S: Upholding human rights

Challenge
Our policy
Responsible executive (as of April 2023)
Action promotion system (as of April 2023)
Activities
Grievance mechanism

Challenge

Upholding human rights

Relevant stakeholders

Direct: Employees, local communities, suppliers
Indirect: Shareholders and investors, creditors, NGOs, industry groups

Our policy

In the Toyo Tire Group, the majority of employees work outside of Japan, and more than half of our consolidated net sales are generated overseas. Our business is expanding globally, and we have growing opportunities to communicate with diverse stakeholders both in and outside of the company, making it ever more important to act in a way that respects the human rights of everyone involved in our corporate activities.
In January 2019, we enacted the Global Human Rights & Labor Policy, which supports the Universal Declaration of Human Rights, ILO Declaration and 10 principles of the United Nations Global Compact.
As our business globalizes and our stakeholders diversify, we strive to carry out our business in a way that respects the human rights of everyone involved in our corporate activities, including those in our workplaces, at our suppliers, and within the communities where we operate. This will help us contribute to creating an inclusive society that supports everyone, including socially vulnerable people, by protecting them from exclusion, conflict, loneliness and isolation. Group employees also recognize that they may potentially cause, contribute to or be complicit in adverse impacts on human rights through their own activities, and work to prevent this.

Responsible executive (as of April 2023)

Corporate Officer and Vice President of Corporate Headquarters

Action promotion system (as of April 2023)

Corporate Headquarters leads promotion of activities and reports progress to the Sustainability Committee.
The Sustainability Committee, chaired by the President, meets four times a year to report, discuss and approve activities related to human rights.
Corporate Headquarters takes the lead in promoting activities and discussing the promotion of human rights based on the Global Human Rights & Labor Policy. We have also set up a system to prevent human rights violations on a daily basis.

Activities

Human rights due diligence

In accordance with our Global Human Rights & Labor Policy, we conduct human rights due diligence to recognize and take action against adverse impacts on human rights (human rights risks) in Group business activities and the supply chain.
In 2023, we identified and assessed which human rights risks are relevant throughout all of our Group business activities and the supply chain, then went further to identify which risks are the most important for us to take action on. In order to ensure objectivity, this process was conducted with the help of external experts in business and human rights.
Our continued and further efforts will prioritize preventing and mitigating these important risks.

Identifying important risks

Identifying human rights risks
We identified relevant human rights risks in our business activities and the supply chain by surveying each of our division headquarters to understand the business characteristics that are linked to risks, and comparing these with risks considered inherent to our industry based on reports and recommendations of prominent international institutions and organizations, as well as actual cases of risk that have manifested within the industry.

Assessing the significance of human rights risks

The identified relevant human rights risks were scored by severity (the level of harm should an incident occur) and likelihood (the ease of manifestation within the Group). The significance of each risk was then assessed, with more weight given to severity in accordance with the UN Guiding Principles on Business and Human Rights. The most significant (level 6-9 in the following matrix) were then established as the Group’s important human rights risks.

Variables	Scoring method
Severity	Focuses on the scale of harm, possibility to provide remedy, and the scope of impact
Likelihood	Focuses on potential factors (highlighted by international institutions as a important industry risk; problem that occurred at another company in the same industry; factor inherent to our business) and actual factors (real cases at our company)

Assessing the significance of human rights risks

Identifying important human rights risks
The relevant human rights risks were then assessed according to the type of rights holders (those who have the human rights that are at risk of being adversely impacted), which led to identification of the following important risks: occupational health and safety, forced or child labor, indirect complicity in conflict, consumer safety infringement, adverse impact on local communities, discriminatory treatment or power harassment in workplaces, and long working hours.

(1) Right holders: Group employees, job applicants

(2) Right holders: Manufacturing contractors, distributors, raw material suppliers

(3) Right holders: Sales partners, consumers, indigenous and other local communities

Addressing important risks

To prevent and mitigate these important risks, we will both continue and strengthen our existing measures while constructing and enhancing management schemes.
For human rights-related measures in the supply chain, see “Promote supply chain sustainability.”

Rights holders		Important risks	Prevention & mitigation measures
(1)	Group employees, job applicants	Lack of health & safety at workplaces\	Strengthen occupational health & safety management
		Forced/compulsory or child labor	Discover any current forced/compulsory or child labor, build systems to eliminate
		Power harassment or discrimination	Enhance training on preventing harassment and discrimination
		Discrimination against candidates in hiring interviews	Review materials for employees in charge of interviews
		Long working hours, excessively strenuous work	Strengthen efforts to secure necessary personnel and improve productivity
(2)	Manufacturing contractors, distributors	Lack of workplace health & safety at manufacturing sites	Accelerate efficient logistics initiatives (distributors)
		Lack of workplace health & safety at manufacturing sites	Strengthen manufacturing contractor/distributor management scheme
		Forced/compulsory or child labor, Long working hours, excessively strenuous work at manufacturing sites
	Raw material suppliers	Forced/compulsory or child labor at raw material production sites	Enhance sustainable procurement
	Raw material suppliers		Strengthen raw material supplier management scheme
(3)	Sales partners, consumers, indigenous and other local communities	Indirect complicity in wars of aggression through sourcing of conflict minerals and other materials	Enhance surveying of smelters about parts potentially using conflict minerals
		Indirect complicity in conflict through sales practices	Strengthen sales partner management scheme
		Adverse impact on local communities through production or disposal of our products	Further improve wastewater management, noise control
		Infringement on consumer health and safety through defective products	Accelerate initiatives based on quality management system operation

Preventing forced labor and child labor

The Group does not allow labor practices that violate laws in any country or region. We comply with Japan’s Labor Standards Act and do not employ children under the working age, nor physically or mentally restrain workers, nor engage in unwilling forced labor. Before hiring, we check that the person is of working age and provide a notice of employment conditions, prior to concluding an employment contract based on mutual agreement.
Preventing low-wage labor and long working hours

Toyo Tire Corporation pays appropriate wages that exceed the minimum and living wages based on Japan’s Minimum Wage Act, in order to improve the lives and health of our workers. From the standpoint of preventing long working hours, we formulate and announce an annual Policy on Employee-Employer Agreement under Article 36 of the Labor Standards Act, conduct thorough labor-management negotiations, and manage working hours properly in order to reduce overtime work.

Raising awareness of respect for human rights

We work continuously to raise awareness of the company’s responsibility to respect human rights by providing all Group employees e-learning sessions on our Corporate Code of Conduct, and level-specific and other training organized by the HR department that focuses on human rights issues within business. We also conduct human rights education for new employees and at position- and level-specific training sessions, and participate in human rights awareness activities at every region where our business sites are located. In addition, we strive to respect the human rights of everyone related to our business operations, including suppliers and communities where we conduct business. On Human Rights Day each December 10, the President of Toyo Tire Corporation sends a message on human rights to all employees of the Group, stressing the importance of having a foundation of deeply diverse talent to generate value through our business, and of demonstrating sincerity with all stakeholders, as declared in our philosophy. The Toyo Tire Group will remain committed to improving awareness of human rights and preventing adverse impacts on them within our corporate activities and workplaces.

Compliance with laws and regulations of each country

We publish information on our measures to ensure that neither modern slavery or human trafficking is taking place within our supply chains or any part of our business in accordance with Section 54-1 of the UK Modern Slavery Act and Section 16 of the Australian Modern Slavery Act.

FY2023 Statement on the UK Modern Slavery Act (Toyo Tire Corporation)

FY2022 Modern Slavery Statement (Toyo Tyre Australia PTY LTD.)

Grievance mechanism

Internal reporting system

Since 2006, the Group has operated an internal reporting system for all compliance issues, including human rights, for employees and suppliers. We accept anonymous reports to consider the privacy of those seeking advice and protect whistleblowers. When consulted or a report is received, we conduct an internal investigation as needed and take corrective action to address any actual issues. In addition, we continuously hold training sessions based on specific cases to detect potential issues at an early stage and prevent occurrence.

Reporting hotline (whistle-blowing system): For executives, employees and suppliers
Customer Relations Department: For customers (consumers) and local communities
Online inquiry form: For customers (consumers), shareholders and investors, and NGOs
Labor-Management Council Meetings: For employees

TOYO TIRES WORLDWIDE