Supplier assessment (environmental and social)

Material Issue　Supplier assessment (environmental and social)

  • Targets/Vision
  • ●Supplier with negative environmental impact *1 : None
  • ●Supplier with social impact *2 : None
  • *1Determined based on whether there was any case resulting in a fine or lawsuit for violation of pollution/environment laws and regulations
  • *2Determined based on whether there was any case resulting in a fine or lawsuit for violation of labor standard-related laws and regulations

Management and Promotion Method of Supplier assessment (environmental and social)

[Responsible Departments]
  • Procurement Department of Manufacturing Planning Center
[Policy/Point of view]

The Bando Group considers its suppliers as partners and believes that it is important to build a relationship that allows each other to trust and develop to ensure stable procurement in the future.
The Group sets forth fair procurement transactions in the “Group Code of Conduct” stipulating rules to be complied with by all Bando Group officers and employees and also established the “procurement policy” and “CSR Procurement Guidelines” to promote, together with our business partners, initiatives in the fields of product safety and quality assurance, human rights and labor, compliance, and environmental preservation.
The Group developed the “Group human rights policy” and conducts activities for respecting human rights of our stakeholders.

[Targets/Vision]

Supplier with negative environmental impact: None
(Determined based on whether there was any case resulting in a fine or lawsuit for violation of pollution/environment laws and regulations)
Supplier with social impact: None
(Determined based on whether there was any case resulting in a fine or lawsuit for violation of labor standard-related laws and regulations)

[Measures]
  • Explain our procurement policies
  • Evaluate the environmental impact when initiating transactions
  • Conduct a CSR survey to confirm the environmental/social initiatives
  • Visit suppliers who did not meet our requirements as a result of the CSR survey to perform an on-site assessment and exchange opinions
  • Follow up on the improvements

Policy/Point of view

The Group established the “Bando Group Procurement Policy” and the “CSR Procurement Guidelines” under “Fair and equitable procurement transactions” set forth in the “Bando Group Code of Conduct” and disseminates them to our suppliers along with the “Bando Group Human Rights Policy.” Based on them, we are, together with our suppliers, promoting initiatives in the fields of product safety and quality assurance, human rights and labor, compliance and environmental preservation. In fiscal 2024, we revised the “CSR Procurement Guidelines” and added initiatives related to “Provision of appropriate information on products and services,” “Information disclosure to stakeholders” and “Preservation of biodiversitiy.”

Bando Group Procurement Policy

1. Fair trade
The Bando Group shall maintain appropriate business relationships with all suppliers to ensure fair and just trade.
We shall comply with laws and social norms in Japan and overseas for our procurement activities.
2. Equality of opportunity
The Bando Group shall select suppliers based on free competition regardless of the size or nationality of the companies.
We shall commence transactions after conducting sufficient assessment of suppliers’ product quality, price, delivery time, technological capabilities, stable supply capabilities, and management reliability and completing appropriate procedures.
3. Mutual development
The Bando Group considers all of its suppliers as partners and strives to build relationships that allow each other to trust and develop.
4. Social responsibility
The Bando Group, together with its suppliers, promotes CSR initiatives in the fields of product safety and quality assurance, human rights and labor practices, compliance, and environmental preservation.

(Amended in December 2018)

CSR Procurement Guidelines

The Bando Group asks its suppliers to follow the articles described below:

1. CSR promotion system
Set a CSR policy, build a system to promote it and implement CSR activities based on the plan on a continuous basis.
  • ■ Establishment of CSR promotion system
  • ■ Understanding of applicable laws and regulations
  • ■ Formulation of a BCP
2. Product safety and quality assurance
Build and operate the management system that considers product quality.
Ensure safety of products that you supply to us.
  • ■ Establishment of a quality management system
  • ■ Compliance with safety standards in each country and region
  • ■ Appropriate management of chemical substances contained in products
  • ■ Provision of appropriate information on products and services
3. Human rights and labor practices
Establish a workplace that respects human rights and eliminates discrimination in line with the global trend of respect for human rights.
Create safe and comfortable working environment from the viewpoint of occupational health and safety.
  • ■ Compliance with health and safety standards in each country and region
  • ■ Respect for basic human rights and prohibition of discrimination
  • ■ Prohibition of child labor
  • ■ Prohibition of forced labor
  • ■ Compliance with laws and regulations on wages and working hours in each country and region
  • ■ Respect for freedom of association and collective bargaining rights
4. Compliance
Comply with laws and regulations and social norms and conduct corporate activities based on corporate ethics.
  • ■ Compliance
  • ■ Elimination of antisocial forces
  • ■ Corruption prevention
  • ■ Respect for intellectual property rights
  • ■ Avoidance of use of Conflict Minerals
  • ■ Compliance with laws and regulations on export control in each country and region
  • ■ Management and protection of confidential information
  • ■ Information security
  • ■ Information disclosure to stakeholders
  • ■ Establishment of an internal reporting system and protection of the internal reporters
5. Environmental preservation
Establish and implement the environmentally-friendly management system.
  • ■ Promotion of environmental preservation activities
  • ■ Reduction of greenhouse gas emissions
  • ■ Preservation of environment such as air, water, and soil
  • ■ Resource saving and waste reduction
  • ■ Preservation of biodiversity
6. Consideration to local communities
We recommend that you conduct voluntary activities to contribute to the development of global society and local communities.
  • ■ Respect for traditions and customs in countries and regions where you operate
7. Expansion to suppliers
Work with your suppliers to disseminate and spread these CSR initiatives.
  • ■ Thorough dissemination to supply chain

(Amended in August 2024)

Environmental and social assessment of suppliers

We evaluate the environmental and social impact of new suppliers and conduct a CSR survey to existing suppliers, with an expanded scope to include those of domestic and overseas affiliates, to confirm their social initiatives on human rights, occupational safety, and compliance as well as environmental initiatives.
In fiscal 2024, we conducted a CSR survey of suppliers as well as interviews with raw material suppliers of identified as having potential human rights risks to confirm that there were no suppliers with negative environmental or social impact. In fiscal 2025, we will conduct CSR follow-up meetings with four companies based on the survey results in fiscal 2024. In addition, we will provide CSR procurement education to expatriates assigned to overseas affiliates to promote understanding of our initiatives.

Key questions in the CSR survey

[Product safety and quality assurance]
Quality management, securing of product safety, management of chemical substances

[Human Rights/Labor]
Occupational health and safety management, prohibition of forced or compulsory labor/child labor, non-use of conflict minerals, decent working hours and wages

[Compliance]
Cutoff of any relationship with anti-social forces, framework to prevent corruption

[Environmental Conservation]
Environmental management, monitoring of greenhouse gas emissions, compliance with water quality standard, reduction of wastes

  • Targets/Vision

  • ●Supplier* (raw material) identified as having a risk of child/forced labor : None

    *Investigated raw materials imported by the Company (natural rubber and textile products) by tracing back the supply chain

  • ●Maintain “no child labor”

Management and Promotion Method of Human rights
(child labor/forced or compulsory labor)

[Responsible Departments]
  • Personnel Department
  • Procurement Department of Manufacturing Planning Center
[Policy/Point of view]

The Bando Group developed the “Group human rights policy” and conducts activities for respecting human rights of our stakeholders.
The Group sets forth the compliance with laws and regulations and corporate ethics, and respect of human rights, personality and individuality in the “Group Code of Conduct” stipulating rules to be complied with by all Bando Group officers and employees and also established the “procurement policy” and the “CSR Procurement Guidelines” to promote, together with our busines partners, CSR initiatives in the fields of product safety and quality assurance, human rights and labor, compliance, and environmental preservation.
In addition, for group companies, we established and implement the “Employment regulations” to ensure no unfair labor practice.

[Targets/Vision]

(Group) Maintain “no child, forced or compulsory labor”
Supplier (raw material) identified as having a risk of child/forced labor: None

[Measures] (Group)
  • Confirm applicants’ age with their ID at the time of recruitment. Not to employ those who have not reached the legal working age of the respective country/region
  • Include in the “employment regulations” a rule not to keep the original of the employees’ ID at the time of recruitment and implement it
  • Provide “human rights education” at the time of recruitment/employment
  • Conduct review during the Bando Group Corporate Ethics Month in every October. Hold seminars on human rights in each business facility
[Measures] (Suppliers)
  • Explain our procurement policies
  • Investigate suppliers
  • Visit suppliers who did not meet our requirements to perform an on-site assessment and exchange opinions
  • Follow up on the improvements

Formulated Bando Group Human Rights Policy

In accordance with international norms such as the United Nations Guiding Principles on Business and Human Rights, the Company developed the Human Rights Policy in April 2023. We strive to fulfill our responsibilities to respect human rights in all our business activities and promote initiatives to respect human rights of all stakeholders including employees and business partners.

Group human rights policy

With the spirit of “harmony and in good faith” as our management philosophy, the Bando Group aims to realize a sustainable society through its business. Recognizing that respect for human rights is a premise of sustainable corporate activities and that our business activities may have direct or indirect impacts on human rights, we will strive to fulfill our responsibilities to respect human rights.

1. Basic Stance
In accordance with international norms such as the United Nations‘ Universal Declaration of Human Rights, the Guiding Principles on Business and Human Rights, and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Bando Group will strive to fulfill its responsibilities to respect human rights and promote efforts to respect human rights of all stakeholders, including employees and business partners, in all of its business activities.
The Bando Group complies with international norms and local laws and regulations on respect for human rights in countries and regions where it conducts its business activities. If local laws and regulations are in conflict with international norms, we will pursue ways to give maximum respect to the international norms.
2. Scope of Application of the Human Rights Policy
This Policy applies to all officers and employees of the Bando Group. We also expect all of our business partners to understand and practice this Policy.
3. Positioning of the Human Rights Policy
This Policy clarifies our efforts to respect human rights to fulfill our responsibilities to all of our stakeholders based on our corporate philosophy. We position this Policy as a high-level policy on all documents and norms related to efforts to respect human rights in the Bando Group’s business activities.
4. Human Rights Issues Related to Our Business Activities
The Bando Group puts emphasis on the following human rights issues related to its business activities and addresses each of them.
  • Forced labor and child labor
    The Bando Group prohibits labor by anyone under the minimum working age stipulated by laws and regulations in countries and regions it operates as well as forced labor.
  • Discrimination
    The Bando Group prohibits discrimination of any kind, including on the grounds of gender, age, nationality, ethnic origin, race, birthplace, religion, creed, social status, disability or sexual orientation. We promote equal opportunities and fairness in recruitment, assignment, and treatment.
  • Harassment
    The Bando Group prohibits harassment of any kind that could harm personal dignity.
  • Fair wages and appropriate working hours
    The Bando Group secures fair wages and manages appropriate working hours, leave, and non-working days in compliance with labor-related laws and regulations in countries and regions it operates.
  • Freedom of association and right to collective bargaining
    The Bando Group respects freedom of association and right to collective bargaining in compliance with labor-related laws and regulations in countries and regions it operates. We also strive to secure favorable working environment through employee engagement.
  • Occupational health and safety
    In compliance with laws and regulations, internal rules and policies regarding health and safety of workplace, the Bando Group maintains and improves healthy and safe environment, and maintains and enhances mental and physical health, with an aim to create comfortable working environment.
5. Prevention of Human Rights Violations
The Bando Group provides appropriate education regarding this Policy and strives to identify and reduce negative impacts that could be caused by its business activities in line with human rights due diligence framework.
6. Responses to Violations
The Bando Group appropriately deals with any negative impacts on human rights caused by its business activities to relieve and correct them. In case negative impacts on human rights are caused by our business partners, we will encourage them to take appropriate responses through engagement, etc.

This Human Rights Policy was approved by the Board of Directors of Bando Chemical Industries, Ltd. on March 10, 2023.

Human rights management system

The Group promotes initiatives to respect human rights of all stakeholders in line with the “Bando Group Human Rights Policy.”Initiatives to address human rights issues identified as priorities are promoted through collaboration among relevant departments and are also deliberated by the Sustainability Committee and reported to the Board of Directors. In addition, the Group has set up contact points for reporting and consultation separately for reporting by business partners and internal reporting.
If our business activities cause any adverse impact on human rights, we take appropriate measures to provide remedy and take corrective actions. In cases where negative impacts on human rights are found among our business partners, we encourage them to take appropriate action through dialogue and other means.

Implementation of human rights due diligence

The Group has established a human rights due diligence system based on the procedures in line with the United Nations’ “Guiding Principles on Business and Human Rights” and “OECD Due Diligence Guidance for Responsible Business Conduct” and continuously implement it to prevent, remedy and mitigate adverse impacts on human rights.

1. Assess impact on human rights

In 2024, the Group assessed actual and potential adverse impacts of its value chain on human rights through interviews and surveys with both the Group and suppliers and identified human rights issues.
For the identified human rights issues, we assessed their human rights risks by calculating the severity and likelihood of each issue based on themes presented by international organizations and mapping them. We identified human rights issues with the support and advice of external experts.

Identified human rights issues of the Group and those prioritized for action

Human rights issues prioritized for action (marked with ★) were determined based on our ability to exert influence.

2. Implement preventive, mitigating, and remedial measures and assess their effectiveness

We recognize that the human rights issues prioritized for action are also our material issues, and we continue to address them in collaboration with stakeholders based on the nature of each issue. To address human rights of workers in the supply chain, we visit suppliers based on the results of the supplier surveys and carry out interviews to understand actual working conditions.
Regarding occupational safety and health incidents, we share information with the labor unions and hold discussions to determine appropriate responses. Through these initiatives, we strive to prevent and mitigate adverse impacts, and implement remedial measures when necessary.

● Effectiveness assessment

In fiscal 2022, four suppliers employing technical intern trainees were identified as having contracts that stipulated penalty clauses. The fiscal 2024 survey confirmed that these practices have since been rectified.
Within the company, the number of harassment-related consultations has decreased due to the effect of our internal harassment prevention training. For each reported case, interviews and investigations were conducted. Where harassment was confirmed, disciplinary actions were taken in accordance with the company regulations. In cases where disciplinary action was not warranted, corrective and preventive measures, including guidance for improvement, were implemented.

● Remediation mechanism <reporting/consultation desk>

For reporting and consultation, we have a contact point for the supplier reporting system for external parties and a contact point for internal reporting (external contact point independent from the company and the Bando Group) and harassment-related consultation. Reports can be made anonymously, and all internal and external reporting channels are governed by internal regulations that stipulate the “maintenance of confidentiality and strict prohibition of retaliatory actions” in order to thoroughly protect whistleblowers from any disadvantageous treatment.

● Response to suppliers

The Group conducts a supplier assessment on matters including human rights to confirm whether there are any cases of child or forced labor. Our efforts to maintain zero child labor within the Group include confirming applicants' age with their ID card at the time of recruitment, not employing or hiring those who have not reached the legal working age of the respective country/region, providing “human rights education” at the time of recruitment/employment, conducting review during the Bando Group Corporate Ethics Month in October every year, and holding seminars related to human rights in each office. In fiscal 2024, there was no child or forced labor.

● Response to employees

To eradicate employee harassment, we conduct periodic fact-finding surveys (questionnaires) and provide harassment training for management and e-learning education for all employees. In addition, we hung sexual harassment eradication posters and stickers with QR codes containing information on where to report and set up “contact points for harassment consultation” to make it easier for employees to seek consultation, with an aim to create a safe and positive work environment.

● Response to conflict minerals

It is alleged that the mining and trading of certain minerals from the Democratic Republic of the Congo and surrounding countries serve as a source of funding for armed groups responsible for human rights violations and conflict in the regions. Amid such a situation, the U.S. Dodd-Frank Act, which was enacted in July 2010, requires U.S. listed companies to report their use of conflict minerals to the SEC. Also in the EU, the Conflict Minerals Regulation came into effect in January 2021, requiring importers of ores and unprocessed metals to identify and report annually on risks of adverse impacts on supply chains in conflict-affected and high-risk areas.

In response to these circumstances, the Group actively cooperates with customer surveys on the use of conflict minerals in our products and investigates whether 3TG (tin, tantalum, tungsten, and gold), cobalt, and mica are contained in the subject parts purchased from suppliers. As a result, we have not identified any use of conflict minerals related to human rights violations or other issues in any of our products that have been investigated so far.