Social Human Rights

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As a business entity that considers people as its primary asset, the Hakuhodo DY Group believes that human rights considerations are part of its business foundation. Under the Group Human Rights Policy developed in line with international standards, we are promoting efforts to respect the human rights not only of our employees but also of people working along the whole value chain including our partners.

The Hakuhodo DY Group’s Human Rights Policy

The Hakuhodo DY Group aims to “create a society abounding in sei-katsu-sha’s aspirations and where they can live vibrant lives” through our creative human resources, who serve as our greatest asset. Respect for human rights is the foundation upon which the Hakuhodo DY Group is built, and we promote respect for human rights as the root of ethical, sustainable business. In order to fulfill our responsibility to respect human rights more thoroughly, we have formulated a Human Rights Policy for the Group based on the “Protect, Respect and Remedy” framework outlined in the United Nations Guiding Principles on Business and Human Rights (UNGPs).

Scope of the Human Rights Policy

The Hakuhodo DY Group’s Human Rights Policy (hereinafter referred to as “the Policy”) applies to all officers, employees, etc. (including all corporate officers, regular employees, contract staff, and temporary staff) working at the Hakuhodo DY Group (i.e., Hakuhodo DY Holdings Inc., hereinafter referred to as “the Company,” and its consolidated subsidiaries). We also expect all of our business partners to act in accordance with the Policy.

Our Commitment to Respecting Human Rights

The Hakuhodo DY Group will respond with sincerity to the various impacts on human rights that may arise in relation to its business activities. We aim to create a society abounding in sei-katsu-sha’s aspirations and where they can live vibrant lives.

We have also made the following commitments in order to further promote the Group’s Diversity, Equity & Inclusion (DE&I) initiatives.

We will strive to respect human rights in all of our business activities in line with the UN Guiding Principles on Business and Human Rights (UNGPs), based on our understanding of the human rights specified by the International Bill of Human Rights (an international standard for human rights); the basic principles relating to human rights outlined in the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, as well as in the UN Global Compact; and the Children’s Rights and Business Principles developed by UNICEF, the UN Global Compact, and Save the Children.

We will comply with the domestic laws and regulations in each country or region where we conduct business activities, and in cases where these laws or regulations conflict with internationally recognized norms, we will strive to find ways to respect internationally recognized norms while still taking each country’s laws and regulations into account. We will not discriminate against people or infringe upon human rights on the basis of race, ethnicity, nationality, birthplace, language, religion, gender, age, political views, wealth, gender self-identification, sexual orientation, disability, background, etc. We will prohibit human trafficking, forced labor, and child labor. We will respect employees’ basic human rights in relation to freedom of association and collective bargaining rights as recognized by law, and we will ensure that employees have appropriate working hours, wages, etc. in conformity with the laws of each country or region in which we conduct business activities, thereby providing a healthy working environment to employees.

In the event that our business activities have a negative impact on human rights, we will take appropriate action to remedy the situation, and we will not do anything to further such negative impacts. We will also strive to prevent or mitigate any negative impacts on human rights in the Group’s value chain.

In addition, we will be on our guard for any incidents that could affect the human rights of sei-katsu-sha, such as incidents relating to freedom of expression, harassment, or invasion of privacy. We will proactively implement measures aimed at eliminating the infringement of human rights through our business activities, and we will strive to encourage and spread awareness of activities that contribute to the safeguarding of human rights. We will implement periodic evaluation of the content of the abovementioned measures and activities. Furthermore, we will identify any significant human rights issues that are likely to emerge in the future due to changes in society or in business activities and give priority to addressing these issues.

Governance and Internal Systems

The Company’s Board of Directors has a responsibility to implement ongoing monitoring of all activities stipulated by this Policy in regard to respect for human rights. While fulfilling the monitoring function in relation to measures addressing particularly significant human rights issues, the board will also devise appropriate measures to prevent any direct or indirect involvement in human rights infringements. The Corporate Sustainability Division, as the unit responsible for sustainability matters, will work under the guidance of the director responsible for overseeing sustainability to spread awareness of the Policy and promote all initiatives related to respect for human rights.

Human Rights Due Diligence

By implementing human rights due diligence to ensure that our responsibility to respect human rights is properly fulfilled in accordance with the UNGPs, the Hakuhodo DY Group will strive to demonstrate accountability for the impact of the Group’s business activities in relation to human rights.

Furthermore, based on the results of human rights due diligence, we will strive to focus on measures addressing significant human rights issues. Besides ensuring effective coordination between the internal control departments of each Group company, including not only existing businesses but also operating companies that may become part of the Group through M&A activity, we will also collate, assess, and consider response strategies for negative impacts on human rights that could arise through our business activities as part of our risk management measures.

Remedy Mechanism (Response Liaisons)

The Hakuhodo DY Group has established internal reporting and consultation liaisons for all corporate officers and employees. Reports and requests for consultation regarding human rights issues are handled with the utmost anonymity and confidentiality, and we respond in good faith so that any party who has had their human rights infringed upon can have this situation remedied. Furthermore, in order to be able to evaluate negative impacts on human rights in any Group company and consider response measures, we implement periodic examination of the number of reports received by our internal reporting and consultation liaisons regarding human rights as well as trends in these reports, discuss response measures in relation to situations where there is a possibility of serious human rights infringements, and report on them to the Group Compliance Committee.

Dialogue with Stakeholders and Information Disclosure

The Hakuhodo DY Group implements appropriate responses to human rights impacts through dialogue with related stakeholders. In addition, information related to the progress of activities connected to respect for human rights and the results achieved, including initiatives specified in this Policy, is disclosed on our corporate website, as part of our efforts to adopt a more proactive stance.

Spreading Awareness of Our Human Rights Policy and Related Educational/Training Activities

In order to enhance the effectiveness of this Policy as implemented in our business activities, the Hakuhodo DY Group will work to disseminate the Policy to all corporate officers and employees as well as to ensure that they are thoroughly familiar with it, while also implementing education and training to enhance understanding of human rights. We will also further strengthen our existing training programs related to various types of harassment, along with our training on representational risk in advertising.

Revision and Adjustment

This Policy has been approved by the Company’s Board of Directors. It will be adjusted and improved on a regular basis going forward in order to further strengthen initiatives related to respect for human rights.

Yasuo Nishiyama

Representative Director & President

Implementation of Human Rights Due Diligence

Development of Human Rights Due Diligence Guidelines

Development of Human Rights Due Diligence Guidelines
To fulfill our responsibility to respect human rights in operations, as set forth in the Hakuhodo DY Group Human Rights Policy, we have developed Human Rights Due Diligence Guidelines stipulating details of the roles and processes for relevant departments and Group companies to ensure the implementation of human rights due diligence, to which we have committed ourselves under the Human Rights Policy.

In developing the Due Diligence Guidelines, reference was made to relevant international norms including the UN Guiding Principles on Business and Human Rights, Universal Declaration of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, and OECD Due Diligence Guidance for Responsible Business Conduct.

Identification of Salient Human Rights Issues

Before determining human rights risks, we identified our salient human rights issues by taking the following steps.

1. Exhaustive Listing of Human Rights Issues
We developed an exhaustive list of material human rights issues in which we might be involved before conducting surveys on human rights issues and interviews with relevant staff members in the countries and regions where we operate. Based on the results, we developed a shortlist of human rights issues that might emerge along the value chain.

2. Materiality Assessment
We prioritized the human rights issues by assessing their materiality in terms of negative impact on human rights (likelihood and severity) and relevance to our Group’s operations, taking into account the possibility of occurrence in the past and future.

3. Identification of Salient Human Rights Issues
The Group Sustainability Committee identified our salient human rights issues in consultation, based on the results of the materiality assessment.

Human rights issues Rights holders whose human rights
could potentially be negatively impacted
Employees Suppliers* Sei-katsu-sha
Expression and
dissemination
of information
Restrictions on expression in production process Medium Medium -
Discrimination arising from expression or dissemination of information - - High
Leakage of personal information or invasion of privacy Low - High
Labor Workplace discrimination or harassment High High -
Discrimination in hiring Low Low -
Overwork or long working hours/safety and health High High -
Forced labor Low Medium -
Child labor Low Medium -
Religion Religious freedom Medium Medium -
  • * Mainly business partners

Assessment of Human Rights Risks for Employees

We conduct a questionnaire to measure the reach of human rights education in the Hakuhodo DY Group, detect any potential human rights issues and assess the progress of human rights due diligence.
We are also considering how to engage with external stakeholders including suppliers and sei-katsu-sha to establish and maintain a value chain mindful and respectful of human rights.

Human Rights Training

We conduct human rights training to promote an understanding of human rights and human rights infringement risks among employees of the Hakuhodo DY Group, and to encourage employees to embrace respect for human rights in their daily work.The training is provided in the form of original video content. In fiscal 2024, we provided this training to regular and contract employees of eight major companies in Japan (Hakuhodo, Daiko Advertising, YOMIKO ADVERTISING, Hakuhodo DY ONE, SoldOut, Hakuhodo DY Media Partners, Hakuhodo technologies, and HAKUHODO PRODUCT’S).

Item Results
Rate of Participation in Human Rights Training 91.2%
  • Target: FY2024
  • ※Coverage: Hakuhodo, HDaiko Advertising, YOMIKO ADVERTISING, Hakuhodo DY ONE, SoldOut, akuhodo DY Media Partners, Hakuhodo technologies, and HAKUHODO PRODUCT’S

Human Rights Assessment

We conducted a survey among employees of eight major companies in Japan (Hakuhodo, Daiko Advertising, YOMIKO ADVERTISING, Hakuhodo DY ONE, SoldOut, Hakuhodo DY Media Partners, Hakuhodo technologies, and HAKUHODO PRODUCT’S) to measure the extent to which human rights education permeates the organization and to identify and evaluate specific human rights issues that need to be addressed.

Item Results
Questionnaire Return Rate 79.4%
  • Target: FY2024
  • ※Coverage: Hakuhodo, HDaiko Advertising, YOMIKO ADVERTISING, Hakuhodo DY ONE, SoldOut, akuhodo DY Media Partners, Hakuhodo technologies, and HAKUHODO PRODUCT’S

Overview and Results of Human Rights Assessment

■Implementation process

• We carefully reviewed the survey and developed a questionnaire based on the nine items identified as the Group’s most prominent human rights issues.
• We conducted anonymous surveys of regular and contract employees at eight major companies in Japan (Hakuhodo, Daiko Advertising, YOMIKO ADVERTISING, Hakuhodo DY ONE, SoldOut, Hakuhodo DY Media Partners, Hakuhodo technologies, and HAKUHODO PRODUCT’S).
• Hakuhodo DY Holdings compiled and analyzed the survey results to identify potential human rights risks.
• Feedback was provided to each Group company, and each company considered specific measures to prevent and mitigate human rights risks.

■Survey overview

• Survey method: Online questionnaire
• Aggregation and analysis: Standalone totals for the eight major companies in Japan (Hakuhodo, Daiko Advertising, YOMIKO ADVERTISING, Hakuhodo DY ONE, SoldOut, Hakuhodo DY Media Partners, Hakuhodo Technologies, and HAKUHODO PRODUCT’S) with consolidated figures only for SoldOut.
• Return rate:79.4% (The questionnaire was sent to 11,195 people, and 8,892 people responded.)

■Human rights assessment (questionnaire) results

• General: No serious human rights risks were found that urgently need to be addressed.
• Basic understanding of human rights: The level of basic understanding of human rights exceeded 90% for each company.
• Human rights response system:
While awareness and understanding of the whistleblowing channel are very high, we will implement further initiatives to promote understanding of how to use the channel and how anonymity is ensured, and work to ensure thorough internal communication.
• Potential risks related to significant human rights issues:
While steady improvements have been observed compared to the previous year in the areas of "overwork or long working hours / safety and health" and "workplace discrimination or harassment", we will continue to plan and promote risk prevention and recommendation measures aimed at further improvement.

■Plans for the future

• Continue to implement human rights training and assessment at Group companies
• Monitor risk prevention and mitigation measures at Group companies
• Expand the scope of human rights assessment (domestic and overseas subsidiaries)