Respecting human rights

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 have.

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 have a responsibility to respect the rights of those they impact through their business operations and supply chains.

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 continuous improvement.

Charlie Watson,
Director, Human Rights, JT International

Our approach and progress

Embed

Our approach

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 Policy.

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 human rights.

Our progress

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 other markets.

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

Our approach

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.

Our progress

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 reality.

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 Egypt.

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 workers.

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 Sustainability.

Respond

Our approach

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 rights.

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.

Our 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.

Case study

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 the business.

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 rights
  • 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)

Measure

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.

Report

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.

Programs

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

Asia, Americas

Bangladesh (2019)
  1. International tobacco business

    JTI operations: Leaf, Factory, Office, Sales & Distribution
    Total number of JTI employees: 3,678 (Male: 3,604 & Female: 74)
    Agricultural Labor Practices: in process of being set up
    ARISE: in process of being set up
    Operational Grievance Mechanism “Your Voice”: active since 2019
    Certified Top Employer: No
    Human Rights Impact Assessment: July 2019
    Action Plan (resulting from assessment) launched: September 2019

    Key findings include:

    Human rights category: Health & Safety
    Driver safety is a significant risk with a large number of motorcycles in use.

    WE HAVE: checked the validity of all driving licenses, conducted a driver safety program and training on safety rules, and provided personal protective equipment (PPE) such as helmets to all JTI employees and third-party employees.

Dominican Republic (2018)
  1. International tobacco business

    JTI operations: Factory, Office, Sales & Distribution
    Total number of employees: 173 (Male: 140 & Female: 33)
    Operational Grievance Mechanism “Your Voice”: active since 2017
    Certified Top Employer: Yes
    Human Rights Impact Assessment: September 2018
    Action Plan (resulting from assessment) launched: November 2018

    Key findings include:

    Human rights category: Health & Safety
    Transitioning from one to three shifts at the factory could lead to potential human rights risks.

    WE HAVE: adopted a human rights-based approach to identify and respect the rights of vulnerable groups, maintaining heightened awareness of those whose rights could be affected by the transition. This includes open dialogue with employees and a survey to understand each employee’s individual situation and preferences, transport to and from the factory for night workers, increased communication regarding rest and breaks, and a new canteen open 24/7.

China (2019)
  1. Processed food business

    JT operations (6 group companies): Factory, Office
    Total number of employees: 1,254 (Male: 427 & Female: 827)
    Operational Grievance Mechanism: reporting concern hotline active
    Human Rights Impact Assessment: January to May 2019
    Action Plan (resulting from assessment) launched: September 2019

    Key findings include:

    Human rights category: Labor rights
    Employees were only able to view their pay slips using a shared computer in the administration office.

    WE WILL: start distributing pay slips via a smartphone app, so that every employee can access their details using their own device.

India (2019)
  1. International tobacco business

    JTI operations: Leaf (third-party)
    Total number of employees: 0
    Due diligence: JTI is working with the sector on building a joined approach to human rights due diligence
    Human Rights Impact Assessment: November 2019
    Action Plan (resulting from assessment) in process of being launched

    Key findings include:

    Human rights category: Health & Safety
    One of the key challenges mapped: Crop Protection Agents (CPA) usage always presents a risk in agriculture. There is a risk that workers could be exposed to these agents due to inconsistent CPA management and a lack of personal protection equipment.

    OUR SUPPLIERS WILL: besides continuous training and awareness raising, eliminate the use of Highly Hazardous Pesticides Criteria 1 in our leaf global supply chain by the end of 2021. This will be done in cooperation with the Indian Tobacco Board and the rest of the industry. More details below in Eliminating highly hazardous pesticides criteria 1 in our supply chain.

Japan (2017/2018)
  1. Japanese domestic business

    JT operations (29 group companies): Leaf, Factory, Office, Sales & Distribution
    Total number of employees: 15,913 (Male: 12,426 & Female: 3,487)
    Agricultural Labor Practices: active since 2017
    Operational Grievance Mechanism: reporting concern hotline active
    Human Rights Impact Assessment: February to November 2017
    Action Plan (resulting from assessment) launched: December 2017

    Key findings include:

    Human rights category: Labor rights
    The guidelines in some of our Japanese subsidiary companies were not optimized for migrant workers in Japan.

    WE HAVE: developed a set of Group-wide guidelines on responsible recruitment and labor management, with a focus on migrant workers. We have made the Reporting Concerns Mechanism more accessible to migrant workers by offering it in Vietnamese and Nepali, in addition to Japanese, English, and Chinese.

Kazakhstan & Kyrgyzstan (2019)
  1. International tobacco business

    Kazakhstan:
    JTI operations: Factory, Office, Sales & Distribution
    Total number employees: 597 (Male: 415 & Female: 182)
    Operational Grievance Mechanism “Your Voice”: active since 2008
    Certified Top Employer: Yes
    Human Rights Impact Assessment: September 2019
    Action Plan (resulting from assessment) launched: November 2019

    Kyrgyzstan:
    JTI operations: Office, Sales & Distribution
    Total number of employees: 56 (Male: 46 & Female: 10)
    Operational Grievance Mechanism “Your Voice”: active since 2008
    Certified Top Employer: No
    Human Rights Impact Assessment: September 2019
    Action Plan (resulting from assessment) launched: November 2019

    Key findings include:

    Human rights category: Access to grievance mechanism
    Employees are generally familiar with the grievance mechanism Your Voice, but there are opportunities to further raise awareness.

    WE WILL: improve our Your Voice communications, including posters in offices and onboarding for new employees across our operations.

Malaysia (2018)
  1. International tobacco business

    JTI operations: Office, Sales & Distribution
    Total number of JTI employees: 385 (Male: 240 & Female: 145)
    Operational Grievance Mechanism “Your Voice”: active since 2008
    Certified Top Employer: Yes
    Human Rights Impact Assessment: November 2018
    Action Plan (resulting from assessment) launched: February 2019

    Key findings include:

    Human rights category: Living wage and working hours
    Workers at a JTI supplier reported long working hours.

    WE HAVE: together with the supplier, reviewed the labor laws on working hours and overtime to ensure their full compliance with applicable laws and regulations. We have also strengthened awareness of available rest breaks and vacation entitlement among workers through consultations. We conducted training for managers and other employees on the links between rest, productivity, and safety performance.

Mexico (2018)
  1. International tobacco business

    JTI operations: Factory, Office, Sales & Distribution
    Total number of employees: 112 (Male: 73 & Female: 39)
    Operational Grievance Mechanism “Your Voice”: active since 2012
    Certified Top Employer: Yes
    Human Rights Impact Assessment: September 2018
    Action Plan (resulting from assessment) launched: November 2018

    Key findings include:

    Human rights category: Health & Safety
    We will continue to take Mexico’s severe security concerns into consideration when developing routes and sales objectives across the country. As the third-party sales team expands, workers at JTI distributors need to be properly trained on security and safety.

    WE HAVE: designed a training platform for employees at JTI distributors, enabling them to easily access information on their smartphones. This is in addition to the existing due diligence and routes modification to ensure appropriate security provisions are in place. The platform contributes to our overall training program for sales workers, ensuring the necessary security measures are in place to protect people from harm.

Myanmar (2018)
  1. International tobacco business

    JTI operations: Factory, Office, Sales & Distribution
    Total number of employees: 227 (Male: 160 & Female: 67)
    Operational Grievance Mechanism “Your Voice”: active since 2014
    Certified Top Employer: No
    Human Rights Impact Assessment: November 2018
    Action Plan (resulting from assessment) launched: January 2019

    Key findings include:

    Human rights category: Labor rights
    Contracted workers had written contracts and received pay slips, but this documentation was not communicated in the local language.

    WE HAVE: translated all contract worker contracts and pay slips into Burmese. All communication posters regarding the Your Voice grievance mechanism and ‘Your Guide to Making Ethical Decisions’ are now available in both English and Burmese.

Thailand (2019)
  1. Processed food business

    JT operations: Factory, Office
    Total number of employees: 457 (Male: 259 & Female: 198)
    Operational Grievance Mechanism: reporting concern hotline active
    Human Rights Impact Assessment: January-June 2019
    Action Plan (resulting from assessment) launched: September 2019

    Key findings include:

    Human rights category: Health & Safety
    Employees were not always wearing the appropriate personal protection equipment (PPE) in hot weather.

    WE WILL: hire an expert to improve our existing Environmental Health and Safety assessments. We will also train employees to properly understand the importance of protecting themselves.

Africa, Middle East

Egypt (2019)
  1. International tobacco business

    JTI operations: Factory, Office, Sales & Distribution
    Total number of employees: 864 (Male: 828 & Female: 36)
    Operational Grievance Mechanism “Your Voice” active since 2014
    Certified Top Employer: Yes
    Human Rights Impact Assessment: October 2019
    Action Plan (resulting from assessment) launched: January 2020

    Key findings include:

    Human rights category: Non-discrimination
    Within our international business there is a respectful environment towards women, but there are opportunities to further encourage diversity in the workforce.

    WE WILL: further promote equal opportunity by actively seeking to employ more women across all departments. We will make job descriptions and roles more inclusive for women by addressing safety concerns, creating mixed teams, seeking women's feedback, and raising awareness in line with JTI's Gender Equality commitment.

Ethiopia (2019)
  1. International tobacco business

    JTI operations: Leaf, Factory, Office, Sales & Distribution
    Total number of JTI employees: 809 (Male: 549 & Female: 260)
    Agricultural Labor Practices: in process of being set up
    ARISE: in process of being set up
    Operational Grievance Mechanism “Your Voice”: active since 2019
    Certified Top Employer: No
    Human Rights Impact Assessment: July 2019
    Action Plan (resulting from assessment) launched: October 2019

    Key findings include:

    Human rights category: Non-discrimination
    Women’s rights and health are high-risk with possible cases of harassment and gender discrimination.

    WE WILL: ensure equal working conditions and opportunities for both men and women by carrying out an internal assessment to better understand the situation, implement a training program to raise awareness, establish a gender mainstreaming policy, and create a women’s association to empower, educate, and support women in the workplace.

Malawi (2019)
  1. International tobacco business

    JTI operations: Leaf
    Total number of employees: 310 (Male: 229 & Female: 81)
    Agricultural Labor Practices: active since 2014
    ARISE: active since 2012
    Operational Grievance Mechanism “Your Voice”: active since 2014
    Certified Top Employer: Yes
    Human Rights Impact Assessment: June 2019
    Action Plan (resulting from assessment) launched September 2019

    Key findings include:

    Human rights category: Exploitation of workers
    It is believed that tenant farming could lead to the exploitation of tenants and their families by the farmer or landlord, potentially causing many adverse impacts.

    WE HAVE: proactively run supply chain due diligence throughout our leaf supply chain globally. We have enforced our approach in Malawi in 2018. As a preventive response, among other actions, we have committed in 2019 to moving away from tenant farming in Malawi by March 2021. All of our large-scale commercial growers operating a tenant farming system will transition their tenant farmers to employment contracts in 2020.

Tanzania (2018)
  1. International tobacco business

    JTI operations: Leaf, Factory, Office, Sales & Distribution
    Total number of employees: 560 (Male: 464 & Female: 96)
    Agricultural Labor Practices: active since 2015
    ARISE: active since 2016
    Operational Grievance Mechanism “Your Voice”: active since 2008
    Certified Top Employer: Yes
    Human Rights Impact Assessment: February 2018
    Action Plan (resulting from assessment) launched: May 2018

    Key findings include:

    Human rights category: Access to grievance mechanism
    Awareness of the Your Voice grievance mechanism could be improved to increase its overall effectiveness.

    WE HAVE: relaunched the Your Voice communication campaign in May 2018 to reach all employees. We translated our communications and training programs into Kiswahili, the local language. We have actively promoted Your Voice and the Code of Conduct on notice boards, leaflets, at a launch event, and in direct communication from the General Manager. In our ongoing global effort to encourage employees to speak up, we continue to provide targeted communications for markets.

Zimbabwe (2019)
  1. International tobacco business

    JTI operations: Leaf (third-party)
    Total number of JTI employees: 0
    Due diligence: JTI building an industry approach to human rights due diligence
    Human Rights Workshop with Leaf Merchants: January 2019

    Key findings include:

    Human rights category: Health & Safety
    Workers on farms could be exposed to the risk of toxic substances.

    OUR SUPPLIERS WILL: eliminate the use of Highly Hazardous Pesticides (HHPs) Criteria 1 in our leaf global supply chain by the end of 2021. Furthermore, all of our suppliers have made a commitment to develop a human rights policy.
    More details below in Eliminating highly hazardous pesticides criteria 1 in our supply chain.


    Case study

    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 publicly available
    • 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

    Case study

    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 supply chain by the end of 2021.

    HHPs Criteria 1 are pesticide formulations that meet the criteria of hazard classes 1a and 1b of the World 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 Criteria 1 Pyrethroids insecticides, which are still legally used in several countries.



    External recognition

    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.

    Going forward

    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 business.

    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.