Basic approach

Nippon Paint Group 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, the Japan Group aims 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, discrimination, and inhumane treatment; elimination of child labor; protection of young workers, adequate wages; appropriate management of working hours; and the right of employees to organize (freedom of association and collective bargaining).

Policy Implementation Structure

The Nippon Paint Group has clearly stated in the Nippon Paint Group Global Code of Conduct that we respect the human rights of employees and stakeholders.

Global Code of Conduct

Due diligence in human rights

Actions of the Japan Group

The 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.

Actions of DuluxGroup (responses to the Modern Slavery Statement)

For the past two years, DuluxGroup has published its Modern Slavery Statement in compliance with Australian legislation. DuluxGroup is committed to identifying, assessing and addressing modern slavery risks within its operations and throughout its supply chain. Modern slavery is a serious violation of a person’s basic human rights. DuluxGroup opposes modern slavery in all its forms, and respects and supports the human rights and freedoms of workers within our operations and throughout our supply chain.
Modern Slavery Statement

Work environment

Opening of a harassment help desk

In 2020 Japan Group set in place a harassment prevention policy and launched the "Harassment Help Desk," an in-house advice service specializing in harassment. 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 to allow employees to seek advice easily, even if they are unsure that certain behaviors constitute harassment. To prevent harassment and foster harassment-free working environments, we provide appropriate feedback while giving due attention to preserving the privacy of employees who make reports and that of the people involved.
In fiscal 2021 there were nine incidents of people consulting the harassment help desk, with each incident dealt in a prompt, appropriate manner. We also utilize a range of tools such as employee training, surveys of all staff, and analysis of stress check results, and work to assess risks and prevent problems related to labor issues.

Nippon Paint Holdings Harassment Prevention Policy

1. 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.
2. 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.
3. We will respect the individuality and diversity of others, and will continue to pursue create healthy working environments that allow everyone to work as a team with peace of mind.

Nippon Paint Group’s Policy on Addressing Customer Harassment

Nippon Paint Holdings Co., Ltd. and its group companies in Japan (collectively, “the Group”) regard customer harassment as a serious concern and have adopted the following policy to address it. The Group welcomes constructive feedback and requests from customers and uses them to continually improve its products, services, and operations. At the same time, it will not tolerate conduct or language that compromises employees’ dignity or negatively affects their working environment. When such behavior occurs, the Group will take a firm, unified stance.

1. Definition of Customer Harassment

Customer harassment refers to remarks, conduct, or actions by customers or other individuals that exceed socially acceptable bounds in their content, method, or manner and adversely affect employees’ working environment. (This definition is based on the Act on Comprehensively Advancing Labor Measures, and Stabilizing the Employment of Workers, and Enriching Workers' Vocational Lives and guidelines issued by the Ministry of Health, Labour, and Welfare.)

Examples of Customer Harassment

• Unreasonable demand: Demands that substantially exceed the quality or scope of products or services specified in the contract, or requests for compensation unrelated to those products or services, that go beyond socially acceptable bounds.
• Physical aggression: Hitting, kicking, throwing objects at employees, or spitting.
• Psychological intimidation: Threatening to post negative reviews on social media, disclosing officers’ or employees’ personal information online, taking photographs or making recordings without authorization, demanding that employees kneel, or using loud or intimidating language.
• Persistent or restrictive conduct: Repeatedly asking the same or similar questions, excessively challenging employees’ responses, or prolonging telephone calls in ways that interfere with employees’ ability to perform their duties.

2. Response to Customer Harassment

When an Incident Occurs

• Employees will ask the customer to stop the behavior and seek a resolution through calm, constructive dialogue.
• Employees must report the incident to, and consult with, their supervisors or other relevant personnel. The Group will respond in a coordinated manner.
• The Group will prioritize the safety and well-being of affected employees and provide support as needed, including assigning another employee to handle the customer or taking other appropriate measures.
• If the Group determines that a customer’s remarks, conduct, or actions constitute customer harassment, it may decline to provide further service or support to that customer.
• In particularly malicious cases, the Group may work with the policy, legal counsel, or other external specialists to take appropriate action.

Preventive Measures

• The Group will provide internal training to equip employees to respond appropriately to customer harassment.
• The Group will conduct internal education programs to prevent employees from engaging in customer harassment, including in dealings with business partners and related companies.
• The Group will establish arrangements for cooperation with the policy, legal counsel, and other external specialists.

Policy Established: October 1, 2026

Japan Region Code of Conduct

In 2022, the Japan Group established the "Japan Region Code of Conduct,", based on the Global Code of Conduct and various internal regulations. This Code of Conduct clearly outlines the actions that employees should take and those that they should avoid in order to fulfill their responsibilities to customers, business partners, employees, and society. Regarding respect for human rights, the Code promotes actions such as respecting diversity and supporting flexible working arrangements for childcare and caregiving, while identifying actions to avoid, including discrimination, harassment, and imposing personal values on others. To ensure that the "Japan Region Code of Conduct" is deeply ingrained in each employee, the Japan Group companies are engaged in awareness initiatives, such as conducting departmental discussions titled "Code of Conduct Study Sessions."

Thorough implementation of labor standards

Japan Group have put a range of systems in place in order to promote appropriate work environment. Our thinking and initiatives regarding labor standards such as wages and working hours are made public at each Group company so that all employees working for us in Japan and internationally can understand them, and we have also concluded a collective agreement with the labor union. In order to engage in constructive dialog between management and labor, we hold labor-management dialogs and committee meetings between company management and representatives of the labor union, facilitating regular exchanges of opinions on the business environment and improvement to various systems, as well as discussions on wages, lump-sum payments, and occupational health and safety.
Additionally, we endeavor to ensure that labor standards are well understood, and working conditions such as remuneration, work hours and holidays, occupational safety and health, benefits, and service rules are always explained at orientations for employees when they join the company, and are now always available for reference on the company intranet. Labor standards for Japan are published on the intranet in both Japanese and English to ensure that they are understood. We have created an environment that allows employees to use internal reporting systems to report any violations that may occur, and we disclose the number of reports made annually.
See here for details of the internal reporting system.

Management of working hours

In addition to complying with Agreement 36 (Labor-Management Agreement relating to Overtime Work and Work on Days Off) and other rules and regulations, Japan Group monitor employee working conditions and hours at the management, human resources, and workplace level to promote appropriate management of working hours. Work management e-learning and seminars are held for all employees at least once annually to alleviate and prevent overwork, protect their mental and physical health, and ensure that they are able to utilize their abilities to the full.

Fair wages

We comply with labor laws and regulations in all countries where we operate and uphold a fundamental policy of paying wages that exceed the minimum wage to support stable living. In fiscal 2023, the average annual salary at Nippon Paint Holdings was JPY 9.774 million. Guided by the principle of "equal pay for equal work," we are committed to eliminating unjustifiable disparities in treatment that arise from differences in employment types, such as between regular employees and non-regular employees, thereby ensuring fair and equitable treatment for all.

Society initiatives

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