We operate in parts of the world where human rights are at risk, and are therefore
exposed to human rights-related issues, such as child labor, bribery and corruption, workplace discrimination,
Our sustainability strategy is driven by three absolute requirements that are at the heart of everything we do.
One of these requirements is respecting human rights.
Our human rights strategy
The JT Group Human Rights Policy
follows the framework provided by the UN Guiding
Principles on Business and Human Rights (UNGPs) to monitor, influence, and improve business practices within our
own operations and those of our suppliers and partners. This means avoiding infringing the rights of others and
addressing the adverse impacts of our global operations. We not only have a responsibility to respect human
– we also have the ability to advance and promote these rights in all the areas we operate.
Our commitment to human rights is reinforced in both our Codes of Conduct and our Reporting Concerns Mechanism,
which ensure that we listen to and act on the grievances of those whose human rights are impacted by our
activities. We encourage employees and suppliers to speak up on human rights, without fear of retribution, about
any concerns they may have.
Our suppliers and growers throughout the world are also obliged to respect human rights by adopting and
maintaining internationally recognized labor standards regarding child labor, rights of workers, and workplace
health and safety. They do this in line with our JT Group Responsible Procurement Policy, JT Group Supplier
Standards, and Agricultural Labor Practices (ALP).
Our strategy is based on three pillars: Inform, Assess, and Improve. Each plays a crucial role in embedding
human rights protections into the business and driving continuous improvement. This approach provides a
consistent, efficient, and systematic way of conducting ongoing due diligence and allows us to proactively shape
a strategic plan regarding human rights.
Our commitment to conducting human rights due diligence
In line with the UN Guiding Principles (UNGPs) on Business and Human Rights, we have
made human rights due diligence an essential and integrated part of our business. This enables us to identify
and assess actual and potential human rights risks, as stated in our JT Group Human Rights Policy.
Conducting human rights due diligence – through Human Rights Impact Assessments – is part of our Company’s
responsibility to prevent adverse impacts on people and ensure the highest standards of behavior are upheld
within our business and value chain.
To achieve this, we are committed to assessing 100% of our high-risk countries by 2025, in our tobacco business.
We recognize respecting human rights
as one of our absolute requirements
Whilst we have made progress,
respecting human rights is a journey,
and our approach and management
of human rights issues will evolve
We still have much more work
to do and we will update you on
our progress as our human rights
initiatives unfold in the coming
Senior Vice President, Sustainability Management, JT
Our approach and progress in 2018
Our efforts to build awareness of the JT Group Human Rights Policy and provide human
rights information to employees start with training, awareness raising, and communication. This is about getting
human rights thinking into the culture of the Company and helping employees understand the human rights
implications of business decisions.
We train our employees on human rights through an online human rights e-learning module, available in 25
languages. By June 2018, 75% of our employees had completed the module in our international tobacco business. To
reach employees without computer access, we now have a dedicated section on respecting human rights integrated
into face-to-face training on the Code of Conduct.
In November 2018, we organized an awareness raising session on human rights, which 81 employees (*E) attended.
The objective of the session was to engage and educate our staff on the subject through an external voice. In
line with our aim to harness external expertise as part of our strategy, we invited BSR’s Human Rights Managing
Director, Margaret Jungk, to give a speech at the session. Margaret previously directed the business and human
rights department at the Danish Institute for Human Rights and was a member of the UN Working Group on Business
and Human Rights. Her speech was recorded and shared with the rest of the Company via our intranet.
We also provide printed communications materials to increase employee awareness and strengthen their
of human rights. In 2018, we developed an educational booklet on respecting human rights in our businesses in
with the UNGPs and shared this with over 25,000 employees in our Japanese operations. In addition, our Code of
Conduct was revised to include updated information on human rights.
In 2018, we completed our pilot year of Human Rights Impact Assessments in five
high-risk countries in our international tobacco business. These countries were identified through a risk
analysis using publicly available country risk human rights indices.
They covered a mix of geographical regions and the breadth of our supply chain operations, from farm to store.
In line with the UNGPs, the Human Rights Impact Assessments focused on the greatest risk to people, both within
our own Company and through business relationships with our suppliers.
The Impact Assessments took place in Dominican Republic, Malaysia, Mexico, Myanmar, and Tanzania, demonstrating
our willingness to go into countries where serious human rights violations have been reported, and assess the
In our Japanese operations, the Impact Assessments were implemented through self-assessment questionnaires and
site visits. We conducted due diligence through self-assessment questionnaires in our processed food business in
China and Thailand, which will be followed by site visits and capacity building in 2019.
Our corporate policies are consistent with human rights best practice, as demonstrated by a third-party
assessment. Human Rights Impact Assessments enable us to test the effectiveness of these policies on the ground,
and make improvements where necessary.
To address issues identified through Human Rights Impact Assessments and self-assessment
questionnaires, we develop action plans. These plans enable us to drive improvements and integrate human rights
into our existing management processes, in a consistent manner.
The plans have defined responsibilities, clear timelines for implementation, and key performance indicators to
In 2018, we developed five action plans with the respective countries, each with an agreed timeline. A total of
12 Human Rights Champions were appointed within these countries, as part of a network. The responsibility of
this network is to ensure that action plans are managed and implemented by each country and respect for human
rights is firmly established in the business.
In our Japan operations, we agreed on action plans for 21 key sites (*C) which have
head office functions. In addition to those local efforts, we also enhanced our corporate policy and Reporting
Concerns Mechanism towards migrant workers.
Governance and stakeholder engagement
Given the breadth of the JT Group’s operations around the world, it was critical to
establish an appropriate governance structure. We believe it is important to embed respect for human rights
throughout our entire organizational structure. This is driven by our dedicated human rights team, which is
responsible for raising awareness and improving engagement internally. Our Business Ethics Committee (*E) also has an important role to play, as it provides overall governance to ensure that
rights holders’ concerns are listened to and addressed effectively.
Central to our governance structure was the establishment of a Human Rights Champions network in 2018. This
network comprises employees from the countries in which we have conducted Human Rights Impact Assessments, and
facilitates the sharing of guidance and best practice on human rights.
To advance the rights of our stakeholders, it is important that we listen to the advice, concerns, and
criticisms of people outside the JT Group. Therefore, we have continued to take counsel from our Human Rights
External Advisory Board.
To further strengthen our external engagement, we have partnered with Business for Social Responsibility (BSR),
Mazars, EY, and KPMG Azusa Sustainability. These organizations provide technical support with our ongoing human
rights due diligence approach and overall human rights strategy.
Human rights impact assesments
Our Human Rights Impact Assessments focus on our main operations and value streams. Key
activities during the Impact Assessment include visiting and observing farming, processing, manufacturing, and
sales and distribution operations. During the assessments, we conduct a series of interviews with employees and
workers, in our international tobacco business as well as representatives from suppliers, clients, and
For more details, please refer to:
The JT Group Sustainability Report
Human rights correspondence – Our responses to human rights related inquires
JTI UK Modern Slavery Statement
JTI UK, the JT Group’s UK subsidiary, published a statement pursuant to the Modern
Slavery Act 2015 of the United Kingdom.
JTI UK Modern
Slavery Statement (JTI UK Website)