Human rights due diligence
Human rights due diligence is an ongoing process of investigating and identifying potential human rights risks, formulating and implementing appropriate measures to address such risks, and disclosing the progress and results of those measures. The aim of this due diligence is to prevent and mitigate the negative human rights impacts of the Group’s business on its stakeholders. To seriously address human rights issues faced by stakeholders throughout the value chain, the Group has established a human rights due diligence system in accordance with TIS INTEC Group Human Rights Policy based on the United Nations Guiding Principles on Business and Human Rights.
Human rights due diligence implementation process
In accordance with the United Nations Guiding Principles on Business and Human Rights, we will: 1. Identify and assess negative human rights impacts; 2. Prevent and mitigate negative human rights impacts; 3. Track the effectiveness of our responses; and 4. Communicate to external parties. Through these processes, we will emphasize stakeholder engagement and promote remediation.
The Group intends to carry out the above four processes on a regular basis.
Identify and assess negative human rights impacts
In fiscal 2021, with the cooperation of NPO Caux Round Table Japan , we conducted a human rights risk assessment for the first process, “1. Identify and assess negative human rights impacts” Specifically, we evaluated the potential for negative human rights impacts at each stage of the value chain (procurement, development, manufacturing, sales, use, and disposal) of the Group’s operations. Through this process, we identified potential human rights risks and clarified the countries, operations, and rights holders (subjects who may be negatively affected by human rights issues) that should be prioritized for future action.
Human rights risk assessment conducted
We conducted an assessment of potential human rights risks based on the risks in countries where we have business operations and the risks associated with our business.
1. Country risk assessment
Using a database of international organizations specializing in risk analysis, research, and strategic forecasting, we conducted a four-stage assessment of human rights risk by country and human rights indicator.
2. Business risk assessment
- We evaluated the degree of impact on human rights risks based on the scale of the business (sales, procurement/outsourcing, number of employees, and presence of large-scale facilities, etc.).
- We evaluated inherent human rights risks associated with products/services, procured goods, business operations, etc.
3. Potential human rights risk assessment
Based on the results of the country risk and business risk assessments, we conducted desktop surveys and workshops to evaluate the potential for our business to have negative human rights impacts, focusing on rights holders, human rights issues, and our value chain.
Scope of human rights risk assessment
Countries: The following 11 countries where the Group’s business sites and major offshore development sites are located
Japan, India, Indonesia, Singapore, Thailand, China, USA, Vietnam, Philippines, Malaysia, Myanmar
Business: All businesses of our group (all 61 Group companies)
- System software development
- Hardware sales
- BPO services
- Other operations incidental to our businesses (investment and financing, construction and maintenance of business facilities, M&As, new business planning, etc.)
Human rights issues: Of the human rights listed in international norms, the following 19 human rights issues are closely related to our business
Decent wages (Living wages, Equal remuneration), Decent working time, Discrimination, Occupational health and safety, Freedom of association and collective bargaining, Forced labour, Child labour, Young workers, Migrant workers, Human trafficking, Right to privacy, Freedom of expression, Housing, land and property rights, Rights of indigenous peoples, Security forces and human rights, Rights of women and girls, Rights of sexual minorities, Access to remedy, Complicity in human rights abuse
Rights holders:
- Workers and employees (the Group and its suppliers/business partners)
- Consumers and users of our products and services
- Local community residents, the general public
Value chain:Assessment of impacts at each stage of the business process and the scope of potential impact
- Business processes: Procurement, development, manufacturing, sales, use, disposal
- Scope of impact: Suppliers, business partners, the Group, customers/users of our products and services
Potential human rights risks identified
Through the human rights risk assessment, we identified the following five items with potentially high human rights risks and clarified the countries, operations, and rights holders that should be prioritized for future action. Below is a list of human rights issues related to each item, their relevance to rights holders and the Group, and our approach to preventing and mitigating them.
Potential human rights risk 1: Labor issues related to TIS Group employees
[Relevant human rights issues]
Decent working time, Occupational health and safety, Decent wages, Discrimination
[Rights holders]
TIS Group employees
[Relevance to the Group’s business]
We estimate that long working hours have been partially problematic for some time. Regarding discriminatory practices, it we concluded that, in reality, there could be disparities in promotion and compensation even if there was no intentional discriminatory treatment and the system was applied uniformly.
[Approach to prevention/mitigation]
- Build a more explicit mechanism for engagement with employees
- To address any consequent disparity in promotion and compensation, improve working environments and systems with the purpose of embracing international diversity
[Prevention and mitigation initiatives]
We conduct awareness surveys of approximately 91% of our employees to ascertain employee engagement and understand the actual status of long working hours. We also monitor harassment through our helpline and take corrective actions to address any incidents that are reported. The results of these activities are disclosed as non-financial information.
Potential human rights risk 2: Labor issues related to outsourced employees
[Relevant human rights issues]
Decent working time, Occupational health and safety, Decent wages, Discrimination, Freedom of association and collective bargaining
[Rights holders]
Employees of contracted companies
[Relevance to the Group’s business]
We estimate that long working hours at contracted companies have been partially problematic in light of their close relationships the Group’s business structure. We also found issues with the effectiveness of labor management among contractors.
[Approach to prevention/mitigation]
- Establish a grievance mechanism directly targeting workers in the supply chain and proceed with an exhaustive bottom-up approach
- Spread awareness of the Group’s human rights policies, provide education and training, and share of the Group’s Code of Conduct
[Prevention and mitigation initiatives]
We conduct surveys of our business partners to identify any labor issues. Based on the survey results, we plan to engage in further dialogue with them. Additionally, we provide training to enhance our business partners’ knowledge of occupational health and safety. Group companies subject to these surveys account for around 88% of consolidated net sales.
Potential human rights risk 3: Labor exploitation in equipment supplier supply chain
[Relevant human rights issues]
Forced labour, Child labour, Occupational health and safety, Discrimination, Freedom of association and collective bargaining, Young workers, Migrant workers, Rights of women and girls
[Rights holders]
Workers of equipment suppliers
[Relevance to the Group’s business]
The Group procures equipment in the form of purchasing finished products from major manufacturers, so any direct risk of labor exploitation in the electronics manufacturing process was assessed as low. However, PCs, servers, and the like are closely linked to labor exploitation and conflict minerals in the supply chain, and because we procure such items, we estimate that there is a potential risk of human rights violations.
[Approach to prevention/mitigation]
For items procured from countries with high human rights risks, we incorporate protocols (e.g., supplier procurement standards) for checking and managing human rights into the procurement process. In this way, we will establish a Groupwide system to ensure prompt and appropriate responses when human rights violations materialize.
[Prevention and mitigation initiatives]
We actively reuse and recycle IT devices to promote the circulation of rare metals used in them. By reducing demand for newly mined rare metals, we are contributing to the resolution of conflict minerals issues.
Thanks to these initiative, we reduced consumption of approximately 22.6 grams of gold, 68.1 grams of silver, 24,369 grams of copper, and 0.8 grams of palladium through the reuse of 149 servers, network devices, and PCs.
(Calculation by Get-It Co., Ltd.)
We are committed to addressing the conflict minerals issue by not only implementing this initiative within our own Group but also extending it to our customers and business partners.
Potential human rights risk 4: Right to privacy in the handling of personal information
[Relevant human rights issues]
Right to privacy, Complicity in human rights abuse
[Rights holders]
Individuals whose personal information is managed by a Group customer
[Relevance to the Group’s business]
Since many of our customers handle important personal information, we estimated that there is a risk that privacy rights associated with handling such information may be violated. We also estimated that there are risks associated with doing business with government agencies and that services provided may be used to violate privacy rights.
[Approach to prevention/mitigation]
- Share assumptions and awareness of potential human rights risks across the Group based on a broad understanding of global trends related to privacy rights
- Examine uncertain potential risk assumptions and response policies, including policies related to AI and policies for handling government requests, across the Group
[Prevention and mitigation initiatives]
In the fiscal year ending March 2024, we revised our Personal Information Protection Policy and strengthened the handling of personal information across the entire Group. Moving forward, we will focus on enhancing the effectiveness of this policy.
Potential human rights risk 5: Unintended use of our products/services
[Relevant human rights issues]
Right to privacy, Complicity in human rights abuse
[Rights holders]
End-users/individuals in society in general
[Relevance to the Group’s business]
We estimated that there is a risk of unintended use of our products/services during the process of providing such products/services to client companies and regular individuals, and there is also a risk of client companies being involved in omission.
[Approach to prevention/mitigation]
- Share assumptions and perceptions of potential human rights risks across the Group
- Consider Groupwide discussions on uncertain potential risk assumptions and response policies
[Prevention and mitigation initiatives]
To enhance the detection of human rights impacts from the misuse of our products and services, we conducted a seminar to share awareness and understanding of potential human rights risks across the Group. The Group companies that participated in this seminar account for around 91% of consolidated net sales.