Basic Approach to and Policy on Human Rights

Basic Approach to and Policy on Human Rights

Tokio Marine Group has considered “protecting customers and society in times of need” to be its purpose since its founding. The insurance business has been called a “people’s business,” and everything about insurance comes from the trust created by people. As we continue with our business, we must earn the trust of customers, employees and local residents and respect the human rights of all people.

As an insurance company, we are connected with customers, stakeholders and other rightsholders from a broad range of industries. Our impact on society is not minor. Every employee who comes into contact with customers and society must remain aware of the importance of respecting human rights and put this into action. To this end, Tokio Marine Group formulated the Tokio Marine Group Basic Policy on Human Rights and the Responsible Procurement Guidelines based on related principles such as the Universal Declaration of Human Rights, OECD Guidelines for Multinational Enterprises, ILO International Labour Standards, UN Guiding Principles on Business and Human Rights and UN Global Compact.

With the mission of providing customers and local communities with safety and security and protecting them against risks, we need to understand how our business activities are directly or indirectly connected to human rights and how they can impact human rights. Accordingly, we provide education to employees of Group companies and increase their awareness. In fiscal 2022, we formulated a human rights risk map to assess our impact on human rights in Japan, clarified issues that should be prioritized and urgently addressed, conducted a study on corresponding issues and implemented concrete measures.

If there is a possibility that human rights will be negatively affected, we implement measures to prevent it. It is also essential to set up a system to ensure that the problem is reported by the workplace to top management so that it can be addressed immediately in case a human rights issue does occur, even though such an issue is unacceptable.

Amid the rapid changes in the external environment, it is not possible to complete a system for respecting human rights in our business activities and extensive value chain overnight. Nevertheless, we strongly believe that the management team should attentively listen to the voices of rightsholders and other stakeholders and continue to discuss the approaches and processes needed to do so. Each employee should also be more sensitive to human rights and, in cooperation with business partners, promote responsible procurement initiatives. Sharing a strong commitment to upholding human rights, we will continue these initiatives step by step. This should enable us to earn the trust of customers, local communities (residents), the employees of different organizations and other stakeholders.

As our Corporate Philosophy states, with customer trust as the foundation for all its activities, Tokio Marine Group (the “Group”) continually strives to raise corporate value. The foundation for implementing this Corporate Philosophy is respect for the human rights of all people, such as customers, society (including business partners and civil society organizations), employees, shareholders and investors, and future generations, and we are committed to respecting human rights across all of our business activities. The Tokio Marine Group Basic Policy on Human Rights (the “Policy”) is based on the Corporate Philosophy and Code of Conduct and outlines our approach to respecting human rights throughout our business activities, including our entire value chain.

Each officer and employee (including temporary staff) of Tokio Marine Group's companies is expected to act in line with this Policy to ensure that our business activities comply with the Group's human rights commitment.

We also expect our business partners to support and practice the principles expressed in this Policy and aim to work together toward the promotion of respect for human rights.

1. Our Commitment to Respect Human Rights

Tokio Marine Group is committed to respect human rights as stipulated in the International Bill of Human Rights*1 and the ILO’s Declaration on Fundamental Principles and the Rights at Work.*2 We also support international standards such as the Guiding Principles on Business and Human Rights, and will base our efforts on these principles. We are also a signatory to the United Nations Global Compact and support its ten principles.

Tokio Marine Group does not tolerate any form of forced or compulsory labor, human trafficking, child labor, discrimination or harassment, or any other conduct that undermines human dignity. We also respect fundamental rights concerning freedom of association and the right to collective bargaining in accordance with applicable local laws and regulations.

Tokio Marine Group respects human rights in its business activities including insurance underwriting and investment and financing through the signing and supporting of, among others, the United Nations Environment Programme Finance Initiative (UNEP FI), the Principles for Sustainable Insurance (PSI) and the United Nations-supported Principles for Responsible Investment (PRI). We also endeavor to address human rights issues, where possible, through the provision of insurance products as well as investment and financing.

Tokio Marine Group shall comply with applicable laws and regulations in the countries and regions in which it operates. If requirements of the local laws and regulations are in conflict with internationally recognized human rights, we will seek ways to honor the principles of internationally recognized human rights while complying with local laws and regulations.

The Board of Directors of Tokio Marine Holdings are informed of the compliance status of this Policy and has overseeing responsibility for the Group’s human-rights-related efforts. Each department of each Group company promotes activities related to respect for human rights in a proactive manner and in cooperation with one another.

  • *1
    The International Bill of Human Rights is the name given for the set of three documents: the Universal Declaration of Human Rights, and its corresponding two international treaties, namely the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights.
  • *2
    The ILO Declaration on Fundamental Principles and Rights at Work sets forth four categories as a minimum standard to be observed in relation to labor: “freedom of association and the effective recognition of the right to collective bargaining,” “the elimination of forced or compulsory labour,” “the abolition of child labour,” and “the elimination of discrimination in respect of employment and occupation”.

2. Our Approach to Respect Human Rights

Tokio Marine Group strives to conduct appropriate human rights due diligence to identify, assess, prevent and mitigate, and account for negative human rights impacts related to its business activities. We shall also comply with country-specific laws and regulations related to human rights due diligence, wherever applicable to our operations. Where we identify that our business activities have caused or contributed to negative impacts on human rights, we endeavor to remediate such impacts through appropriate processes and by holding dialogue with relevant stakeholders.

3. Respecting Human Rights as an Employer

In order for Tokio Marine Group to protect customers and society from all forms of emergencies, it is important that employees respect the diverse values and work styles of others, find their work rewarding and work with enthusiasm with colleagues. It is also essential to gain the trust from all people and society by always acting in a way that respect human rights. Tokio Marine Group shall comply with laws and regulations concerning working conditions, including working hours and wages. We provide a dynamic working environment that is both safe and healthy and we promote training and education for our employees. Therefore, the officers and employees of Tokio Marine Group are expected to respect human rights as set out in this Policy while their human rights are also subject to protection under this Policy.

Prohibition of forced labor and human trafficking
Forced labor is not permitted, nor is any form of slave labor, including bonded labor and human trafficking.
Prohibition of child labor
We do not tolerate child labor and shall observe the minimum working age as stipulated by law. We do not allow young workers to engage in hazardous work.
Freedom of association and the right to collective bargaining
We respect fundamental rights concerning the freedom of association and the right to collective bargaining of Group employees in accordance with applicable local laws and regulations. We shall not engage in any intimidation or retaliation against union representatives or members who exercise these rights.
Prohibition of discrimination and harassment
We do not discriminate in any way based on sex, gender, sexual orientation or gender identity, age, profession, nationality, race, thought, creed, religion, social status or birth, age, or physical or mental disability. We do not tolerate any form of harassment, whether it be physical or mental, including sexual harassment and power harassment.
Respect for diversity and promotion of inclusion
We respect the individuality and diversity of each Group employee and create an environment in which all employees can fully exert their capabilities regardless of gender, age, nationality, disability, or other attributes. Our employees are passionate and bring a challenging spirit to their endeavors and we will be purposeful in our efforts to provide them with equal opportunities for career development and ongoing personal growth. Tokio Marine Group's approach to human resources is also outlined in "Tokio Marine Group - Our People.”

4. Integrating Human Rights into Our Core Business

Tokio Marine Group treats all customers fairly in the provision of its products and services and does not discriminate against any customer based on unreasonable grounds.

We strive to be a “Good Company” that is trusted by all people and society by supporting customers and society in times of need. We strive not only to prevent and mitigate negative human rights impacts associated with our products and services, but also promote the human rights of all of our customers and contribute to an inclusive society by providing products and services to meet its needs for safety and security.

Across our insurance business and others, in compliance with applicable laws, rules and regulations as well as the Tokio Marine Group Privacy Policy, we shall safeguard private information and specific personal information, etc., including customers' information, and we shall not use such information except on a need basis to carry out our business operations, in order to avoid any breach of privacy.

Tokio Marine Group endeavors to consider environmental, social and governance (“ESG”) issues, including human rights, in its decision-making and other processes related to insurance underwriting and investment and financing operations.

5. Respecting Human Rights in Our Value Chain

Tokio Marine Group aims to fulfill its social responsibility and achieve sustainable development together with its business partners.

Tokio Marine Group expects its business partners to support and implement the principles expressed in this Policy and aims to work together towards the promotion of respect for human rights.

Tokio Marine Group also strives to prevent the occurrence of slave labor and human trafficking in its own business and value chain (supply chain) and encourages various stakeholders to work towards addressing such issues.

6. Grievance Mechanisms

Tokio Marine Group has established internal and external hotlines (whistle-blowing hotlines) where officers and employees of Group companies can report and consult on matters that may involve human rights concerns. The Group provides its officers and employees with multiple contact points and reporting channel options including internal and external hotlines, as well as a company audit hotline. We prohibit any disadvantageous treatment or retaliation against relevant officers, employees and those who cooperate in investigations because of such reports or consultations. In addition, we strictly manage the confidentiality of reports and consultations by ensuring anonymity and sharing information only to the extent necessary for effective investigations and corrective measures. Tokio Marine Holdings monitors the handling of the reports and provides support for the appropriate installation and operation of the whistle-blowing system, thereby establishing a mechanism that allows officers and employees of each Group company to report concerns without fear of retaliation.

7. Education & Training

Tokio Marine Group will provide the necessary training and capacity building for the implementation of this Policy to the officers and employees of each Group company. We further endeavour to provide the latest information and tools related to human rights and foster a culture of respect for human rights.

8. Communication and Disclosure

Tokio Marine Group will continuously monitor the implementation of its Policy and make improvements as necessary to ensure its effectiveness. In addition, we regularly disclose our efforts to respect human rights both internally and externally to ensure transparency and accountability.

9. Amendment or Repeal

This Policy may be amended or repealed by the Board of Directors of the Company. Notwithstanding the foregoing, the General Manager of the Human Resources Department may approve minor amendments to the Policy.

This Policy was approved by the Board of Directors of Tokio Marine Holdings, Inc.

Adopted December 21, 2021

Tokio Marine Group’s business activities (business domains) can be classified into three domains, namely “insurance underwriting, investments and financing,” “value chain” and “direct operations.” The table below shows the rightsholders, human rights issues (e.g., negative impacts on human rights) and our response regarding the issues in each of these business activities (domains).

[Business domain:Insurance underwriting, and investments, and financing Rightsholder:Customers, insured persons, victims, Employees of companies we have invested in/financed, Local residents Human rights issue:Privacy rights (leakage of personal information, infringement of privacy) Negative impact on the community Our response:Privacy Policy, Policy to Address Environmental and Social Risks][Business domain:Value chain Rightsholder:Insurance agencies, outsourcing contractors, and employees of suppliers Human rights issue:Workers’ rights (regarding discrimination, harassment, long working hours, etc.) Treatment of immigrant/foreign workers Prevention of harassment Our response:Responsible Procurement Guidelines][Business domain:Direct operations Rightsholder:Directors, officers, employees, and staff within the Group Human rights issue:Workers’ rights (regarding discrimination and harassment) Our response:Promotion of diversity and inclusion]

Tokio Marine Group’s main business activity is providing customers and society with safety and security through insurance underwriting. The table below shows issues relating to rightsholders and human rights (e.g., a negative impact on human rights) in the flow of insurance operations.

Our action:Identify customers' needs→Recommend insurance products→Contract procedures→Offer insurance products→[Occurrence of an accident]→Report the accident, investigate damage→Pay insurance claims→Propose recurrence prevention measures [Respect for human rights through the provision of products and services] Rightsholders: Customers, insurees, victims, and local residents. Human rights issue:Discriminatory expressions in the development and advertising of products and services. Appropriate response to claims service. Leakage of personal data and privacy infringement. [Respect for human rights in the value chain]Rightsholders: Employees of insurance agencies, outsourcing contractors, and suppliers. Human rights issue:Long working hours and harassment of employees [Prevention of long working hours and harassment and promotion of D&I] Rightsholders: Directors, officers, and employees within the Group. Human rights issue:Long working hours and harassment of employees

Human Rights-Related Policy

In implementing our Corporate Philosophy, we have formulated the Tokio Marine Group Sustainability Charter as principles of conduct required from the perspective of social responsibility, and strive to respect human rights for all people, including customers, shareholders/investors, insurance agents, business partners, employees, local communities/society and future generations. The insurance business, which forms the core of Tokio Marine Group’s business, has been called a “people’s business,” and respect for human rights forms the basis for its sustainable growth. Tokio Marine Holdings endorses and respects the Universal Declaration of Human Rights, OECD Guidelines for Multinational Enterprises, ILO Core Labour Standards, UN Guiding Principles on Business and Human Rights and ISO 26000, and has signed the United Nations Global Compact. Tokio Marine Group fully understands international action principles and guidelines concerning human rights and participates in and contributes to initiatives concerning social responsibility, and by doing so, fulfills its role toward realizing a sustainable society.

Tokio Marine Group Basic Policy on Human Rights

As our Corporate Philosophy states, with customer trust as the foundation for all its activities, Tokio Marine Group (the “Group”) continually strives to raise corporate value. The foundation for implementing this Corporate Philosophy is respect for the human rights of all people, such as customers, society (including business partners and civil society organizations), employees, shareholders and investors, and future generations, and we are committed to respecting human rights across all of our business activities. The Tokio Marine Group Basic Policy on Human Rights* (the “Policy”) is based on the Corporate Philosophy and Code of Conduct and outlines our approach to respecting human rights throughout our business activities, including our entire value chain.

Each officer and employee (including temporary staff) of Tokio Marine Group’s companies is expected to act in line with this Policy to ensure that our business activities comply with the Group’s human rights commitment.

We also expect our business partners to support and practice the principles expressed in this Policy and aim to work together toward the promotion of respect for human rights.

  • *
    The policy is in accordance with UN Guiding Principles on Business and Human Rights and was approved at Tokio Marine Holdings’ Board of Directors meeting in December 2021.

Within Tokio Marine Group, actions to address sustainability issues, including human rights risks and other human rights-related issues, are discussed by the Sustainability Committee and the Management Meeting. Decisions are made before plans and progress are reported to the Board of Directors. The process is operated leveraging a governance structure led by related executive bodies under the guidance and supervision of the Board of Directors.

Sustainability Committee

To address sustainability issues, including human rights, the Sustainability Committee, which is composed of the Group CEO, the Group Chief Human Resources Officer (CHRO), the Group Diversity, Equity & Inclusion Officer (CDIO), the Group Chief Sustainability Officer (CSUO) and other members, discuss topics such as the formulation of strategies and targets as well as the coordination and promotion of initiatives.

Human Rights Subcommittee

To examine human rights issues, we have established the Human Rights Subcommittee, subordinate to the Sustainability Committee. The subcommittee consists of permanent members from the Human Resources Department, the Legal & Compliance Department and the Corporate Planning Department of Tokio Marine Holdings. Advised by human rights specialists, the subcommittee discusses initiatives to respect human rights and how to apply them throughout the Group.

Compensation for Directors, Audit & Supervisory Board Members and Executive Officers

At Tokio Marine Group, non-financial indicators regarding the main issues of the sustainability strategy, including the promotion and penetration of DE&I initiatives, have been incorporated into the performance-linked compensation for directors and executive officers since fiscal 2022. The Sustainability Committee reviews the progress of initiatives to reach goals, which is presented as an index, before the Compensation Committee deliberates on compensation and makes final decisions.

At each Group company, all employees and other co-workers are working to build a vibrant corporate culture without discrimination or harassment. In fiscal 2023, we created a video to be used commonly in training at Tokio Marine Group. Topics ranged from human rights due diligence related to the UN Guiding Principles on Business and Human Rights to issues regarding respect for human rights in the Group. We subsequently started training programs for all employees of the Group in Japan. A training video in English will also be released in fiscal 2024 for overseas Tokio Marine Group companies. At Tokio Marine & Nichido, we formulate the Basic Policies and Measures Related to Human Rights at the beginning of each fiscal year, and under the human rights awareness promotion structure, provide support to all for their relevant initiatives made in relation to operations that involve human rights and inspect the status of their initiatives at the end of the fiscal year. We go through the plan-do-check-act (PDCA) cycle on a constant basis to survey the status, identify issues and take improvement measures.

Principal Initiatives

  • Conducting human rights awareness training (to be attended by all employees) and execution of daily business operations with an awareness of human rights
  • Achievement of diversity, equity and inclusion (achievement of normalization within the Group and promotion of employment and retention of persons with disabilities)
  • Prevention of, education on and appropriate response to various types of harassment
  • Fair hiring selection practices
  • Initiatives to raise human rights awareness of agents

Process to Monitor the Promotion of Human Rights Awareness (Tokio Marine & Nichido)

  1. 1.
    Establish and thoroughly implement policies for promoting human rights awareness.
  2. 2.
    Develop an organizational structure to promote human rights awareness with the president as the responsible person.
  3. 3.
    Implement human rights awareness training for all directors, officers and employees at least once a year.
  4. 4.
    Formulate and thoroughly implement policies aimed at implementing fair recruitment selection practices and establish the Human Rights Awareness Committee for Fair Selection and Recruitment.
  5. 5.
    Promote normalization (increasing employment of persons with disabilities and improving their workplace environment in terms of both “software” and “hardware”).
  6. 6.
    Establish rules for the prevention of harassment in the workplace and set up an in-house consultation desk.
  7. 7.
    Request and support agents’ voluntary efforts to raise human rights awareness.

Human Rights Awareness Training

Every year, each member company of Tokio Marine Group holds human rights training in the workplace and e-learning training, in which all employees and other co-workers attend to practice the Basic Policy on Human Rights and build a vibrant corporate culture without discrimination or harassment. Training is based on themes that reflect societal challenges and employees learn about a wide range of areas, which encompass acquiring knowledge concerning a number of human rights issues in Japan, including discrimination against people belonging to minority communities, normalization, LGBTQ+ and harassment issues as well as issues regarding foreign residents and the Sustainable Development Goals (SDGs).

Tokio Marine & Nichido has established a promotion structure mainly comprising the Human Rights Awareness Promotion Headquarters and the Human Rights Awareness Promotion Committee members of each branch office. Aside from the annual human rights awareness training held in the workplace, the company also holds rank-based training, such as executive seminars. In addition to employees, the company provides various training tools to agents to support their human rights awareness training.

Fostering a Culture to Respect Human Rights by Soliciting and Awarding Human Rights-Related Slogans

During Human Rights Week, which takes place from December 4 to 10 every year, each Group company solicits human rights-related slogans from employees and their families. The aim is to facilitate an understanding of the importance of respecting human rights and raise human rights awareness in the workplace, at home and within local communities. We select excellent slogans and disseminate them through our in-house intranet, Group newsletters and posters to be put up in each workplace as an effort to instill and spread the awareness of respecting human rights.

Keeping the Human Rights Perspective in Daily Business Operations and Thoroughly Ensuring Prevention of Discriminatory Practices

Tokio Marine & Nichido has in place a document inspection system to check for any expression (including illustrations, photos and videos) or wording undesirable from the perspective of human rights in its advertisements and insurance soliciting documents for customers as well as in its daily business operations. The system also performs a check to make sure the company does not obtain unnecessary personal information. Moreover, the company has established a system to appropriately report and respond by prescribing rules for handling cases of discrimination events that are discovered or encountered and making these known internally.

Sustainability Training

Every year, Tokio Marine Holdings, Tokio Marine & Nichido and other major Group companies provide all employees, dispatched employees, contractors’ employees and others with sustainability training in different forms, including e-learning programs. The training program seeks to facilitate a deeper understanding and penetration of human rights issues among employees and encourage the independent resolution of human rights issues by learning about the UN Guiding Principles on Business and Human Rights, trends in human rights due diligence in and outside Japan, the Basic Policy on Human Rights, the Policy to Address Environmental and Social Risks and the Responsible Procurement Guidelines.

Disseminating Responsible Procurement Guidelines

In March 2023, Tokio Marine Group formulated and published its Responsible Procurement Guidelines and has been working to ensure the employees of Group companies and business partners are well aware of the guidelines. Information about the guidelines is published on the websites of Tokio Marine Holdings and major Group companies. At the same time, we are committed to making the guidelines disseminated to the employees of the Group companies and our major business partners and requesting that international norms relating to human rights and labor are respected and laws and regulations are obeyed.

From the perspective of social responsibility, Tokio Marine & Nichido shares its Principle of Transactions with business partners (suppliers and subcontractors) and requests a commitment to compliance with laws, regulations and social norms, the promotion of fair and honest transactions, thorough information management and consideration of the environment, including domains related to respect for human rights.

Tokio Marine Group has established a system to ensure human rights due diligence (HRDD) based on the UN Guiding Principles on Business and Human Rights.

For Tokio Marine Group, HRDD means an ongoing, preventive and voluntary process to become a “Good Company” and to avoid or mitigate any negative impact of corporate activities on human rights. Based on this process, Tokio Marine Group has conducted a human rights risk assessment with the assistance of the specified NPO Caux Round Table Japan (CRT Japan), outside experts and specialists. Going forward, we plan to update the assessment on a periodic basis while considering the impacts of significant changes to our business operations. The assessments were conducted on Group companies in and outside Japan, and we identified potential human rights risks against our major rightsholders, which we need to tackle in order to prevent risks from occurring. For details, please refer to the human rights risk map.

Structure for the Management of HRDD

Tokio Marine Group’s Human Rights Subcommittee stays up to date on the progress of its HRDD initiatives.

Human Rights Risk Map — Identifying and Evaluating Human Rights Risks

Aim of Identifying Human Rights Risks

In putting our Corporate Philosophy into practice, Tokio Marine Holdings has established the “Tokio Marine Group Sustainability Charter” as our code of conduct to fulfill our social responsibility. This outlines our commitment to respecting the human rights of all people including customers, shareholders & investors, agents & business partners, employees, local communities & society and future generations. We have also established the “Tokio Marine Group Basic Policy on Human Rights,” and are committed to respecting human rights as an employer, through our main business operations and in our value chain.

Tokio Marine Holdings supports and respects the Universal Declaration of Human Rights, OECD Guidelines for Multinational Enterprises, ILO’s International Labour Standards, UN Guiding Principles on Business and Human Rights, ISO 26000 and SA8000, and is a signatory to the UN Global Compact. We understand internationally recognized principles and guidelines related to human rights and have comprehensively assessed and identified in particular the human rights issues of our business-related key stakeholders and rightsholders (negative impacts on human rights and other issues) for fulfilling our role in realizing a sustainable society through participating in and contributing to social responsibility-related initiatives and respecting human rights/promoting HRDD.

In mergers and acquisitions (M&A), Tokio Marine Group places importance on factors relating to the environment, society and governance (ESG). Specifically, the Group's guidelines for the implementation of M&A projects clearly state that the ESG policy of the target company is an important factor in evaluations. Details of the policy on the environment, society (including human rights) and governance and how the policy is implemented are important criteria in evaluations.

Based on the results of the comprehensive assessment of human rights risks, Tokio Marine Group organized a human rights workshop for employees engaged in practical operations. Featuring advice from outside experts, the workshop narrowed down human rights risks that should be prioritized from a practical perspective.

Human Rights Workshop’s Assessment of Risks and Impact

In November 2022, a human rights workshop was held with the participation of members from the corporate planning and administrative departments of Tokio Marine Holdings and Tokio Marine & Nichido. The workshop consisted of three parts: “global trends in business and human rights,” “workshop session 1: sharing and discussing current initiatives and issues” and “workshop session 2: value chain development.” Based on the opinions of outside specialists, we narrowed down risks in the areas of our business (direct operations, value chain, insurance underwriting, investment and financing). As a result, the following priority human rights risks were identified.

  • Respect for the human rights of non-Japanese technical trainees
  • Respect for human rights to be practiced with business partners in our value chain
  • Respect for the human rights of all insurance customers
  • Prevention of damage to corporate value through insurance underwriting, investment and financing
  • Prevention of the infringement of employees’ human rights
  • Prevention of the furtherance of prejudice and discrimination in advertisements and product development

Impact assessments, including interviews of rightsholders, were also conducted in some areas that have been specified by the human rights workshop as being high risk.

Progress of Initiatives for HRDD by Area of Business Domains

Presented below is the progress in human rights DD by business domain in consideration of the results of the human rights workshop.

Respect for Human Rights in Insurance Underwriting, Investment and Financing: Respect for the Rights of Indigenous People and Local Residents through Insurance Underwriting, Investment and Financing

We recognize the importance of responding to the identified human rights risks within insurance underwriting, investment and financing, and periodically review the sectors that should be prohibited or considered within the framework of the Policy to Address Environmental and Social Risks, while referencing international principles of action and guidelines. We also review them whenever necessary based on dialogues with experts, NGOs and other parties. In September 2022, we revised the Policy to Address Environmental and Social Risks and made the implementation of insurance underwriting, investment and financing in the oil sands sector oil and gas extraction projects in the Arctic Circle more strictly, as they are likely to negatively impact the rights of indigenous peoples and other local residents.

Respect for Human Rights in the Value Chain: Interviewing Rightsholders to Conduct Impact Assessments

Auto insurance is a major insurance product in the non-life insurance business. Car dealers and repair/maintenance operators are valuable stakeholders in Tokio Marine Group’s value chain. With the cooperation of CRT Japan, a human rights expert, we engaged in dialogue with technical trainees and other people engaged in car repair and maintenance and exchanged opinions to better respect human rights.

IT development companies and printing companies are important business partners for insurance companies building a system and sending out printed materials. As these industries are associated with a high risk of long working hours, we conducted a survey via interviews and questionnaires with people working in the IT system development and printing companies. While staying up to date on risk-related information about these companies, we call attention to issues and improve communication in-house based on the findings from the interviews. In this way, we are advancing initiatives for respecting human rights in the value chain.

Respect for Human Rights in In-House Operations: Preventing Infringement of Employees’ Human Rights through Self-Inspection

We seek to increase an understanding of how Tokio Marine Group companies in Japan and overseas respect human rights as an employer, as well as identify human rights and labor issues connected to the employees of the Group while preventing such issues from occurring, minimizing them when they occur and making improvements.

Accordingly, we encourage each Tokio Marine Group company to conduct self-assessments using the Tokio Marine Group Checklist on Human Rights Issues, which references international standards regarding respect for human rights and labor. We aim to link these assessments to strengthen initiatives to respect human rights as an employer throughout the Group.

Respect for Human Rights in Sustainable Investment and Financing

Giving consideration to environmental, social and governance (ESG) issues in investment and financing is becoming increasingly important from the perspective of improving long-term risk/return. Tokio Marine & Nichido places great importance on the social role and responsibilities that the insurance industry is expected to fulfill, and in June 2012 signed as a drafting member the Principles for Sustainable Insurance (PSI) advocated by the United Nations Environment Programme Finance Initiative (UNEP FI). In April 2011, Tokio Marine Asset Management signed the United Nations-supported Principles for Responsible Investment (PRI) initiative, accepting these principles as an asset management company. As an insurance firm that has taken ESG issues into account in its insurance underwriting, investment analysis and other actions, Tokio Marine & Nichido signed the PRI in August 2012. Through PRI and PSI related activities, Tokio Marine Group is strengthening its initiatives for respecting human rights in investment and financing.

Supporting Corporate ESG Management through Directors and Officers Liability Insurance

In its directors and officers liability insurance, Tokio Marine & Nichido provides a rider regarding compensation for, in the event of a human rights issue or an environmental issue, expenses for the investigation of the cause of the issue and expenses to prevent the recurrence incurred to the relevant company. This rider compensates companies for expenses incurred in the investigation of human rights issues and environmental issues, for the establishment and activities of a third-party committee and for the prevention of recurrence. The insurance will compensate for the expenses incurred in handling situations, such as when child labor is reported in a company’s supply chain, where the issue may lead to their business partners discontinuing transactions and the company may have to establish a third-party committee for an investigation. Or there may be a case when a company is criticized on the Internet by people who insist its TV commercials include sexist expressions, and the company conducts an in-house investigation to formulate a plan to prevent recurrence. Through insurance, Tokio Marine Group will continue to support companies' efforts to reinforce their ESG management.

Fact-Finding Survey of Initiatives to Respect Human Rights among Tokio Marine Group Companies in Japan and Overseas

We have conducted a written survey among Tokio Marine Group companies to gain basic information on topics such as the relevant laws and regulations in the countries where they are located, major outsourcing contractors and suppliers and current initiatives to respect human rights. The survey aimed to find facts about their initiatives regarding respect for human rights, and the results were used as a reference to formulate human rights-related measures for the entire Group.

The results revealed that each Group company is not engaged in transactions in industries that have particularly conspicuous human rights issues in terms of outsourcing and procurement. At the same time, few companies were found taking action in accordance with international rules on human rights established by the UN Guiding Principles on Business and Human Rights. This renewed our understanding of the need to involve all Group companies in the promotion of these initiatives.

Human Rights Violations in the Value Chain

In March 2024, we set up a hotline on human rights violations for external stakeholders of Tokio Marine Group. The purpose of this hotline is to establish a means to identify negative impacts on human rights and formulate a process to correct and remedy negative impacts in cases where human rights issues are of concern in the value chain (including the supply chain).

Whenever a negative impact on human rights comes to light, we will correct and remedy the matter by implementing appropriate procedures and engaging in sincere dialogue with the stakeholders involved. We prohibit any disadvantageous treatment or retaliation against relevant stakeholders and those who cooperate in investigations because of such reports or consultations. In addition, we strictly manage the confidentiality of reports and consultations by ensuring anonymity and sharing information only to the extent necessary for effective investigations and corrective measures.

Human Rights Related Grievances (“Global Stakeholder‘s Hotline”)

Tokio Marine Group has now established a “Global Stakeholders Hotline,” operated by TSUHO Support Center Co., Ltd., for external stakeholders to submit their grievances and concerns relating to human rights violations. This hotline has been established in line with the UN Guiding Principles on Business and Human Rights, to establish an effective grievance mechanism for individuals and communities who may be adversely impacted.

Though the Global Stakeholders Hotline allows for anonymous submissions, Tokio Marine Group promises to protect the privacy of individuals providing information through the Global Stakeholders Hotline and prohibits retribution or retaliation of any kind towards information providers. If you agree to the “Hotline’s Scope” set forth below and Tokio Marines Group’s Privacy Policy, please use the link below to navigate to the Global Stakeholders Hotline and enter the Company Code for Tokio Marine Group. Please note that by entering Tokio Marine Group’s Company Code and providing information through the Global Stakeholders Hotline, you are agreeing to the Hotline’s Scope and Tokio Marine Group’s Privacy Policy.

Please note that in order to provide information through the Global Stakeholders Hotline, you must also agree to TSUHO Support Center Co., Ltd.’s Terms of Use and Privacy Policy, which you can will find in the Global Stakeholders Hotline site linked below.

Global Stakeholders Hotline
Company Code
TokioMarine
Hotline’s Scope
The Global Stakeholders Hotline is only available for human rights related grievances:
  • (a)
    that the Tokio Marine Group has caused or contributed to, OR
  • (b)
    that can be directly linked to the Tokio Marine Group’s operations.

Please refer here(List of Group Companies | Tokio Marine Holdings, Inc. (tokiomarinehd.com)) for information regarding other Tokio Marine Group entities, if you wish to contact a Tokio Marine Group entity for other matters.

With respect to group employees, we use whistle blower and hotline systems to capture employees’ opinions in an effort to realize a better workplace environment.

Human Rights Violations Involving Tokio Marine Group’s Officers and Employees

Tokio Marine Group has established internal and external hotlines (whistle-blowing hotlines) where officers and employees of Group companies can report and consult on matters that may involve human rights concerns. The Group provides its officers and employees with multiple contact points and reporting channel options including internal and external hotlines, as well as a company audit hotline. We prohibit any disadvantageous treatment or retaliation against relevant officers, employees and those who cooperate in investigations because of such reports or consultations. In addition, we strictly manage the confidentiality of reports and consultations by ensuring anonymity and sharing information only to the extent necessary for effective investigations and corrective measures.

Tokio Marine Holdings monitors the handling of the reports and provides support for the appropriate installation and operation of the whistle-blowing system, thereby establishing a mechanism that allows officers and employees of each Group company to report concerns without fear of retaliation.

Tokio Marine & Nichido, Tokio Marine Kiln and other Tokio Marine Group companies published a modern slavery statement in compliance with the UK’s Modern Slavery Act 2015. Meanwhile, Tokio Marine & Nichido and other companies submitted a modern slavery statement to the Australian government in compliance with its Modern Slavery Act 2018.

Actions Taken by Tokio Marine & Nichido

Tokio Marine & Nichido has been publishing its statement every year since 2016 under the Modern Slavery Act 2015 of the United Kingdom. Starting from 2020, the company also annually reports (registers) its modern slavery statement to and with the Australian government under the country’s Modern Slavery Act 2018. Tokio Marine & Nichido will continue to report its modern slavery statement without fail, and together with its employees and business partners, will implement initiatives to prevent slave labor and human trafficking.

Modern Slavery

Modern Slavery refers to enslavement and servitude, all forms of forced labor and human trafficking, etc. The International Labour Organization (ILO) reported in a 2014 survey that there were approximately 21 million victims of forced labor worldwide (as of 2012) while annual illicit profits reached US$150 billion (estimate), which shows that even in present times slave labor and human trafficking are serious social problems.

Modern Slavery Act 2015 of the United Kingdom

In March 2015, the British government enacted the Modern Slavery Act 2015 to prevent forced labor and other present-day slave labor as well as human trafficking. The act went into effect in October 2015. Section 54 of the act requires commercial organizations that undertake business in the United Kingdom and that have annual sales of £36 million or more to publish a statement of steps taken each fiscal year to prevent slave labor and human trafficking in their own businesses and value chain (supply chain).

Modern Slavery Act 2018 of Australia

Following the United Kingdom, the Australian government enforced the Modern Slavery Act 2018 in January 2018. The act requires entities based or operating in Australia and have an annual consolidated revenue of more than ASD 100 million, to report (register) every fiscal year on how they assess risks of modern slavery in their operations and supply chains as well as actions to address these risks.

Tokio Marine Group believes that the practice of high-quality business management regarding respect for human rights requires the establishment of mutual trust through dialogue with stakeholders and leads it to the resolution of human rights issues.

Our top management takes charge of listening to the opinions of outside experts. Employees work to understand human rights issues by listening to customers’ opinions directed to the Group companies, communicating with shareholders, investors, employees, business partners and civil society organizations and exchanging opinions with outside experts. These insights are reflected in the Group’s initiatives, such as in HRDD. Through integrated annual reports, sustainability reports and individual interviews, we strive to promote an understanding of Tokio Marine Group’s views, values and initiatives.

We then implement a process for the continued improvement of the Group’s initiatives to respect human rights based on dialogues with stakeholders. In this way, we aim to improve the quality of our management regarding the respect of human rights.

Advisory Council

In August 2022, Tokio Marine Holdings held an Advisory Council meeting to discuss the human rights actions that global enterprises are expected to implement. The council consists of Group CEO Satoru Komiya, CFO Kenji Okada, CHRO Kenichi Kitazawa, CSUO Kiyoshi Wada, CDIO Mika Nabeshima and other members. The meeting was also joined by outside experts, including Mr. Hiroshi Ishida, the Executive Director of CRT Japan, Ms. Chikako Miyata, the Executive Vice President of ANA Holdings Inc. and Ms. Yuko Tsutsui, the Executive Officer of NYK Line. (Positions are those held at the time.)

The Advisory Council received advice on topics such as changes in the external environment surrounding human rights issues, best practices of progressive companies, ways to identify human rights issues, excellent mechanisms for handling complaints and practical application of HRDD. We utilized the advice of outside experts in the formulation and implementation of Tokio Marine Group’s HRDD action plans.

Participating in the Stakeholder Engagement Program

Tokio Marine Holdings participated in the Stakeholder Engagement Program (SHE) organized by the Japan CSR Consortium, for which CRT Japan acts as the administrative office. The program facilitates companies from various sectors, NPOs and NGOs to share the latest knowledge about human rights issues and discuss the contexts where human rights issues arise, the connection between business activities and human rights, important human rights issues and the importance of business activities that consider human rights. Through our participation in SHE, we deepen our understanding of human rights issues and strive to improve Tokio Marine Group’s initiatives to respect human rights.

Dialogues with Human Rights-Related NGOs and NPOs

Through dialogues with human rights-related NGOs and NPOs, Tokio Marine Group companies increase their understanding of various human rights issues, the connection between human rights issues and the respective companies’ business activities, as well as the negative impact of our business activities on human rights. The insights gained through these activities are utilized in their respective initiatives to respect human rights.