Human Rights Due Diligence

Our Human Rights Due Diligence Procedure

The KOSÉ Group is promoting human rights due diligence in keeping with the procedures outlined in the United Nations’ “Guiding Principles on Business and Human Rights (UNGPs),” and based on the laws and regulations of each country in which we do business.
This is an ongoing process, guided by the KOSÉ Group Human Rights Policy, in which we (1) determine possible negative impacts and issues to be addressed, (2) implement appropriate measures, (3) conduct monitoring and follow-up evaluations, and (4) disclose relevant information, as well as communicate with external stakeholders.

Human Rights Due Diligence

Human Rights Due Diligence Process

KOSÉ Group Initiatives, Step by Step

KOSÉ Group Initiatives, Step by Step

Identification of Possible Negative Impacts on Human Rights and In-House Review of Human Rights Issues

In order to determine possible negative impacts and issues to be addressed—step one of the process set out by UNGPs— we have been conducting human rights risk assessments (assessments of potential risks to human rights posed by our business activity) on an ongoing basis since FY2021.
To do this, we have carried out desk research into human rights risks in each of the countries in which the KOSÉ Group does business and conducted reviews in eight divisions within the Company (including associated Group companies) of actual and potential human rights risks that could arise in the value chain of our business, using the table of human rights issues specific to the cosmetics and daily necessities industry published by Caux Round Table Japan (based on the Human Rights Guidance Tool developed by the United Nations Environment Programme Finance Initiative [UNEP FI]). We have also used additional interviews with both Japanese and overseas divisions to verify the severity of certain risks and incorporated social perspectives acquired through discussion with NPOs representing small-scale palm farmers and the third sector, employee satisfaction surveys, and other engagement with rights-holders. We have also examined the possibility of actual and potential negative human rights impacts occurring in Japan and overseas, as well as the status of preventative and corrective measures implemented by the KOSÉ Group in response, and used this information to evaluate particularly critical human rights issues.
We have examined the value chain of our business at every step, from research, planning, and development, to procurement, production, logistics, offices, public relations and advertising, sales, (customers’) use of our products, and wastage. We consider external supply chains, employees at KOSÉ Group facilities (regardless of employment status), customers, and wider society (including indigenous people, local residents, immigrants, and others living near our facilities) to be rights-holders with the potential to have an impact. We have established (1) gender, including LGBTQ+ and women, (2) working conditions, (3) race and nationality, including religious and cultural background, (4) safety, including hygiene, and (5) other (environment and living conditions, disability status, age, work experience, etc.) as our human rights metrics.
In FY2022, we expanded our risk assessment framework and carried out assessments at all KOSÉ Group operating bases (47 bases and divisions), alongside a survey using our Human Rights Self-Assessment Checklist (Response rate: 100%). This qualitative survey allows us to ascertain the different human rights risks and countermeasures arising due to unique factors in each of our bases and businesses. This data is consolidated and used in the ongoing implementation of our governance structure for the management of potential risk from a short- to medium-term perspective.

An Overview of Possible Negative Impacts of the KOSÉ Group on Human Rights (Identified Internally)

Potential Negative Impacts on Human Rights Human Rights Metrics Our Value Chain and Rights-Holders
External Supply Chain
(Suppliers, production & logistics contractors, etc.)
KOSÉ Group Facilities
(Research, production, internal distribution, offices, sales and marketing sites, etc.)
Wider Society
(Communications, website & public relations, customers’ use of our products, etc.)
Employees of our business partners, residents of areas in near their facilities Employees, residents of areas near our facilities, recruiters Average consumers, our customers
Gender
  • Discriminatory treatment on the basis of gender
  • Discriminatory treatment on the basis of gender
  • Discrimination in hiring practices
  • Reinforcement of a stereotypical approach to gender
  • Discrimination in products, promotions, customer service response, etc.
Working Conditions
  • Child labor, long-working hours, forced labor, work in harsh conditions (e.g., high heat)
  • Lack of appropriate remuneration
  • Harassment (all categories)
  • Adverse effects on employees’ mental and physical health due to overwork
  • Mental and physical difficulties due to the COVID-19 pandemic
  • Lack of appropriate remuneration
Race & Nationality
  • Conflict arising as a result of national or other cultural differences

  • Exploitative labor practices concerning workers taking part in the Specified Technical Intern Training Program
  • Harm arising as a result of national or other cultural differences
  • Isolation due to language barriers
  • Discrimination in hiring practices
  • Reinforcement of discrimination through product and value provision that does not allow for diversity of skin and hair colors
  • Discrimination in the information we share or our communications
Safety
  • Lack of a safe environment for the handling of chemicals, hazardous substances, etc.
  • Lack of sanitary conditions, in terms of pandemics, water access, etc.
  • Lack of a safe environment for the handling of chemicals, hazardous substances, etc.
  • Lack of sanitary conditions, in terms of pandemics, water access, etc.
  • Health impacts due to provision of products that do not meet safety/quality standards
  • Misuse of products or health impacts, including skin problems, due to inadequate or flawed product descriptions
Other
  • Living conditions, water access, and health impacts affecting those living near operating bases
  • Contribution to climate change and impact on biodiversity through environmental impacts on areas surrounding operating bases
  • Depletion of resources in areas surrounding operating bases
  • Discrimination against employees with disabilities
  • Discrimination on the basis of age, years of experience, or employment status
  • Breach of privacy in digital spaces
  • Living conditions, water access, and health impacts affecting those living near operating bases
  • Contribution to climate change and impact on biodiversity through environmental impacts on areas surrounding operating bases
  • Depletion of resources in areas surrounding operating bases
  • Delay in ascertaining issues due to inadequate governance systems as a result of expansion of our business activities
  • Breach of customer privacy when using digital tools
  • Reinforcement of age-related stereotypes
  • Reinforcement of a public consensus that encourages dismissal of environmental impacts
Key Group Initiatives

Basic Procurement Policy and Sustainable Procurement Guidelines

Initiatives aimed at our suppliers

  • Holding procurement policy briefings and events to show appreciation for our valued suppliers
  • Monitoring for sustainable procurement
  • Joining Sedex

Support for sustainable palm oil

  • Becoming a member of the RSPO and working toward procurement of RSPO-certified palm oil (goal of 100% by 2030)
  • Acquiring SCC certification
  • Monitoring working conditions through site visits and data collection

Compliance with privacy protection policies

Promotion of diversity & inclusion

  • Initiatives allowing staff to play actives roles in the Company regardless of their gender, age, past career, disability status, or nationality

Initiatives for meeting compliance requirements

  • Initiatives for compliance with KOSÉ Group Principle of Conduct
  • Conducting educational programs to prevent all types of harassment

■ Promoting attention to occupational hygiene and Health & Productivity Management

Compliance with privacy protection policies

■ Provision of products, public relations, and services tailored to our diverse customers

Compliance with privacy protection policies

Complaints Processing Mechanisms
  • Establishing a Harassment Help Desk
  • Establishing a Reporting and Consultation Desk

As a result of our assessments, we have identified two particularly salient human rights issues for the KOSÉ Group: continuously ascertaining human rights issues in the raw materials procurement supply chain, and diversity and inclusion in the Company and human rights in the workplace. In the former area, our assessments showed that continuous monitoring for human rights violations in the category of working conditions—such as forced or child labor—is particularly vital in supply chains connected with the development of oil palm plantations. We made this judgment based on our extensive use of palm oil derivatives in our cosmetics, the large scale of the impact that the unlikely event of a human rights violation would have on rights-holders, and the high risk that any such incident would be reported on or otherwise documented in the international community, among other factors. The issue of diversity and inclusion in the Company and human rights in the workplace was selected as a key issue due to the fact that we judged employee awareness to be high around preventing harassment, promoting active roles for women, and compliance in general, but Company education and awareness-raising on gender and sexual diversity (LGBTQ+) to be lacking. While we have confirmed that the KOSÉ Group has no employees taking part in the Specified Technical Intern Training Program, our judgment on this issue was also informed by the fact that raising the level of employee awareness around diverse nationalities and cultures and improving human rights awareness will become increasingly important going forward as we globalize our business. We additionally identified promoting communication of information and responses (public relations, advertising, customer service, product explanations, etc.) that keep diversity in mind as an important factor in allowing us to have a positive impact on society through our respect for human rights. For all of these issues, a third-party organization specializing in human rights risk assessment provides an objective evaluation of the suitability of the KOSÉ Group’s process for determining human rights risks and the status of our initiatives, with a particular focus on issues we should address.
Going forward, we will continue to conduct regular annual reviews to ascertain the risk and nature of human rights issues potentially arising in our value chain, determine critical human rights issues, and implement appropriate measures to counteract these identified issues on an ongoing basis.

Top Priority Human Rights Issues and Risk Management

For each of our identified priority human rights themes, we are advancing the risk management measures listed below.

Identified Human Rights Theme Status and Response Measures
Continuously ascertaining human rights issues in the raw materials procurement supply chain
  • Ascertain through platforms such as Sedex* and self-assessment questionnaires (SAQs)
  • Ascertain through direct dialogue with small-scale palm growers
Diversity and inclusion in the Company and human rights in the workplace
Promote the communication of information and our responses (public relations, advertising, customer service, product explanations, etc.) with diversity in mind
  • Promotion of adaptability as a management strategy and incorporation in business activities
  • Unconscious bias education, mainly for people in charge of marketing

*Sedex(Supplier Ethical Data Exchange)
Sedex is the world’s largest cooperative platform for buyers and suppliers to share and confirm information regarding labor practices, health and safety, the environment, and business. It was established to promote ethical and responsible business practices in global supply chains.

Third-Party Opinion

As we advance our human rights due diligence, our initiatives to promote respect for human rights consider not only KOSÉ Group perspectives but also emphasize viewpoints from wider society. We conduct our human rights risk assessments with the collaboration of the Caux Round Table (CRT) Japan.

VOICE

Hiroshi Ishida
Executive Director of CRT Japan

Hiroshi Ishida Executive Director of CRT Japan

Hiroshi Ishida
Executive Director of CRT Japan

Human Rights Due Diligence Initiatives

I confirm that the KOSÉ Group has recently conducted human rights due diligence and risk assessments, based on UNGPs and with the involvement of relevant departments and third-party organizations, which identified human rights issues along the Company’s value chain with the potential to have significant negative effects on society.
Going forward, I hope to see the KOSÉ Group determine salient human rights issues through direct dialogue with others, respond to these issues, and facilitate expansion and use of its current grievance mechanisms involving its supply chains.