天美传媒

Human Rights Policy

The Chiyoda Group (Chiyoda Group) regards respecting human rights as an essential element of a solid business foundation.
We have established Chiyoda Group's Code of Conduct/Conduct Guidelines (Code of Conduct), prescribing the importance of respecting human rights, prevention of human rights violations and respecting international human rights standards.
We also established our 'Human Rights Policy' in September 2018 to clearly articulate our commitment to complying with the Code of Conduct and fulfilling our respect for human rights responsibilities.
The Human Rights Policy was revised in April 2021 to further promote human rights initiatives in response to growing social demands for respecting human rights in corporate activities.
The revision clearly addresses Chiyoda Group's compliance with international laws and norms regarding human rights, such as United Nations 'Guiding Principles on Business and Human Rights', our continuous implementation of Human Rights Due Diligence and prioritization of human rights issues. The Policy applies to all officers and employees of the Chiyoda Group, encompassing all individuals and groups that may be affected by Chiyoda Group's business activities and relationships.
We continue to encourage all business partners, including subcontractors and suppliers and other related parties involved to our business activities, to understand and adhere to the Policy.
The Policy was established and revised by a resolution of the Board of Directors in consultation with J.S. Held (*1).

Operational Framework

The Chiyoda Group pursues human rights distinction through an Operational Framework for Sustainability, with a Sustainability Committee chaired by the Chairman of the Board as the Chief Sustainability Officer (CSO).
Under the Committee, we engage in continuous and intensive discussions from a medium to long-term perspective, covering topics and priority issues determining the outcome of our businessstrategies.
As an advisory organization to the CSO that typically meets twice a year, the Committee established a system to consult with an external sustainability advisor and reports the outcome to the Board of Directors for approval.
In June 2024, a Human Rights Working Group was established under the Sustainability Committee. Through cross-organizational dialogue and discussion, the Group promotes effective human rights initiatives that take into account the risks, characteristics, and practices of its business operations. Targets should therefore cover all business enterprise activities, including those with external business partners, such as supply chains. Respect for human rights is managed by responsible divisions/departments/sections (ie: Sustainability Section, Compliance Section, HR Section, SQEI Section, Procurement & Construction Division) in cooperation with other divisions/departments/sections and domestic and overseas Chiyoda Group companies.

Human Rights Due Diligence

The Chiyoda Group has established a mechanism for human rights due diligence in accordance with the processes detailed in the United Nations Guiding Principles on Business and Human Rights, while holding dialogue with stakeholders and cooperating with external consultants. Human rights due diligence refers to an ongoing process undertaken by the business enterprise to identify and assess adverse human rights impacts in their supply chain, to implement appropriate measures to address the impacts and to disclose and account for the progress and results of such measures.

Impact Assessment on Human Rights

• Identification of Priority issues regarding Human Rights开闭ボタン

  To prepare its revision of the Human Rights Policy, the Chiyoda Group assessed potential adverse impacts on human rights from our business activities, and identified priority human rights issues(*2).
  Reflecting the constantly changing circumstances surrounding human rights and in collaboration with J.S. Held, the Chiyoda Group conducted a review of the business activities of every group company in fiscal year 2022, including business country/region activities, based on the latest information such as reports, white papers and other documentation published by United Nations, government organizations and research institutions from each country.
  The review illustrated that no change in human rights priority issues was required.

  In FY2024, the Human Rights Working Group conducted human rights risk assessments based on each organization's business activities, confirmed that there were no changes to the priority issues, and identified those requiring prioritized action. A human rights risk map based on severity and likelihood was also developed and will be reviewed periodically.

  

• Risk Assessment and Prioritization of Chiyoda Group's Businesses/Projects开闭ボタン

  With respect to the identified human rights priority issues and in collaboration with J.S. Held, the Chiyoda Group conducted risk mapping for the countries and business sectors in which it operates. Based on the eight elements of SA8000 (*3), we quantified human rights risk exposure and prepared a heat map to visualize risk levels (high/medium/low). Also based on a set of twelve elements (four newly added to the eight), the Chiyoda Group quantified human rights risk exposure of every business sector and visualized risk areas.

Based on a combination of country-specific risks and operation-specific risks, we identified businesses/projects with elevated human rights risk and those requiring human rights due diligence implementation on a priority basis, considering additional topics such as revenue, investment, number of employees and others.
 

Endeavors to Prevent and Mitigate Adverse Human Rights Impacts

Human Rights Initiatives through Project Execution

The following endeavors support human rights in the execution of EPC projects as our main business, with particular attention paid to Chiyoda Group stakeholders (including project-related parties), suppliers (including project site workers) and local communities.

• Children's Human Rights开闭ボタン

  The Chiyoda Group operates all over the world and protection and respect for children's rights is essential in a global society. As highlighted in our Human Rights Policy, the Chiyoda Group is committed to eliminating child labor in accordance with the 'Children's Rights and Business Principles'. While observing related local laws and regulations, we also investigate supplier initiatives to prevent child labor.

• Human Rights for Migrant and Foreign Workers开闭ボタン

  Migrant and foreign workers are often vulnerable due to language barriers, gender, cross-border and non-regular work,  and human rights violations have been reported.
  Many migrant and foreign workers are employed on our construction sites and in project supply chains in Japan and overseas, and the Chiyoda Group is committed to eliminating forced labor, as expressed in our Human Rights Policy. We also confirm supplier endeavors to prevent forced labor. 
  　

  (Examples of Chiyoda Group endeavors to prevent migrant and foreign worker human rights violations on global projects)

  • Checking supplier management systems and interviewing suppliers regarding migrant and foreign workers, support systems (including living arrangements), information dissemination etc.
  • Providing education and bulletin boards on occupational health and safety in multiple languages and using eye-catching visual images not subject to language barriers
  • Providing meal menus sympathetic to worker countries/regions of origin, religion etc.
  • Providing facilities considering religious beliefs (eg: mosques, churches etc)
• Human Rights in Cooperation with Suppliers开闭ボタン

  The Chiyoda Group investigates and evaluates supplier endeavors and initiatives for respecting human rights through questionnaires prior to engaging in business with them. Identified concerns are communicated to suppliers and they are encouraged to implement additional mitigating or prevention measures to address shortcomings.
  Contractual Terms and Conditions also guarantee supplier, including second and subsequent tier supplier, respect for human rights.
  We are also promoting respect for human rights across the entire supply chain by communicating "Chiyoda Group Contractor and Supplier Expectations", which outlines key areas that require collective efforts throughout the supply chain.

  (Examples of provisions to ensure respect for human rights)

  Prohibition of forced and/or child labor and discrimination and harassment, responsible recruitment, occupational health and safety, wages and remuneration, working hours, anti-bribery, grievance mechanisms etc. 

  Chiyoda Group Contractor and Supplier Expectations
• Respect for Workers' Human Rights at Overseas Project Sites开闭ボタン

  At overseas project sites, we provide training for suppliers on occupational health and safety as well as workers' welfare. In addition, in collaboration with clients, we regularly conduct initiatives such as opportunities for direct dialogue with on-site workers, including suppliers (e.g., "Talk with Workforce"), and awareness surveys. Based on the feedback and survey results obtained through these activities, we implement concrete actions for continuous improvement. In fiscal year 2024, through the activities of the Human Rights Working Group, we developed the framework of a standard human rights due diligence program to be applied to overseas projects with high human rights risks. This framework includes key components such as human rights risk assessment, risk mitigation and remediation measures, periodic monitoring, and information disclosure. In fiscal year 2025, we further developed specific measures and related procedures within the human rights due diligence program, focusing on high-priority human rights issues. These included organizing cost estimation methods for human rights-related measures, standardizing worker recruitment processes, and establishing grievance mechanisms at project sites. In fiscal year 2026, we are working on defining criteria for the application of the human rights due diligence program, establishing monitoring and audit methodologies, and identifying and assessing human rights risks in domestic projects in order to further enhance our management of human rights risks. Furthermore, we are promoting respect for human rights throughout the entire supply chain by communicating our "Request to Business Partners," which outlines key areas requiring collective action across the supply chain.

• Employee Safety and Armed Security Considerations for Communities开闭ボタン

  The Chiyoda Group conducts thorough local surveys before commencing work on site to enhance employee safety. Survey results may dictate the requirement for armed security guards under local laws and regulations. Recognizing that the use of armed security guards potentially increases human rights violation risks due to the inappropriate use of weapons, we stringently and comprehensively evaluate security organizations prior to appointment, ensuring appropriate policies and processes for firearm management and personnel training. The Chiyoda Group only appoints security firms that comply with local laws and regulations and support international agreements such as the 'UN Global Compact' and 'Voluntary Principles on Security and Human Rights'.

  Confirming Adverse Human Rights Impacts through On-site Audits

  The Chiyoda Group executes regular project site audits and conducts interviews with management and employees of project stakeholders (eg: subcontractors and suppliers), including employee living arrangement inspections, to identify shortcomings, implement mitigating action and monitor stakeholder responses.

Respecting Employee Human Rights

Different perspectives strengthen an organization's flexibility and market response dexterity. The Chiyoda Group respects employee diversity and individuality and promotes a corporate culture and working environment where employees are motivated to work proactively, irrespective of gender, nationality, age, religion, sexual orientation etc. Initiatives include establishing a task team to raise and promote human rights awareness, providing prayer rooms and attracting global employees through briefing programs.

• Promoting Women's Advancement开闭ボタン

  The Chiyoda Group drew up the "Action Plan to Promote Women's Advancement" following the enactment of the Act on the Promotion of Women's Active Engagement in Professional Life (Women's Advancement Promotion Law).
  　

  <Action Plan to Promote Women's Advancement>
  Chiyoda Corporation hereby declares the following action plan to promote the activity of its women employees:

  2024-2028 Act for women empowerment

  We will continue promoting internal reform whereby all next generation employees, including female employees, can play an active role in the future of the Chiyoda Group, accompanying modern changes in society and maximizing the potential of all Chiyoda Group colleagues.
  We will continue to promote an environment where female employees can continue to work regardless of circumstances.

• Establishing a Health Management & Diversity Promotion Office开闭ボタン

  The Chiyoda Group respects employee diversity and individuality and we established a 'Health Management and Diversity Promotion Office' within the Human Resources Department in April 2022 from a task team that has been continuously working to raise awareness of women's human resource development and advancement since 2014. The Chiyoda Group promotes a corporate culture that respects all employees and encourages a working environment within which all individuals play an active role, regardless of gender, nationality, age, religion, sexual orientation etc. We will continue our initiatives to realize Diversity & Inclusion to create innovation by combining different perspectives and ideas in a culture unafraid of change.

  Health and Productivity Management Initiatives
• Occupational Safety and Health开闭ボタン

  Our Code of Conduct details the Chiyoda Group's initiatives to maintain a healthy and safe working environment to ensure the well-being of all employees. We promote Safety, Quality and Environmental management based on our 'Corporate Safety, Quality and Environment (SQE) Policy' and as highlighted as an essential human rights issue in the Human Rights Policy.
  We continue implementing initiatives to provide a working environment within which employees can work with peace of mind. Refer to Sustainability > Safety.

  Sustainability / Our Initiative to SafetySafety, Quality and Environment (SQE) Policy
• Labor-Management Consultation开闭ボタン

  We hold regular dialogue with a labor union formed by our members (labor-management consultation) to discuss labor conditions and other issues, the results of which are reflected in employment regulation revisions and other measures.

Prevention and Mitigation Measures within the Chiyoda Group

The Chiyoda Group is working to further disseminate its policies, such as the Code of Conduct and the Human Rights Policy, and initiatives to respect human rights among officers and employees, by implementing the following programs in multilingual format.

• Specific initiatives开闭ボタン
  • The Chiyoda Group Employee Handbook is distributed to employees to ensure they are familiar with human rights policies.
    Chiyoda Group Employee Handbook&苍产蝉辫;　＞
  • Conducting a yearly compliance e-learning program for all officers and employees, including international norms on human rights, Chiyoda Group's Human Rights Policy, respect for human rights, prevention of harassment, anti-bribery and corruption, internal reporting systems and others. Officers and employees also pledge compliance with our Code of Conduct.
  • In 2021, we invited an external consultant, Mr. Keisuke Hanyuda (Chief Executive Officer of OWLS Consulting Group, Inc.) to give a lecture on 'Human Rights Issues and Risks in EPC Business'. Mr Hanyuda discussed the growing global demand, and the importance of corporate endeavors, for respecting human rights. Panel discussions with employees also encompass contemplating and addressing human rights issues in the Chiyoda Group.
  • We conduct trainings on the following human rights issues, striving to deepen the understanding of human rights among Chiyoda Group officers and employees and to prevent and mitigate adverse impacts on human rights:
    
    ?Business and Human Rights
    ?Prevention of Harassment
    ?Anti-Bribery and Corruption
    ?Occupational Health and Safety
    ?Information Security
    　
  • We also conduct annual organizational culture surveys for Chiyoda Group officers and employees on observing compliance, using anonymous questionnaires to investigate items such as the presence (or absence) of a work environment that supports compliance observance, raising compliance awareness and the credibility of our consultation/reporting system in promptly identifying compliance concerns in each organization. We continue working to strengthen our organizational culture of observing compliance by extracting strengths and issues, feeding survey results into each organization and linking them to specific improvement actions.

External Human Rights Initiatives

• Global Compact Network Japan开闭ボタン

  The Chiyoda Group signed the United Nations Global Compact in 2012 and expressed our support for its ten principles. We also joined the Global Compact Network Japan (GCNJ), a local network of the UN Global Compact in Japan, to harvest knowledge and information through discussions with other participating companies at the following subcommittee meetings, exchanging information on initiatives and attending lectures by experts, and linking them to Chiyoda Group's initiatives.

  • Supply Chain Subcommittee (participated as a member since 2014)
  • Anti-Corruption Subcommittee (participated as a member since 2013)
  • Human Rights Due Diligence Subcommittee (participated as a member since 2024)

  United Nations Global Compact
• Building Responsibly开闭ボタン

  The Chiyoda Group has been an associate member of 'Building Responsibly' (*4) since 2021. We participate in regular meetings and working groups to discuss and exchange opinions with other companies on issues related to human rights, linking them to Chiyoda Group's initiatives.

Effectiveness Evaluation

• On-site audit开闭ボタン

  In fiscal year 2025, we conducted an audit of one overseas project to verify the operational framework and status of the human rights due diligence program implemented at the project. Specifically, we established audit criteria based on the seven key human rights issues defined in the Chiyoda Corporation Group Human Rights Policy, as well as the SA8000 standard. The audit included interviews with management and employees of both major suppliers and our project organization, review of relevant documentation (such as employment contracts, payroll statements, contracts with recruitment agents, and policies related to respect for human rights), site inspections of facilities (including water supply, fire prevention equipment, restrooms, and rest areas), as well as assessments of workers' living conditions. We also conducted stakeholder engagement activities, including dialogues with clients and supplier employees. As a result of the audit, no significant human rights issues were identified. However, regarding issues related to employment condition notices and payroll statements identified during the audit, we instructed the relevant suppliers to take corrective actions. We plan to continue conducting on-site audit(s) in fiscal year 2026.

• Monitoring开闭ボタン

  The Chiyoda Group also conducts an annual survey of the corporate culture for compliance, and monitors respect for human rights to evaluate the effectiveness of their human rights due diligence for review and improvement.

Remedial and Relief Measures

Establishing a Consultation and Reporting System

• The Chiyoda Group established a compliance consultation and reporting system (anonymously if desired) as a grievance mechanism for officers and employees and business partners.
• A 'harassment in the workplace' hotline with external consultation was also established. If the user seeks a solution, we implement measures as necessary, following  confirmation of the user's intention, based on discussions with the consultant.
• The Chiyoda Group also conducts an annual organizational 'climate survey' on observing compliance, enabling officers and employees to confirm their awareness of the compliance consultation/reporting system. In fiscal year 2025, a total of 30 cases related to human rights (including harassment) were reported through the compliance consultation / reporting system. Of these, three cases were determined to constitute human rights violations (including harassment), and corrective and remedial measures were implemented. Going forward, we will continue to enhance awareness and utilization of our consultation and reporting channels. At the same time, in light of the requirements set forth in the United Nations Guiding Principles on Business and Human Rights, we will continuously work to establish more effective processes to ensure that victims can access appropriate remedies, as well as to improve the compliance consultation / reporting system.

• Introduction of Application for On-site Workers开闭ボタン

  We continue collaborating with customers and business partners on some projects to introduce an application that allows on-site workers (including second and subsequent tier supplier employees) to report human rights concerns and grievances.
  Specifically, when a two-dimensional code is read on a smartphone, a report form is displayed, allowing workers to report concerns and grievances (anonymously if desired). In overseas projects, the application supports multiple languages, including the project's local language and the languages of worker country/region points of origin. The application is promoted through posters, handbooks, morning assemblies and other site meetings.

  

  （An example of two-dimensional code）

• Dialogue with Stakeholders开闭ボタン

  The Chiyoda Group engages in dialogue with all stakeholders, sharing information to ensure respect for human rights in all business activities. We continue dialogue with labor unions, on-site workers (including supplier workers in the 'Talk with the Workforce' initiative), participation in 'Building Responsibly' and collaborating with external consultants in the field of 'Business and Human Rights'.

1. A global consulting company with over 100 offices worldwide and over 1,500 consultants with government organization, regulatory agency, journalism, consulting and other experience, providing comprehensive business intelligence and solutions for business risks. J.S. Held provides global environmental, social and governance (ESG) advisory services, including independent recommendations, risk research, business intelligence, quantitative due diligence, corporate research and human rights due diligence, to global companies, government organizations, financial institutions, leading law firms, regulatory agencies and others.
2. 1. Elimination of Discrimination and Harassment 
   2. Prohibition of Forced Labor and Child Labor 
   3. Respect for Diversity and Work-Life Balance 
   4. Occupation Health and Safety 
   5. Working Hours and Wage 
   6. Respect for Basic Labor Rights 
   7. Harmony with Society
3. An international standard regarding labor and human rights, issued by the US NGO 'Social Accountability International', providing voluntary employer requirements, including worker rights in the workplace, the working environment and management systems. 
4. Established in 2017, 'Building Responsibility' is an organization led by companies in the engineering and construction sectors with the aim of promoting respect for human rights and the welfare of workers throughout the industry, to meet stakeholder expectations and legal requirements and maintain and manage a healthy and productive workforce.