Human Rights Due Diligence

Human rights due diligence process

In accordance with the United Nations Guiding Principles on Business and Human Rights, we have established a human rights due diligence* process to ensure that we respect the human rights of all stakeholders affected by our business activities.

[Note]
  1. *
    Human rights due diligence is an appropriate and ongoing corporate initiative to human rights.
Human Rights Due Diligence Process

Mapping human rights risks

We have mapped human rights issues that are at risk of negative impacts due to our business activities. Based on the human rights due diligence process, we have identified and evaluated the actual and potential human rights impacts of these risks.

For human rights risks that are actually occurring, we will work to resolve the problems by removing negative impacts and, if necessary, implement appropriate remedies for victims. We will also implement appropriate measures to mitigate potential risks.

The mapping is conducted by evaluating the residual risk values after various countermeasures have been implemented for each risk item. Moreover, the mapping items will be reviewed on an ongoing basis.

[Note]
  1. *
    Since FY2022, we have renewed our assessment criteria for human rights risks. It is based on our general risk assessment criteria with the addition of the difficulty of remediation (the possibility of remediation in the event of human rights violations).
Human Rights Risk Mapping

Identification and assessment of
negative human rights impacts

As part of our human rights due diligence, we have been conducting assessments to identify human rights risks in key segments since FY2020.
The key themes, targeted segments, and assessment results for the FY2023 assessment are as follows.

Key themes in assessment
  1. Ⅰ.
    Basic attitude toward human rights and Major initiatives
  2. Ⅱ.
    Prohibit forced labor, trafficking in persons and child labor (avoidance of complicity in human rights abuses)
  3. Ⅲ.
    Prohibition of harassment and discrimination
  4. Ⅳ.
    Reduction of working hours
  5. Ⅴ.
    Appropriate wages and benefits
  6. Ⅵ.
    Employees' freedom of association and right to organize
  7. Ⅶ.
    Respect for the environment and local communities

(Attached: Human Rights Self-Assessment Items)
(PDF: 772KB/4 pages)
Targeted segments
  1. 1.
    Value chain
    1. (1)
      Key suppliers
    2. (2)
      Sales agents operating SoftBank shops and Ymobile shops
  2. 2.
    Our Group companies: Own business (Softbank Corp. and subsidiaries), joint ventures (affiliates, etc.)
  3. 3.
    Investment targets at the time of considering investment
  4. 4.
    Employees of the Company

List of assessment results

Category Domestic / Overseas Number of Targets Companies Assessed % of Total Assessed Companies with Identified Risks % of Total Assessed Where Risks Have Been Identified Sites with risk mitigation plans and implemented mitigation plans % of Risk with mitigation Actions Taken
Value Chain
Key Suppliers*1 Domestic / Overseas 65 65 100% 2 3% 2 100%
Store Management / Sales Agent*2 Domestic 83 83 100% 6 8% 6 100%
Overseas Sales Agents Overseas 1 1 100% 0 - - -
Total 149 149 100% 8 5% 8 100%
Our Operation
SoftBank and our subsidiaries*3 Domestic 119 106 89% 11 10% 11 100%
Overseas 50 39 78% 2 5% 2 100%
Total 169 145 86% 13 9% 13 100%
Joint Venture
SoftBank affiliates, etc. Domestic 21 21 100% 2 10% 2 100%
Overseas 8 7 88% 0 - - -
Total 29 28 97% 2 7% 2 100%
Grand Total 347 322 93% 23 7% 23 100%
[Notes]
  1. *1
    Key suppliers are cumulative figures for the past 3 years
  2. *2
    Shop business is conducted only in Japan
  3. *3
    Only subsidiaries with at least one employee were assessed

Mitigation actions for major risk items

As a result of the FY2022 assessment, there were 23 assessment recipients in our value chain, own business, and joint venture that were subject to risk mitigation. The major potential human rights risk items identified at these targets and the actions made to mitigate the risks are listed below.

Potential human rights risks
Absence of commitment to respect for human rights Overall human rights risks for employees Inadequacies in the grievance mechanism Forced labor, Human trafficking, and Prohibition of child labor
Overview of potential risks There is no established human rights policy demonstrating the commitment to fulfilling the responsibility to respect human rights as a company, and there is a possibility that the management's awareness of human rights is low. There is a possibility of human rights issues arising due to inadequate surveys among employees of each company and insufficient awareness campaigns aimed at prevention and mitigation. There is no established consultation service, which is a mechanism for understanding and addressing human rights issues related to business activities, and there are cases where remedial actions cannot be taken when problems arise. The existence of technical intern trainees in the supply chain and whether their human rights are being protected are not being monitored, raising the possibility that forced labor and other abuses are occurring.
Mitigation Measures, Mitigation Remedial Plan, Number of Sites Covered Key Suppliers 2 companies - - -
Shop operation sales agents 5 companies 2 companies 2 companies 6 companies
SoftBank Subsidiary 8 companies 7 companies 2 companies 7 companies
Softbank affiliates, etc. (Joint Venture) - 2 companies 2 companies 1 company
Mitigation measure Common
  • Request for improvement efforts on risk items: Request for submission of improvement plans as necessary.
  • Providing SoftBank's response procedures, samples, and usage formats.
  • Introducing response procedures and best practice examples at seminars for group companies.
  • Tracing improvement status based on this year's assessments.
Individual
  • Establishment of human rights policies
  • Conducting human rights surveys for employees
  • Conducting training sessions for employees
  • Establishment of a human rights consultation office
  • Conducting investigations into the supply chain
    <Investigation items>
    • ①Hiring status
    • ②Management of third-party fraudulent salary deductions
    • ③Verification of employment routes (compliance with laws and regulations)
    • ④Proper management of passports
    • ⑤Establishment of consultation service for technical interns

Human rights assessment by segment

Human rights assessment for the value chain

As part of our value chain initiatives, FY2020 and onwards, we have been conducting ongoing self-assessments of our key suppliers and sales agents who operate SoftBank stores and Ymobile stores, which are our main sales channels and points of contact with customers etc., regarding their human rights initiatives and whether they are complicit in human rights abuses. In cases where human rights risks are identified in this assessment, efforts are being made to resolve and correct the problem. The assessment will be conducted regularly, and we will continue to monitor and propose improvements in order to further reduce risks.

Key suppliers

Since FY2020, our Company has conducted annual sustainability procurement surveys on key suppliers. In FY2023, NTT, KDDI, and our Company conducted the common SAQ*1 (self-assessment survey) for sustainable procurement to suppliers*2 subject to the survey.
Starting from FY2024, we will introduce the third-party assessment platform EcoVadis*3 to further enhance engagement with our business partners.

Global Compact Network Japan

Human rights Assessment Results for the Value Chain

Sales agents operating stores

Self-assessments were conducted for all 83 sales agents operating SoftBank stores and Ymobile stores (including stage stores in electronics retail stores) nationwide. As a result, no apparent human rights impacts were found. On the other hand, for the 6 companies where potential human rights risks were observed, we asked them to make improvements to items for which their efforts were insufficient and to request surveys of their suppliers as risk mitigation measures.
We also requested all agencies that conducted parallel surveys to further promote their efforts by introducing examples of human rights initiatives and providing other reference information.

[Notes]
  1. *1
    In FY2023, a standardized sustainability questionnaire was implemented among NTT, KDDI, and SoftBank. This SAQ extracts items related to environment, human rights and labor, health and safety, fair trade and ethics, quality and safety, information security, and other areas, designed for sharing between buyers and suppliers across industries.
  2. *2
    Target suppliers for the survey: key suppliers included in the top 89% of purchases in FY2023
  3. *3
    A sustainability assessment service composed of four parts: “Environment,” “Labor Practices and Human Rights,” “Ethics,” and “Sustainable Materials Procurement.”

Human rights assessment for group companies

Self-assessments on human rights were conducted for our company and 145 domestic and overseas subsidiaries, and 28 affiliated companies. As a result, no apparent human rights impacts were found. On the other hand, for the 15 companies (including 2 affiliates) where potential human rights risks were identified, we did not only requested improvements, but also provided support for improvement initiatives by providing manuals describing risk mitigation procedures, necessary survey forms, and educational content for employees at each company.
We will continue to implement these measures on a regular basis and strive to further reduce risks through continuous monitoring and improvement proposals.

Investment targets at the time of considering investment

In addition to human rights assessments for existing business activities, we also conduct human rights assessments for new business activities when developing new businesses from the perspective of respect for human rights. The assessment items cover important issues related to human rights, such as prohibition of forced labor, prohibition of discrimination, prohibition of harassment, respect for the right to organize, and prohibition of child labor, and passing the assessment has become one of our investment criteria.

Human rights assessment when considering joint venture investment

  1. Existence of policies to prevent human trafficking, forced labor, child labor, land grabbing, deforestation and mineral conflicts involving suppliers and business partners (contract workers).
  2. Existence or nonexistence of policy that seeks to eliminate discrimination in hiring, placement, evaluation, compensation and promotion practices based on race, ethnicity, religion, nationality, origin, gender, gender identity, sexual orientation, age, disability, disease and to ensure equality of opportunity and fairness in treatment including equal pay for equal work.
  3. Existence or nonexistence of a policy that respects the right of employees of the company to organize as a means of achieving labor-management consultation on working conditions and wages.

Human rights assessment for our employees

As part of our human rights due diligence, we conduct personnel interview measures and surveys with employees and take direct or indirect remedial measures when problems are found.

Conduct HR interviews / roundtable discussions with employees

The HR Division conducted HR interviews with employees from 2015 to 2021 to understand the condition of employees (cumulative total of 26,100 employees).
If any risks related to human rights were identified, we promptly took remedial action in cooperation with the relevant divisions. Furthermore, from 2022, we conducted roundtable discussions with HR department heads and employees at all nine major business locations nationwide (total participants: 166).
We will continue to place importance on dialogue with employees to understand and improve the actual situation onsite.

Conducted human rights survey for employees

Every year, we conduct training and provide educational content to employees on human rights, with a focus on discrimination and harassment. In addition, all employees are informed of a consultation service in the event of human rights violations, and efforts are made to prevent human rights violations before they occur. In cases where human rights violations do occur, we handle them strictly in accordance with the regulations.
Furthermore, we conduct an annual survey of all employees to identify any potential human rights violations. In FY2023, a survey was conducted 26,500 employees, and no responses were received requesting remedy for human rights violations in the workplace.

However, based on the results of the survey, we have identified eight issues (four of which are key issues) that could become human rights risks, and we are working with the divisions in charge to examine and implement measures to reduce these risks.
The results of this investigation and risk mitigation measures are made available to employees. We will continue to respect the human rights of our employees through continuous surveys and monitoring.

Subjects Potential risk items (key issues) Risk mitigation measures
Discrimination /
Harassment		 Abuse of authority Continuous training for employees and further expansion of content
Harassment related to pregnancy, childbirth, and maternity leave Continued implementation of employee training (maternity harassment, paternity harassment, caregiver discrimination and gender discrimination)
Discrimination on the basis of gender Ongoing training for employees (Unconscious Bias)
Age-related discrimination and harassment
  • Ongoing training for employees
  • Verification of age-related systems / ongoing consideration of their framework
Customer Harrasment
  • Establishment of a consultation service and mental health care system
  • Conduct training for employees (on correct understanding and how to deal with the situation)
Survey On Human Rights Questionnaire Items for Employees
(PDF: 176KB/1 page)

Individual surveys on specific themes where business-related human rights risks are anticipated

Since FY2020, as part of our human rights due diligence, we have identified initiatives to reduce human rights risks by focusing on specific themes in our business where we expect the human rights risks to be particularly high.
The survey was conducted in the form of interviews conducted by human rights staff with managers in charge of the subject theme, and included confirmation of on-site business processes and operational realities that are difficult to ascertain through quantitative questionnaires.

  1. Personal data management
  2. Consideration for the elderly / children and juniors / people with disabilities
  3. Safety management for contractors involved in the construction of base stations and other facilities
  4. Human rights management for the utilization of AI

Personal data management

As a telecommunications carrier, we hold personal data, including information about ourselves and about our customers and their use of our services.We recognize the management of such personal data as a human rights issue specific to our business.

As a result of the investigation, we have confirmed that we are appropriately managing personal data through the following measures.

Person in charge and organizational structure

The CDO (Chief Data Officer) is responsible for formulating policies and regulations regarding personal data, monitoring their operation and providing employee training. And in order to handle personal data from diverse perspectives such as laws and regulations, public opinion, and customer sentiments, we have established a specialized organization across the company.

Privacy Policy and Consultation Services

We have established a privacy policy in which we specify the purpose and scope of the use of personal data held by our company, and disclose it.
Furthermore, we have set up a customer consultation service to handle complaints regarding the disclosure of held data and the handling of personal data.

Information Security Policy Privacy
Handling of Personal Information

Preventing human rights violations through privacy impact assessments

When using privacy information, we strive to prevent human rights violations by assessing not only whether the information will benefit our customers and serve the public interest, but also whether it will infringe on privacy and cause disadvantages to our customers.

Privacy and customer care

Protection of Personal Data

In order to protect our customers' data, we are strengthening our system by assigning a person in charge of security, data utilization, and information systems.
Furthermore, we have established an information security policy and rules for data utilization, and conduct education and training for employees on a regular basis to disseminate and raise awareness of the concept and cautions related to data protection.

Continuous Security Enhancement

Consideration for
the elderly / children and juniors / people with disabilities

As a telecommunications carrier that provides public services, we believe that we have a responsibility to provide services that all users can use with peace of mind. In particular, the support and protection provided by telecommunications carriers is effective in respecting the human rights of older people, children and junior citizens, and people with disabilities.

As a result of the survey, we have confirmed that we are taking the following actions to ensure that we are appropriately taking care of these people.

Measures to support the elderly Kantan smartphone 3

SoftBank's Kantan Smartphone 3, for which we decided the specifications and entrusted the production to a device manufacturer, was developed to help hesitant users shift from feature phones to smartphones, and to protect elderly people from criminal behavior.

For the Senior Generation
Protection of children and junior generations Kids Phone 3 / Junior smartphone

To respect the rights of child users in their formative years, we have developed and provide Kids Phone 3 for elementary school students and Junior Smartphone for older children as devices and services designed with safeguards geared to each age group while protecting users from behavior that infringes human rights in networks.

Safety Concerns
Protection of people with disabilities Assist Guide

To respect the rights of children in need, we provide Assist Guide, a smartphone app that helps to facilitate their everyday life.

Understanding Disability

Safety management for contractors involved in the construction of base stations and other facilities

We are actively upgrading our wireless base stations to further improve the quality of our calls.

Cell phone wireless base stations are often installed on steel towers and buildings, so it is important to create a system to protect the safety of workers and ensure reliable operation at the site. Therefore, we positioned the safety of workers involved in base station construction as a human rights risk specific to the business, and confirmed that appropriate measures were being taken through the following initiatives.

Safety management of field workers

Human rights management for AI utilization

In our company, the utilization of AI is advancing in various fields of business, and we have conducted investigations into the impact on human rights, considering the expected diversification of utilization methods and the advancement of technology in the future.
The results of the survey confirmed that the company has established an ethical policy on AI and a governance structure based on the policy, and has put in place a system to manage human rights risks while improving convenience for customers through the introduction of AI.

Establishment of SoftBank AI Ethics Policy

In July 2022, we established and published the “SoftBank AI Ethics Policy”.
This policy establishes guidelines for six principles, including “Human-Centered Approach” and “Protection of Privacy and Security.” It outlines our commitment to conducting business operations and service development in accordance with these guidelines.

SoftBank AI Ethics Policy

Applying the Policy at Group Companies

The policy is ready to be applied to group companies, and as of July 2024, 74 companies have decided to apply the SoftBank AI Ethics Policy.

Establishment of governance structure

Various regulations and management systems are in place, including a governance structure to link policies to operations and an operational process to ensure that development is in line with policies at the service development stage.

Implementation of human rights awareness activities

Human rights awareness training

PRIDE Index Gold Rating

The SoftBank Code of Conduct stipulates the respect for human rights and the prohibition of discrimination and harassment, and we conduct human rights enlightenment training for employees in order to foster an awareness of respect for human rights within the company. In addition to training for new employees and new managers by job level, employees in managerial positions and above receive regular training on how to deal with reports of bullying and harassment, as well as consultations, and training at the time of appointment.
In 2023, we received the highest “Gold” rating on the PRIDE Index*, an evaluation index for LGBTQ initiatives, for the Seventh consecutive year.

[Note]
  1. *
    Indicators developed by the voluntary organization “work with Pride”.

List of training programs (FY2023)

Training title Training conducted Training type
Pledge to the SoftBank Code of Conduct All employees Other
Compliance training for new employees New employees / Mid-career employees e learning training
New Management Training New management positions e learning training
Compliance Test All employees e learning training
New: Harassment Prevention Course (Abuse of authority/ Sexual Harassment / Sexual Orientation and Gender Identity (SOGI) Discrimination) All employees e learning training
Harassment Prevention Course
(“What are Maternity Harassment, Paternity Harassment, and Caregiver Discrimination?”)		 All employees e learning training
Harassment Prevention Course
(Harassment using a position of superiority)		 All employees e learning training
Human Rights Training: “Business and Human Rights” All employees e learning training
Unconscious Bias Training All employees e learning training
Diversity & Inclusion Training Management positions Online training
Diversity Management Training Management positions Online training

Raising awareness among group companies

In an initiative to mitigate human rights risks for subsidiaries and affiliated companies, we provide a self-assessment tool on human rights that we utilize within our company. Based on the results of these assessments, we make individualized improvement requests to each company, aiming to mitigate human rights risks and enhance their commitment to human rights.

Specifically, along with the regular provision of information on the Company's human rights due diligence activities and relevant information to human rights personnel, in 2023 we provided knowledge focusing on our initiatives and content on introduction of Group company initiatives, and human rights training “Business and Human Rights”.

We will continue to check the status of human rights initiatives at each group company, and through interactive provision of information and sharing of know-how, we plan to continue to raise the level of human rights promotion activities throughout the group.