Business and Human Rights

Overall Picture of Business and Human Rights Initiatives

In order to fulfill our responsibility to respect human rights, the Group recognizes that it is important to make efforts in business and human rights based on international standards in accordance with the International Guiding Principles. Specifically, we are working on: 1. Establishment and disclosure of human rights policy; 2. Human rights due diligence (“Human rights DD”); 3. Remediation mechanisms (in cases where our company causes, contributes, or directly linked to adverse human rights impacts).
We will engage in dialogue with stakeholders to understand their expectations and drive our initiatives forward based on those.

Created with reference to the Ministry of Economy Japan Trade and industry's "Reference Material on Practical Approaches for Business Enterprises to Respect Human Rights in Responsible Supply Chains"

Structure

In order to promote appropriate measures for sustainability, the Sompo Group has established a promotion system led by the Group Sustainable Management Promotion Committee to strengthen our efforts in business and human rights. A Business and Human Rights Working Group has been established under the Committee, with the Sustainable Management Office serving as the secretariat, and a working group consisting of members from 26 Group companies has been organized to create an effective system.
For the current fiscal year, the secretariat is engaged in individual dialogues with 25 domestic Group companies to assist them in identifying human rights risks and selecting priority issues tailored to each company’s specific business characteristics. In addition, we are also checking the status of each company’s promotion system for business and human rights, as well as its corrective measures and remedial response system in the event of adverse human rights impacts.
As the next step, the status of initiatives across Group companies will be shared among Working Group members to continuously enhance awareness and knowledge of business and human rights. Concurrently, the secretariat will drive the continuous promotion of business and human rights initiatives by monitoring each company’s progress on its priority issues.

1. Establishment and Disclosure of Human Rights Policy

The Sompo Group recognizes that all business activities in the global marketplace have the potential to adversely impact human rights. In recognition of this, we have supported the United Nations Global Compact since 2006 and respect international norms on human rights, including the ILO Declaration on Fundamental Principles and Rights at Work. In addition to respect for these international norms, the Group Policy for Human Rights, which is independently established by the Group and shared by all executives and employees, is also an important guideline for us and is valued in all our business activities.
The Group does not tolerate any form of forced labor, trafficking in persons, child labor, discrimination or harassment related to employment and occupation (sexual harassment, power harassment, customer harassment, etc.), or any conduct that undermines human dignity. We also respect basic human rights such as freedom of association and the right to collective bargaining, a safe and healthy working environment, gender equality, and women’s rights, while complying with applicable laws and regulations.
In order to establish sound labor practices, we also promote the payment of an appropriate living wage, equal remuneration for men and women, avoidance or reduction of overtime and excessive working hours, the establishment of clear maximum working hours, and the use of annual paid leave in accordance with Health and Productivity Management Strategy. When dismissing workers, we will comply with the Labor Standards Act^*1, Labor Contract Act^*2, and other relevant laws and regulations to ensure employment stability and livelihood security, and will respond appropriately. We aim to promote these ideas and policies in collaboration with all directors and employees, as well as with our partners such as business partners, collaborators, suppliers and contractors.
For further details on each labor practice, please refer to the following:

• Group Policy for Human Rights
• Wellness Management
• ESG Data

1. Rules regarding dismissal and termination of employment (in Japanese):
   https://www.mhlw.go.jp/stf/houdou/2r98520000014uzs-att/2r9852000001dhat.pdf
2. Laws and regulations regarding labor contracts (conclusion of contracts, changes in working conditions, dismissal, etc.)—rules (in Japanese):
   https://www.mhlw.go.jp/stf/seisakunitsuite/bunya/koyou_roudou/roudoukijun/keiyaku/index.html

2. Human Rights Due Diligence

In accordance with the UN Guiding Principles on Business and Human Rights, the Group has established a human rights due diligence (human rights DD) framework for identifying, preventing, mitigating, implementing appropriate measures, and disclosing information on risks that adversely impact human rights with the following four steps.

Human rights DD processes

• Step1 Identification and assessment of adverse human rights impacts (Risk assessment)
• Step2 Identification of priority issues, prevention or mitigation of adverse human rights risks
• Step3 Tracking effectiveness of the efforts (Monitoring)
• Step4 Disclosure of information

Step１ Identification and assessment of adverse human rights impacts (Risk assessment)

Our Group conducts an annual human rights risk assessment, leveraging its ERM (Enterprise Risk Management) framework. This assessment identifies potential adverse impacts of our Group's business activities on human rights and identification of priority issues, prevention or mitigation of adverse human rights risks, all while referencing international codes of conduct and guidelines. In identifying these risks, we also consider SOMPO's human rights risks and extend our investigations to cover our supply chain, including agencies and investees. For the fiscal year 2024, human rights risk assessments were carried out across 26 Group companies within the scope of our ERM.

Human Rights Assessment-Details

• The development of mitigation measures is mandatory upon the identification of human rights risks, ensuring a 100% coverage of identified risks with mitigation plans.

Sompo’s Human rights risks

The Group recognizes that the scope and breadth of human rights evolve with the times. Therefore, we regularly engage in dialogues with experts to identify potential human rights risks (new human rights risks that should be extracted) that would be difficult to identify solely within our own group. In assessing human rights risks for fiscal 2025, we have identified risks related to the adverse impacts of climate change on human rights.

Human rights risk map for FY2025

Based on the risk assessment conducted for the entire the Group and reflecting the opinions of external experts on human rights, we create a human rights risk map once a year, using Severity^*1 and Likelihood of Occurrence^*2 as the evaluation axes.
We also consider the relationship between our company and human rights risks (individual or collective) and the distance between our company and human rights risks (cause, contribute, or directly linked), and organize adverse impacts from multiple perspectives.

1. Evaluated based on scale (gravity of the adverse human rights impact), scope (scope of the adverse impact), and irremediability (difficulty of restoring to the situation equivalent to the situation before the impact).
2. Evaluated based on the likelihood (frequency) of the risk actually occurring, i.e., “whether it occurs approximately once every n years.”

Step２ Identification of priority issues, prevention or mitigation of adverse human rights risks

From the human rights risk map, we designate issues with high severity and high likelihood of occurrence as priorities for action.
In fiscal year 2025, we have newly prioritized Access to Services as a key issue. This encompasses risks that could infringe upon customers’ right to access services, specifically those arising from the occurrence of natural disasters due to climate change, pandemics, or system failures, and also from business suspension or stagnation due to factors such as labor shortages.

• Money Laundering and Transparency (tax avoidance), Business in Conflict Countries, and Migrant Labor (including foreign workers), which were prioritized issues for FY2024, have not been prioritized this fiscal year because the likelihood of their occurrence has been reduced.

Prevention or mitigation initiatives

The Group is promoting company-wide efforts related to business and human rights.
Since Group employees have many opportunities to come into contact with customers, suppliers, local communities, and other stakeholders and rights holders in their daily work, we believe that a deep understanding of the essence of respect for human rights by each and every employee will lead to concrete actions to put it into practice on a daily basis.
In order to promote employees’ understanding and put it into practice, we continuously hold study sessions and training sessions by job level.

● Study sessions by external lecturers for the Group executives and employees
Two study sessions were held in April and May 2025 for members of the Business and Human Rights Working Group (WG) of each group company, inviting outside lecturers. The first session was held in an interactive format to deepen participants’ basic knowledge and understanding of business and human rights. In the second session, group work was conducted based on case studies, and participants actively exchanged opinions on human rights from their respective perspectives. The lecturer’s message that “there is no single answer to business and human rights” provided participants with an opportunity to view human rights from various perspectives through spontaneous presentations and free thinking.
Additionally, participants had the image of their ideal self they aimed to achieve after this study session before attending using a questionnaire. This provided an opportunity for them to approach business and human rights with a stronger sense of ownership and translate them into concrete actions.

・Questionnaire for participants
A questionnaire of participants prior to the implementation of this study session confirmed that they were aware of human rights violation risks such as harassment, discrimination, and excessive working hours, and that training was in fact being implemented as a prevention and mitigation measure. It was also found that the reason for working on prevention and mitigation of human rights risks is to avoid or reduce corporate social responsibility and reputational risks.
In the post-study session questionnaire, participants were asked to select the following items regarding their change in status after participating in the training: (1) understood the training, including the background, and (2) could take action (could hold study sessions, conduct risk assessments, and explain their company’s initiatives). As a result, 43.6% of the respondents answered Understood and 56.4% answered Able to take action. We believe that the fact that the group work was closer in content to practical operations was a major factor in the participants’ change in behavior. We will continue to conduct training and study sessions because correct understanding and actions by each person in charge are indispensable for the promotion and establishment of Group-wide initiatives on business and human rights.

Comments from the lecturer

● Human rights awareness training for all executives and employees
Every year, the Group conducts Sustainability and Human Rights Training (including e-Learning) for all executives and employees with the aim of deepening mutual understanding among employees based on respect for human beings and creating a rewarding, comfortable, lively, and energetic workplace.
In this training, participants learn about Group Policy for Human Rights and an overview of business and human rights, as well as a wide range of human rights issues reflecting social issues, such as normalization, LGBTQ+, harassment, foreign residents, and the SDGs.

● Study session for all executives
To improve the knowledge of all executives on business and human rights, a study session was held by inviting outside experts. The study session provided an opportunity to understand current trends in business and human rights, starting from the essence of a company’s responsibility to respect human rights.

● Distribution of the Request for Your Consideration of Human Rights document
Sompo Japan asks business partners to give consideration to human rights. This is because our Group Policy for Human Rights and Group Sustainable Procurement Policy clearly state our commitment to human rights throughout the value chain.

● Establishment of customer harassment response system
We believe that it is important to create a workplace environment in which employees can work in a safe and healthy manner, both mentally and physically, and that protecting each and every employee from acts that may be considered customer harassment is necessary to ensure the continued provision of high quality services to our customers. Each group company is provided with materials on how to respond to customer harassment, with reference to the Manual on Customer Harassment Prevention for Corporations published by the Ministry of Health, Labour and Welfare in Japan.
As for measures at each group company, for example, Sompo Japan has been promoting efforts such as publicizing its Policy on Customer Harassment, providing education and training for employees, and establishing a consultation and reporting system for employees.

● Initiatives to protect the health and peace of mind of our customers through personal accident insurance products
Sompo Japan’s “THE Karada no Hoken,” a comprehensive personal accident and income insurance policy, provides coverage for medical expenses incurred due to heatstroke as a standard feature. This initiative is featured on Ministry of the Environment’s Website Heat Illness Prevention Information as a private-sector contribution to heatstroke prevention and mitigation. Given the Ministry of Health, Labour and Welfare’s mandate for companies to implement heatstroke countermeasures, which took effect in June 2025, the significance of securing insurance to mitigate heatstroke risks has grown considerably.
Sompo Japan will continue to contribute to solving social issues through insurance.

● Promoting food assistance to socially vulnerable groups through insurance products
Sompo Japan supports the activities of food banks, which provide free food to the needy, welfare facilities, and children’s cafeterias. In order to further support this food bank activity, we will start selling “Food Bank Activity Insurance” in October 2025, based on the amount of food handled. By purchasing this insurance, food banks are compensated in the event that they are legally liable for damages due to defects in their activities or in the storage of food. This will enable donors to donate food with peace of mind, and is expand the circle of food assistance.

Step３ Tracking effectiveness of the efforts (Monitoring)

Survey on initiatives for respecting human rights

Through human rights risk assessment, we identify potential human rights risks and identify priority issues. The effectiveness of the identified priority issues and countermeasures is confirmed through ongoing follow-up surveys (Monitoring). In particular, we are continuously monitoring and improving our response to priority issues related to adverse impacts on human rights that were identified in the previous year.

● Initiatives for deterrence and prevention of harassment incidents
In order to build a healthy work environment free from harassment, the Group considers the deterrence and prevention of harassment as a key management priority. To realize this goal, we have set the year-on-year reduction of the number of substantiated cases of harassment as a primary KPI. Since FY2024, we have been focusing on the following initiatives to strengthen both prevention and appropriate responses when cases occur. Although the number of reports has remained flat, we recognize that employees’ awareness of human rights and sensitivity to workplace conditions are increasing, as seen in earlier consultations and more third-party reporting. For incidents that have occurred, we take appropriate measures based on the facts and circumstances of each case.

• Through the Group Common Competencies, which were formulated based on SOMPO’s Values (Integrity, Self-motivation and Diversity), we encourage behaviors such as respecting others, active listening, and constructive dialogue. By integrating these perspectives into our evaluation system and promoting daily behavioral change, we seek to foster a corporate culture that prevents harassment.
• We have revised the standards for the appointment of directors and established new criteria for the appointment of managerial positions, clarifying that employees with harassment-related concerns will not be appointed.
• We have updated the Guidance on the compliance code of conduct, an explanatory guidebook for the Sompo Group Compliance Code of Conduct, to promote a zero-tolerance policy for all forms of harassment, through behavioral examples, and to clearly indicate the consultation channels available when concerns or issues are identified, with aims to foster an environment where employees feel comfortable with seeking advice.
• We have revised our disciplinary rules to more clearly define specific types of inappropriate conduct subject to disciplinary action, as well as the methods of discipline, thereby fostering greater employee awareness.
• We have updated our anti-harassment training for managers to strengthen their awareness of harassment prevention and enhance their ability to respond appropriately.

Related Pages

• Human Resource Strategy
• Compliance System

● Inappropriate disclosure of customer private data or privacy violations
We recognize that Inappropriate Disclosure of Customer Private Data or Privacy Violations is an issue of extremely high priority from the perspective of human rights and compliance. To address this issue, we conduct periodic mandatory training to improve the knowledge and awareness of employees and the organization as a whole.
The training session classifies types of accidents that may occur, and aims to improve knowledge and awareness through self-learning and organizational learning. In the event of an information leakage incident, we respond based on specific rules that define a series of steps, including the response flow, formulation of preventive measures, and confirmation that the measures have been implemented.

● Insurance underwriting, investment and loan initiatives
We have established a Sustainability-related Policy for Underwriting, Investments and Loans and are working to reduce and prevent any adverse impact that underwriting, investment, and loans may have on human rights.

Sustainability through Underwriting, Investment and Loans

● Excessive working hours
The fiscal year 2025 risk assessment revealed that 80.7%^* of the Group companies within the scope of ERM identified the risk of "excessive working hours for their employees and for workers in their supply chain. "All affected organizations are formulating and implementing measures aimed at mitigating the risk of excessive working hours.

• Calculation based on the number of companies

● Migrant workers – Supporting the active role of foreign employees
At Sompo Care, we also employ personnel from overseas as key contributors to our nursing care services, enabling them to fully bring out their abilities.
To ensure that employees from abroad can work and grow with confidence, we provide an initial orientation program (a 15-day group training) and first-year training after arrival in Japan. These programs aim to foster mutual understanding of cultures and customs, while preventing discrimination and harassment.
In addition to improving job-related skills, the training also offers practical support for daily life in Japan, such as guidance on using public transportation and navigation apps.
Following assignment to a workplace, we continue to provide on-the-job and follow-up training, along with ongoing support for Japanese language learning and professional certification. Through these efforts, we are building a work environment where overseas personnel can enhance their expertise, and where individuals with diverse backgrounds can grow together.

Step４ Disclosure of information

In line with Group Policy for Human Rights, we report on the progress of initiatives to address adverse impacts on human rights on our website and in our sustainability report. We also disclose our position on the UK Modern Slavery Act on our website. Through this type of communication, we are reviewing and improving our assessment process.

• Integrated Annual Reports
• Our Response to the Modern Slavery Act
• Modern Slavery Act Policy and Statement

3. Remediation Mechanisms

We recognize that the Group’s business activities may have an adverse impact on human rights and that we are responsible for mitigating such impacts and providing appropriate remedies. To fulfill this responsibility, in addition to our existing whistleblower system, we have established a system to receive a wide range of complaints, consultations, and opinions regarding human rights from a diverse range of stakeholders and rights holders. We ensure the anonymity of whistleblowers and consultants, take the utmost care in handling information, and strive to protect whistleblowers, consultants, and stakeholders and rights holders from any disadvantage. In the future, the Group will continue its efforts to further improve access to remedies, to make the internal whistleblower hotline known to all employees, and to enhance the knowledge of the staff in charge of the hotline. In addition, we will promote collaboration with stakeholders and rights holders to build a more effective grievance mechanism.

Receiving and addressing feedback and complaints

Sompo Japan regards customer dissatisfaction with the Group’s overall business activities as a complaint. We take complaints received from customers seriously and promote initiatives to improve our operations, products, and services by compiling and analyzing the trends and details of such complaints.

Reporting and consultation system from employee and corrective measures

In addition to a reporting and consultation service for general compliance issues, the Group has established a human rights consultation service to provide individual consultation by phone or e-mail in order to quickly identify information on harassment, bullying, harassment, and other problematic behavior in the workplace and build a comfortable working environment.
If any of the reports or consultations received raise concerns or problems that are suspected to be in violation of laws and regulations, internal rules, or the spirit of the Sompo Group Compliance Code of Conduct, the Company will conduct an investigation in a strict and fair manner.
In cases where violations of laws, regulations, the code of conduct, or other internal regulations are confirmed, the Group implements corrective measures, such as disciplinary action, against the violators in accordance with the standards and requirements stipulated in employment contracts and employment regulations.

Details of each reporting system

• System to Utilize Voice of Customer (VOC) in Management (in Japanese)
• Complaints received (in Japanese)
• Whistle-blowing and Consultation System
• Sompo Group Compliance Code of Conduct