Basic Principle

Code of Conduct

• Respect the personality, diverse values and individuality, and respect all basic human rights.
• Respect the human rights of all stakeholders involved in our business activities.
• Comply with applicable laws and regulations in each country or region in which we operate.
  Where laws, regulations and international human rights standards differ in the country concerned, we pursue ways to respect internationally recognized human rights.
• Strive to create a safe and comfortable working environment in which the human rights of each employee are respected.
• Provide a healthy and safe working environment free from harassment, and respect the minimum wage, proper management of working hours, and privacy protection.
• No forms of forced labor, child labor and human trafficking are permitted

Code of Conduct

Policies for Human Rights

Human Rights Policy

The NS United Kaiun Group, as a global corporation, has established a Group Corporate Philosophy and a Code of Conduct to realize this philosophy.

Recognizing that it is our social responsibility to respect human rights as stated therein, we have newly formulated the “NS United Kaiun Group Human Rights Policy”.

This Policy was approved by the Board of Directors on January 31, 2023.
Subsequent revisions or abolition of the policy will also be determined by approval of the Board.

Modern Slavery Statement

In response to the "Modern Slavery Act 2015" of the United Kingdom, the Group has published a "Modern Slavery Statement" on its website as follows.

• Modern Slavery Statement for FY2022

Promotion Framework

We have in place a framework to promote initiatives for respecting human rights, which features the following systems and programs and started in August 2023.

Establishment of Human Rights Due Diligence Promotion Team

We have established the Human Rights Diligence Promotion Team (“Promotion Team”), which is composed of relevant directors and executive officers.

The Promotion Team meets once a month, in principle, to confirm the progress of conducting human rights due diligence (“Human Rights DD”) based on reports from the Secretariat and discuss ways of promoting the practice.

Establishment of Human Rights DD Secretariat

The Human Rights DD Secretariat (“Secretariat”) has been set up in the following organizations. The Secretariat is tasked with performing human rights DD and carrying out related initiatives.

• General Affairs Group: responsible for onshore personnel affairs and promoting ESG management
• Safety Management Group: responsible for offshore personnel affairs (seafarers)
• Capesize Group: representative of sales divisions

Ensuring Objectivity of Initiatives

In order to implement initiatives for respecting human rights properly in accordance with the UN Guiding Principles on Business and Human Rights, we regularly receive advice from SDG Partners, Inc., a specialist consultant, to ensure the objectivity and validity of each phase of implementing initiatives.

Reporting to the Board of Directors

The Promotion Team shares discussion results with the Internal Control and Compliance Committee, which reports to the Board of Directors by way of the ESG Committee and the Executive Committee

Click to enlarge

Human Rights Due Diligence

At present, we are working to identify and assess actual and potential adverse impacts on human rights caused by our Group’s business activities. This is to understand the relevant situation accurately and take appropriate steps in order to avoid or mitigate the adverse impacts.

OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct
Design：Peggy King Cointepas

① Human Rights Policy

• Policies for Human Rights

② Identify & Assess Adverse Impacts

• Conducting Risk Assessments

Conducting Risk Assessments

Starting from August 2023, we assess human rights risks in reference to external experts’ advice and international indicators of country-specific human rights risks and the like, specifically by identifying risk factors to be taken into account when conducting the Group’s business, specifying stakeholders that may be affected, and performing desk analyses working with related business divisions.

Value Chains and Right Holders Related to International Shipping Business (confirmatory result)

Click to enlarge

Human Rights of Seafarers

In response to the above results, we will carry out additional surveys for the categories of seafarers identified as having serious and highly probable risks of facing human-rights abuses, starting with Japanese seafarers of the Company in fiscal 2023.

Based on our recognition of seafarers as the most important function to support the safety of our operations as well as for the purpose of securing and developing human resources, one of our material issues, we are committed to the well-being of seafarers, setting higher standards than compliance with international treaties for protecting human rights.

• Initiatives to Support Safety
• Workstyle Reforms・Health Management

Maritime Labour Convention, 2006 (MLC 2006)

Article 3 of the Maritime Labour Convention 2006 (MLC 2006) stipulates respect for the following fundamental rights.

• (a) freedom of association and the effective recognition of the right to collective bargaining;
• (b) the elimination of all forms of forced or compulsory labour;
• (c) the effective abolition of child labour; and
• (d) the elimination of discrimination in respect of employment and occupation.

We stipulate respect for human rights and prohibition of discrimination based on religion, nationality, age, and gender. For harassment and other compliance violations, We have established Compliance Advisory Service Desks (whistleblower hotlines) both inside and a third-party organization.

Group-wide Human Rights Seminars for All Executives and Employees

We conducted a seminar for all executives and employees of the Group to help them have a deeper understanding of human rights.

Stakeholder Engagement

Participation in the Human Rights Due Diligence Workshop

We participated in the Human Rights Due Diligence Workshop hosted by Caux Round Table Japan (CRT Japan), attending eight sessions held between June 1 and July 27, 2023.

In the workshop, we discussed a wide range of human rights issues with participating companies, NGOs and NPOs, and academics and experts on human rights, which helped us gain a deeper understanding of human rights due diligence as required by the UN Guiding Principles on Business and Human Rights and acquire knowledge for practical application.

Also, working with other participating companies from the transportation and logistics industries, we reviewed the “sector-specific key human rights issues” identified using the UN Environment Programme Finance Initiative (UNEP FI) Human Rights Guidance Tool. This helped deepen our understanding of human rights issues to be addressed by the transportation sector.

• Human Rights Due Diligence Workshop

Participation in the Business and Human Rights Conference

We participated in the Dialogue with External Experts (October 17, 2023) and the Business and Human Rights Conference (October 20, 2023). In the two events, we learned about global trends related to business and human rights challenges, particularly from the world’s latest trends and views on this topic shared with by participating foreign academics and experts, NGOs and NPOs, and business corporations as well as reported practices of human rights due diligence

We will continue pursuing stakeholder dialogue as a way to appropriately understand human rights issues to address.

• Business and Human Rights Conference

Initiatives for Individual Human Rights Issues

Preventing Harassment

Basic Principle

We formulated the Anti-harassment Guidelines in 2017, and implement the following programs to prevent harassment.

Initiatives

• Understand the current situation and collect issues through employee attitude survey questionnaire and engagement survey
• Enhance the system for the Compliance Advisory Service Desks, and engage external service desks.

• Promoting Compliance

Conducting Education and Training

Onshore personnel and seafarers

• Educate and promote compliance among employees by continuing the monthly program for internal control and compliance awareness.
• Continue the use of e-learning.
• Harassment prevention training programs run by our corporate lawyer for all executives and employees of the Group (March 2022)

Offshore

In Japan and Vietnam, we have started to provide harassment and anger management seminars periodically inviting instructors. Particularly for Japanese seamen, we have set up an external consultation desk, and conduct internal attitude and engagement surveys on a regular basis, in order to collect information for understanding the situation and issues related to onboard living.

Reduction of Long Working Hours

• Workstyle Reforms ・Health Management

Participation in the UN Global Compact

The Ten Principles of the UN Global Compact

Participation in GCNJ’s activities in fiscal 2023

・Participation in subcommittee

• Subcommittee of the Global Compact Network Japan (GCNJ)

・Attendance at sustainability management seminars

• Sustainability Management Seminar