Respect for Human Rights
Human Rights Initiatives
“people & technology” is the origin of our business. As it implies, we place the utmost importance on respecting human rights of all our stakeholders in everything we do and in all areas of our corporate activities. Our Compliance Codes of Conduct sets forth our commitment to always maintain safe and healthy workplaces, prohibit discriminatory conduct of any kind on the basis of nationality, race, ethnic group, belief, religion, gender, age, sexual orientation, gender identity, and disability, freedom from harassment including sexual and maternity harassment as well as forced labor and child labor. We ensure that all our employees are aware of the Codes and implement the Codes throughout our businesses.
We have established the transcosmos Human Rights Policy, and have been promoting human rights initiatives. In March 2024, we revised the policy to the transcosmos Group Human Rights Policy given board approval.
We have posted the transcosmos Group Human Rights Policy on our website and provide Human Rights training covering all our employees to ensure that everyone is fully aware of the transcosmos Group Human Rights Policy. In addition, we are now taking steps to implement the transcosmos Group Human Rights Policy across all our Group companies.
transcosmos Group Human Rights Policy
“people & technology” is the origin of our business, in other words, “people” have been an integral part of our business since our foundation. Under the transcosmos Fundamental Sustainability Policy, we also aim to enrich lives and happiness - the well-being of all our stakeholders through our business activities.
Based on the philosophy above, we respect human rights of all our stakeholders in everything we do and in all areas of our corporate activities, while positioning the philosophy as the foundation of all documents and standards related to our Group’s activities on human rights.
1. Upholding and Respecting International Human Rights Standards
We uphold the International Bill of Human Rights (the Universal Declaration of Human Rights and the International Covenants on Human Rights) - the international norm of human rights - the United Nations Guiding Principles on Business and Human Rights, as well as the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises that stipulate fundamental rights of workers.
Supporting the United Nations Convention on the Rights of the Child and Child Rights and Business Principles that define fundamental principles of children’s rights, we respect children’s rights including their rights to be free from child labor.
We comply with applicable local, national and international laws and regulations in countries and regions where we operate. When national or regional laws conflict with internationally recognized human rights, we seek ways to honor the principles of internationally recognized human rights to the maximum extent possible.
2. Respecting Human Rights in our Corporate Activities
We respect the diversity of people in every country and region where we operate. Therefore, we prohibit all forms of human rights violations including discrimination on the basis of nationality, race, ethnic group, belief, religion, gender, age, sexual orientation, gender identity, disability, etc., all types of harassment including sexual harassment and maternity harassment – harassment against women due to pregnancy, childbirth, and taking childcare leave – as well as forced labor and child labor. We also recognize the importance of freedom of expression and privacy, and pay close attention to protect such rights.
We comply with applicable laws and regulations of each country and region where we operate, and respect freedom of association, the right to collective bargaining and action.
3. Scope of our Human Rights Policy
Our Human Rights Policy applies to all corporate activities, officers and employees of our Group. All people working at transcosmos Group, including officers and employees, are protected by our Human Rights Policy, and are acting on the policy.
Also, we encourage all our Group’s business partners and stakeholders to value our Human Rights Policy, and engage in initiatives to promote respect for human rights.
4. Our Framework for Promoting Human Rights
At transcosmos, the Human Rights Promotion Committee discusses and submits proposals on human rights action policies and key initiatives to the transcosmos SDGs Committee. The transcosmos SDGs Committee then deliberates the proposals and makes a decision.
The Board of Directors is responsible for the oversight of human rights risk management, and carries out a continuous monitoring function to ensure the Group’s commitment to, and compliance with the Human Rights Policy in its decision-making process on important human rights issues and initiatives.
5. Offering Equal Employment Opportunity & Fair Working Conditions
We do not discriminate against applicants or employees on the grounds of personal characteristics, and take all appropriate measures to eliminate any form of discrimination to provide fair opportunity in every aspect of employment including, but not limited to, job advertisement, hiring, training and promotion.
In compliance with the laws and regulations related to occupational safety and health of each country/region, we strive to maintain a safe and healthy workplace environment, being mindful of each and every employee’s physical and mental well-being.
We do not tolerate any form of forced labor or modern slavery.
In light of equal pay for equal work guidelines, we provide employees with a fair remuneration package that meets or exceeds the legal minimum standards in compliance with the applicable laws and regulations of each country/region where we operate.
Also, we address and reduce long working hours in line with the applicable laws and regulations of each country/region, and manage employees’ work hours appropriately.
6. Identifying Human Rights Challenges
We maintain a continuous dialogue with our stakeholders including third party experts, employees, suppliers and communities to identify and address human rights challenge specific to each party.
7. Human Rights Due Diligence
We undertake human rights due diligence on an ongoing basis based on our Human Rights Policy to identify, prevent and mitigate adverse human rights impact associated with our corporate activities.
8. Access to Remedy
transcosmos Group offers remedy mechanisms including hotlines. In situations where our Group’s corporate activities may have caused an adverse human rights impact, we will take appropriate remedial action for affected persons and/or organizations.
9. Education and Training
We provide our officers and employees across the Group with human rights education and training to promote their understanding of our Human Rights Policy and to ensure all our people put our Human Rights Policy into practice throughout corporate activities.
10. Reporting
We report our initiatives to promote respect for human rights and their progress through various reporting documents, our corporate website and other channels.
Date of Enactment: July 1, 2023
Date of Revision: March 28, 2024
Takeshi Kamiya
Representative Director, Co-president
transcosmos inc.
Human Rights Promotion Framework
At transcosmos, the transcosmos SDGs Committee plans, deliberates and decides sustainability-related initiatives in line with our Fundamental Sustainability Policy.
The transcosmos SDGs Committee plans human rights action policies and key initiatives, and gives directions to the Human Rights Promotion Committee, which consists of managers of related departments to draft policies and initiatives based on the plans. After receiving proposals from the Human Rights Promotion Committee, the transcosmos SDGs Committee deliberates the proposals and makes final decisions on the policies and key initiatives. The Human Rights Promotion Office and each department execute the initiatives in line with the policies set by the transcosmos SDGs Committee.
| Meetings & Structure | Roles & Responsibilities |
|---|---|
| Human Rights Promotion Committee | Chaired by the manager of Legal & Compliance Division, the Human Rights Promotion Committee discusses and submits proposals on human rights action policies and key initiatives based on draft plans developed by the transcosmos SDGs Committee. |
| Human Rights Promotion Office | The Human Rights Promotion Office discusses specific measures and processes of human rights action policies and key initiatives based on the proposals submitted by the Human Rights Promotion Office, and executes the initiatives with human rights-related departments and members in charge of human rights in each business department. |
| Human Rights-related Departments | Each department shares its human rights-related challenges and action plans with the Human Rights Promotion Office, and executes human rights initiatives relevant to each department. |
| Members in charge of human rights in each business department | Each department under Sales, Service, Global and Corporate Headquarters organizations has members responsible for human rights initiatives, and they carry out and lead initiatives discussed and decided by the transcosmos SDGs Committee. |
Fundamental Sustainability Policy_Sustainability Promotion Framework
Human Rights Due Diligence
As part of our human rights initiatives based on the transcosmos Group Human Rights Policy, we have identified material human rights risk areas and are taking action to mitigate them.
Material Human Rights Risk Areas
We have identified human rights risks that are specific to the industries, sectors, and business activities of rights holders related to and affected by our business, based on guidance provided by third-party experts. We then assessed the severity and likelihood of potential human rights violations. Given that existing information on the likelihood of risk occurrence was insufficient, we conducted additional research by distributing questionnaires to relevant departments and selected employees to supplement the missing information. In line with the assessment results, we identified material human rights risk areas within our business from among the 25 human rights categories that companies should respect, as specified in the Report on the “Research on Business and Human Rights”: How Companies Should Respond Today, published by the Ministry of Justice in 2021.
| Material human rights areas | Our initiatives |
|---|---|
| Excessive or unreasonable working hours | Sustainable Work Culture & Employee Well-being
|
| Forced labor | Sustainable Work Culture & Employee Well-being
|
| Occupational health and safety | Sustainable Work Culture & Employee Well-being
|
| Harassments | Compliance
|
| Access to remedy | Compliance
|
Employee Survey
We recognize that the assessment conducted to identify the human rights risk areas described above was based on limited information. Therefore, in FY2025/3, we conducted a survey covering 14,000 employees, including all full-time employees and officers. Based on the survey results, we also carried out hearing sessions with third-party experts to gain a more detailed understanding of the current situation.
After analyzing the results of the survey and the hearing sessions with third-party experts, we identified “Excessive or unreasonable working hours” and “Harassment” as priority areas. The Human Rights Promotion Committee, in collaboration with responsible departments, will take the lead in discussing and implementing mitigation measures from FY2027/3.
Human Rights Training & Awareness Campaigns
Business and Human Rights Training
At transcosmos, we provide Business and Human Rights Training that covers topics such as fundamental concepts of human rights, trends shaping the business and human rights landscape, and common human rights risks in the workplace.
In FY2025/3, the training covered all full-time employees and officers of the parent company, and approximately 25,000 employees completed the training. In FY2026/3, the training covered officers and employees who joined the company after the previous training, and approximately 3,000 employees completed the training. In addition, coverage was expanded in FY2026/3 to include 11 domestic Group companies, with approximately 3,000 employees completing the training.
Human Rights Handbook
To make it easy for employees to learn about human rights, we created an internal Human Rights Handbook and distributed it throughout the company in December 2024.
The handbook was developed to help each of us recognize that there are many situations and actions around us that could violate human rights, and to acquire the knowledge needed to prevent such violations.
The handbook was developed entirely by our in-house Normalization Promotion Department*.
*In 2005, we created the Normalization Promotion Department which specializes in hiring, training, and managing people with disabilities working at transcosmos.
Compliance Training
We provide an annual Compliance Training program that includes topics such as information security, anti-harassment, human rights, and anti-discrimination.
The training covers all transcosmos officers and employees, and in FY2026/3, approximately 37,000 employees completed the program.
In addition, we continuously work to raise compliance awareness by distributing a monthly compliance magazine.
Risk Management Training
We provide annual risk management training for all transcosmos employees in managerial positions. The training covers topics such as compliance and risk management, and in FY2026/3, approximately 4,000 employees completed the training.
To mitigate labor compliance risks, the program includes learning sessions focused on harassment prevention and labor management. Through this risk management training, we are committed to creating a healthy workplace.
LGBTQ Training & Awareness Activities
We conduct an annual e-learning program on LGBTQ/SOGIE for more than 40,000 employees, with the aim of respecting human rights and preventing harassment. We also hold an LGBTQ Forum for officers and managers who are responsible for creating inclusive workplaces.
Featuring messages from our co-presidents and panel discussions with LGBTQ members as guest speakers, the forum helps promote participants’ understanding of the topic. In addition, through continuous awareness activities such as internal email newsletters and internal and external events, we are working to create a pleasant workplace for all.
Barrier Free Mind Training
We have more than 700 employees with disabilities. Through this training, we aim to deepen understanding of disabilities by recognizing them not as a personal matter, but as social barriers, and help create an inclusive society where everyone can be fully engaged.
