The Gakken Group has established the Gakken Group Procurement Guidelines under the Gakken Group Procurement Policy for the Group to work together and for suppliers to understand this Policy. We will continue our dialogue to provide better services and procurement.

Gakken Group Procurement Policy and Guidelines

Guidelines follow each policy.

Gakken Group will conduct procurement activities with consideration for environmental protection, safety, human rights, and other issues in order to meet the expectations and needs of our stakeholders, including a wide range of customers from infants to the elderly, and to realize a sustainable society in which “everyone has fulfilling lives,” as stated in Gakken Group’s mission. We believe that these activities are not only our social responsibility to fulfill, but also the responsibility of all suppliers who are important partners of the Group. We look forward to the implementation of procurement activities based on cooperation and collaboration.

1. Compliance with Laws, Regulations, and Social Norms

We will not only comply with the laws and regulations of the countries and regions in which we operate and with international standards such as the ISO20400 Guidelines for Sustainable Procurement, but also strive to provide the education necessary for responsible procurement, protect human rights, ensure compliance, and conduct our business activities based on a high level of ethics.

(a) Anti-corruption

We will never engage in any kind of bribery, corruption, extortion, embezzlement, etc. We will also develop anti-corruption policies and education systems.

(b) Import and export control

We will comply with all laws and regulations related to imports and exports. In addition, we will have no relationship with countries, regions, organizations, or individuals subject to international economic sanctions regarding the provision of funds or materials for products or raw materials, or wages as compensation for labor.

(c) Development of a whistle-blowing system and protection of whistle-blowers

We will introduce a system to properly handle reports and consultations regarding systematic and individual misconduct from both inside and outside the company. We will strive to prevent, detect, and correct human rights violations and misconduct at an early stage, and will ensure thorough human rights protection and compliance. In addition, we will protect the confidentiality of the reported information and the anonymity of whistle-blowers, and we will not treat them unfavorably.

(d) Cutting off ties with anti-social forces

We will have no connection with anti-social forces. We will also take measures to cut off relations with anti-social forces, confirm that our suppliers are not anti-social forces, and stipulate clauses in various contracts that exclude anti-social forces.

2. Respect and Protection of Human Rights

We will comply with the laws and regulations of the countries and regions in which we operate and with international human rights standards, and respect social norms based on the environment, culture, religion, customs, etc. of those countries and regions. In addition, we will strive to respect and protect the human rights of all people involved in procurement, including prohibiting all forms of forced labor and child labor, and will work to reduce human rights risks throughout the supply chain.

(a) Prohibition of forced labor

We will not use labor obtained through forced, bonded, inhumane prisoner labor, slavery, or human trafficking. We will also not force any and all employment and will protect the right of workers to leave or terminate their employment of their own accord.

(b) Prohibition of child labor and consideration for young and elderly workers

We will not allow children under the minimum working age to work. In addition, we will not allow young workers under the age of 18 to work night shifts, overtime, or any other hazardous work that may compromise their health and safety. We will take physical and mental care of elderly workers.

(c) Prohibition of inhumane treatment

We will respect the human rights of workers and will never conduct inhumane treatment, including mental or physical abuse, coercion, discrimination, and harassment, as well as will never engage in any conduct that could lead to such treatment to workers.

(d) Achieving diversity, including employment of persons with disabilities

We will strive to achieve a legal employment rate to realize a society where people, with or without disabilities, can work together. We will also put in place a working environment for foreign nationals and sexual minorities.

(e) Corrective and remedial measures

In the event of any negative impact on human rights, we will work together to remedy the situation. We will also establish a system for consultation and reporting.

(f) Respect for local community norms

We will not engage in business activities that impede the survival and health of residents.

3. Protection of Rights and Development of a Favorable Working Environment

We will not only comply with the laws and regulations of the countries and regions in which we operate, but also pay attention to the Guidelines for Occupational Health and Safety Management Systems of the International Labour Organization (ILO) and other relevant guidelines to protect the rights of employees protected by various laws and regulations. We will also work to create a safe and hygienic work environment that minimizes work-related injuries and mental and physical illnesses. In case of a disaster, we will minimize the accident, followed by ensuring the prescribed procedures, including immediate reporting to prevent its recurrence.

(a) Occupational safety

We will identify and evaluate risks to working safety, and ensure safety through appropriate design, planning, technology, and control measures. The above risks to safety include the risk of workers being exposed to harmful biological, chemical, and physical effects, physically demanding work environments and tasks, as well as machinery and equipment.

(b) Healthcare, safety and health

We will ensure proper safety and health in facilities (dormitories, cafeterias, restrooms, etc.) provided for the livelihood of workers. In addition, we will provide appropriate healthcare for all employees.

(c) Health and safety awareness

We will provide workers with proper safety and health information, education, and training on the various working hazards that workers may be exposed to, in language and methods that they can understand.

(d) Consideration of working hours

We will not allow workers to work beyond the limits set by the laws and regulations in the regions where they work. Taking into account international standards, we will appropriately manage their working hours and days off.

(e) Appropriate wages and benefits

We will comply with all applicable laws and regulations regarding compensation paid to workers (including minimum wage, overtime pay, and legally mandated benefits and wage deductions).

(f) Workers' rights

We will comply with the laws and regulations in the regions where workers work and will not infringe on workers' rights. We will also build good relationships with workers through healthy and sincere dialogue.

4. Environmental Considerations

We will implement controls to reduce environmental risks and minimize environmental impact by reducing CO₂ emissions from our operations, promoting efficient energy use and renewable energy, using resources efficiently, using water appropriately, managing chemical substances and waste, preserving biodiversity, and other measures, and will procure raw materials in accordance with these controls. Furthermore, we will procure raw materials from responsibly managed forests and use sustainable production methods and transportation, given that the production of paper uses large amounts of forest resources, water, and energy.

(a) Compliance with environmental laws and regulations

In accordance with environmental laws and regulations in the regions where our business is located, we will obtain necessary permits and approvals for our business and will register, monitor, and report on our activities. In addition, we will promptly disclose emergencies such as spills of hazardous substances.

(b) Reduction of energy and greenhouse gases

We will strive to improve energy efficiency and continuously reduce energy consumption and greenhouse gas emissions. We will also disclose greenhouse gas emissions from production as much as possible.

(c) Proper management of water

We will comply with laws and regulations, monitor the source, use, and discharge of water used, and thereby conserve water. Any wastewater will be characterized, monitored, controlled, and treated as necessary before discharge or disposal.

(d) Effective use of resources and reduction of waste

We will promote reduction, reuse, and recycling, and will strive for the effective use of resources to minimize waste generation.

(e) Biodiversity conservation through the use of appropriate materials

In the procurement of raw materials, we will avoid and minimize the impact on biodiversity as much as possible and will avoid the use of illegally harvested, cultivated, or traded natural resources. In business activities that may have an impact on living organisms and their habitats, we will reduce the impact on biodiversity by taking measures to mitigate the impact and taking measures in accordance with relevant regulations in raw material procurement locations.

For paper in particular, we will ensure the traceability of wood materials and confirm that the materials come from properly managed forests.

(f) Pollution prevention and proper management of chemical substances

We will identify, label, and manage chemicals and other substances that pose risks to humans and the environment to ensure safe handling, movement, storage, use, recycling or reuse, and disposal.

5. Fair and Equitable Transactions

In selecting suppliers for procurement activities, we will appropriately evaluate quality, safety, ESG initiatives, prices, delivery times, as well as management conditions, to provide fair, equitable, and free opportunities for competition.

(a) Fair conduct of business

We will respect free and fair competition and abide by the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade and other laws and regulations as well as internal rules. In addition, when conducting transactions, we will follow sound business practices under appropriate conditions and will not impede fair and free competition.

(b) Prohibition of unauthorized use of intellectual property

Patents, trademarks, copyrights, trade secrets, utility models, and designs are important intellectual property, and we will comply with various laws and regulations to ensure that our company does not infringe these rights as well as not allowing the infringement of our rights.

(c) Fair and equitable opportunity

We will provide all suppliers with fair and equitable entry opportunities and evaluate them appropriately.

(d) Strengthening partner relationships

We will establish partnerships based on mutual understanding and trust with our suppliers and aim to prosper together.

6. Quality and Safety

We will not only comply with various laws and regulations regarding the safety and quality of the products and services we provide, but also establish a system that emphasizes quality control and provide accurate information.

(a) Ensuring product safety

We will provide products that meet the safety standards set forth by the laws and regulations in each country. We will fulfill our responsibilities as a supplier by designing, manufacturing, and selling products that ensure sufficient product safety especially for infants, children, and the elderly.

(b) Quality control

In addition to complying with all applicable laws and regulations regarding the quality of products and services, we will also comply with our company’s quality standards and the Gakken Group’s requirements.

(c) Providing accurate product and service information

We will provide accurate and non-misleading information about our products and services.

7. Information Management and Prevention of Confidential Data Leaks

We will prevent leaks of confidential and personal information, strengthen information security, and take protective measures against cyber-attacks and other threats.

(a) Defense against cyber-attacks

We will take defensive measures against threats from cyber-attacks and the like, and take control to prevent damage to our company and others.

(b) Personal information

In compliance with all relevant laws and regulations, we will properly manage and protect all personal information of our company’s suppliers, customers, consumers, employees, etc.

(c) Prevention of leakage of confidential information

We will properly manage and protect confidential information received from customers and third parties to prevent leakage.

8. Formulate Plans for Emergency Situations

In preparation for emergencies such as disasters and accidents, we will minimize the impact of such emergencies by preparing countermeasures and ensuring that all employees are aware of these countermeasures.

(a) Actions according to each company's BCP

Initiatives to prepare for disasters and other emergencies will be carried out by each company's BCP.

(b) Regular training

While considering residents, we will implement disaster countermeasures that minimize damage to ensure the safety of our employees as the top priority, and will conduct training regularly.

Establishment of management system

We will endeavor to establish a management system to ensure compliance with these Guidelines. If there is a problem in compliance with these Guidelines, we will promptly report it and make efforts to improve the situation.

(a) Monitoring compliance with the Procurement Guidelines

We will establish a monitoring system to monitor the status of compliance with these Guidelines and strive to provide safety and security to our customers, co-exist and co-prosper with our suppliers, and promote these Guidelines. We will also accept requests for disclosure and sharing.

(b) Improvement and correction

If the results of the monitoring find that there is any non-compliance with these Guidelines, we will make efforts to improve and correct the situation.

 

As of March, 2023 (Policy)

March, 2024 (Guidelines)