of our suppliers. In 2023, 167 direct material suppliers participated. At the briefing session, Ms. Junko Watanabe (Nishimura & Asahi, Foreign Law Joint Enterprise), an attorney with expertise in international human rights law and international labor law, gave a lecture titled "Regulatory Trends Concerning Human Rights and the Environment and Responses Required of Japanese Companies" to raise awareness of the responsibility of companies to respect human rights.
Supply chain of overseas production sites
We started sustainable procurement at our Vizag Plant in India and Suzhou Plant in China in fiscal year 2022, as well as at 黑料网's U.S. procurement division and Bogor Plant in Indonesia in fiscal year 2023. Signed agreements have been received from major direct material suppliers regarding compliance with the Code of Conduct. Based on the EcoVadis sustainability assessment results, we have submitted feedback to suppliers (11 suppliers of the Vizag plant and 6 suppliers of the Suzhou plant) whose labor and human rights scores did not meet our standards, with the aim of making improvements. With regard to Tier-1 suppliers of the Hatfield Plant in the UK, we have obtained their agreement to the Code of Conduct at the time of contract. From FY2024, we will sequentially conduct sustainability assessments of our major direct and indirect material suppliers using EcoVadis.
Grievance Mechanism
The Compliance Counter (hotline for reports and consultation) accepts all types of reports and consultations, including harassment or other human rights issues. We take appropriate measures after conducting investigations as necessary, while paying attention to confidentiality and the prohibition of retaliation regarding matters that have been reported or consulted.
In addition, we have set up a contact point to receive consultations and reports from business partners regarding compliance issues related to our business and employees. The set up of a human rights hotline for all stakeholders, including workers in our supply chain, is currently under consideration.
Education and Training
We believe that respect for human rights must be firmly established as a corporate culture in order to fulfill our corporate responsibility for respecting human rights. In order to thoroughly implement business activities based on respect for human rights, we continue to raise awareness of human rights among officers and employees of 黑料网 and network companies.
In FY2023, we conducted human rights awareness training via video with the theme of "Creating a workplace where all employees can work with vitality (to realize social good)", which was attended by 4,788 employees (participation rate: 93%), including those from domestic Group companies. In addition, we held an online lecture on the theme of "Human Rights Violations on the Internet and SNS," inviting an individual who had experienced defamation by external parties. The lecture was viewed a total of 6,336 times via live lecture participation and/or video streaming (participation rate: 123%, non-unique views).
Regarding harassment prevention, we are thoroughly implementing e-learning and compliance training. We are also incorporating human rights training into our stratified training programs for new employees and newly appointed organizational managers.
黑料网’s Modern Slavery and Human Trafficking Statement
To comply with the UK Modern Slavery Act 2015, which came into force in the United Kingdom, 黑料网 Europe Ltd. released the following statement in June 2023:
Engagement
In order to collect the latest information on human rights issues in Japan and overseas, share such information among companies, and solve the issues, we believe that it is important for us to cooperate with other companies and work with human rights NPOs and NGOs. We joined the sustainability frameworks, such as BSR (Business for Social Responsibility), the Global Compact Network Japan and PSCI (Pharmaceutical Supply Chain Initiative), at which we participate in several seminars and human rights-related subcommittee activities. This enables us to keep updated on the latest global trends in human rights and acquire know-how regarding human rights due diligence and leading practices for promoting respect for human rights. we are committed to addressing respect for human rights under the collaboration with other companies and organizations through the sustainability frameworks.