We operate in parts of the world where human rights are at risk, and are therefore
exposed to human rights-related issues, such as forced labor, child labor, bribery, and corruption.
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
We respect human rights across our value chain and recognize the Universal Declaration of Human Rights, the
International Bill of Human Rights and the International Labor Organization’s Declaration on Fundamental
Principles and Rights at Work. Our JT Group Human Rights Policy follows the framework provided by the UN Guiding
Principles on Business and Human Rights (UNGPs). This means avoiding infringing the rights of others and
addressing any adverse impacts of our global operations.
Our commitment to human rights is reinforced by our Board of Directors through our Code of Conduct. Our
Reporting Concerns Mechanism helps us ensure that we listen to and act on the grievances of those whose human rights might be impacted by our activities. Through this legitimate, fair, and accessible mechanism, we encourage
employees and suppliers to speak up on human rights, without fear of retribution, about any concerns they may
Our suppliers and growers throughout the world are 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 the JT Group Responsible Procurement Policy, JT Group Supplier Standards, and
Agricultural Labor Practices (ALP).
Our human rights strategy is based on five pillars: Embed, Identify and Prioritize, Respond, Measure, and Report. This circular approach provides a systematic way of conducting ongoing due diligence and is in line with the UNGPs, the Organisation for Economic Co-operation and Development (OECD) guidelines, and the Food and Agriculture Organization guidance on responsible agricultural supply chains.
Our human rights due diligence
In line with the United Nations Guiding Principles (UNGPs), 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.
Embedding human rights due diligence – which is in part informed by our widely applied Human Rights Impact
Assessments – is our responsibility and helps us to prevent adverse impacts on people and ensure the highest
standards of behavior are upheld within our business and value chain. As part of this program, we are
committed to assessing 100% of our high-risk countries by 2025, in our tobacco business.
The United Nations Guiding Principles on Business and Human Rights make the pathway clear: companies
a responsibility to respect the rights of those they impact through their business operations and supply
As a Company, we have embraced our obligation to respect human rights and are committed to tackling the
challenges this will bring. We have made solid progress and will continue the work on our journey of
Director, Human Rights, JT International
Our approach and progress
We are working hard to embed human rights thinking in our Company culture, and to
improve employees’ understanding of the human rights implications of business decisions. To do this, we provide
regular training and continuously share information about human rights and the JT Group Human Rights
The training involves an online human rights e-learning module, which is available in 25 languages. We also
provide printed communication materials to increase employee awareness and strengthen their understanding of
In 2019, we relaunched our human rights e-learning module globally to target the
employees who had not completed the training in the first phase. To train employees without computer access, we
integrated a section on respecting human rights into our face-to-face Code of Conduct training in Malawi,
Ethiopia, Zimbabwe, and Bangladesh. This section will be included in all future Code of Conduct trainings in our
Employees in our Japanese operations have completed an online human rights e-learning module, which was offered
in Japanese, English, and Chinese. The scope of the training included our subsidiary companies in China and
Thailand (processed food business) and the U.S. (pharmaceutical business).
Identify and prioritize
We conduct Human Rights Impact Assessments (HRIAs) to identify and assess actual and
potential human rights risks. In line with the United Nations Guiding Principles (UNGPs), our HRIAs focus on the greatest risk to people, both
within our own Company and through business relationships with our suppliers, from farm to store. As a result of
the HRIAs, we aim to address the identified risks of the rights-holders, meet our stakeholder expectations on
respecting human rights, and mitigate against the overall risks to people and the business.
As part of our commitment to assess 100% of high-risk countries by 2025 in our tobacco
business, we have completed nine HRIAs across our entire value chain in the last two years: Dominican Republic,
Egypt, Ethiopia, Kazakhstan, Kyrgyzstan, Malaysia, Mexico, Myanmar, and Tanzania. This demonstrates our approach
to prioritizing, which involves considering where our greatest risks to people lie. It also shows our
willingness to go into countries with reported human rights violations and assess the on-the-ground
Over the last year, we have also conducted HRIAs in our tobacco leaf supply chain in various markets, including
Ethiopia and India. These assessments provide a more comprehensive understanding of the human rights impacts
within one specific part of our value chain – our tobacco supply chain and tobacco growing business – and the
challenges that tobacco growers face in their communities.
In Bangladesh, we carried out a post-acquisition Human Rights and Environmental Health and Safety (EHS)
Assessment. The purpose was to identify actual and potential impacts on people across all five segments of JTI
operations: Leaf, Processing, Manufacturing, Offices, and Sales and Distribution.
As suggested by our External Human Rights Advisory Board, in 2019, we introduced a self-assessment questionnaire
to evaluate the human rights profile of more countries, to increase the scope and impact of our human rights due
diligence. Following the same methodology as our HRIAs, this smartly designed survey targets our lower ranked
high-risk countries that have not been prioritized for HRIAs in the short term.
Piloted in Morocco and Colombia, the questionnaire is designed to identify human rights risks to people, so that
we can act on that information and meet our responsibility to respect human rights. Effectively assessing human
rights impact requires building the know-how of the colleagues involved in the assessment.
To further increase our human rights due diligence work, we also enhanced our inclusion of human rights in our
internal audit methodology starting in one pilot country, Egypt, this year. Our internal auditors received
guidance on how to further integrate human rights into their standard audit. The findings made by the internal
audit - such as some related to health and safety - were then shared with our human rights team prior to the HRIA.
This helped create a more targeted and effective impact assessment. Each finding was formalized into
recommendations for improvement, as part of a human rights action plan approved by the local management in
In our Japanese operations, we started conducting due diligence in our processed food business in China and
Thailand in 2019, with the support of KPMG AZSA Sustainability. This followed the review of three of our
business operations – our Japanese domestic tobacco business, pharmaceutical business, and processed food
business – in 2017 and 2018, supported by Ernst & Young. In those three business operations in Japan, we
identified the risks unique to migrant workers as key. Please see ‘Our progress in Asia, including Japan’ for
more details about how we addressed the risks concerning this most vulnerable group.
To identify the most important current and potential risks, we first conducted self-assessment questionnaires in
all seven of our subsidiary companies in China and Thailand. The questionnaires covered a broad spectrum of
human rights issues and aimed to identify the greatest potential risks in our operations. These included forced
labor and environmental health and safety, especially with regards to vulnerable groups such as migrant
Based on the results of the questionnaires, three out of seven subsidiary companies were identified as
potentially high-risk for human rights. We therefore decided to carry out site visits in these specific
companies to examine the risk in more detail. As a result, we identified occupational health and safety, working
conditions, and social security as risks, and we put robust action plans in place to address these. These plans
were agreed between the general managers of these companies, our human rights team, and KPMG Azusa
HRIAs are a means to an end, not an end in themselves. We need to act appropriately on
the information generated from the assessments, in order to meet our responsibility to respect human
We develop action plans to address issues identified through HRIAs and self-assessment questionnaires. 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 monitor progress.
Since 2018, we have developed nine action plans for specific countries, each with an
agreed timeline. A total of 20 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.
The Human Rights Champions are selected by the local management, typically from departments in which human
rights improvements are required. The Champions manage the implementation of the action plans locally, on top of
their usual roles. Our head office provides the Champions with training materials on the UN Guiding Principles
on Business & Human Rights, as well as support with specific points within the action plans.
In 2019, we carried out a review of our high-risk countries, including a more detailed analysis on which
countries have the greatest risk to people. Previously, we identified our high-risk countries using publicly
available geopolitical data on human rights. We decided to improve this process by integrating additional
criteria regarding JTI’s operations and impact into our overall matrix.
The criteria included the number and type of JTI operations in each country, historical data on human rights
cases in our operational grievance mechanism or Agricultural Labor Practices Program, the health and safety
performance of JTI operations in each country, and our salient issues. This improvement to the process ensures
we have a much more accurate picture of our potential risks in each country, and that we are able to prioritize
our actions where they are needed most.
Our progress in Asia, including Japan
Since 2018, we have established action plans for 21 key sites in Japan*C, covering all of the head offices
of our Japanese operations. We have also agreed action plans for seven of our subsidiary companies in the
processed food business in China and Thailand, as high-risk countries outside of Japan.
In addition to local efforts, our Japanese headquarters has improved our corporate guidelines to address the
potential risks relating to migrant workers, identified as the most vulnerable group through our HRIAs. The
number of migrant workers in Japan has increased rapidly in the past few years. Consequently, there was a need
for common, Group-wide guidelines regarding the hiring and labor management of migrant workers, aligned with
the international norm, the United Nations Guiding Principles (UNGPs).
We now offer our external Reporting Concerns Mechanism in five languages – Japanese, English, Chinese,
Vietnamese, and Nepali – to give migrant workers easier access to reporting channels.
We also launched a new scheme, in which central management regularly checks the employment status of migrant
workers across our entire Japanese operations. By making sure we have the most up-to-date information, we can
better protect this vulnerable group and address any potential and actual risks.
Identifying our salient issues
To strengthen the focus of our policies and programs on human rights areas that matter most, it is
crucial to have an understanding of our respective salient human rights issues. The concept of salience
focuses on the risk to people, not to the business, and impacts are prioritized according to their
severity and likelihood. The risks that are viewed as most salient are likely to converge as a risk to
To identify the salient human rights issues in our value chain, in 2019 we conducted an assessment with
the support of Mazars. This exercise included a review of relevant internal policies and procedures, and
a workshop with internal stakeholders.
A total of sixteen human rights issues important to JTI were presented and discussed. The idea was to
understand which specific activities associated with our business may put human rights at risk, so that
we can proactively identify those issues to prioritize. Forced & Bonded Labor, Child Labor, and Living
Wage were among the seven human rights issues identified as salient.
To ensure that our ongoing human rights program and due diligence processes already target these salient
issues, we have integrated them into our HRIA methodology and self-assessment questionnaires. These
issues are now also included in our methodology for identifying high-risk countries, which helps us to
prioritize our due diligence process based on where our greatest potential impacts lie.
Going forward, our overall goal is to achieve appropriate and effective action plans for each salient
issue in order to mitigate the risks for both the rights-holders and JTI. We will conduct further
research into our salient issues to deepen our understanding of risks and opportunities for improvement.
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.
To ensure an effective due diligence system is in place, it is critical to link impact assessments to effective
governance structures that ensure accountability for acting on the findings. For this reason, the establishment
of a Human Rights Champions Network was central to our governance structure in 2018. This network comprises
employees from the countries in which we have conducted HRIAs, 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 external advisory board*E
Our Human Rights External Advisory Board plays a vital role in providing us with a broad external perspective
in the human rights area. Made up of international experts on business and human rights, the Board advises us
on all issues that the members consider relevant for the implementation of our human rights strategy. The
panel of experts guides us with their expertise and challenges us where they believe we need to improve,
helping to strengthen our efforts to deliver on our human rights commitments.
In 2019, we implemented several key changes to our due diligence strategy based on the Advisory Board’s expert
guidance and recommendations. These changes included, among many others:
- Developing our new country-level prioritization matrix, after the Board identified a need to add a
‘salient issues’ lens to the prioritization criteria
- Creating a smart self-assessment questionnaire as a means of engaging with more countries on human
- Appointing Human Rights Champions from the core business and operations, rather than from Corporate
Affairs or Human Resources, to ensure more effective action plan implementation
Board members include:
- Paul Bowden (Professor of Law, The Nottingham Law School)
- Donna L. Westerman (Sustainable Purchasing Leadership Council)
- Rona Starr (Association for Professional Social Compliance Auditors)
- Jonathan Drimmer (Paul Hastings)
- Richard Karmel (Mazars)
We are committed to continually measuring the effectiveness of, and improving where possible, our approach to respecting human rights.
Since we started our HRIAs in 2018, we have been measuring the effectiveness of our Action Plans. Each Action Plan we develop includes an individual set of key performance indicators to measure the effectiveness of our improvements over time. More broadly, as we expand our HRIAs globally, we will measure the overall effectiveness of our HRIA responses collectively.
There are various ways to measure the effectiveness of our responses in our leaf supply chain. One of them is the number of issues which we may observe during subsequent crop cycles. Read more on our approach.
Our understanding of our obligations under the United Nations Guiding Principles (UNGPs) is to ‘know and show’ that we are aware of the potential human rights related risks to which we may be connected, and that we are taking appropriate steps to manage those that occur. The UNGPs encourage corporate transparency to the benefit of a broad set of stakeholders and we are committed to this level of transparency and disclosure.
In 2019, we published our human rights correspondence with Human Rights Watch, the UN Human Rights Council, and The Guardian on our website.
To address our human rights issues, markets put in place their own customized corrective measures through human
rights action plans. We also have programs that can be applied globally to ensure a consistent approach across
the Group. Read more:
JTI UK Modern Slavery Statement
JTI UK, the JT Group’s U.K. subsidiary, has been publishing a Modern Slavery Act Statement since 2017.
JTI UK Modern Slavery Statement (JTI UK Website)
Human Rights Impact Assessments
Our HRIAs focus on impacts to people within our main operations and value streams. Key activities during an
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, as well as
representatives of suppliers, clients, and partners.
At the end of the assessment, we write a report and discuss recommendations for improvement with local
management. Our head office then works closely with the local team to address any issues raised and improve the
situation. The following list of key findings includes one human rights risk identified in each of our
assessments, to demonstrate the wide range of issues our stakeholders may face.
Read more about key findings and how we are addressing them by selecting a country
Using leverage with our leaf merchants
The United Nations Guiding Principles recommend the following:
UN Guiding Principle 13 (b):
The responsibility to respect human rights requires that business enterprises seek to prevent or
mitigate adverse impacts that are directly linked to their operations, products or services by their
business relationships, even if they have not contributed to those impacts.
UN Guiding Principle 19 (b) (ii):
In order to prevent and mitigate adverse human rights impacts, business enterprises should integrate
the findings from their impact assessments (…) and take appropriate action. Appropriate action will
vary according to (…) the extent of its leverage in addressing the adverse impact.
With this in mind, we have been receiving Agricultural Labor Practices reports from major suppliers
since 2016. Through these, we recognized Crop Agents Protection management challenges in Zimbabwe. We
have been looking for solutions beyond providing Personal Protective Equipment, which led us to initiate
a Highly Hazardous Pesticide response.
In May 2018, we received a letter from the United Nations Office of the High Commissioner for Human
Rights that highlighted several alleged human rights violations such as child labor, health and safety,
and a variety of labor rights abuses in tobacco growing in Zimbabwe.
Although we have no operations in Zimbabwe and only purchase tobacco leaf through leaf merchants
(third-party suppliers), we were still connected through our business relationship. This meant that we
had to use the commercial leverage we have with our suppliers to prevent the harm from occurring. We
therefore worked alongside some of our biggest leaf merchants – Alliance One International, Inc. (AOI),
Premium Tobacco International DMCC (Premium), and Universal Leaf Tobacco Company, Inc.,
CONTRAF-NICOTEX-TOBACCO GmbH – to encourage them to adopt and implement the United Nations Guiding
Principles on Business and Human Rights (UNGPs), and where necessary to change their business practices,
not just in Zimbabwe but globally.
All of our suppliers engaged positively and made the following commitments:
- Eliminate the use of the most hazardous pesticides to human health – Highly Hazardous Pesticides
Criteria 1 – by the end of 2021
- Develop a human rights policy approved at the most senior level of their organization and make it
- Develop an industry-wide grievance mechanism
- Focus their efforts on six key issues identified as having the potential to cause the most severe
harm and that are most likely to occur: exposure of workers to hazardous substances, land rights,
child labor, gender discrimination, freedom of association, and environmental impacts
We also engaged in open dialogue with the Zimbabwe Ministry of Labor, the Tobacco Industry and Marketing
Board, the Tobacco Research Board, and the National Employment Council for Agriculture and
We will monitor the commitments our suppliers have made and continue to work together with them to
ensure the best possible outcome for those impacted.
Read our full correspondence with the United Nations Office of the High Commissioner for
Eliminating Highly Hazardous Pesticides Criteria 1 in our supply chain
Our objective is to phase out the use of Highly Hazardous Pesticides (HHPs) Criteria 1 from our leaf
chain by the end of 2021.
HHPs Criteria 1 are pesticide formulations that meet the criteria of hazard classes 1a and 1b of the
Health Organization Recommended Classification of Pesticides by Hazard.
Our suppliers have committed to an assessment by country to identify any HHPs Criteria 1 which are still
registered, recommended, or used in tobacco production. They will also identify available alternatives,
prioritizing Bio-CPAs (Crop Protection Agents). There will be a special focus on eliminating HHPs
Pyrethroids insecticides, which are still legally used in several countries.
We were categorized as a ‘leader’ by the Global Child Forum in their latest study, conducted in collaboration
with the Boston Consulting Group. This benchmark report analyses just under 700 of the world’s largest
companies and how they are safeguarding children’s rights as part of their business value chain.
We are proud that the study recognizes the concrete actions we have taken to embed respect for children’s
rights in our supply chain, notably through our flagship child labor elimination program ARISE.
Our work to promote and respect human rights will evolve and adapt to the changing economic and political
context of the countries where we operate. Our approach to human rights due diligence is ongoing, as the risks
to human rights may change over time. We will continue to act where actions are necessary and focus on our
human rights priority areas.
In 2020, we will continue to prioritize countries based on a set of risk-based criteria in order to assess our
most high-risk countries first. Going forward, we are committed to assessing actual and potential human rights
risks in at least six countries each year and will continue to embed respect for human rights within the
In our Japanese operations, we will carry on monitoring the progress of our Human Rights Impact Assessment
action plans and provide the necessary support to ensure that they are implemented. Given the increase in
migrant workers since Japan’s immigration policy was revised in April 2019, we will continue to pay special
attention to this particularly vulnerable group.
In 2020, we will start introducing an enhanced supply chain management system. The new system will reflect our
revised Supplier Code of Conduct, which is aligned with the JT Group Human Rights Policy and the United Nations Guiding Principles.