Social
Human Rights
Policies and Basic Approach
As Mitsui & Co. conducts business globally in many countries and regions around the world, we recognize that we must make efforts to respect human rights not only within our own company but also across our supply chain. Therefore, we regard respect for human rights that follows international standards as the foundation of our sustainability management. We position respect for human rights as one of the most important issues in our corporate activities, and have continued to incorporate respect for human rights into both the Mitsui & Co. Group Conduct Guidelines and our Business Conduct Guidelines for Employees and Officers of Mitsui & Co., Ltd., and we have implemented various initiatives.
In August 2020, we formulated a Human Rights Policy setting out that Mitsui & Co. and its officers and employees will work together with a wide range of stakeholders, including business partners, to address respect for human rights through our business activities. In 2025, we conducted a review of our Materiality in pursuit of our Mission, "Build brighter futures, everywhere." We newly added "Cultivate societies that respect human rights" as one of our material issues.
The Mitsui & Co. will continue efforts to promote business activities that respect human rights across the entire group in accordance with our Human Rights Policy, international standards, and newly revised Materiality. We will do so by ensuring that the Human Rights Policy is fully communicated to all group officers and employees, advancing initiatives in collaboration with group companies, while engaging in ongoing dialogue and collaboration with stakeholders.
Human Rights Policy
We will strive to respect human rights through our group business activities in countries and regions around the world, in accordance with our Sustainability Policy and this Policy.
In addition, we expect various stakeholders including our business partners, to understand and respect human rights in line with this Policy, and aim to collaboratively promote respect for human rights.
- Respecting Human Rights in our Business Activities
- We strive not to infringe on human rights in our business activities, nor to contribute to human rights infringements by others through our business relationships, including supply chains.
- Respecting Internationally Recognized Human Rights Standards
- We are committed to respecting human rights, which we understand as, at minimum, those set out in the International Bill of Human Rights, including the UN Declaration of Human Rights, and the ILO (International Labour Organization) Declaration on Fundamental Principles and Rights at Work. We also support the United Nations Guiding Principles on Business and Human Rights and the Ten Principles of the United Nations Global Compact and conduct our business activities in line with these Principles. We comply with laws and regulations of the countries and regions in which we conduct our business activities. Where internationally recognized human rights standards and national/regional laws and regulations are in conflict, we seek ways to honor the principles of internationally recognized human rights while complying with the laws and regulations.
- Governance/Management Structure
- Our Board of Directors is responsible for overseeing the adherence to this Policy and the Policy implementation.
- Human Rights Due Diligence
- We will implement human rights due diligence to identify, assess, prevent and mitigate adverse human rights impacts associated with our business activities.
- Human Rights Issues related to Business Activities
- Forced Labor
We do not tolerate forced labor. In addition, we do not tolerate any forms of modern slavery, including bonded labor or human trafficking. - Child Labor
We do not tolerate child labor, and we comply with the minimum working age stipulated by the law. We do not hire individuals that are under the age of 18 for roles requiring hazardous work. - Discrimination
We prohibit any form of discrimination based on race, creed, sex, social status, religion, nationality, age, sexual orientation, gender identity, physical and mental disability or any other grounds. We respect the individuality and diversity of each individual employee and officer of the Mitsui & Co. group, and seek to cultivate an environment in which they can perform to the best of their abilities. - Harassment and Inhumane Treatment
We do not tolerate any form of harassment, whether physical or mental, including sexual harassment or power harassment. Furthermore, we prohibit any language or behavior that could be harmful to the working environment of others including discriminatory language or behavior as well as harassment. - Freedom of Association and Right to Collective Bargaining
We respect the rights of employees to associate freely and bargain collectively in our labor-management relations. - Working Hours and Wages
We monitor employees' working hours, holidays, leaves of absence and wages to ensure we are operating in accordance with applicable laws and regulations. - Occupational Health and Safety
In line with applicable laws and regulations, we aim to develop safe, healthy working environments in which every individual employee can work with peace of mind. - Community Impact
To prevent adverse impacts on the safety and health of local communities, we conduct human rights impact assessments, covering issues such as prevention of pollution and water stress, and implement necessary measures in line with international standards to avoid risks and mitigate negative impacts.
- Stakeholder Engagement
- We believe it is critical to understand human rights issues from the perspectives of affected stakeholders. We further recognize that certain groups of stakeholders are more vulnerable to adverse human rights impacts and thus require special attention. We therefore value the importance of dialogues with relevant parties and strive to properly respond to human rights issues associated with our business activities.
- Remedy
- Where we identify that our business activities have caused adverse human rights impact or contributed to it through our business transactions including our supply chains, we will work to remediate such impacts through appropriate processes.
- Grievance Mechanisms
- We continue to build upon our whistleblowing procedures and grievance mechanisms to promptly identify and respond to human rights issues related to our employees and officers or wider business activities.
- Education and Training
- We will provide necessary training and capacity building to our employees and officers to ensure that they understand this Policy and act in line with the commitments in this Policy.
- Reporting
- We will continuously report our efforts and progress on respecting human rights through our reports, websites, and other communication channels.
Formulated in August 2020
Revised in February 2022
Makoto Sato
Representative Director, Senior Executive Managing Officer,
Chief Strategy Officer (CSO),
Chairperson of the Sustainability Committee
Policies for Responding to Specific Issues
- Policy on Response to the Modern Slavery Act
- We strive to eradicate modern slavery, such as forced labor or human trafficking in our business and supply to.
- Policy on Rights of the Child
- We support Rights of the Child and Business Principles and strive to conduct business activities with respect to rights of the child.
- Policy on Rights of Indigenous Peoples
- We strive to respect the human rights and cultures of indigenous peoples by complying with all applicable laws and regulations of the countries and regions in which we conduct our business activities as well as by respecting relevant international standards such as the United Nations Declaration on the Rights of Indigenous Peoples, the Convention concerning Indigenous and Tribal Peoples in Independent Countries (ILO Convention: C169), and the principle of "free, prior and informed consent (FPIC).
- Policy on Activities of Security Personnel
- When advancing business activities around the world, we hire security companies to ensure the safety of these business activities. We recognize that security operations pose a risk of potential human rights violations through the use of force, so when appointing a security company, we comply with relevant local laws and regulations in the countries and regions in which we conduct our business activities, and select security companies based on relevant international standards such as the Voluntary Principles on Security and Human Rights, UN Code of Conduct for Law Enforcement Officials, and the Principles on the Use of Force and Firearms by Law Enforcement Officials.
Goals and Targets
- Continue and strengthen the implementation of human rights due diligence, including the identification, assessment, and remediation of adverse human rights impacts in our business activities and supply chains.
- Promote efforts to respect human rights in our business activities and supply chains by raising awareness of our Human Rights Policy and Business and Human Rights initiatives among Mitsui & Co. Group officers and employees, sharing our Sustainable Supply Chain Policy with business partners, and conducting human rights training sessions.
- Improve the effectiveness of human rights risk management systems by optimizing and strengthening internal management systems.
Sustainability Governance and Oversight
Compliance Framework
The Compliance & Integrity Department of the Strategic & Administrative Legal Division leads compliance-related initiatives under the direction and supervision of the Chief Compliance Officer (CCO) and in collaboration with the Compliance Supervising Officers (including corporate and regional Business Unit COOs, general managers of branch offices, and chief representatives of blocs) appointed in each of Mitsui's units and offices in Japan and overseas. The objectives of these efforts implemented on a Mitsui & Co. global group basis are to prevent human rights problems by thoroughly raising compliance awareness, including awareness of issues such as harassment and discrimination, improving and strengthening compliance programs, and responding to specific compliance-related matters as they arise.
Sustainability Committee
Please refer to the links below for more information on Mitsui's Sustainability Management Framework and the activities of the Sustainability Committee.
Human Rights Management
The Board of Directors of Mitsui & Co., Ltd. is responsible for overseeing the adherence to this Policy, and the Executive Committee makes material decisions regarding the Policy execution. The Sustainability Committee, a subordinate body of the Executive Committee, is in charge of deciding detailed plans based on this Policy, as well as planning and developing measures, and building and maintaining a framework for Policy implementation.
Business Risk Management
When participating in a new business, expanding a business, or withdrawing from a business, we use sustainability due diligence checklists to assess the sustainability-related impact of each business division. These checklists, developed with the support of external experts, comprehensively cover environmental and social factors including human rights and environmental impact such as climate change, pollution prevention, ecosystems, water stress, human rights, labor conditions, and occupational health and safety. For human rights, internal screening is carried out by the relevant corporate staff divisions based on these checklists, covering aspects such as occupational health and safety, and the impact of business development on the human rights of local residents and other stakeholders. We have also created business-specific environmental and social risk heat maps that summarize key environmental and social risks for each representative business field based on past examples, etc., for use when considering investment and participation in new business. For projects that pose significant risks related to the environment or society, we assess not only at the launch of the project, but also during operations, and when withdrawing from the project,whether there have been any changes to the sustainability impact assessment conducted at the time of entry. We consult with the experts of the Sustainability Advisory Board and external experts in matters such as human rights and the environment, as necessary, and incorporate their advice on risk mitigation. Ultimately, the final decision on whether to continue with any given project and how matters should be handled is made through deliberation and approval by the Executive Committee, and the Board of Directors, which supervise sustainability risks, in accordance with qualitative and quantitative standards.
In addition to self-assessments of affiliated companies conducted by the Business Units, we implement measures that contribute to mitigating human rights risks across our supply chains. These include introducing sustainability-related risk management initiatives and, adding a human rights clause to the standard general terms and conditions of purchase contracts.
In the unlikely event that a serious human rights violation is suspected in our business activities, we will first verify the facts through interviews with the relevant parties and carefully assess the relationship between our Group and the parties concerned, as well as the extent of our influence over them. Based on this assessment, we will consider and implement appropriate measures and monitoring actions to address the human rights issue and prevent the spread of harm and recurrence. Where it is deemed necessary to accelerate and advance the resolution of an issue, we will call on the relevant parties responsible for addressing it to implement corrective measures, and we will also work to provide remedy to affected victims. If, despite repeated engagement and corrective actions by Mitsui & Co., there is no clear willingness on the part of those parties to undertake appropriate remediation, if resolution or improvement is not confirmed within a certain period, or if there is serious falsification or concealment in the information or reports they provide, we will consider reviewing our approach to the relevant business, including the possibility of withdrawal.
For further details on the Sustainability Due Diligence Checklist, please refer to the link below.
Consultation Channels
- In-house consultation channels
- In addition to personnel and workplace-related consultation services, we have established various consultation services addressing employees' physical and mental health.
- Grievance Mechanism for the General Public and Other Stakeholders
- Mitsui & Co. is a member of the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER), a general incorporated association that provides a dialogue and remedy platform aligned with the UN Guiding Principles on Business and Human Rights. Through this framework, we accept complaints and reports related to business and human rights issues, including cases involving actual or suspected violations of international standards such as the International Bill of Human Rights, as well as applicable domestic laws and regulations in each country.
We accept complaints through JaCER, an independent third party, to ensure greater fairness and transparency. Where issues arise, we are committed to engaging in sincere and good-faith dialogue and providing appropriate remedy. In receiving reports, we ensure the anonymity of the reporting party and the confidentiality of the information provided. Also, we will not engage in any form of retaliation against or other disadvantageous treatment of whistleblowers, and we will endeavor to prevent such conduct. For reports submitted through JaCER, information on the content of the complaint and the status of responses is periodically disclosed on JaCER's website in a manner that protects anonymity, following consultation with JaCER.
Furthermore, our website provides a framework for receiving and responding to sustainability-related complaints and inquiries from all stakeholders, including those across our supply chains. In handling such matters, we protect the privacy of the individuals involved and ensure appropriate confidentiality.
Complaints received through JaCER and via our website are handled by the Corporate Sustainability Division, which serves as the central contact point, and takes responsibility for the response in cooperation with the appropriate Business Units, Corporate Staff Divisions or other related divisions. We also regularly review the effectiveness of our grievance mechanisms based on feedback and input from both internal and external stakeholders and make improvements to their operation as necessary.
Collaborating with Stakeholders
We are promoting and expanding our efforts to address human rights through participation in initiatives. Participation in each initiative is decided after confirming that it is consistent with our basic policy and initiatives for human rights.
PEFC/SGEC
Initiatives
Targets and Progress
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Human Rights Due Diligence Initiatives
We strive to respect human rights through Mitsui & Co. Group's business activities in countries and regions around the world, in accordance with our Sustainability Policy and Human Rights Policy. In addition, we expect various stakeholders including our business partners, to understand and respect human rights in line with these Policies, and aim to collaboratively promote respect for human rights. We assure not to infringe on human rights in our business activities, nor to contribute to human rights infringements by others through our business relationships, including supply chains. We are committed to respecting human rights, which we understand as, at minimum, those set out in the International Bill of Human Rights including the Universal Declaration of Human Rights, and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. We also support the United Nations Guiding Principles on Business and Human Rights and the Ten Principles of the United Nations Global Compact.
Based on these international standards, we have formulated a Human Rights Policy, an Environmental Policy, and a Sustainable Supply Chain Policy. With these efforts to respect human rights, we aim at reducing business risks and sustainable enhancement of corporate value.
Based on the various international standards listed above, since the fiscal year ended March 2020, we have identified areas within our supply chain where human rights issues, such as forced labor and child labor, are more likely to occur as "high-risk areas," and have conducted human rights due diligence.
In the fiscal year ended March 2020, we appointed external experts to conduct an assessment of human rights risks across the supply chains of products handled by Mitsui and overseas trading affiliates, as well as the main business operations of consolidated subsidiaries. As a result, we concluded that products mainly related to food, textiles, and building materials, primarily in emerging countries in production regions including Southeast Asia, Africa, and South America, are generally high-risk areas.
High-risk areas are reviewed in response to changes in society and the business environment, and are currently identified in principle for each medium-term management plan period.
Identification of high-risk areas and status of due diligence under Medium-term Management Plan 2026
Under the Medium-term Management Plan 2026, high-risk areas for human rights due diligence were identified based on three perspectives: industry risk, country-of-origin risk, and significance to Mitsui & Co.
Specifically, with input from external experts and by utilizing external databases provided by ESG rating agencies, we conducted analyses of industries and countries with elevated human rights risks. For industry risk, we analyzed the occurrence of human rights-related incidents over the past 20 years across the industries in which we operate. For country-of-origin risk, we assessed human rights risks in countries from which we procure or conduct transactions. Both were classified into four levels (Low, Medium, High, Severe). In addition, significance to Mitsui & Co. (based on transaction volume) was categorized into three levels (Low, Medium, High).
Through this three-axis analysis—industry risk × country-of-origin risk × significance to Mitsui & Co.—we identify high-risk areas and enhance the effectiveness of our human rights due diligence.
In the fiscal year ended March 2024, using the above methodology, we newly designated mining, oil and gas, chemicals, and industrial materials as high-risk areas, and conducted human rights due diligence from the fiscal year ended March 2025. Based on analysis of survey responses and additional targeted interviews, no severe human rights issues were identified.
Initiatives at affiliated companies
We manage sustainability-related risk across our supply chain and affiliated companies.
For affiliated companies, we assess the risk management status based on the common check items across all businesses, such as initiatives to respect human rights and responses to environmental risks, as well as additional items tailored to specific business characteristics, ensuring both comprehensive coverage and depth in risk management.
For example, in the fisheries business, based on our environmental and social risk heat maps and Sustainability Due Diligence Checklist, we assessed environmental and social risk status including biodiversity, water resources and human rights at affiliated companies. As a result, we confirmed that certifications such as ASC (Aquaculture Stewardship Council) and BAP (Best Aquaculture Practices), which are internationally recognized aquaculture sustainability certification programs that comprehensively address environmental and social impact, had been obtained and maintained at main facility and their supply. In addition, given the high dependence on natural capital, we identified land use change, water stress, and pollution/waste as key risk factors.
We will continue to enhance the visualization and management of sustainability-related risks across our affiliated companies and supply chains.
Strengthening governance and monitoring systems
Additionally, to enhance the effectiveness of human rights due diligence, we are also strengthening our internal governance framework. In the fiscal year ended March 2025, we established "Rules on Human Rights Management Framework," and guidelines for each process, including awareness, identification, investigation, disclosure, and improvement. Through this framework, business divisions take the lead in managing human rights-related risks in each business activity while Corporate Staff Divisions provide monitoring and support.
Our human rights-related initiatives and policies, including the implementation status of human rights due diligence, are reported annually to the Sustainability Committee, as well as regularly to the Executive Committee and the Board of Directors, and are revised as necessary.
We also place importance on dialogue with stakeholders such as shareholders, suppliers, and local communities, and review and revise our policies as necessary in response to identified issues.
Please refer to the link below for details of our initiatives and achievements.
Respecting Indigenous Peoples
When conducting operations, we comply with all laws of the applicable country or region, and strive to respect the human rights and cultures of indigenous people in each country and region in accordance with international standards, such as the United Nations Declaration on the Rights of Indigenous Peoples and the Convention Concerning Indigenous and Tribal Peoples in Independent Countries (ILO Convention: C169).
For example, the operations of our forest resource business in Australia are guided by respect for the traditional rights of the indigenous peoples. We have and we ensured accountability by obtaining through certification which requires regular audits by third-party certification bodies.
Mitsui & Co. (Australia) Ltd. : Group Companies (Mitsui & Co. Wood Resources Oceania)
In Japan, we conduct forest management respecting the traditions and culture of indigenous people. In Hokkaido, where a part of Mitsui's Forests is located, Mitsui has entered into agreements with the Biratori Ainu Association and with the town of Biratori to cooperate in activities to protect, and pass on, traditional indigenous culture through the conservation of forests.
Mitsui Australia, in cooperation with its consolidated subsidiaries in Australia, is engaged in a range of initiatives to ensure respect for the rights of the indigenous people in Australia. These include training for employees, Acknowledgement of Country (a statement of respect for indigenous peoples) at major events and meetings, and the planning of new initiatives through regular information exchanges among staff from each branch and subsidiary in Australia.
Employees' Human Rights
As a company engaged in business on a global scale, we not only work to promote diversity and inclusion, but also take various steps to prevent harassment and discrimination. These measures include establishing whistleblowing systems that allow an employee to report compliance issues, including cases relating to human rights and discrimination, and obtain advice through channels within or outside the employee's direct reporting line. Another example of our efforts in this area is our fostering of a "speak up" culture in which employees are encouraged to report situations that concern them. We have also established the Integrity Committee as a forum for discussing all matters relating to compliance. With an Audit & Supervisory Board Member and an external attorney as an observer, the Integrity Committee discusses action plans for improving our compliance framework based on various compliance-related matters that have been reported. Minutes of committee meetings are released on the company intranet. We will continue to implement initiatives to ensure respect for the human rights of our employees, including implementing training programs and raising awareness of relevant policies.
Human Rights Training
We carry out various training programs to ensure thorough awareness of our Human Rights Policy at workplaces and that respect for human rights is incorporated into operations. In addition to compliance training, which includes prevention of harassment and other human rights and character violations, we also carry out online training for domestic and overseas employees of Mitsui and consolidated subsidiaries on human rights initiatives in the supply chain.
| Training program details | Participants/Number of Times | |
|---|---|---|
| FY March 2026 | We invited Mr. Kazuo Tase of SDG Partners as a lecturer to conduct a human rights training session for our business partners, our employees and officers in Japan and overseas. | Approx. 160 persons |
| We conducted training sessions for employees and officers in Japan and overseas on human rights management regulations. | Approx. 90 persons | |
| We conducted role-play training simulating an on-site visit as part of human rights due diligence for employees in Japan. | Approx. 20 persons | |
| FY March 2025 | We invited Mr. Kazuo Tase of SDG Partners as a lecturer to conduct a human rights training session for our business partners, our employees and officers in Japan and overseas. | Approx. 280 persons |
| We expanded our e-learning content (in Japanese and English) for employees and officers to include topics related to "Business and Human Rights," and made parts of the program mandatory. The content was also added to the onboarding training for mid-career hires. | – | |
| We internally distributed a video to raise awareness of human rights among our employees and officers. | – | |
| FY March 2024 | We invited Ms. Akiko Sato, Attorney at Law at KOTONOHA Law Office, to conduct online training for employees of Mitsui & Co. and consolidated subsidiaries, along with their suppliers in Japan and overseas. The training focused on our policy on respect of human rights and human rights due diligence. | Approx. 400 persons |
| We introduced e-learning about our Sustainability initiatives for Mitsui & Co. Group employees in Japan and overseas. | Approx. 500 persons | |
| We had various lecture sessions for Business Units and affiliates as needed and also added content on "Business and Human Rights" to career stage-aligned training programs (for new recruits/line managers). | As needed | |
| Mitsui & Co. Australia invited an external lecturer to conduct a training session on aboriginal heritage management for employees of Mitsui & Co. Australia and Mitsui & Co NZ, as well as employees of consolidated subsidiaries in Australia. | Approx. 60 persons | |
| FY March 2023 | We invited Daisuke Takahashi, an attorney at Shinwa Sogo Law Office, who supervised the development of the "Sustainable Supply Chain Management Handbook," to conduct online training for suppliers of Mitsui and consolidated subsidiaries, along with employees of Mitsui and consolidated subsidiaries in Japan and overseas. The training focused on our human rights policy and initiatives, and on how to conduct human rights due diligence in supply chain management. | Approx. 450 persons |
| Mitsui & Co. Australia invited an external lecturer to conduct a training session on laws concerning the rights of indigenous Australians and the use of land for employees of Mitsui & Co. Australia and Mitsui & Co NZ, as well as employees of consolidated subsidiaries in Australia. | Approx. 70 persons |
