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Respect for Human Rights Promoting Human Rights Due Diligence

Human Rights Due Diligence

The Lion Group, in order to take responsibility for identifying, preventing, mitigating and addressing negative human rights impacts caused or contributed to by its business activities, established the Human Rights Review Committee, a cross-departmental organization that takes the lead in promoting human rights due diligence*through the following process based on the UN Guiding Principles on Business and Human Rights while also engaging in dialogue with stakeholders involved with the Group’s business, including employees and temporary employees, business partners, suppliers, communities, consumers, external experts and organizations related to human rights.

Recognizing that human rights risks may change as the Lion Group’s business activities, social conditions and human rights conditions evolve, we will seek better ways to enhance the effectiveness of our efforts, such as by regularly implementing each step of the Human Rights Due Diligence Process, including the human rights impact assessment.

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Overview of Human Rights Due Diligence

* Corporate measures to avoid causing human rights violations and provide remediation for the victims of such violations

Human Rights Impact Assessment

Overview of Anticipated Human Rights Risks in the Group’s Business Activities

The Group’s main business encompasses the development, manufacture and sale of household products. Among these, we notably handle many cleaning products, including laundry detergents. The surfactants that comprise the washing ingredients of such products are derived from such raw materials as palm oil, palm kernel oil and their derivatives. The main production areas for palm oil and palm kernel oil are Malaysia and Indonesia, and we recognize that these countries and areas as well as the commodities themselves bear relatively high human rights risks and pose problems regarding sustainable procurement, including human rights based on data provided by international human rights organizations and Sedex. Specifically, human rights risks such as overwork, the use of child labor and smoke damage from illegal slash-and-burn forest clearing are assumed for stakeholders who may be placed in vulnerable positions such as palm plantation workers.

Corrugated boxes used to package and transport household products use a large amount of paper and pulp as packaging materials, which may pose environmental human rights risks due to inadequate forest management and other factors.

In addition to palm oil and palm kernel oil and paper and pulp suppliers, we secure the cooperation of a wide array of raw material manufacturers and production contractors in procuring raw materials and other aspects of our manufacturing processes. If human rights risks in procurement become apparent due to transactions with suppliers that are not fully committed to sustainable procurement, including human rights, this could lead to business risks related to the supply of products and impact the reputation of the Group.

Furthermore, with regard to planning, manufacturing and sales of household products, we have multiple points of contact in and outside Japan with stakeholders, starting with Lion employees, temporary employees and business partners throughout the value chain, including those working in planning, procurement, research, production, sales and administration. Each point of contact has the potential to cause or encourage human rights risks such as discrimination and harassment on the basis of race or gender, overwork and excessive working hours. When expanding contacts with consumers as a result of changes in business structure, we must be more vigilant regarding privacy rights, including the management of personal information*.

* Refers to the International Trade Union Confederation (ITUC) Global Rights Index, etc.

Extrapolation of Human Rights Issues Anticipated in the Lion Group Business Activities

In order to further clarify the potential and actual human rights risks that may occur in the value chain in the countries and areas where the Group operates, we have identified as relevant to the Group’s business activities the following human rights issues* from the International Bill of Human Rights, the Ten Principles of the UN Global Compact, the ILO Declaration on Fundamental Principles and Rights at Work, the Children’s Rights and Business Principles and other international standards related to human rights.

In extrapolating human rights issues, we have referred to the social context surrounding business operations and human rights, the United Nations Environment Programme Finance Initiative (UNEP), guidelines on human rights formulated by the Japan Business Federation and advice from external experts.

* Extrapolated Human Rights Issues
Forced and coerced labor; freedom of movement and residence; child labor; right to an education; rights of young workers; freedom to form and join trade unions; equal pay for equal work; discrimination in hiring; discrimination in the terms and conditions of employment; discrimination in opportunities and evaluations; protection of motherhood and childhood; harassment; freedom of thought and religion; overwork and excessive working hours; right to rest and leisure; just compensation and living wages; freedom of employment and unemployment insurance; right to safe and healthy working conditions; right to a decent standard of living and health; right to social security; right to privacy; impacts on the lives of local residents; access to water; environmental management; consumer safety and health

The Lion Group’s Human Rights Impact Assessment and Identification of Priorities

The Lion Group has identified certain human rights issues as potential challenges to its business activities through an assessment of potential and actual impacts on our stakeholders: our employees and temporary employees; business partners, including contractors; suppliers; communities, including indigenous peoples; and consumers.

Based on the United Nations Guiding Principles Framework and other guidelines on human rights, we assess the scale of human rights violations, the scope of those violations, the likelihood of occurrence and the possibility of resolution. This task was undertaken mainly by persons responsible for the relevant departments as well as an investigative committee on human rights, who after making a comprehensive judgment based on such factors as changes in business and society and the opinions of stakeholders, including external experts, created a risk map based on the results of the Human Rights Issue Check Sheet, which identifies outstanding human rights issues as priorities for the Company.

Implementation of Prevention, Mitigation and Corrective Measures

For priority issues (salient human rights issues) identified by the human rights impact assessment, we implement the following actions to prevent, mitigate and remedy negative human rights impacts.

Priority Issues for the Company (Salient human rights issues) Measures and progress toward preventing, mitigating and correcting negative impacts
Suppliers using forced labor or child labor, violating the rights of young workers, imposing overwork and excessive working hours, impinging the right to enjoy safe and healthy working conditions, freedom of residence and relocation, denying the right to education, freedom of work and employment security
  • We are promoting the procurement of third-party certified raw materials, such as RSPO and FSC certified products like palm oil, palm kernel oil, paper and pulp, in cases where human rights risks are of particular concern.
    2024 results
    Certified palm oil and palm kernel oil derivatives: 46% of the Group (based on key raw materials)
    Certified paper and pulp: 46% of the Group (item ratio)
  • We are using self-checks based on the Lion Group Supplier CSR Guidelines and Sedex and implementing risk assessments at suppliers.
    2024 results
    Supplier risk assessment implementation rate: 92% of the Group
  • We add the Lion Human Rights Policy, the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work to the memorandum of the Lion Group Supplier CSR Guidelines and are requiring that the human rights policy be endorsed and followed by suppliers as well.
    2024 results
    Memorandum of Understanding on human rights signed with 42 of the 90 major domestic companies
Supplier’s local community access to clean water resources, impact on local livelihoods and environmental management
  • To prevent, mitigate and correct such negative impacts as lack of access to water resources in local residential communities near supplier bases, self-checks based on the Lion Group CSR Guidelines are including questions regarding environmental management to ascertain the status of specific initiatives undertaken for the community.
    2024 results
    Monitoring has been conducted using self-checks based on the Lion Group CSR Guidelines
Overwork, excessive working hours and internal employee harassment among our business partners
  • To prevent, mitigate and correct the causes, contributing factors and the negative effects themselves of overwork and excessive working hours at our business partners, we are working to disseminate and establish the Lion Group Charter of Corporate Behavior and the Lion Human Rights Policy through e-learning and training programs for our employees. In addition, we are quantitatively assessing our employees’ understanding of these issues and evaluate their behavior at work through the Compliance Awareness Survey.
    2024 results
    Human rights training has been conducted at the Company and seven of our domestic affiliates and seven of our overseas affiliates.
Consumers’ right to privacy
  • To prevent and reduce the risk of personal information leaks and thereby protect consumers’ right to privacy, we have established policies and regulations such as the Personal Information Management Regulations, the Basic Policy of Our Information Management, the Information Management Regulations and the Information Security Regulations in accordance with the Act on the Protection of Personal Information. We also implement annual e-learning programs on information security and information management systems as part of Company employee education, and continually strengthen information security measures, including personal information protection at overseas affiliated companies, in accordance with laws and regulations.
    2024 results
    Training for domestic employees on compliance with personal information management regulations has been conducted through e-learning
    Certification for information management systems is maintained for services entailing the handling of medical information

Access to Relief (Establishment of Grievance Mechanisms)

The Group has established the AL (All Lion) Heart Hotline, an internal and external whistle-blowing system, as a grievance mechanism to manage complaints about transgressions of business ethics, particularly those involving human rights.

Under this system, whistleblowers can be stakeholders from outside the Group, like business partners. The privacy of whistleblowers and reported parties informants is safeguarded and secrecy is assured for any investigations. Aside from anonymous reports, etc., all instances are also relayed to all whistleblowers.

For details of the system and the details of consultation and reporting, please refer to the following link on the Company’s website.

Internal and External Whistle-Blowing System (AL Heart Hotline)

Monitoring

Each preventive, mitigating and corrective measure is assigned a qualitative or quantitative indicator and the investigative committee on human rights regularly reports the monitoring results for each measure to the S Subcommittee (Social Environment) twice a year.

Communication

External Disclosure

The status of human rights initiatives, etc. is published on the Company’s website as necessary.

Education, Dialogue

Lion implements annual e-learning training for all domestic employees (including part-time employees) to ensure that the Lion Group Charter of Corporate Behavior and the Lion Human Rights Policy are widely understood and firmly established.

In addition, every year we conduct a Compliance Awareness Survey for all domestic employees (including part-time employees) to quantitatively and qualitatively assess their awareness of compliance, including with regard to human rights and workplace behavior, while providing feedback to each department on the results to raise employee awareness and create a better environment.

In promoting human rights due diligence, we held study sessions and exchanged opinions on business and human rights with directors, Audit & Supervisory Board members, executive officers, managers of divisions with human rights jurisdiction and external experts to deepen understanding of the issues.

Participation in External Initiatives on Human Rights

The Group also participates in such external initiatives as workshops held by the Human Rights Due Diligence (HRDD) Subcommittee of the Global Compact Network Japan (GCNJ) and in working groups of the Supply Chain Subcommittee to promote understanding and awareness of social conditions surrounding human rights. The Japan Cosmetic Industry Association (JCIA), to which we belong, has formulated Sustainability Guidelines as well as the Guide to Human Rights and Labor Risk Responses in the Value Chain. In 2024, a social issues subcommittee that includes Lion employees, conducted a survey on gender equality for JCIA members.
Going forward, we will continue to actively work toward the realization of the sustainable development of society, including human rights.

Initiatives at Overseas Group Companies

Risk Assessment in the Lion Group

We regularly conduct hearings with each of our overseas Group company on issues regarding human rights that are assumed to be incorporated into their business activities. During those hearings the Company uses the Sustainability Activities Conformation Sheet, which with the help of external experts, identifies the issues that need to be considered in the countries and areas where we operate with respect to key sustainability issues as a means of ascertaining the status of prevention, mitigation and corrective measures and responses, as well as monitoring the progress of such measures and responses.

Risk Assessment of Suppliers

For suppliers that conduct business with our overseas affiliates, we use self-checks based on the Lion Group Supplier CSR Guidelines and Sedex’s data analysis to assess the impact of suppliers on matters related to the Group’s Procurement Policy, including human rights and labor.

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