Basic Approach on Respect for Human Rights

Mitsubishi Corporation RtM Japan believes that respect for human rights is fundamental to conducting of businesses.
Our Code of Conduct stipulates : respect for human rights ; prohibition of discrimination ; prohibition of harassment; learning the culture, customs, and history of each country and region, and having a proper understanding and recognition of human rights issues; not supporting forced labor, child labor, or other inhumane treatment at our business partners or in our supply chain; and striking a balance between work and life. Mitsubishi Corporation RtM Supply Chain CSR Guidelines also sets forth: prohibition of forced labor, prohibition of child labor, prohibition of discrimination, and prohibition of inhumane treatment.
Moreover, after reorganizing and clarifying our approach on respect for human rights and to promote efforts to do so, we formulated the following Human Rights Policy in November 2024, which has been approved by the Board of Directors.

Human Rights Policy

1. Our commitment to respect human rights
   We believe that respect for human rights is fundamental to our business across the world. In an increasingly complex business environment, we face various human rights challenges. We believe that respecting and promoting human rights are directly linked to the sustainability of our business activities. Since our founding, we, as a subsidiary 100% owned by Mitsubishi Corporation, have been promoting fair and sound business activities based on our corporate philosophy, the Three Corporate Principles. The Three Corporate Principles guide us in striving to enrich society, both materially and spiritually, while contributing towards the preservation of the global environment. We believe respect for human rights relates deeply rooted in our philosophy. Based on these beliefs, we have established this Human Rights Policy (hereafter “this Policy”), which represents our commitment to respect human rights throughout our business activities.
2. Scope of application
   This Policy applies to all persons working for Mitsubishi Corporation RtM Japan Ltd.
3. Outreach to business partners
   We recognize the importance of respecting human rights not only within our own business activities but also throughout our value chain. We will work together with our business partners, including our suppliers, to respect human rights in line with this Policy.
4. Support and respect for international norms
   We support international norms on human rights, including the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights), the Declaration on the Fundamental Principles and Rights at Work of the International Labour Organization (ILO), the United Nations Guiding Principles on Business and Human Rights.
   We comply with the local laws and regulations of the countries and regions in which we operate. In cases where there is a conflict between internationally recognized human rights principles and the laws and regulations of the country or region in which we operate, we will seek ways to honor the international principles.
5. Human Rights Due Diligence
   We conduct human rights due diligence to identify, prevent and mitigate adverse impacts on human rights and engage with affected stakeholders where relevant. We pay special attention to vulnerable or marginalized individuals and strive to identify actual or potential adverse human rights impacts that our business activities have caused or contributed to.
6. Human rights issues related to business activities
   We recognize the following as major human rights issues related to our business activities and will work to address them.
   1. Prohibition of discrimination
      We prohibit any discrimination based on race, ethnicity, creed, religion, gender, gender identity, sexual orientation, nationality, age, origin, mental or physical disability, illness, or any other grounds.
   2. Prohibition of inhumane treatment
      We do not tolerate any forms of inhumane treatment including mental or physical abuse and harassment.
   3. Providing a safe and healthy working environment
      We provide our employees with a safe, and healthy working environment.
   4. Respect for freedom of association and right to collective bargaining
      We respect the right of employees to organize and to bargain collectively as a means to facilitate dialogue among employees and management regarding, but not limited to, working conditions and wage levels.
   5. Securing appropriate working hours and wages
      We properly manage our employees’ working hours. We compensate our employees at least the statutory minimum wage, and endeavor to pay at least the living wage.
   6. Prohibition of all forms of forced labor
      We employ all of our employees at their free will and prohibit the use of forced labor.
   7. Prohibition of all forms of child labor
      We do not employ children under the minimum working age and prohibit any forms of work that impairs their physical and mental development.
   8. Rights of indigenous peoples and local communities
      We respect the rights of indigenous and local people as defined by the laws and international arrangements of the countries and regions in which we operate. We will take measures that our business operation will not cause or contribute to cause threat to the rights of indigenous and local people.
   9. Environment
      Acknowledging the adverse impact of environmental destruction on human rights, we take measures to protect the global environment within our business activities. This includes addressing climate change and preserving and restoring natural capital, notably biodiversity.
   10. Diversity, Equity & Inclusion
       We aim to foster an inclusive society where individuals with diverse values and personalities are respected and have equal opportunities to participate and contribute.
7. Remedy
   When we identify that our business activities have caused or contributed to adverse human rights impacts, we will remediate such impacts through legitimate processes.
   In case if adverse impacts were directly linked to our operations, products, or services by a business relationship, we will endeavor to correct and remedy the situation by using our leverage.
8. Grievance mechanism
   We recognize that establishing a grievance mechanism, which consists of a series of processes to address internal and external stakeholder grievances, is crucial to identifying adverse human rights impacts concerning our operations and value chain. We will establish and operate grievance mechanisms to enable individuals and groups to show concerns about adverse human rights impacts caused by our business activities and seek remedies.
9. Education and capacity building
   We will provide the necessary training and capacity building to ensure that our officers, employees, suppliers, and other business partners understand the importance of respecting human rights and put it into practice.
10. Information disclosure
    We ensure transparency by regularly and appropriately disclosing information on our human rights efforts and their progress.
11. Stakeholder engagement
    We engage with relevant stakeholders through sincere and constructive dialogue to understand, improve and address human rights issues.
12. Governance and management system
    Our human rights efforts are overseen by the Officer Responsible for Sustainability and CSR. Following deliberations by the Management Committee, these efforts and practices are put forward or reported to the Board of Directors.

Established on November 8, 2024

Human Rights Due Diligence

We are a general trading company operating as a 100% subsidiary of Mitsubishi Corporation, and our main business is trading in various types of metal resources. Our activities related to human rights due diligence are positioned as part of the human rights and environmental due diligence for trading operations of the Mitsubishi Corporation Group.

We also recognize respect for human rights through supply chain management as one of our key issues for sustainability (materiality).

Procurement activities that take human rights into account are an essential step for realizing responsible corporate conduct by our company, and we present our stance toward achieving that in our Sustainable Procurement Policy.

We present specific requirements to our suppliers, including respect for human rights, in our Sustainable Procurement Guidelines, confirm the compliance situation through our Sustainable Procurement Survey, and conduct on-site investigations of business partners as necessary.

Grievance Mechanism