Policies for Human Rights

Human Rights Policy

NS United Kaiun Group , as a global corporate group, 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 formulated the “NS United Kaiun Group Human Rights Policy” ("Policy") as follows.

 

This Policy was established by the Board of Directors on January 31, 2023, and approved the revision by the Board of Directors on March 27, 2025. 

Modern Slavery Statement

As we have subsidiary in UK, which is assigned a key role in boosting relationships with sustainability-focused customers in Europe, winning new contracts for environmentally conscious business, and collecting information about the situation in Europe as the world leader in promoting environmental action, in response to the "Modern Slavery Act 2015" of the United Kingdom, we have published a "Modern Slavery Statement" on our website as follows.

Promotion Framework

Based on the Human Rights Policy, we are promoting efforts to respect human rights under the following framework.

Sustainability Committee

We host the Sustainability Committee once every six months,  which is chaired by the President, Representative Director and Executive Officer  and the membership consists of all executive officers. With regards to general sustainability matters, including human rights, the committee discusses how to proceed with such matters, checks the status of initiatives, reports to the Board of Directors, and makes suggestions.

Human Rights DD Promotion Team

We have established a cross-departmental Human Rights DD Promotion Team (hereinafter, the “Promotion Team”), which is composed of the relevant directors and executives. Approximately every other month, the Promotion Team monitors human rights DD and assesses initiatives based on the report from the Human Rights DD Secretariat.

Human Rights DD Secretariat

The Human Rights DD Secretariat (hereinafter, the “Secretariat”) composed of the following three departments has been established, and it performs discussions approximately every other month.

 

In cooperation with each department and according to our Human Rights Policy, the Secretariat examines and implements initiatives for respecting human rights, human rights DD, and preventive and corrective measures against human rights risks, and reports the results thereof to the Human Rights DD Promotion Team.

 

  • 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.

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

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.

Performing Desk Analyses

Target Operations

International Shipping

Target Countries

WALKFREE - GLOBAL SLAVERY INDEX

Africa 5 countries, America 15 countries, Europe 22 countries, Oceania 3 countries, Middle East 3 countries, South Asia 3 countries, East / Southeast Asia 11 countries

Cargo

Iron ore, Steel products, Coal, Coke

Human Rights Issues

Occupational Health and Safety, Rights of Foreign Workers, Forced Work, Insufficient / Unpaid Wages / Living Wages, Discrimination, Child Labour, Excessive / Unfair Work, Sexual Harassment, Power Harassment, General Vulnerability, Industry-Specific Vulnerability, Right to Social Security, Discrimination, Freedom of Residential Transfer, Freedom of Association, Human Rights Issues Related to Gender, Rights of Indigenous Peoples and Local Populations, Human Rights Issues Related to Environment and Climate Change

Conducting Internal Interview

Date

International Shipping

Participating Department

  • Human Resource Department:Secretary and Personnel Team, Seamen Team, Seafarer Training Team
  • Safety Management Department:Quality Control Team
  • Ship Management Department:Ship Maintenance Team
  • Technical Management Team
  • Sales Department:Capesize Team, Second , Ocean-going Tramp Team, Second
  • Fuel Procurement Department:Energy Team, Third

Contents

  •  Regarding the occurrence of potential risks
  •  Involvement of NSU with stakeholders in the supply chain
  •  Overview of NSU educational system
  •  Overview of existing auditing system

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

Conducting Fact-finding Survey and Efforts for Correction

Japanese Seafarers

  • In FY 2023, following the result of the risk assessment, we conducted a questionnaire survey of 50 seafarers, who were working at the office, based on the 25 types of human rights risks identified by the Japanese Ministry of Justice, and based on the results of the questionnaire, NSU conducted interview with 12 seafarers comprising different age groups and job ranks. 

 

  • Using the findings from the two surveys, in FY 2024, we conducted a qustionnaire survey of 52 Japanese Seafarers onboarding and on leave, and conducted remote interview with 23 seafarers comprising different age groups, genders and job ranks.
     
  • With regards to the human rights risks that were uncovered during the course of the surveys, the Safety Management Group examined corrective measures and formulated an action plan.With respect to this series of initiatives, the Human Rights DD Promotion Team performs monitoring and assessment.

 

  • We will report on the progress of initiatives to the Sustainability Committee and the Board of Directors. The results of reports are reflected in reviews of corrective measures.

Non-Japanese Seafarers

  • As a result of the COVID-19 pandemic, many crewmembers 
    suff ered from very stressful work conditions due to rigorous 
    embarkation/disembarkation controls and restricted opportunities to go ashore. .In this context,  since FY2022, the Safety Management Group has conducted a well-being survey for foreign national ship crew of the Company. 

 

  • In the past, the questions focused on engagement and on health and welfare. In FY2024, we added questions on human rights risks and, by utilizing our conventional initiatives, we have added non-Japanese seafarers to the scope of human rights DD.

 

  • We have pushed forward various well-being initiatives based on the well-being survey results. With regards to the human rights risks that were uncovered during the survey, the Safety Management Group examined corrective measures and formulated an action plan. With respect to this series of initiatives, the Human Rights DD Promotion Team performs monitoring and assessment.

 

  • We will report on the progress of initiatives to the Sustainability Committee and the Board of Directors. The results of reports are reflected in reviews of corrective measures.

NS United Kaiun Group

  • Since 2011, we have conducted an employee awareness survey of all employees of the NS United Kaiun Group on an annual basis in order to foster an environment in which they can work at ease, exercising their full potential, and foster a culture in which it is easy to consult and report.

 

  • Conventionally, the questions were about compliance, internal controls, harassment, and corporate culture as well as items such as awareness of the whistleblowing system. In FY2024, we added questions about human rights, starting with awareness of the Group's Human Rights Policy.

 

  • With regards to issues uncovered in employee awareness surveys, the ESG/Internal Control Team, in cooperation with departments such as Human Resources and IT, will examine corrective measures and create action plans.

 

  • The Human Rights DD Promotion Team will perform monitoring and assessment. And we will report on the progress of initiatives to the Sustainability Committee and the Board of Directors. The results of reports are reflected in reviews of corrective

Supply Chain Initiatives

Since FY 2023, we have been holding safety meetings with shipowners in an effort to foster understanding including well-being and human rights.

And In August 2024, we established the Sustainable Procurement Basic Policy , and in March 2025, we established the NS United Kaiun Group Supplier Procurement Guidelines. We will consider conducting surveys on the status of sustainability initiatives, including those related to human rights, for our suppliers.

Education and Training

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

Year and month

Contents

September 2024

Webinar incorporating educational video materials of Global Compact Network Japan for all employees of our Group (Viewing rate 92%)

August 2024

Human rights in-house seminar (in English) held by the ESG/internal control team for all ships under our management

Since August 2023

Posting and distribution of ESG/internal control team newsletters on human rights (three times)

August 2023

Human Rights Seminar by Mr. Kazuo Tase, Representative of SDG Partners, Inc. (Viewing rate 78%)

Stakeholder Engagement

Participation in the Human Rights Due Diligence Workshop

Since 2023, We participated in the Human Rights Due Diligence Workshop hosted by Caux Round Table Japan (CRT Japan).

 

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.

Participation in the Business and Human Rights Conference

We participated in the Business and Human Rights Conference in 2023 and 2024. In the 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.

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

  • Conduct questionnaire survey on employee awareness and engagement survey.
  • Continue to perform enlightenment activities utilizing Compliance Awareness Month.
  • Enhance the system for the whistleblowing system, and engage external service desks.

Conducting Education and Training

Onshore personnel and seafarers
  • Continue to perform enlightenment activities utilizing Compliance Awareness Month.
  • Conducted e-learning on prevention of harassment. (in October 2024)
  • Harassment prevention training programs run by our corporate lawyer for all executives and employees of the Group (in March 2022)
Offshore

Our offices in Japan, the Philippines, and Vietnam regularly conduct e-learning and workshops on harassment and anger management.

Reduction of Long Working Hours

Participation in the UN Global Compact

On March 26, 2023, we have supported and participated in the United Nations Global Compact, a corporate sustainability initiative with universal principles on human rights, labor, environment and anti-corruption.
 

Through Global Compact Network Japan, a local network in Japan of the UN Global Compact, we will deepen our knowledge in related fields and use it for sustainability activities in our company.

Employees are encouraged to participate in workshops and attend various seminars organized by the Global Compact Network Japan (GCNJ), as part of the Company’s sustainability activities.

The Ten Principles of the UN Global Compact

Participation in GCNJ’s activities in fiscal 2024

  • Participation in subcommittee