Respect for Human Rights
Our Approach
The SUBARU Group puts people first and engages in people-oriented manufacturing. Based on the belief that respect for the rights and characteristics of individuals is an important management issue for SUBARU, the SUBARU Group established its Human Rights Policy in April 2020. In this policy, the Group respects the human rights stipulated in international norms such as the Universal Declaration of Human Rights (UDHR), International Bill on Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work. It also applies to SUBARU CORPORATION and all its subsidiaries, as well as to business partners, and other stakeholders. The policy states that we do not tolerate any discrimination based on race, age, sex, gender identification or expression, sexual orientation, national origin, ethnicity, religion, creed, profession, disability, family relations, or any other status protected by applicable law.
This policy was formulated with full consideration to stakeholders’ expectations, incorporating discussions with outside experts and overseas subsidiaries. It was officially established after agreement by the second meeting of the CSR Committee for FYE March 2020 and reported to the Board of Directors in March 2020. This policy is run globally and appropriately, being ready to address future environmental changes.
- *
- Renamed in FYE March 2022 from the CSR Committee to the Sustainability Committee.
Human Rights Policy
Principle of Respect for Human Rights
The SUBARU Group, through its automotive and aerospace businesses, puts people first and engages in people-oriented manufacturing.
The Group considers respect for the rights and characteristics of individuals as an important management issue for SUBARU. Based on this policy, the SUBARU Group clarifies its responsibilities to respect human rights based on the United Nations Guiding Principles on Business and Human Rights.
1. Compliance with Laws and Regulations to Respect Human Rights
(Scope and Management Structure)
- This policy applies to the SUBARU Group worldwide―SUBARU CORPORATION and its all subsidiaries, expects and encourages our business partners and other stakeholders associated with our operations, including those in the supply chain, to respect human rights in accordance with this policy. To realize these goals, we have appointed the Representative Director, President and CEO as a director who is responsible for leading the process of developing this policy and assigning resources as needed for its implementation and continued improvement.
(Related Laws and International Norms)
- We will comply with the relevant laws and regulations of each country, and respect the human rights stipulated in international norms such as The Universal Declaration of Human Rights (UDHR), International Bill on Human Rights(International Covenant on Economic, Social and Cultural Rights, and International Covenant on Civil and Political Rights), and the ILO Declaration on Fundamental Principles and Rights at Work. If the standards set forth in the international norms exceed those set forth in applicable law, we will aim to adhere to the international norms.
2. Implementation of Human Rights Due Diligence
(Response to Human Rights Risks)
- We will identify potential or actual human rights risks linked to our business and establish and continuously operate mechanisms to prevent or mitigate such risks.
(Corrective Actions)
- We will strive to remedy any adverse human rights impact that we have caused or are involved in. We will also establish and maintain our grievance mechanism to do so.
(Training)
- To ensure that this policy is understood and practiced by all the members of the SUBARU Group, we conduct regular training and awareness-raising programs for executives, employees, and other stakeholders to respect human rights.
(Dialogue and Consultation)
- We engage in dialogue and consultation with relevant stakeholders in order to improve our commitment to respect for human rights.
(Information Disclosure)
- We will annually report on our commitments and the actions we have taken to respect and promote human rights pursuant to this policy.
Revised in March 2022
Human Rights Policy Appendix
Priority Human Rights Issues in SUBARU Group’s Businesses
The SUBARU Group’s manufacturing is supported not only by our own factories, but also by an extremely large number of people working in the multilayered supply chains. We also have contact with a variety of people in areas such as marketing, sales, and after-sales service through distributors and dealerships all over the world. In the mobility society in which we are involved, we provide products and services through our businesses that value the many irreplaceable lives around the world. In order to respect human rights, and the numerous irreplaceable lives of all those involved in the SUBARU Group, we will actively address the following as priority issues identified so far.
We will regularly review the priority issues in this Appendix based on changes in social demands, including laws and regulations, technical progress, and the business operations of the SUBARU Group.
(Respect for Rights to Human Life and Property)
- In order to protect the basic rights of people and their families who interact with SUBARU Group’s products and services, such as drivers, passengers, and pedestrians, we aim to eliminate all traffic accident deaths that involve SUBARU vehicles.
- We will promote the humanitarian use of the SUBARU Group’s various products and services, including disaster relief, and strive to avoid nonhumane use.
(Respect for Individuals, Diversity and Inclusion)
- We value the unique characteristics of our employees, our business partners, and the members of the communities in which we operate and strive to create an environment of diversity and inclusion.
- We will conduct our business activities with full respect for privacy, including protecting the personal information of not only our customers and employees, but also those involved with the SUBARU Group.
(Zero Tolerance for Discrimination and Harassment)
- We do not tolerate any discrimination based on race, age, sex, gender identification or expression, sexual orientation, national origin, ethnicity, religion, creed, profession, disability, family relations, or any other status protected by applicable law among all persons involved in the SUBARU Group. Moreover, we do not tolerate any harassment that harms human dignity.
- We will carefully consider potential human rights risks in our marketing and other communication activities, and do not tolerate expressions that are discriminatory or may adversely affect children.
(Respect for the Workers’ Rights in SUBARU Group and Encouraging Our Supply Chains)
- We do not tolerate child labor, forced labor, slave labor, and human trafficking.
- We do not expose young workers to hazardous work.
- We will give due consideration to the human rights of foreign workers and migrant workers.
- We respect freedom of association and the right to collective bargaining, which are fundamental workers’ rights. We are committed to engagement with employees to ensure a positive working environment.
- We will maintain a worthwhile, safe, and hygienic working environment.
- In order to promote the well-being of workers, we will pay appropriate wages more than the minimum and living wages, and manage working hours appropriately.
- We expect and encourage our supply chains to respect the rights of workers.
(Respect for the Rights of Vulnerable People in Local Communities)
- We engage in responsible procurement practices including those related to conflict minerals.
- We will give special consideration to respect for the human rights of women, children, people with disabilities, social minorities, ethnic minorities, indigenous peoples, and other vulnerable groups.
(Contributions to Respect for Human Rights)
- We will actively contribute to human rights protection worldwide through the SUBARU Group’s corporate citizenship activities.
Established in April 2020
Management System
To strengthen and advance its initiatives for human rights, the SUBARU Group has appointed the Representative Director, President and CEO as a director who is responsible for leading the process of developing this policy and assigning resources as needed. Specifically, we formed the Human Rights Task Team comprised of management personnel including the General Managers from the Human Resources Department, IR Department, Sustainability Promotion Department, Risk Management and Compliance Office, Global Purchasing Planning Department, the Gunma Plant General Administration Department, and the Aerospace Company Procurement Department. This team regularly examines human rights issues and their countermeasures and implements the plan-do-check-act (PDCA) cycle. The content of examinations within the team is regularly reported and deliberated upon in the Sustainability Committee, chaired by the Representative Director, President and CEO. The details and outcomes are then submitted and reported to the Board of Directors, where they are monitored for their impact on the SUBARU Group’s business and appropriately addressed.
| FYE March | Description |
|---|---|
| 2019 | ·Establishment of the Human Rights Policy |
| 2020 | ·Human rights risks and corresponding measures in the SUBARU Group |
| 2021 | ·Progress update on measures addressing human rights risks ·Newly identified human rights risks and corresponding measures |
| 2022 | ·Human rights initiatives in the SUBARU Group ·Progress update on measures addressing human rights risks |
| 2023 | ·Progress update on measures addressing human rights risks ·Additional measures addressing human rights risks |
For specific human rights risks and measures, please see Initiatives.
Targets and Metrics
The SUBARU Group puts people first and engages in people-oriented manufacturing. SUBARU is working to embody its belief that respect for the rights and characteristics of individuals is an important management issue.
Risks and Measures in Initiatives for Respect of Human Rights
At the SUBARU Group, we recognize that the area of respect for human rights presents risks related to industries and business activities.
If the SUBARU Group or its business partners or other affiliated parties engage in activities that violate regulations regarding labor environments and occupational health and safety, or activities constituting any kind of harassment, infringement of workers' rights and opportunities, or procurement that violates human rights, we believe that this is not just a violation of relevant laws and regulations. Beyond this, we believe that this could result in a loss of customer trust and confidence, lead to a damaged brand image due to flagging opinions and reputations in society, impede sales, lead to turnover in human resources, make it difficult to procure materials and funds, or other negative outcomes, which could have a significant impact on our business foundation and our business performance and financial position.
The SUBARU Group has formulated the Human Rights Policy, and based on this policy, we carry out human rights due diligence to identify business-related human rights risks and formulate and implement measures to address them. Of these risks, we are steadily implementing measures to address those of particular importance to the SUBARU Group, and we are continuously working to mitigate risks. In addition, we are advancing initiatives for the respect of human rights in encouraging our business partners and other stakeholders associated with our operations, including those in the supply chain, to respect human rights in accordance with this policy.
Initiatives
Establishment of the Human Rights Policy
Based on the belief that respect for the rights and characteristics of individuals is an important management issue for SUBARU, the SUBARU Group established its Human Rights Policy in April 2020. This policy was developed through discussions with external experts, consultations with specialists, and deliberations with overseas subsidiaries, taking into full consideration the expectations of stakeholders. It sets forth that the SUBARU Group’s universal sense of purpose in acting for the good of people not only applies to our customers and employees but also extends across the entire value chain. This policy is published on our website in Japanese and English for stakeholders in each country and region.
Based on the Human Rights Policy, the SUBARU Group, in order to fulfill its social responsibility in its global business activities, will respect the human rights of all stakeholders associated with the Group and continue managing its operations in line with respect for human rights, working to prevent and mitigate potential negative impacts on human rights.
Activities to Raise Awareness of Human Rights
SUBARU has held seminars and taken other measures to encourage understanding every year since FYE March 2021 aimed at helping employees obtain knowledge about business and human rights. Specifically, the seminars aim to foster awareness of the importance of respecting human rights in one’s own duties and everyday business activities by understanding the changing external landscape and real-life instances of human rights issues, while recognizing the SUBARU Group’s stance on respect for human rights through the Human Rights Policy. In the second half of FYE March 2024, we provided all employees with harassment prevention education, and during Human Rights Week in December, we sent out messages on business and human rights and the SUBARU Group's Human Rights Policy via our intranet.
We also raise awareness of human rights initiatives among our suppliers through measures such as procurement policy briefings and business partner CSR briefings.
| Eligible participants | Program period | |
|---|---|---|
| FYE March 2021 | SUBARU human resource departments’ manager-class employees | September 2020 |
| All SUBARU procurement departments’ employees | September 2020 | |
| FYE March 2022 | All SUBARU executives | January 2022 |
| FYE March 2023 | SUBARU Gunma Plant’s manager-class employees | March 2023 |
| FYE March 2024 | All SUBARU employees | September 2023 to March 2024 |
Stakeholder Engagement
In the SUBARU Group, we strive to accurately grasp stakeholder expectations related to human rights. To ensure timely response, we hold discussions with experts and maintain communication with institutional investors and external assessment organizations as required. In FYE March 2024, we once again engaged in discussions with multiple institutional investors, during which we explained the SUBARU Group’s perspective and initiatives regarding human rights. Specifically, we discussed issues such as human rights due diligence and grievance mechanisms in the supply chain. Moreover, we actively shared the latest information on our initiatives to external evaluating organizations, and expectations and suggestions raised by each organization are reported to the Sustainability Committee and shared among all executives.
Human Rights Due Diligence
The SUBARU Group carries out human rights due diligence in accordance with the procedures stipulated in the United Nations Guiding Principles on Business and Human Rights. We will actively work on this initiative together with our suppliers.
From FYE March 2021 to FYE March 2022, with cooperation from LRQA Sustainability Co., Ltd. (https://lrqa-sus.co.jp/), an organization with specialized knowledge on business and human rights, we identified and conducted impact assessments for human rights risks in the domains of human resources and procurement, identifying particularly key risks for the SUBARU Group. We have also formulated measures to address each of these risks. These are agreed upon by the Sustainability Committee and reported to the Board of Directors.
Beginning in FYE March 2023, we put into action measures to mitigate risks, while concurrently monitoring the progress and challenges through the Human Rights Task Team. This procedure includes presenting reports to the Sustainability Committee and the Board of Directors, thus establishing the PDCA cycle.
- Identifying human rights risks
In FYE March 2021, we held study groups on business and human rights for SUBARU employees in each of the domains of human resources and procurement as well as workshops with representatives from hands-on teams. Through these workshops, we identified potential human rights issues, and based on these issues, we conducted interviews and factory inspections with stakeholders in each domain, identifying human rights risks. In FYE March 2021, the workshop identified risks encompassing the human resource domain at the Gunma Plant and the procurement domain in the Automotive Business, with the scope expanded in FYE March 2022 to include the human resource domain at the Head Office, Tokyo Office, and Utsunomiya Plant, and the procurement domain in the Aerospace Business.
In FYE March 2024, we re-examined the human rights risks and measures in the human resource domain that we identified in FYE March 2021 from the perspective of automobile manufacturing through a sampling survey, including on-site inspections and interviews with relevant personnel by LRQA Sustainability Co., Ltd. As a result, from the perspective of compliance, there were no issues identified that required improvement or that posed an immediate risk of harm to the people being interviewed. Going forward, we plan to expand and continue our examinations. - Conducting impact assessments and identifying particularly key risks
Human rights risks identified in each domain were considered mainly along the axes of magnitude of impact and likelihood of occurrence. Though the results of a detailed analysis of the results of the human rights risk survey revealed no significant risks requiring urgent action or violations of local laws or international norms, particularly key risks for the SUBARU Group were identified.
Particularly key human rights risks Human resources domain Long working hours, occupational accidents, harassment of workers, forced labor among foreign workers Procurement domain Human rights violations among suppliers, responsible mineral procurement (e.g., conflict minerals, cobalt), harassment of suppliers - Formulation of measures to address key risks
For each of the human rights risks identified in each domain, we formulated measures to prevent and mitigate potential negative impacts. In addition, we have formulated new measures for further improvement and more thorough preparation in response to risks in the human resource domain that were re-examined from the perspective of automobile manufacturing in FYE March 2024. All of these measures have been reviewed by LRQA Sustainability Co., Ltd. - Implementation and monitoring of measures
The departments in charge of each domain are implementing measures for each risk identified, with the Human Rights Task Team monitoring the progress of the measures. In addition, we ensure continuous monitoring by regularly reporting the progress to the Sustainability Committee and the Board of Directors, aiming to mitigate the risks. For measures in the procurement domain, we collaborate with our business partners to advance initiatives based on the SUBARU Supplier CSR Guidelines.
SUBARU Supplier CSR Guidelines - Conducting harassment prevention workshops for management
- Held department study groups during No Workplace Harassment Month to create a pleasant working environment
- Preventing harassment and fostering greater awareness among employees
- Operating a harassment consultation service
- Early detection of risk issues using 360-degree evaluations for managers
- Informed employees about and encouraged use of consultation services
- Identified high-risk individuals from evaluation results and conducted follow-ups with target workplaces
- Collaborating with supervisory bodies based on memorandums of understanding* regarding foreign trainee workers, and preventing misconduct and unfair treatment through regular audits
* SUBARU bears the cost of recruitment expenses (such as travel and training fees). - Maintained daily coordination with supervisory bodies and conducted regular audits every three months and workplace patrols every month
- Enhancing collaboration with supervisory bodies and staffing agencies
- Ensuring installation of sanitary boxes in women's bathrooms at factories
- Carrying out of supply chain human rights due diligence
- Continued to carry out business partner CSR briefings and CSR surveys
- Improving the accuracy of supply chain and human rights due diligence
- Building a supply chain grievance mechanism
- Maintained a worker consultation service via JP-MIRAI’s collaborative program
- Establishing consultation and remediation services
- Human rights measures for conflict minerals (gold, tin, tantalum, and tungsten)
- Continued to implement conflict mineral surveys
- Gathering information and preparing for compliance with new international laws and regulations
- Human rights measures for non-conflict minerals
- Continued to implement cobalt surveys for battery manufacturers
- Partnership Formation Oath (Japanese version only)
- Implemented the provisions of the Oath
- Promoting and increasing awareness of fair trade throughout the supply chain
- Compliance with the JAMA Voluntary Action Plan
- Checked with business partners whether price negotiations are necessary, and conducted explicit consultations
| Human rights risks | Example measures implemented | FYE March 2024 results | Issues | |
|---|---|---|---|---|
| Human resources domain | Harassment of workers | |||
| Forced labor among foreign workers | ||||
| Infringement of rights of vulnerable people in local communities (automobile manufacturing perspective) | - | - | ||
| Procurement domain | Human rights violations among suppliers | |||
| Responsible mineral procurement | ||||
| Harassment of suppliers | ||||
Prevention of harassment
The SUBARU Group has re-identified harassment of workers as a particularly key risk, and in our Human Rights Policy, we clearly state that there is “zero tolerance for discrimination and harassment.” Seeking to prevent all forms of harassment, we prohibit such behavior in our work regulations, and it is also mentioned in the Compliance Manual and spread among all Group companies, not just SUBARU. SUBARU has also formulated the Harassment Explanatory Booklet and is working to create an environment in which harassment does not occur in workplaces overall.
Also, SUBARU has formulated and distributes the Harassment Explanatory Booklet and holds study groups for all managers and supervisors to exchange opinions and discuss cases from both inside and outside the Company, in an effort to create an environment where harassment does not occur in workplaces overall.
Additionally, for instances where harassment or similar issues have been identified, we use training sessions for rectification led by the Risk Management and Compliance Office to prevent any future occurrences.
Contact for opinions and consultation services
The SUBARU Group has established a system for hearing voices from a range of stakeholders.
Diverse inquiries, feedback, and grievances, including those pertaining to human rights, are handled appropriately and confidentially through respective channels, with confidentiality and anonymity assured. There shall be absolutely no retaliation for any kind of complaint that may be made through this system.
- For employees
We have set up a Compliance Hotline and a Harassment Advice Line internally and externally, creating an environment in which all employees, including those at Group companies, can receive advice. In particular, the Compliance Hotline provides consultation services in four languages (English, Chinese, Portuguese, and Spanish). We also introduced confidential online consultations in October 2022. We encourage open conversations through an easily approachable consultation system and focus on early identification and resolution of issues through internal assessments and discussions with relevant parties and stakeholders.
Compliance Hotline - For customers
SUBARU Customer Center: SUBARU Call has been established as a system for promptly sharing information on customer opinions and comments with relevant departments and utilizing this information to make improvements.
We respond earnestly to inquiries about products and services as well as various other opinions and concerns. If requested by the individual submitting the inquiry, we treat the matter as confidential.
In addition, we communicate the feedback received from individuals in the regions where SUBARU has its offices with the relevant departments in an effort to resolve matters.
SUBARU Call for Japanese customer - For business partners (suppliers)
At SUBARU, we are taking actions to promote fair trade based on the Automobile Industry Fair Trade Guidelines. As part of this effort, we have established a consultation service for promoting fair trade for business partners in SUBARU’s supply chain, with the aim of early detection, prevention, corrective measures, and preventing recurrence of compliance issues.
In FYE March 2023, we endorsed and cooperated with the supply chain human rights initiative, Japan Platform for Migrant Workers towards Responsible and Inclusive Society (JP-MIRAI), on the establishment of a consultation service for foreign workers in the supply chain in Japan. As background to this, employees of the Purchasing Division, including the general manager in charge, took part in JP-MIRAI’s “Consultation and Relief Pilot Project for Foreign Workers.” We continued our participation with the “Collaborative Program for Companies Responsibly Hosting Foreign Migrant Workers,” which marked the full-fledged implementation of the program in FYE March 2024, targeting local business partners.
We provide support in 22 languages*1 for the consultation service, the area of the program that SUBARU is involved in. This service is available not only for non-Japanese but also Japanese workers employed by business partners. The consultation service covers a wide range of topics, from gathering information about daily life in Japan to addressing concerns related to human rights and labor issues. For matters that cannot be resolved through the consultation service, we provide accompanying support through consultations with specialists such as lawyers, or utilize the Tokyo Bar Association's Alternative Dispute Resolution (ADR) for added assistance. This ensures a fair and transparent approach through third-party involvement. In addition to the consultation service, we offer a portal site that compiles various information for foreign workers, available as a smartphone app, making it accessible to anyone with ease. We promote awareness of the consultation service for workers by distributing flyers with QR codes to business partners and organizing briefings to explain the usage process.
The overall program, including the consultation service, has been developed by taking into account the feedback and input from companies and stakeholders, including suppliers, that participated in the pilot project.- *1
- Easy Japanese, English, Chinese, Korean, Thai, Vietnamese, Indonesian, Malay, Tagalog, Nepali, Myanmar, Khmer, Mongolian, Sinhalese, Hindi, Bengali, Portuguese, Spanish, German, French, Italian, and Russian
JP-MIRAI consultation service
Consultation service for promoting fair trade (Japanese version only)
JP-MIRAI’s “Collaborative Program for Companies Responsibly Hosting Foreign Migrant Workers”