The Tomoku Group is committed to helping create a society where the human rights of every individual are protected, and everyone can live with dignity and security. We believe it is important for all people to accept and respect one another, regardless of gender, nationality, age, disability status, beliefs, or values.
Recognizing that our business activities may have a direct or indirect impact on human rights, we have established the Tomoku Group Human Rights Policy to fulfill our responsibility to respect the human rights of everyone involved in our business. Guided by this Policy, we will further promote our initiatives to respect human rights throughout the Group.
Human Rights Policy
Practicing Respect for Human Rights
The TOMOKU Group regards the United Nations Guiding Principles on Business and Human Rights as its framework for implementation, and supports and respects international norms, including the International Bill of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. We have established the Tomoku Group Human Rights Policy (the “Policy”) and will promote initiatives to respect of human rights.
Compliance with Applicable Laws and Regulations
We comply with the laws and regulations of Japan and of each country and region in which it conducts business activities. If there is a conflict between internationally recognized human rights and the laws and regulations of any country or region, we will seek ways to respect international human rights principles to the greatest extent possible.
Scope of Application
The Policy applies to all officers and employees of the Group. We also expect all business partners involved in the Tomoku Group’s products and services to support the Policy and endeavor to respect human rights.
Responsibility to Respect Human Rights
We don’t infringe on the human rights of people affected by our business activities. If our business activities adversely affect human rights, we will take appropriate steps to remedy the situation and fulfill our responsibility to respect them. We prohibit all forms of discrimination based on race, nationality, ethnicity, gender, religion, beliefs, personal status, birth, age, disability status, sexual orientation, gender identity, or any other personal attribute, as well as harassment. We do not tolerate slavery labor, forced labor, child labor, or human trafficking. We provide a safe working environment, ensure compliance with minimum wage requirements, including appropriate management of working hours, and respect freedom of association and the right to collective bargaining. We also provide a safe and comfortable workplace that fosters open and active communication.
Human Rights Due Diligence
We will establish and continuously implement a system to identify adverse impacts on human rights and prevent or mitigate them.
Education and Training
We will provide appropriate education and training to ensure that the Policy is integrated into all our business activities and implemented effectively.
Dialogue and Consultation with Stakeholders
We will sincerely engage in dialogue and consultation with our stakeholders in the process of implementing the Policy.
Remediation
If it becomes clear that our business activities have caused adverse impacts on human rights, or our involvement in such impacts is identified, we will work to provide remediation through procedures based on international standards. In addition, we will maintain an effective reporting and response system, including contact points through which concerns related to our business activities can be reported.
Information Disclosure
We will disclose the progress of our initiatives to respect human rights on our website and through other channels.
Established: October 26, 2021
Revised: June 24, 2026
Terutaka Fukazawa
President & COO
Tomoku Co., Ltd
Framework for Promoting Respect for Human Rights
At Tomoku Co., Ltd., human rights-related departments—the President’s Office, Labor Relations Department, Legal and Compliance Office, and ESG Promotion Office—work together to develop mechanisms and systems to promote respect for human rights and to continuously gather relevant information. These departments regularly submit recommendations and reports to the Sustainability Project Team and the Sustainability Committee.
In addition, the Legal and Compliance Office, which receives reports and consultations, responds appropriately according to the nature of each matter and reports to the Executive Officers’ Committee and the Board of Directors as necessary. Decisions made by the Board of Directors are appropriately communicated to the relevant departments and reflected in their responses and initiatives.
Human Rights Due Diligence
We understand human rights due diligence (human rights DD) to be a series of processes to identify and assess risks of adverse impacts on human rights within the Group, among our business partners, and throughout the supply chain; to prevent and mitigate such risks; and to verify and disclose the status of our responses. We conduct this process on an ongoing basis with reference to the United Nations Guiding Principles on Business and Human Rights and the Japanese government’s Guidelines on Respecting Human Rights in Responsible Supply Chains, etc.
As a Sedex supplier member, Tomoku Co., Ltd. has all of its production sites complete the Sedex Self-Assessment Questionnaire (SAQ) annually and undergo assessment. In particular, we have identified migrant workers in Japan, including technical intern trainees employed by the Company, as a priority human rights risk area, as this issue has been pointed out by international human rights NGOs and in the U.S. Department of State’s Trafficking in Persons Report. To monitor this risk, we have introduced “Ninja,” a tool provided by the human rights NPO Caux Round Table Japan.
In addition, Tomoku Co., Ltd. conducts SAQs covering overall CSR topics for its raw material suppliers every two years in accordance with the Sustainable Procurement Guidelines. Group companies are requested to complete SAQs based on the Tomoku Group Human Rights Policy at the same frequency. To date, these SAQ surveys have not identified any significant human rights issues.
Since fiscal 2023, Tomoku Co., Ltd. has conducted an annual employee awareness survey covering all employees and positioned it as a means of identifying and monitoring human rights risks as part of its human rights due diligence process. Starting in fiscal 2025, major Group companies have also participated in the survey, strengthening the framework for identifying and monitoring human rights risks among the participating Group companies.