Policy
Sanwa Group has established the "Sanwa Group Compliance Code of Conduct," which concretize the principles and values that should be upheld when putting into action the group's shared values of "mission," "management philosophy," and "action guidelines." The group has always taken a stance of respecting human dignity, recognizing diverse individual values, and respecting individual personalities and uniqueness. In November 2023, considering the changing awareness and issues regarding human rights in the international community, the "Sanwa Group Human Rights Policy" was established.
Sanwa Group supports and respects international human rights norms, the International Bill of Human Rights, including the "Universal Declaration of Human Rights", the "International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work", and the "United Nations Guiding Principles on Business and Human Rights", and conducts its business activities accordingly.
Sanwa Group complies with the laws and regulations of the countries and regions where it operates, and respects internationally recognized human rights. Particularly, in cases where the laws and regulations of those countries and regions, or their enforcement, do not adequately protect internationally recognized human rights, the group will strive to respect those rights to the maximum extent possible.
If a violation of human rights occurs, we promptly take corrective action through appropriate procedures after sufficiently verifying the facts.
Sanwa Group Human Rights Policy
Approach to Respecting Human Rights
The Sanwa Group promotes initiatives to respect human rights based on the philosophy put forward in the "Sanwa Group Human Rights Policy". We also fulfill our commitment to respecting human rights by incorporating appropriate procedures into our business activities to help us achieve this goal.
To our customers
The Sanwa Group believes that improving product safety and quality is the most important responsibility of a manufacturer. We believe that providing products and services that provide safety, security, and convenience to society is the key to resolving social issues and that this in turn will lead to creating value for the Sanwa Group.
To our employees
The Sanwa Group respects the character and individuality of each person. In addition to legal compliance, we do not tolerate discrimination or harassment, and we respect the freedom of association and collective bargaining rights as fundamental rights of employees. In addition, we do not permit child labor or forced labor.
To our suppliers and distributors
The Sanwa Group emphasizes respect for human rights in our relationships with our suppliers and distributors. We strive to be the best partner to our suppliers and distributors, and to grow together with them through ongoing transactions.
Additionally, we advocate for the support of the "Sanwa Group Human Rights Policy" and the respect of human rights to our business partners, including our clients.
Rectification・redress
The Sanwa Group has introduced an anonymous internal whistleblowing system (Corporate Ethics Hotline) in Japan, the U.S., Europe and Asia to accept reports on the negative impact of Sanwa Group's business activities on human rights. In addition, we have developed a system to familiarize and ensure our employees understand our initiatives using native languages (or equivalents) in each region, displaying posters and distributing cards to employees in English, Chinese (simplified, traditional), Vietnamese, and Thai. We are working to increase trust by keeping reported information secret and prohibiting the adverse treatment of system users. If we determine that there has been an impact or intervention on human rights, we take remedies through appropriate procedures after sufficiently verifying the facts.
Educate and Instill
Training for managers at the Sanwa Group companies is conducted nationwide to raise compliance and human rights awareness and eliminate breaches of laws, regulations and rules. Furthermore, starting from the FY2024, we plan to implement e-learning training for all employees of the Sanwa group companies.
In addition, we distribute our Compliance Code of Conduct and Case Study Booklet to all employees. We have also designated November as Compliance Month during which we implement various initiatives to foster greater awareness of compliance, including respect for human rights.
Human rights due diligence
The process of human rights due diligence
Sanwa Group has established a human rights due diligence framework to minimize the negative impact on human rights and will continuously implement it.
Through this framework, we will work on identifying, preventing, and mitigating negative impacts on human rights. The human rights due diligence process is shown in the diagram below.

Human Rights Due Diligence Initiatives
- Identification and assessment of negative impacts on human rights
To identify and assess the actual or potential negative impacts (human rights risks) on the human rights of individuals potentially affected by Sanwa Group's business activities, we have created a human rights risk map as shown below, using the evaluation axes of impact on human rights (severity, number of people affected, possibility of remedy, etc.) and likelihood of occurrence. - Actions for appropriate response
We analyzed the importance of the need for measures against human rights risks based on the human rights risk map and determined the priority of responses. As a result, we conducted a written questionnaire survey on discrimination and harassment, labor and safety, and foreign workers, targeting a total of 57 companies, including major suppliers and in-house cooperative companies at our factories. - Evaluation
We did not identify any specific issues related to human rights in the survey results.
Moving forward, we will continue our efforts by expanding the scope of the survey, among other measures. - Disclosure and Communication
We will disclose information on the progress and results of our human rights due diligence by publishing it on our website, integrated reports, and securities reports, as well as explaining it at financial results briefings and stakeholder dialogues.
Additionally, we accept inquiries from stakeholders in our supply chain regarding any concerns that our business activities may have, or potentially have, negative impacts on human rights, through the inquiry form on the Sanwa Holdings corporate website.
Engagement Related to Human Rights
Collaboration with Stakeholders
The Sanwa Group engages in dialogue with our stakeholders on human rights issues related to our business activities and works to prevent human rights violations. We have established an internal whistleblowing system (Corporate Ethics Hotline) as an external point of contact for employees and affiliated companies, and we accept information from all stakeholders through the contact form on the Sanwa Holdings corporate website and at our Customer Center.
Disclosure
The Sanwa Group discloses corporate information in a timely, appropriate and proactive manner in order to gain the understanding and trust of our customers, shareholders, investors, local communities and other stakeholders.
Policy on Children’s Rights
The Sanwa Group believes that children, who will be the leaders of the next generation, are in a position where their rights are easily violated, despite their importance to the sustainable development of society. For this reason, the civil rights of children require special consideration. Based on this understanding, we support the Children's Rights and Business Principles for safeguarding children's rights, and we prohibit, within our Compliance Code of Conduct, and Sanwa Group Human Rights Policy, all forms of forced labor and child labor, including slavery and human trafficking. We also pursue social contribution activities aimed at improving rights of children. For example, we make donations to the Boys & Girls Clubs of America, which provides after-school programs in the U.S.
Compliance Code of Conduct and Case Study Booklet

The Compliance Code of Conduct and Case Study Booklet, which is distributed to all Group employees in Japan, is made up of two sections. The Compliance Code of Conduct outlines how to behave in day-to-day operations while the case studies provide detailed information and explanations on specific case examples. From the standpoint of respect for human rights, we strive to raise awareness of human rights by periodically reviewing content based on the latest social trends, which includes all forms of harassment, such as sexual harassment and workplace bullying, as well as specific case studies concerning LGBT issues.
Training program focusing on harassment

The Sanwa Group conducts compliance training, including tips for preventing harassment in the workplace, for managerial staff at domestic Group companies every other year. This training features learning and discussions on the responsibilities of managers, from daily communication to responding to reports/instances and handling this type of information.
In fiscal 2019, we conducted a training program focused on harassment for 854 people from top management, executives, and managers of domestic Group companies. We are also building a system for sharing actual reported cases and responding appropriately when we receive reports and consultations.
We also put up compliance posters in offices and factories (Group companies in Japan), striving to ensure that all executives and employees have a proper understanding of these issues and are aware that they relate to themselves.
Internal whistleblowing system (Corporate Ethics Hotline)
Anonymous reporting is available for early detection of violations of the human rights compliance code of conduct, including bullying and harassment, and for reporting suspicious behavior. An internal whistleblowing system (Corporate Ethics Hotline) has been established both internally and externally which ensure that information is treated as confidential.
To ensure reports can be made in the strictest confidence we have established a basic policy of never disclosing information that may identify the whistleblower to a third party without his or her consent, taking the utmost care to ensure that the whistleblower is not identified when examining the facts, and making sure that the whistleblower is not dismissed or otherwise treated disadvantageously simply for making a report.
Further, in FY2023 we received 87 reports (39 were made in Japan) through our internal whistleblower system, on a consolidated Group basis. We verified the facts and swiftly investigated each case. We are taking corrective action and seeking to remedy the situation through appropriate procedures in cases where a breach of compliance was confirmed.
The Sanwa Group’s internal whistleblowing system (Corporate Ethics Hotline) accepts reports on human rights and compliance violations not only from employees but also from temporary staff, installers, staff from affiliated companies working designers and staff from affiliated companies working inside our factories. In addition, reports from customers, local communities, business partners, people working in the supply chain and all other stakeholders are accepted through the Sanwa Holdings corporate website inquiry form and our Customer Center. If a report is made, the department in charge will conducts an investigation, considers corrective measures and strives to prevent recurrence.