MS&AD Group will fulfill its corporate responsibility to respect human rights and contribute to the realization of a sustainable society based on the United Nations "Guiding Principles on Business and Human Rights". 

In order to achieve our group's management philosophy (mission), which is to contribute to the development of a vibrant society and help secure a sound future for the planet, by enabling safety and peace of mind through the global insurance and financial services business, it is important to consider and act on the mutual impact between our business activities and society, including the environment and human rights. In the "MS&AD Insurance Group Human Rights Policy", which applies to all employees of our group, business partners such as agents, and a wide range of stakeholders associated with our group, we clarify that our group has a responsibility to respect and protect human rights. Under this human rights policy, we identify and evaluate the adverse impacts on human rights that may occur in our business activities, and work with a wide range of stakeholders to prevent and mitigate them through our commitment to respecting human rights (human rights due diligence).

Human Rights Management System

Our group is committed to respecting human rights and is promoting initiatives in accordance with the management system for respecting human rights, such as the formulation of human rights policies, implementation of human rights due diligence, and providing remedies.

Created with reference to the Ministry of Economy, Trade and Industry's“Reference Material on Practical Approaches for Business Enterprises to Respect Human Rights in Responsible Supply Chains”
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Created with reference to the Ministry of Economy, Trade and Industry's“Reference Material on Practical Approaches for Business Enterprises to Respect Human Rights in Responsible Supply Chains”

MS&AD Insurance Group Basic Policy on Human Rights

In February 2017, our Group established MS&AD Insurance Group Basic Policy on Human Rights to fulfill our corporate responsibility to respect human rights.

MS&AD Insurance Group Basic Policy on Human Rights

 

The MS&AD Insurance Group is committed to enhancing the enterprise value and contributing to the creation of a sustainable and resilient society through behavior that takes into account interaction with the environment and society in all business activities, with the aim of realizing Our Mission.
We recognize our responsibility for the actual and potential adverse impact our business activities have on human rights, including the impact of value chain, and we have pursued activities and dialogues that respect human rights. This Basic Policy has been adopted to prepare for this.

1. Basic Approach

 

(1) Compliance with laws, regulations and norms related to respect for human rights

(i)The Group respects international norms on human rights such as the United Nations International Bill of Human Rights(*1), the corporate code of conduct in the United Nations Global Compact(*2), and the principles concerning fundamental rights set out in the International Labor Organization Declaration on Fundamental Principles and Rights at Work(*3).
(ii) In addition to complying with laws and regulations in countries and regions where we conduct business activities, we seek ways to respect the principles of internationally recognized human rights when these laws and regulations conflict with the principles, while considering the circumstances in such countries and regions.
 

(2) Non-discrimination

We respect basic human rights in all business activities, and not discriminate based on race, nationality, gender, age, ethnic origin, descent (family origin), social status, creed, religion, physical characteristics, disability, sexual orientation, gender identity or pregnancy.
 

(3) Corporate culture that respects human rights

(i) With “achieving mutual growth by respecting one another's individuality and opinions, and by sharing knowledge and ideas” as one of Our Values, we will foster a corporate culture that respects human rights.
(ii) We respect diverse values and engage in the creation of a friendly working environment with consideration for the mental and physical health and safety of every single employee.

2. Human Rights Due Diligence

We will create a system for human rights due diligence in accordance with the United Nations Guiding Principles on Business and Human Rights, and engage in dialogue, consultation and reporting.

 

(1) Assessment and prevention

We will identify and assess any actual and potential human rights risks, and take prioritized steps to prevent and mitigate them.

 

(2) Remedy, remediation and dialogue

If the Group causes adverse human rights impacts, we will perform appropriate remedy and remediation through appropriate procedures, and engage in the prevention of recurrence. Moreover, if it is found that we are involved in such impacts through the value chain, we will sincerely engage in dialogue.

 

(3) Education and Training

We will engage in a broad range of activities to raise awareness of human rights through every opportunity to ensure our officers and employees have a deeper understanding of global, country-specific or regional issues related to human rights and their involvement with our business activities and have respect for human rights.

3. Responsibilities as a Global Insurance and Financial Services Provider

 

(1) Protection of privacy

In light of the importance of personal information and in accordance with our Basic Policy for Management of Customer Information we will protect personal information to ensure that there is no adverse impact on human rights including privacy.

 

(2) Reflection in business processes

As a founding signatory to the UN Principles of Sustainable Insurance (PSI) and a signatory to the UN Principles for Responsible Investment (PRI), we will consider environmental, social and governance (ESG) aspects in order to meet our responsibility to respect human rights in our insurance underwriting and investment decision-making processes.

(*1) International Bill of Human Rights consists of the Universal Declaration of Human Rights and the main instruments through which it has been codified: the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights

(*2)Ten Principles on human rights, labour, environment and anti-corruption. The principles of Human Rights and Labour include: (1) support and respect for the protection of human rights; (2) non-complicity in human rights abuses,(3) recognition of freedom of association and the right to collective bargaining; (4) elimination of forced labour; (5) effective abolition of child labour; and (6) elimination of discrimination in employment and occupation.

(*3) Fundamental Principles and Rights at Work in five categories:(1) freedom of association and the effective recognition of the right to collective bargaining,(2) elimination of all forms of forced or compulsory labour, (3)the effective abolition of child labour, (4) elimination of discrimination in respect of employment and occupation, and (5) safe and healthy working environment.

Established, February 1, 2017
Revised on March 1, 2019
Last Amended, October 11, 2022

 

 

President & CEO

UK Modern Slavery Act 2015 and Australia Modern Slavery Act 2018

MS&AD Holdings, has been publishing annual statements since 2015 in accordance with the UK Modern Slavery Act 2015. Similarly, Mitsui Sumitomo Insurance and Aioi Nissay Dowa Insurance have also published statements based on the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018, respectively, for their overseas operations. In order to prevent human rights abuses in value chains and supply chains, such as forced labor and child labor, we will continue to conduct reporting and engage with our business partners.

UK Modern Slavery Act 2015 MS&AD Holdings

Implementation of Human Rights Due Diligence

Our group relies on the UN "Guiding Principles on Business and Human Rights" and has established a human rights due diligence mechanism as part of our management system for respecting human rights. We are committed to implementing this mechanism continuously. In line with our Human Rights Policy, established on February 2017, we are conducting human rights due diligence as follows.

STEP1: Identification and assessment of adverse impacts on human rights

Our group has organized points of contact where human rights risks may arise within our value chain and stakeholders and identified priority issues in human rights initiatives. Steps taken are as follows.

 

<Priority Issues>
(i) Fair and impartial customer service 
(ii) Consideration of human rights measures by underwriters, investors and external contractors 
(iii) Consideration for employee health and a workplace environment free of discrimination.

 

We conduct the identification and assessment of adverse impacts on human rights every three years as a general principle. We regularly review and determine priority issues based on changes in our group and the surrounding society and environment within our value chain. The initial evaluation was conducted in the fiscal year 2021, taking into account the Ministry of Economy, Trade and Industry's “Reference Material on Practical Approaches for Business Enterprises to Respect Human Rights in Responsible Supply Chains” as well as the overall reflection of human rights initiatives at our overseas entities. The reevaluation of the 2021 assessment was carried out in the fiscal year 2023.

Process of Identification and assessment of adverse impacts on human rights

Identification and assessment Process① Identify and organize any contact points among the Group’s value chain and stakeholders whence human rights risks may arise.

【Value Chain】
(1) Provision of products/services development and sales (including collection of insurance premiums), risk consulting services, insurance payment (including accident investigation personnel)
(2) Management Process: Asset management (including investments and loans), information management, procurement (materials and real estate), human resources/recruitment
【Stakeholders】
Customers, shareholders, business partners, agents, employees, local and international communities, and environment
【Human rights issues】
(1) Discrimination (recruitment, employment and working conditions) (2) Occupational health and safety (3) Excessive and unreasonable working hours (4) Harassment (5) Freedom of association (6) Discrimination (freedom of thought, religion and expression) (7) Defamation and invasion of privacy (8) Consumer safety and the right to know (9) Rights of foreign workers (10) Forced labor (11) Child labor (12) Rights of indigenous peoples and local residents (13) Participation in conflict and inhumane acts (14) Others
Identification and assessment Process② Assess and analyze such risks identified in terms of [1] severity*1 and [2] impact・probability of occurrence (creation of a risk map*2)

(*1) Severity is assessed based on the scale, scope, and difficulty of remediation of the estimated damage
Identification and assessment Process③ Based on the results of the assessment process 2, we have identified significant risks and organized them by stakeholder. From these, we have determined the priority for our human rights-respecting initiatives, prioritizing the issues that require immediate attention.

[Priority Issues]
(1) Fair and impartial customer service
(2) Consideration of human rights measures for underwriters, investors, and external contractors
(3) Consideration for employee health and a workplace environment free of discrimination
Identification and assessment Process④ Consideration and implementation of necessary preventive and improvement measures, and review of their effectiveness.

STEP2: Prevent, Mitigate and Implement Corrective Measures

For each identified priority issues in our human rights-respecting initiatives, we have taken preventive and mitigating measures, as well as corrective actions when necessary. Practical measures for prevention and mitigation include conducting training programs, educational and awareness activities, and establishing internal systems and environments are examples.

■Key preventive and mitigating measures for each priority issue in human rights initiatives

Operational sites with preventive and mitigating measures

46 Entities*

Key preventive and mitigating measures

Fair and impartial customer service

■Comprehensive implementation of customer-first operations
・Implementing initiatives in accordance with A Customer-first Policy in the Business Operations and strive for continuous quality improvement and business enhancement.
■Comprehensive Customer Information Management
・Implementation of information management training to improve information literacy and training on e-mail targeted attacks
・Promoting understanding of human rights initiatives while confirming the information management system through regular inspections and audits for insurance agents, outsourcers, and employees.
Information Management
Group Basic Policy for Management of Outside Vendors
■Consideration for the elderly and persons with disabilities
・Adoption of universal design principles
・Establishment of a dedicated dial-up call service for the elderly and preparation of a response manual
・Introduction of sign language interpretation services

Consideration of human rights measures for underwriters, investors, and external contractors

■Underwriters and investors
In September 2020, we formulated the "Business Activities Considering Sustainability" group policy and implemented business activities considering ESG factors. We consider human rights, including respect for human rights, in insurance underwriting and financing. In July 2022, we established that we will not engage in insurance underwriting and financing for cluster munitions manufacturers that can lead to indiscriminate killings and for manufacturers of inhumane weapons such as biological and chemical weapons and anti-personnel landmines that can lead to indiscriminate killings. We globally conduct insurance underwriting and financing in line with these guidelines. Additionally, for businesses that may potentially violate the human rights of indigenous peoples and local communities, we carefully assess the appropriateness of conducting transactions based on considerations for the local communities of our business partners.
■External Contractors/Agents
To ensure that our business partners (all external contractors) understand our group's commitment to respecting human rights, we distribute our human rights basic policy. For external contractors selected based on risk assessment, we conduct investigations into their organizational structure and provide human rights awareness training tools (such as the human rights policy development guide and internal training materials), as well as communicate and share relevant information on human rights initiatives.

Consideration for employee health and a workplace environment free of discrimination

■Promotion of health management
・Interviews with industrial physicians regarding long working hours, reinforcement of measures to prevent mental illness (use of educational activities and rehabilitation programs that contribute to prevention), utilization of flexible work management, and promotion of health checkups
■Measures against harassment
・In addition to systematic management of working hours, our Group is promoting workstyle reforms for employee health and safety.
・A speak-up system (internal reporting system) and consultation desks have been established. Dissemination of the reporting system and creation of an environment that makes it easy to consult with contact points

Speak-Up system

■Promotion of understanding and awareness concerning LGBTQ

・Implementation of internal seminar to promote understanding of LGBTQ

*The primary businesses undertaken by MS&AD Holdings and its Group companies (subsidiaries and affiliates), and the main Group companies undertaking each business as of March 31, 2023

■Organizational structure for promoting human rights initiatives

The Sustainability Promotion Department of MS&AD Holdings takes the lead and collaborates with the department responsible for overseas compliance and the department responsible for promoting human rights awareness in business companies to promote human rights initiatives both domestically and internationally. Business companies, primarily organized around officers in charge of human rights awareness, aim to deepen the understanding of human rights and corporate social responsibility, foster a culture of human rights within the organization, and enhance awareness of respecting human rights among employees.

<Major initiatives>
• Planning and formulating as well as implementing and managing workplace training programs for all employees
• Raising role awareness of employees involved in human rights education.
ESG Data / Reference Material(Human Rights)

■Promotion of a Sound Relationship with the Labor Union

In the MS&AD Group, the Company and the labor union respect each other's position by complying with agreements in good faith and by engaging in efforts to maintain and improve the company's democratic and healthy development, the employee's working conditions, and their position.Based on the agreement, negotiations and consultations are carried out in the context of wages, personnel systems and operations, work environment, and management plan.

 

<Measures to prevent various types of harassment>
In our group, we declare our commitment to respect human rights, in accordance with our Human Rights Policy and Compliance Policy. We pledge not to engage in discrimination or harassment based on race, nationality, gender, age, occupation, region, creed, disability, or any other factor, including sexual harassment, workplace harassment, and other forms of harassment. In the event that a case requiring remedy arises, we have established the following system to receive reports and consultations from employees and others and provide appropriate remedial measures.

ESG Data/Reference Material (Labor union membership rate)
ESG Data / Reference Material (Speak-up System)

STEP3: Evaluation of the effectiveness of initiatives (Monitoring)/ STEP4: Information Disclosure

We conduct regular evaluations (monitoring) on the effectiveness and implementation of prevention, mitigation, and corrective measures for human rights issues identified and assessed through STEP 1 and STEP 2. Additionally, we provide explanations and disclose information on various initiatives related to respecting human rights through our annual Sustainability Report, website, and other channels.

■Example Initiatives of evaluations(monitoring)

Fair and impartial customer service

■Protection of personal information
Each Group company establishes internal regulations on information management, introduces security measures, and provides education to employees and agents, according to the MS&AD Insurance Group Basic Policy for Management of Customer Information.
To verify the management systems, we regularly conduct inspections and audits of agents, outside vendors, and employees, and promptly implement remedial measures against any found problems.

<Fiscal Year 2023 inspections and audits>
Internal inspections were carried out at the Company and the Group’s domestic insurance companies. We inspected and audited around 25,000 agents and outside vendors, and provided instructions including to strengthen security to approximately 393 companies.

Information Management
Group Basic Policy for Management of Outside Vendors

Consideration of human rights measures for underwriters, investors, and external contractors

■Underwriting and Investments
Based on our "Business Activities with Consideration for Sustainability" group policy, we annually review the underwriting situation to ensure compliance with the policy and make improvements or corrections as necessary, including suspending underwriting if needed. In the regular reassessment of the impact on human rights, we identify countries or regions with high human rights risks based on the Fragile States Index. For our business operations in Myanmar, we conduct due diligence on our investees to confirm that there are no human rights issues.

■External Contractors/Agents
We regularly confirm the implementation of a system for respecting human rights and provide support for necessary organizational improvements as needed.

■Agents/ Foreign technical intern trainees
Regarding the employment status of foreign technical intern trainees, we conducted interviews with relevant departments within our group. While no specific problem cases have been identified, we will continue to follow up on this matter. Additionally, we regularly conduct audits of the labor environment and conditions by third parties to ensure and maintain appropriate working conditions.

Consideration for employee health and a workplace environment free of discrimination

■Creating a safe workplace environment (compliance with labor safety and health laws)
Within our group's domestic insurance companies, we have established hygiene committees based on the Labor Safety and Health Act to investigate and deliberate on matters related to preventing occupational health disorders and promoting health. These committees hold monthly.
・We conduct an annual survey to gauge the awareness of our group's employees, which we use to consider improvements to company systems, policies, and environmental arrangements. Since fiscal year 2019, this survey has also been extended to employees based in overseas locations

Targets (KPI) and Results

Remedy (Consultation Desk)

In our group, we have established a system to promptly address any voices or reports regarding potential human rights violations and ensure appropriate remedial measures are taken if necessary.

Schemes for Receiving Feedback from Customers

Schemes for Receiving Feedback from Customers

We widely accept various voices such as "consultations," "requests," and "complaints" from customers, and stipulate that they will be used to improve quality.

Quality that Earns the Trust of Society

■Reporting System from Employees (Speak-up System)

In our group, we declare our commitment to respect human rights, in accordance with our Human Rights Policy and Compliance Policy. We pledge not to engage in discrimination or harassment based on race, nationality, gender, age, occupation, region, creed, disability, or any other factor, including sexual harassment, workplace harassment, and other forms of harassment. In the event that a case requiring remedy arises, we have established the following system to receive reports and consultations from employees and others and provide appropriate remedial measures.

Reporting System from Employees (Speak-up System)

In order to prevent violations of laws and regulations, violations of internal regulations and inappropriate conduct from being neglected, the MS&AD Insurance Group has in place a reporting and Internal and external consultation services, the Speak-up System, through which employees can report any concerns so the company can promptly identify the facts and take necessary measures. With this system, our Group pushes ahead with compliance with ethics, laws, and regulations.

<Examples of cases which could be reported and consulted>
•    Any matters related to non-compliance
•    Issues related to violation of MS&AD Insurance Group Basic Policy on Human Rights
•    Issues related to employees’ mental and physical health and other issues caused by sexual harassment, power harassment, or any other types of harassment
•    Any matters related to working environment, such as work hours and overtime work

We have made efforts to enable informers and consulters to easily use the system. We protect the informers and consulters by ensuring the informers and consulters’ privacy and protect their information. We also make sure the informers are not treated disadvantageously. We have also set up an external contact point at an outside law firm.

For officers and employees working at overseas entities, we have established a global reporting contact in addition to the reception desks at our domestic offices. We respond to reports in 16 languages, and it is possible to report to the Japanese head office from overseas.


<Corrective Measures>
In response to reports or consultations:
- Depending on the nature of the report or consultation, the appropriate department will conduct a factual investigation.
- If the reported information is confirmed to be violating laws and regulations, internal regulations and inappropriate conduct from being neglected, appropriate actions will be taken, such as disciplinary measures, warnings, or guidance.

ESG Data / Reference Material (Speak-up System)

Harassment Consulting Desk

We have set up a dedicated harassment consulting desk to make sure that employees who feel victimized can consult staff with peace of mind about sexual harassment, power harassment, and maternity harassment cases. Based on verification of facts through prompt investigation, if deemed necessary, corrective measures and actions will be taken in accordance with internal regulations. The company is also making efforts toward prevention of harassment by providing education such as workplace training programs for all employees, level-specific training programs, and e-learning.

■Whistleblowing and Consultation System for Value Chain and Supply Chain (External Contractors):
 

Human Rights Issues Consulting Desk

Establishment of consultation desk mainly for our group's outsourcing partners, utilizing the platform of a specialized organization that relies on the UN "Guiding Principles on Business and Human Rights".
Through this consultation desk, we are working to promptly identify information on human rights violations in our value chain, further strengthen the corrective activities, and improve transparency in problem-solving processes.

Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) 
 

Engaging dialogue with our various stakeholders

In order to promote our commitment to respecting human rights, it is important to understand how our business activities are perceived by stakeholders and the impact they have. In our group, we engage in dialogue with stakeholders throughout the processes of human rights due diligence, which is our management system for respecting human rights. We leverage these dialogues to inform and enhance our initiatives.

Dialogue1: Discussion with NGO on Our Group’s Human Respect Initiatives

In December 2023, a discussion on "Respect for Human Rights Initiatives" took place between Mr. Hideki Wakabayashi (Board member of the Japan NGO Center for International Cooperation (JANIC) / Director of THINK Lobby) and MS&AD Holdings CSuO and members from the Sustainability Promotion Department.
【Outline of the Discussion】
・Date: December 2023
・Method: In-person meeting. Prior to the discussion, a survey was conducted to gather opinions on our group's initiatives. The discussion was based on the survey questions.
・Participants: Mr. Hideki Wakabayashi, board member of the Japan NGO Center for International Cooperation (JANIC) and Director of THINK Lobby, MS&AD Holdings CSuO and members from the Sustainability Promotion department.

【Human rights due diligence and operations 】
After receiving a briefing on the latest developments in business and human rights in Japan and various countries from Mr. Wakabayashi, we had a lively exchange of opinions based on the questionnaire on our company group's commitment to respecting human rights that was previously answered.It was pointed out that human rights risks are risks to people, and that enhancing corporate value should ultimately be achieved through addressing these risks. It was also emphasized that all employees need to understand that human capital, including human rights, is supported by social and natural capital.

MS&AD Holdings will reflect the insights and opinions obtained through the discussion, and strive for further enhancement of our commitment to respecting human rights and disclosure of information.
●The risks pointed out through this dialogue have been reflected in the risk map revised on March 2024
 

Dialogue2: Discussion with NPO on Our Group’s LGBTQ Rights Initiatives

Ms. Maki Muraki
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Ms. Maki Muraki

In December 2023, a discussion on "Respect for LGBTQ Rights Initiatives" took place between Ms. Maki Muraki (Founder/Director of NPO Nijiiro Diversity) and members of the Sustainability Department at MS&AD Holdings.

【Outline of the Discussion】
・Date: December 2023
・Method: Online meeting. Discussion on the group efforts and issues under review.
・Participants: Ms. Maki Muraki, Founder and Director of NPO Nijiiro Diversity, 
and members of the Sustainability Department at MS&AD Holdings.
【Our Group’s LGBTQ Rights Initiatives】
Ms. Muraki briefed us on the latest developments in LGBTQ-related issues in the Japanese government and companies, as well as the difficulties and mental/physical health faced by LGBTQ people. Following that, we held a discussion on the group's LGBTQ rights initiatives, focusing mainly (i) Initiatives for customers and (ii) Initiatives for our group employees.

(i) Initiatives for customers
It was pointed out that as expected from insurance companies, we need to recognize the LGBTQ issues in underwriting and procedures, promote understanding of LGBTQ initiatives for our group employees and agents, and improve our responsiveness to LGBTQ people.

(ii) Initiatives for our group employees 
We discussed various initiatives, including the establishment of employee groups for LGBTQ understanding and support (ALLY), the operation of an employee consultation desk, employee education and awareness programs, and recruitment practices. We also exchanged opinions on the specific methods of these initiatives and effective ways to inform them to our employees.

MS&AD Holdings will reflect the insights and opinions obtained through discussions into the development of internal guidelines and take specific initiatives, to promote the Group’s LGBTQ Rights Initiatives.

●Valuable insights discussed through this dialogue have been reflect to the making of inhouse guidelines.