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 approval 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.
If a company commits an act where human rights issues arise, it not only results in loss of trust from customers but also damages brand image, significantly affecting the business foundation. Therefore, SUBARU recognizes respecting human rights as a risk related to its industry and business operations.
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- Renamed in FYE March 2022 from the CSR 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 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
We have appointed the Representative Director, President and CEO as a director who is responsible for leading the process of developing the policy and assigning resources as needed for its implementation and continued improvement. Specifically, we formed the Human Rights Task Team comprised of management personnel including the General Manager from the Human Resources Department, IR Department, Sustainability Promotion Department, Risk Management and Compliance Office, and Global Purchasing Planning Department. The human rights issues and initiatives discussed within the team are 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 |
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.
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 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 FYE March 2023, the seminars were provided to manager-class employees at the Gunma Plant, and almost all participants responded that they either “fully understood” or “understood” the significance of respecting human rights.
| 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 |
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 2023, we engaged in discussions with multiple institutional investors, during which we explained the SUBARU Group’s perspective and initiatives regarding human rights. Additionally, we proactively shared the latest progress with external assessment organizations. Moreover, 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. “Promoting initiatives to respect human rights based on the Human Rights Policy and communicating the policy throughout the entire supply chain” has been set as a key performance indicator (KPI) under Compliance within the SUBARU Group’s Six Priority Areas for CSR. Together with our business partners, we are actively undertaking efforts in this regard.
From FYE March 2021 to FYE March 2022, with cooperation from LRQA Sustainability Co., Ltd. (formerly Lloyd’s Register Japan K.K.), 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.
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 a plan-do-check-act (PDCA) cycle.
- Identifying human rights risks
We held study groups on business and human rights for 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 encompassed 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. - 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, and 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 - Formulating measures to address risks
For each of the human rights risks identified in each domain, we formulated measures to prevent and mitigate potential negative impacts. - 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.
Examples of measures Human resources domain Example measures implemented FYE March 2023 results Issues Human resources domain Harassment of workers - Conducting harassment prevention workshops for management
- Conducted employee surveys and provided managerial training during Harassment Prevention Month
- Preventing harassment and fostering greater awareness among employees
- Issuing the Harassment Explanatory Booklet for foreign workers in four languages
- Distributed the booklet to new employees
Forced labor among foreign workers - 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
- Enhancing collaboration with supervisory bodies and staffing agencies
Procurement domain Human rights violations among business partners - Beginning regular questionnaires about non-Japanese employees
- Carried out written and interview-based investigations
- Improving the accuracy of supply chain due diligence
- Newly adding questionnaire on human rights initiatives
Responsible mineral procurement (e.g., conflict minerals, cobalt) - Formulating the Responsible Mineral Procurement Policy
- Posted and disseminated the policy within the SUBARU Supplier CSR Guidelines.
- Increasing target minerals, regions, and due diligence items in new international regulations and norms
- Expanding the scope of conflict minerals investigations
- Expanded the scope of the investigations to include dedicated repair parts and conducted surveys
Harassment of suppliers - 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
- Initiated discussions with business partners regarding price adjustments in response to rising costs
Preventing 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 Guidelines and the Compliance Manual. We have prepared the Power Harassment Explanatory Booklet, and ensure that all SUBARU employees, including foreign workers, are aware of its contents.
In addition, we distribute the Power Harassment Explanatory Booklet to all managers and supervisors, and in the harassment prevention workshops for management, we engage in discussions and exchanges of opinions, drawing from both internal and external cases, to effectively address prevention.
Additionally, for departments where instances of harassment or similar issues have been identified, we are arranging training sessions 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 through respective channels. We maintain the confidentiality of all submissions. 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.
For instance, we share 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 nine languages* 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.
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- English, Chinese, Spanish, Portuguese, Indonesian, Tagalog, Burmese, Vietnamese, and Nepali (as well as basic Japanese)
