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ROHM Group Human Rights Policy
Our Basic Policy
ROHM Group recognize “Human rights are the fundamental right, freedom, and standard for treatment that individuals around the world possess”. This policy is a superordinate policy of all documents and norms regarding the efforts to respect human rights in the ROHM Group's business activities and is applied to all activities carried out by the ROHM Group around the world.
As a company with a globally growing business, ROHM Group views respect for human rights as one of the most basic conditions for its business activities. We recognize that it is important to build a sustainable society in which human rights are respected. In particular, we support and respect the following global standards.
And where national law and international human rights standards differ, we will follow the higher standard; where they are in conflict, we will seek ways to respect internationally recognized human rights to the greatest extent possible.
Global Principles and Rules
- ・Ten Principles of the United Nations Global Compact (UNGC)
- ・Universal Declaration of Human Rights
- ・The International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work
- ・United Nations Guiding Principles on Business and Human Rights
- ・OECD Guidelines for Multinational Enterprises
- ・ISO26000
- ・RBA（Responsible Business Alliance）Code of Conduct
Scope of Application of This Policy
This policy applies to all officers and employees, which consists of ROHM Group and its consolidated subsidiaries. In addition, based on this policy, we will ask our business partners and other parties connected to ROHM Group's business, to respect human rights and not to violate them.
Initiatives to Respect Human Rights
- ・ROHM Group will prohibit any form of discrimination based on race, ethnicity, nationality, social status, lineage, gender, disability, health conditions, ideology, faith, gender identity, sexual orientation, occupation or occupational status and harassment.
- ・ROHM Group will commit to responsible labor practices including the provision of a safe and healthy environment in the workplace as well as ensuring adequate working hours and minimum wage. We also commit ourselves to respecting freedom of association and the right to collective bargaining.
- ・ROHM Group will never allow or complicit in slave labor, forced labor, or child labor, including human trafficking.
- ・ROHM Group will acknowledge and seek to uphold our responsibility to the communities, including indigenous groups, affected by our operations.
Practice of Respect for Human Rights
- ・In accordance with principles and norms which we support, ROHM Group will exercise human rights due diligence to identify, prevent and mitigate adverse human rights impacts related to our business activities. We will also endeavor to take appropriate and effective remedies when it becomes clear our activities, products and services by our business relationships have caused or contribute to adverse human rights impacts.
- ・ROHM Group will establish a hotline for human rights violations, and continue to establish an effective reporting response system.
- ・ROHM Group will provide the training necessary for our board member and employees to have the knowledge and capacity to implement this policy.
- ・ROHM Group will strengthen its efforts to respect human rights through the professional advice of external stakeholders about this policy and efforts based on this policy.
- ・ROHM Group will regularly and properly communicate our progress on our efforts to address adverse human rights impacts including through our CSR website and/or integrated report.
October 28, 2021
Isao Matsumoto
President and CEO
ROHM Co., Ltd.
Promotional Structure
In 2011, the UN Human Rights Council endorsed the UN Guiding Principles on Business and Human Rights, calling on companies to do more to address human rights issues. In response, ROHM Group signed the UN Global Contact in October 2011.
At ROHM Group, the EHSS General Committee, which is composed of Board members with executive authority, corporate officers with equivalent authority, and those in charge of business divisions and management systems, oversees eight subordinate management systems (Risk Management, Supply Chain, Labor, Ethics, Health and Safety, Environment, Information, Quality). Each management system checks that the PDCA cycle is being properly implemented in response to human rights risks identified and extracted in each field. The EHSS Management Committee reports and consults with the Board of Directors as appropriate, and also receives supervision and instructions from the Board of Directors.
Resolutions made by the EHSS General Committee are communicated to relevant divisions within ROHM and to group companies through the eight management systems, and measures are implemented accordingly. All management system members are appointed by the chairman of the EHSS General Committee every fiscal year at the same time as the implementation plan is decided, and they carry out their duties.
ROHM Group has obtained management system certification for each theme by implementing the PDCA cycle in cooperation with each specialized subcommittee, relevant departments, and group companies, based on the sustainability management system. Through these activities, we aim to further improve the "Company Quality" and become the company of choice for our stakeholders.
We have acquired ISO14001 and ISO45001 certification for the environment and health and safety.
In the field of labor ethics, we manage human rights issues and risks in labor ethics by building and operating a labor ethics management system that complies with the RBA Code of Conduct.
Human Rights Assessment in the Supply Chain
ROHM Group is conducting activities in compliance with RBA Code of Conduct with the aim of building a sustainable society in which human rights are respected. Furthermore, efforts are being made to ensure human rights are respected throughout the entire supply chain by respecting the human rights of our business partners and asking them to also act in accordance with RBA Code of Conduct.
We respect the human rights of our suppliers and ask our suppliers to follow the RBA Code of Conduct in our efforts to respect human rights throughout the supply chain.
Specifically, our business partners are asked to perform self-evaluations on labor, health and safety, environment, ethics, management systems and procurement BCP indicated in RBA Code of Conduct. Based on the results of their responses and CSR procurement audits, our business partners are asked to make improvements on items with poor evaluations including those related to human rights. Moreover, during audits and meetings, efforts are made to raise awareness of the need to perform CSR procurement throughout the entire supply chain, including the importance of human rights.
Human Rights Assessment at ROHM Group
ROHM Group operates a labor and ethics management system for managing and mitigating human rights issues and risks in terms of labor and ethics.
ROHM on a stand-alone basis has established a Labor Management System and Ethics Management System as subordinate organizations of the EHSS General Committee, and by implementing a management system that draw up plans every year and evaluates their effectiveness at the end of each fiscal year, the company is building a foundation for protecting basic human rights. In addition, Labor and Ethics Committees have been established at each location of domestic and overseas group companies, and these specialized subcommittees and committees serve as the driving force for addressing human rights issues.
As part of the ongoing monitoring of each location, in addition to status checks through the annual SAQ and periodic internal audits, third-party audits by the RBA are conducted on a regular basis.
In FY2023, an RBA audit found safety nonconformities related to excessive working hours and safety on evacuation routes, which are being corrected and initiatives are ongoing to prevent recurrence. At temporary staffing agencies, nonconformities related to payments to employees were identified and corrective actions were taken to have temporary staffing agencies review their contracts and make payments to employees.
Identified Human Rights Risks
| Human Rights Issues (Based on the RBA Code of Conduct) |
Subject | Due Diligence | Grievance Mechanism | |
|---|---|---|---|---|
| Labor | ・Freedom of Employment ・Working Time ・Wages and Benefits ・Elimination of Discrimination ・Harassment Prevention ・Occupational Health and Safety ・Young Workers ・Privacy Protection |
Employees, On-site Contractor Employees |
Internal Audit SAQ based on RBA RBA VAP Audits |
Internal Hotline External Whistleblowing System |
| Ethics | ・Elimination of Discrimination ・Harassment Prevention |
Employees, On-site Contractor Employees |
||
| Health and Safety | ・Occupational Health and Safety ・Emergency Preparedness |
Employees, On-site Contractor Employees |
||
| Environment | ・Water ・Noise ・Atmosphere |
All Stakeholders | ||
| Supply Chain | ・Labor Issues ・Ethical Issues ・Health and Safety Issues ・Environmental Issues ・Responsible Mineral Procurement |
Suppliers | ||
| Information | ・Privacy Protection | Employees, Customers, Suppliers |
Human Rights Training
ROHM Group respects and embraces a variety of cultural backgrounds, religions, customs, and opinions from each country and each region. We conduct rank-specific human rights training programs for new employees, mid-career recruits, new senior managers, directors, and executive officers.
Also, ROHM conducts Labor and Ethics e-Learning for all employees as a part of employee education to ensure that they understand ROHM's approach to international norms and customer requirements, including the RBA Code of Conduct.
[Labor and Ethics e-Learning]
| FY2021 | FY2022 | FY2023 | |
|---|---|---|---|
| Number of Participants | 3,350 | 3,832 | 3,941 |
| Participation Rate (%) | 83.6 | 99.7 | 98.5 |
Prevention of Child Labor and Forced Labor
ROHM Group prohibits forced labor and child labor. In its supply chains as well, ROHM Group Supply Chain Management Guidelines clearly specify that forced labor and child labor are strictly prohibited, and all suppliers are responsible to follow the human rights guidelines. In fiscal year of 2017, ROHM issued "ROHM Group Statement Regarding UK Modern Slavery Act", clearly stating its determination to further strengthen its commitment to preventing child labor and forced labor. The effectiveness of and compliance with the initiative are verified annually through internal audits, as well as through external audits such as customer audits and RBA audits.
Elimination of Discrimination
The entire ROHM Group is committed to showing respect for the human rights of all employees. We respect individuality, human rights, and the privacy of all our employees. We seek to eliminate discrimination of all kinds, whether based on race, nationality, gender, gender identity/sexual orientation, religion, beliefs, or disability, to eliminate child labor and forced labor and we endeavor to create a safe and healthy workplace environment as we have stated in the “ROHM Group Code of Conduct” to help our employees better understand.
As part of our efforts to promote compliance, we have established a whistleblower hotline for employees and business partners（suppliers） to deal with human rights violations
Harassment Prevention
ROHM has established a consultation center with advisors who are available to listen to employees' troubles and provide counseling services. Counseling services via telephone, email, or face-to-face consultation are available issues such as harassment or interpersonal relationships at workplace. By making female advisors available, and ensure all counselors hold license in employment counseling, ROHM works to create an environment in which employees can consult with advisors and receive reliable and professional advices. Furthermore, efforts are being made to raise awareness among employees by continuously conducting training for managers on the prevention of harassment.
Privacy Protection
Appropriate management of personal information of employees, customers, business partners, and other parties involved in the ROHM Group's business activities is essential for providing better products and services to society and for conducting reliable corporate management. ROHM Group regards the protection of privacy as one of the fundamental human rights, and has established a privacy policy and is committed to specifying the purpose of use of personal information, acquiring it appropriately, and managing it safely and strictly. The privacy policy complies with the Act on the Protection of Personal Information and Ministry of Economy, Trade and Industry Guidelines on the Protection of Personal Information, the GDPR (EU General Data Protection Regulation), and the California Consumer Privacy Act (USA).
In addition, through e-learning and level-specific training, we make our employees aware of the risks of personal information and corporate information leaks and improve their security literacy. In the unlikely event of an incident, we will immediately investigate the cause and promptly take appropriate measures to prevent recurrence.
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