Nippon Paint Holdings has formulated its own policy and Global Code of Conduct, referring to international standards and guidelines regarding sustainability, such as the International Bill of Human Rights, the OECD Guidelines for Multinational Enterprises, and ISO 26000.
Based on the laws and regulations of countries around the world, Group companies in Japan aim to eliminate discrimination based on factors such as race, religion, gender, age, sexual orientation, disabilities, nationality, and to become a company where people can fully demonstrate their individuality and capabilities. In addition to respecting the basic human rights of individuals regarding all of our stakeholders, we do not discriminate or commit acts in violation of human rights, and we abide by the principles of the United Nations Guiding Principles on Business and Human Rights, and the Declaration on Fundamental Principles and Rights at Work issued by the International Labour Organization (ILO) in conducting our actions. Specifically, we guarantee the prohibition of forced labor, prohibition of discrimination, prohibition of inhuman treatment, elimination of child labor and protection of young workers, adequate wages, appropriate management of working hours, and the right of employees to organize (freedom of association and collective bargaining).
In 2020, Nippon Paint Holdings formulated an ESG Statement and designated human rights as a material element of Diversity & Inclusion as an item of materiality. We are promoting initiatives based on international standards with regard to respecting human rights.
In 2022, we instituted our Global Code of Conduct, which is shared throughout the Group and clearly states our respect for the human rights of our employees and stakeholders. Specifically, The Global Team that works directly under the Directors, Representative Executive Officers & Co-Presidents (the Co-Presidents) discusses policies and initiatives concerning human resources policies including human rights and reports their outcomes to the Co-Presidents.
See here for the organizational chart
Human rights education
In order to gain a deeper understanding of international human rights standards and of current trends in human rights issues, Nippon Paint Holdings personnel responsible for sustainability in Japan will attend external seminars on human rights and then develop these into measures for utilization in-house.
We have instituted programs to deepen understanding of ESG during induction training of new hires and training for specific job levels, and in future will strengthen our efforts to promote a basic understanding of human rights.
In addition, Group companies in Japan are conducting surveys and offering workshops as measures against harassment, with the goal of creating healthy working environments for everyone. In fiscal 2020 we strengthened these measures still further, holding "Harassment Workshops for Management" that were prompted by the idea that management should cooperate to create a healthy working environment. Managers began by acquiring a basic legal knowledge of harassment, studying about the settings in which harassment occurs and how to prevent it, by looking at a range of actual cases and precedents. In addition to the harassment workshops that have been held on an ongoing basis for all employees, including executives, from fiscal 2020 we have revised the content of the workshops themselves, taking into account the trends in the Nippon Paint Group based on the results of fact-finding surveys, in order to further improve workshop effectiveness. Moreover, we hold a comprehension test after the workshops to ensure that participants retain the content.
All staff at DuluxGroup receive human rights-related training every two years either in person or through e-learning, focusing on discrimination, harassment, and bullying. DuluxGroup also provides separate management training for managers via e-learning.
Due diligence in human rights
In order to assess the inherent (uncontrolled) risk level for each aspect of our operations and supply chain, DuluxGroup considered the geographical risk of operating in and sourcing goods and services from each of the locations and the sector risk of the activities or supply in those locations.
DuluxGroup categorised the geographies in which each activity occurs or supplier operates against the Global Slavery Index 2018 prepared by the Walk Free Institute. DuluxGroup allocated a risk rating for each location on the basis of estimated prevalence of population in modern slavery (victims per 1,000 population), with low risk less than 3 victims per 1,000 people, moderate risk between 3 and 7 victims per 1,000 people and high risk over 7 victims per 1,000 people.
While management of sourcing is a low risk activity, DuluxGroup is aware that manufacturing - especially raw materials production and manufacturing and manufacturing involving chemical processing and products for the building and construction sector may have a higher risk of modern slavery. Many of our key suppliers are large, multi-national organizations located in Australia and New Zealand who are themselves assessing and addressing modern slavery risks.
As most products are highly refined and have their own complex supply chain, it is difficult to have full visibility of each supply chain tier. While in this reporting period, DuluxGroup has focused on the first tier of suppliers, in subsequent reporting periods we intend to focus on the next tier of suppliers deemed to be “high risk” under the Sustainable Procurement Program.
Furthermore, Group companies in Japan utilize self-diagnosis (the UN Global Compact SAQ Survey) provided by UN Global Compact Network Japan to facilitate awareness of supply chain risks, in an effort to survey and understand the status of various ESG-related supplier activities. This survey assesses the level of an organization's initiatives with regard to corporate governance, human rights, labor, the environment, fair corporate activities, quality/safety, information security, supply chains, and coexistence with local communities.
See here for details.
Initiatives to prevent violations of human rights
In 2017, Group companies in Japan created the Nippon Paint Holdings Compliance Guidebook (digital version) to improve awareness of compliance in both employees and executives. The content of the Guidebook was updated in 2020, and in 2021 it was renamed the Compliance Textbook, and the revised version disseminated. Respect for human rights is placed at the start of this textbook, which introduces the rules and regulations to which employees must pay particular attention, and features explanations of case studies and cases that employees of a paint manufacturer may encounter.
The Group also releases its monthly “Compliance Mail Magazine” for Group employees and discloses legal and compliance-related information on an intranet site, in an ongoing action to improve respect for human rights and awareness of compliance. In addition to these, we hope that continuing initiatives such as the implementation of job-level specific training and harassment workshops will improve not just knowledge but also interest and sensitivity with regard to these issues.
We also hold harassment workshops for all employees in Japan, and are working to make ourselves an organization where every person is aware of the issues concerned and is able to confront harassment.
Establishment of a harassment help desk
In 2020 Group companies in Japan set in place a harassment prevention policy and launched a Harassment Help Desk that people can consult, with the goal of constructing a working environment in which no employee has to deal with harassment themselves. These contact points were established separately to the NPHD Group Hotline—which allows people to report possible compliance violations—in order to offer an in-house consulting contact specifically to deal with harassment, thereby enlarging comfortable working environments and allowing employees to continue to work with peace of mind. A system to receive such reports has been established within the Human Resources Department , which takes appropriate measures to prevent recurrence of harassment while giving due attention to preserving the privacy of employees who make reports and that of the people involved. Even in cases when harassment cannot be clearly identified, we have successfully prevented it by consulting with the people who made the reports.
In fiscal 2020 there were ten incidents of people consulting the harassment desk, with each incident dealt with in a prompt, appropriate manner.
Nippon Paint Holdings Harassment Prevention Policy
- Harassment is a human rights issue, and is an act that harms the dignity and personality of the other party. We will not permit or overlook harassment.
- We will seek to resolve any incidences of harassment promptly and appropriately. We will preserve the privacy of those who consult us and those who cooperate with us in checking facts, and will never place them at a disadvantage.
- We will respect the individuality and diversity of others, and will continue to pursue healthy working environments that allow everyone to work as a team with peace of mind.
Compliance with the Modern Slavery Act
DuluxGroup has set in place a policy to ensure that slavery and human trafficking in its businesses and supply chain in relevant regions, and is working to manage risk. In response to the Modern Slavery Act, DuluxGroup publishes its Modern Slavery Statement annually.