Human Rights Management

The Fuji Oil Group operates globally, and is directly or indirectly involved in the human rights of stakeholders at every stage of the value chain. Human rights are the rights of every person to live freely and equally, with the dignity inherent to all human beings. Guided by our vision stated in the Fuji Oil Group Management Philosophy: “Together with our stakeholders, we will co-create a sustainable future for food, based on plant-based ingredients that are both delicious and healthy,” we are committed to sustainability management. We fulfil our responsibility to respect human rights throughout the value chain and work to support the well-being of all our stakeholders.

As one of the values behind the Fuji Oil Group Management Philosophy, we uphold our commitment to work for people, and create value for all the people who form the backbone of the Fuji Oil Group. In April 2017, with approval by the Board of Directors, we established the Fuji Oil Group Human Rights Policy, which lays out our basic approach to human rights.
This policy applies to all Group officers and employees, and we also require the support, understanding and cooperation of our business partners and suppliers in complying with the policy.
We established the Fuji Oil Group Human Rights Guidelines in March 2023 as a set of specific guidelines to ensure that all employees share a common awareness of human rights and are able to properly fulfil their responsibilities to respect them in their business activities.
We require our suppliers to respect human rights in the Fuji Oil Group Supplier Code of Conduct, formulated in April 2021, and in the sourcing policies for our main raw materials. Thus, we put human rights into practice throughout the entire value chain.

Fuji Oil Group Human Rights Guidelines

Based on the Fuji Oil Group Human Rights Policy, we established the Fuji Oil Group Human Rights Guidelines in March 2023 as a set of specific guidelines to address human rights issues related to employees and working environments. The guidelines have been translated into nine languages so that all employees can use them.
We established the Guidelines as a part of our response to the “human rights in the workplace (harassment, forced labor)” risks identified in our second human rights impact assessment in FY2020, aiming to ensure that human rights are respected consistently across all Group companies.
Thus, as well as structuring our response to the major human rights risks related to employees, we strengthen human rights risk management systems throughout the Group.

Fuji Oil Group Supplier Code of Conduct

In April 2021, we established the Fuji Oil Group Supplier Code of Conduct. This Code of Conduct outlines standards of conduct for respecting human rights (non-discrimination, occupational safety and health, labor standards, freedom of association and collective bargaining, prohibition of forced labor and child labor, and consideration for local communities), as well as product safety and quality, the impact of environmental pollution on local communities, and information security and privacy. It also requires suppliers to put in place remediation mechanisms such as internal whistleblowing systems and grievance procedures.
As a Group, we strive to engage with our suppliers^* based on this Code of Conduct, to ensure that products and services are provided in a manner that respects human rights and the environment, and to enhance sustainability throughout the value chain.

• Fuji Oil Group Management Philosophy
  https://www.fujioil.co.jp/en/about/constitution/
• Fuji Oil Group Human Rights Policy
  https://www.fujioil.co.jp/en/sustainability/policy/human_right/
• Fuji Oil Group Human Rights Guidelines
  https://www.fujioil.co.jp/en/sustainability/policy/human_rights_guideline/
• Fuji Oil Group Supplier Code of Conduct
  https://www.fujioil.co.jp/en/sustainability/policy/supplier/
• Group policies on sustainable procurement
  https://www.fujioil.co.jp/en/sustainability/sustainable_procurement/#policy
• * Sustainable Procurement >Engagement with suppliers
  https://www.fujioil.co.jp/en/sustainability/sustainable_procurement/#suppliers_engagement

Our Group has established the Sustainability Committee* as an advisory body to the Board of Directors that is chaired by the President and CEO. The committee identifies and reviews material ESG issues related to human rights from the perspective of multiple stakeholders, including customers, human rights experts, and employees.
The Sustainability Development Department of Fuji Oil Co., Ltd. works with relevant divisions to identify priority human rights risks across the Group through human rights impact assessments. These results are reflected in priority actions to address the material ESG issues, with chief officers in charge of implementing specific initiatives for each of the priority actions. The Sustainability Committee deliberates on and monitors progress on these actions from a multi-stakeholder perspective and makes recommendations to the Board.
Business risks and opportunities related to human rights issues are identified as Group significant risks. We evaluate the severity and priority level of these risks and manage them within our Group-wide risk management framework, including planning and implementing response measures, with status reports to the Board of Directors at least once a year.
We also conduct an ongoing program of human rights awareness training to give officers and employees a deeper understanding of human rights and how to put this into practice, reflecting our commitment to human rights in our management and business activities.

• * Fuji Oil Group’s sustainability management > Governance

  https://www.fujioil.co.jp/en/sustainability/sustainability_management/?tab=1

Respect for human rights is a corporate responsibility and a vital prerequisite for sustainability management. It is also one of the key management issues for our Group. In particular, there are underlying human rights issues in the supply chains of the main raw materials that we rely on, including discrimination, harassment, forced labor, and child labor. Failure to address these issues could pose risks that affect our business continuity and corporate value.
Against the backdrop of growing societal demands related to human rights, and strengthened legal and regulatory frameworks in countries and regions, business risks are also becoming apparent, such as termination of business relationships with customers and impact on market access. Conversely, we see implementing human rights initiatives throughout the value chain as an opportunity to build greater trust with customers and stakeholders, while also enhancing employee engagement.
We conduct human rights due diligence based on the Fuji Oil Group Human Rights Policy and related policies and regulations. By identifying and assessing human rights issues across our value chain and reflecting the results in our material ESG issues and Group significant risks, we systematically manage and implement initiatives with a clear order of priority.

Our Group incorporates risks identified through human rights due diligence into our framework of material ESG issues and Group significant risks to manage issues in an integrated way from both risk and opportunity points of view.
Specifically, the following priority actions to address the material ESG issues are linked with Group significant risks. In this way, we prioritize and take action on issues related to human rights as integral part of our business activities.

Material ESG issues: Priority actions

Ensuring Product Safety and Quality Control, Reduction of Process Contaminants in Oils and Fats, Solutions for Health and Well-being, Creation of Diverse Plant-based Ingredients, Biodiversity Conservation and Restoration, Sustainable Procurement of Palm Oil, Sustainable Procurement of Cocoa, Sustainable Procurement of Soybeans, Sustainable Procurement of Shea Kernels, Promotion of DE&I, Securing and Developing Human Resources, Reducing Occupational Accidents and Property Damage, Information Security Management, Operation of a Trustworthy Whistleblowing System, and Promoting Fair Business Practices

• Fuji Oil Group’s sustainability management > Material ESG issues for FY2026

  https://www.fujioil.co.jp/en/sustainability/sustainability_management/?tab=4

Group significant risks

• Group significant risks > Risk type: Disasters and accidents; Environment and human rights; Procurement; Labor and human resources

  https://www.fujioil.co.jp/en/ir/policies_and_systems/risk/#significant_risks

Human rights due diligenceGRI:2-24,2-25,414-2

Overview

The UN Guiding Principles on Business and Human Rights^*1 clearly state that businesses have a responsibility to respect human rights. These principles require businesses to make policy commitments, conduct human rights due diligence,^*2 implement corrective measures, and ensure rightsholders’ access to remedy.
We conduct human rights due diligence as part of the “Implementation of the Responsibility to Respect Human Rights” specified in the Fuji Oil Group Human Rights Policy. Specifically, we conduct human rights impact assessments to comprehensively identify, assess and prioritize human rights risks in our Group’s business activities. Additionally, for high-priority human rights issues, such as issues in the supply chains of our main raw materials, we conduct due diligence on individual themes.
This enables us to systematically understand and address human rights risks throughout our value chain, and to focus on addressing priority issues.

• *1 Guiding Principles on Business and Human Rights: A set of international standards unanimously endorsed by the UN Human Rights Council in 2011.
• *2 Human rights due diligence: The act of identifying human rights risks in a company’s business throughout the supply chain, and explaining and disclosing information on the effectiveness of initiatives and approaches towards preventing and reducing those risks.

Human rights impact assessmentGRI:3-1

Our Group regularly conducts human rights impact assessments following the process outlined by the UN Guiding Principles on Business and Human Rights in order to identify and assess the possible negative impacts of our business activities on human rights and to clarify priority issues.
We make use of expertise from external experts to make these assessments more objective, enabling us to accurately understand and prioritize human rights risks across our entire value chain.

First and second human rights impact assessments

Third human rights impact assessment

In FY2024, we conducted our third human rights impact assessment under the guidance of US-based NPO Business for Social Responsibility (BSR) to re-identify priority human rights risks to address.

• * Rights holders: Individuals or groups whose human rights are potentially or actually impacted by the company’s business, products, or services

• See “Metrics and Targets” for actions to address the priority human rights risks identified.

  Metrics and Targets

In FY2024, along with our regular human rights impact assessment, we conducted a gap analysis of the effectiveness of our human rights due diligence practices against the UN Guiding Principles on Business and Human Rights and current initiatives in the food industry. The results highlighted the need to further strengthen our human rights governance and implement more robust due diligence initiatives in areas and issues identified as high risk.
In response, we established operational rules for the Fuji Oil Group Supplier Code of Conduct in FY2025 as a framework for Group companies to consistently implement supplier management based on the Code of Conduct. This will make human rights risk management more effective across our entire value chain and strengthen our human rights governance.

Human rights due diligence for key raw materials

In addition to the human rights impact assessment for the whole Group, we conduct human rights due diligence, including direct dialogue with rights holders, for the key raw materials where we are aware of particularly high risks in the supply chain.
This enables us to identify and assess actual and potential human rights risks, and we take action to prevent or mitigate these risks, and ensure effective management of human rights issues across the value chain.

• *1 In our Responsible Palm Oil Sourcing Policy, we have committed to “No Deforestation, No Peat, and No Exploitation (NDPE)."
• *2 Freedom of movement, contract management, ethical employment, grievance management, wages and working hours, freedom of association, health and safety, and accommodation.

Human rights risk management system

Since our first human rights impact assessment in FY2016, we have been working as a Group to understand expectations and views relating to human rights through ongoing dialogues with various stakeholders including experts in the field of business and human rights, industry groups, and NGOs active in regions where our key raw materials are produced.
We have also been working to address the human rights issues identified through this dialogue and our human rights impact assessments, by taking appropriate action to reduce negative impacts and create positive impacts.

• *1 DCF: Deforestation and Conversion Free
• *2 Support for the transition from conventional palm oil agriculture to regenerative agricultural systems that do not rely on chemicals and are responsible for biodiversity.
• *3 We are establishing joint ventures with suppliers that practice responsible farm management to expand the supply of environmentally responsible, high-value-added palm oil.
• *4 HCV/HCS: High Conservation Value / High Carbon Stock
• *5 FPIC: Free, prior, and Informed consent is an international human rights principle which requires that, before any development or business activities affecting land or resources belonging to Indigenous people or local communities, these people should be provided with sufficient and accessible information and should give their prior consent voluntarily, without coercion or undue influence.
• *6 The scope of the Labor Transformation Program covers the following eight areas and works to identify and correct human rights issues: (1) employment contract management, (2) wages and working hours, (3) employee grievance management, (4) freedom of movement, (5) freedom of association, (6) ethical employment, (7) worker accommodation, (8) health and safety.
• *7 NDPE: No Deforestation, No Peat, No Exploitation.
  Our Responsible Palm Oil Sourcing Policy outlines the NDPE goals our Group aims to achieve.
  Responsible Palm Oil Sourcing Policy
  https://www.fujioil.co.jp/en/sustainability/policy/palm_procurement/

Grievance mechanismsGRI:2-25

Whistleblowing system

Our Group has established a whistleblowing system to report violations of laws and regulations or misconduct, as well as acts that may violate or potentially violate laws, regulations, or the Group’s Code of Conduct or policies, including harassment, discrimination, and other human rights violations by the officers and employees.
This system is available to officers and employees (including former employees) of Group companies worldwide, as well as external stakeholders such as business partners, helping us to understand human rights risks throughout the value chain and take prompt corrective action.

• Operation of a Trustworthy Whistleblowing System > Whistleblowing system

  https://www.fujioil.co.jp/en/sustainability/compliance/#whistleblowing

• Governance > Compliance > Whistleblowing system

  https://www.fujioil.co.jp/en/about/governance/compliance/#topic03

Grievance mechanism for our supply chains

Our Group established a grievance mechanism^*1 in May 2018 based on our Responsible Palm Oil Sourcing Policy. This mechanism provides a way for stakeholders and other concerned parties to raise concerns about environmental or human rights issues within the Group’s palm oil supply chain.
To ensure transparency, we set up a grievance mechanism webpage in English^*2 on our Group website, where we publish an overview of the mechanism and updates on progress in our response.

• *1 Sustainable Procurement of Palm Oil > Grievance mechanism

  https://www.fujioil.co.jp/en/sustainability/palm_oil/#grievance_mechanism

• *2 Fuji Oil Group Grievance Mechanism

  https://www.fujioil.co.jp/en/sustainability/grievance_mechanism/

Education, awareness raisingGRI:2-17, 2-24

Executive training on business and human rights: Human rights dialogue

To enable our Group to implement human rights initiatives across the entire value chain, it is crucial for our top management to have a thorough understanding of international standards and social expectations relating to business and human rights agenda, and to reflect this in highly effective policies.
In FY2025, we conducted training sessions for company executives and a dialogue session with an expert. The aim was to deepen understanding of the fundamental concepts and latest social trends in the fields of business and human rights, as well as objective evaluation of the Fuji Oil Group’s human rights initiatives.

In the dialogue session, attendees discussed how to effectively conduct human rights due diligence and prioritize issues, as well as how human rights should be approached given the international situation. These discussions have deepened understanding at the management level, which will be reflected in future actions.

Fuji Oil Group Human Rights Week

We designated the week of December 10, International Human Rights Day, as Fuji Oil Group Human Rights Week. During this period, leadership statements on business and human rights are shared with all Group employees, and e-mail messages are sent to draw attention to the event.
We enhance all our employees’ understanding of human rights and encourage them to put it into practice in their everyday work.

The table below shows the main initiatives to address priority human rights risks identified in our third human rights impact assessment.