[Title] National Action Plan on Business and Human Rights (2020-2025)

Table of Contents

Chapter 1. Towards the Formulation of the National Action Plan (NAP) (Background and Working Process)...P.2

1. Introduction: Increasing International Attention to Business and Human Rights and the Need for NAPs...P.2

2. Positioning of the NAP: Links with International Documents, including the UNGPs and the Sustainable Development Goals (SDGs)...P.5

3. Objectives to be Achieved through the Launch and Implementation of the NAP...P.6

4. The NAP Formulation Process...P.7

Chapter 2. Action Plan...P.8

1. Fundamental Principles of the NAP...P.8

2. Areas of the NAP...P.9

(1) Cross-Cutting Areas...P.10

A. Labour (Promotion of Decent Work)...P.10

B. Promotion and Protection of Children's Rights...P.11

C. Human Rights Associated with the Development of New Technologies...P.13

D. Rights and Roles of Consumers...P.14

E. Equality before the Law (Persons with Disabilities, Women, Persons of

Diverse Sexual Orientation and Gender Identity, and Other Groups)...P.15

F. Acceptance of and Coexistence with Foreign Nationals...P.17

(2) Measures of the Government as an Actor regarding State Duty to Protect Human Rights...P.18

A. Public Procurement...P.18

B. Development Cooperation and Development Finance...P.19

C. Promotion and Expansion of the Business and Human Rights Agenda in the International Community...P.20

D. Human Rights Education and Awareness-Raising...P.21

(3) Measures of the Government Promoting Corporate Responsibility to Respect Human Rights...P.23

A. Measures Related to Domestic and Global Supply Chains and Promotion of Human Rights Due Diligence Based on the UNGPs...P.23

B. Support for Small and Medium Enterprises (SMEs) regarding Business and Human Rights...P.25

(4) Measures regarding Access to Remedy...P.26

Judicial and Non-Judicial Remedy...P.26

(5) Other Measures...P.29

Chapter 3. Government's Expectations towards Business Enterprises...P.30

Chapter 4. Framework for Implementation and Review of the NAP...P.31

Appendix I : Lists of Members of the Advisory Committee for the NAP on Business and Human Rights and the Working Group for the NAP on Business and Human Rights...P.32

Appendix II: References...P.34

Chapter 1. Towards the Formulation of the National Action Plan (NAP) (Background and Working Process)

1 Introduction: Increasing International Attention to Business and Human Rights and the Need for NAPs

(1) With the increasing recognition of the importance of international roles of businesses in economic development, the impact of business activities on society has been attracting growing interest. This has led to a demand for business enterprises to engage in responsible conduct. International instruments considering business activities were also developed as exemplified by: the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises adopted in 1976, which are recommendations to multinational enterprises operating in or from its adhering countries, requesting enterprises to voluntarily engage in expected responsible business conduct; and the International Labour Organization (ILO) Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy (the ILO MNE Declaration) issued in 1977, which provides direct guidance to business enterprises on social policy and inclusive, responsible, and sustainable workplace practices.

(2) As the impact of business activities on human rights became recognized as part of their impact on society, attention given to respecting human rights in business activities further increased. In 1999, the UN Global Compact was launched as a voluntary initiative to realize sustainable growth through the actions of business enterprises and organizations as forces for good in society. The UN Global Compact called on business enterprises to follow ten universal principles in four areas, of which two areas (encompassing six principles) include human rights and labour.*1* In 2005, Professor John Ruggie of the Kennedy School at Harvard University was appointed as the UN Special Representative of the Secretary-General on human rights and transnational corporations and other business enterprises at the 69th session of the UN Commission on Human Rights. In 2008, Professor Ruggie then presented the "Protect, Respect and Remedy" Framework (UN Framework) at the 8th session of the Human Rights Council (HRC). The UN Framework categorizes relations between enterprises and human rights into three pillars: (1) the State duty to protect against human rights abuses by third parties, including business (2) the corporate responsibility to respect human rights, and (3) access to remedy. While the UN Framework clarifies the State duty and the corporate responsibility that relate to the impacts on human rights of business activities, it also places emphasis on the need for mechanisms enabling access to effective remedies, and lists specific areas and cases in which the relevant actors are expected to undertake their duty or responsibility. For the implementation of the UN Framework, Professor Ruggie drafted the Guiding Principles on Business and Human Rights for Implementing the UN "Protect, Respect and Remedy" Framework (the UNGPs), which were endorsed by consensus at the 17th session of the HRC in 2011.

(3) Following their endorsement, the UNGPs have increasingly received support from the international community. In September 2015, the UN General Assembly adopted the 2030 Agenda for Sustainable Development (the 2030 Agenda) with the Sustainable Development Goals (SDGs) at its core. With respect to private business activity, the 2030 Agenda articulated that the UN member states will "foster a dynamic and well-functioning business sector, while protecting labour rights and environmental and health standards in accordance with relevant international standards and agreements and other ongoing initiatives in this regard, such as the UNGPs and the labour standards of the International Labour Organization, the Convention on the Rights of the Child and key multilateral environmental agreements." Moreover, the 2015 Leaders' Declaration G7 Summit in Elmau stated that the G7 strongly supports the UNGPs and welcomes the efforts to set up substantive action plans. In the July 2017 Leaders' Declaration G20 Summit in Hamburg, G20 members, including Japan emphasized that they commit to fostering "human rights in line with internationally recognized frameworks, such as the UNGPs" and "work towards establishing adequate policy frameworks in our countries such as national action plans on business and human rights." Moreover, in response to the endorsement of the UNGPs, a chapter on human rights was added in 2011 to the 5th update of the OECD Guidelines for Multinational Enterprises, mentioned in paragraph (1) above. A reference to the UNGPs was added to the ILO MNE Declaration as part of the revision in 2017 as well. Furthermore, as part of the international efforts concerning business and human rights, the United Nations Children's Fund (UNICEF), together with various organizations, developed the Children's Rights and Business Principles as a supplementary instrument to the UNGPs, to set out ten principles for respecting and supporting children's rights through business action. Several human rights treaty bodies, including the Committee on the Rights of the Child and the Committee on Economic, Social and Cultural Rights, also pointed out the importance of business and human rights in their general comments.

(4) In response to the growing awareness of business and human rights principles, there has been an increasing trend, primarily in the United States and Europe, to introduce legislation requesting business enterprises to respect human rights, including in supply chains. Civil society and consumers also increasingly demand business enterprises to respect human rights. Moreover, in recent years, sustainable investments have been expanding, and institutional investors have also actively been engaged in constructive dialogue (engagement) with purpose with business enterprises. Indeed, investors expect business enterprises to disclose information about their human rights efforts and engage in dialogue based on the disclosed information. In this regard, international initiatives in various financial sectors have also addressed the business and human rights agenda, such as the United Nations Principles for Responsible Investment (PRI), which consider human rights as one of the key elements of the "S (social)" issues of ESG (environmental, social and governance) and cosequently, the business and human rights agenda becomes one of the important initiatives for EST investing. In 2020, the PRI published an investment action framework for institutional investors to achieve outcomes in line with the SDGs. Besides the PRI, the Principles for Sustainable Insurance (PSI) and Principles for Responsible Banking (PRB) were also developed. Likewise, stock exchanges in many countries, including Japan have been participating in the UN Sustainable Stock Exchanges (SSE) Initiative, promoting sustainability in the market. The move towards requesting business enterprises to respect human rights is thus gaining momentum not only among investors but also among the entire financial sector.

(5) In mega-sporting events such as the Olympic and Paralympic Games and other international events, respecting human rights is also expected, including compliance with the UNGPs. As Japan makes arrangements to host the Olympic and Paralympic Games Tokyo 2020 (Tokyo 2020 Games), which have been postponed to 2021, international attention has been focused on the attitude of Japanese society towards respecting human rights, including Japanese business enterprises' efforts. In this regard, preparations for the Tokyo 2020 Games are underway with the intention of making the Games the first Olympic and Paralympic Games to be held in accordance with the UNGPs.

(6) In response to the global trend, business enterprises are expected to demonstrate respect for human rights in business activities. Particularly, for business enterprises operating overseas, an international trend shows that business activities are evaluated in light of international standards, in addition to compliance with the laws and regulations of the countries where they operate. Consequently, business enterprises themselves are faced with a need to identify and address human rights-related risks in their business operations, including in supply chains.

(7) To date, the relevant ministries and agencies of Japan have implemented various legislative measures and policies contributing to the protection of human rights, and business enterprises have been responding to them. For example, Keidanren (the Japan Business Federation) revised its Charter of Corporate Behavior in November 2017 to add a principle on respect for human rights, and promotes human rights through the understanding of internationally recognized human rights norms, due diligence, information disclosure, and the creation of an inclusive society in its Implementation Guidance on Charter of Corporate Behavior. Small and medium-sized enterprises (SMEs) have been engaging in people-centered management in their business operations despite limited human and physical resources. They have also been undertaking business operations in ways that appreciate the local community and employees. Moreover, Japanese business enterprises have been engaging in unique and responsible business conduct when entering overseas markets, such as labour practices that enable business enterprises to prevent disputes and improve practices through good labour-management relations by employing distinctively Japanese approaches to technology, culture, and development of human resources.

(8) Nevertheless, further efforts are required, considering the current increasing social demands regarding business and human rights. Against this background, the Government launched Japan's National Action Plan (NAP) on Business and Human Rights. By arranging various legislative measures and policies contributing to the protection of human rights that were implemented individually by the relevant ministries and agencies, from the perspective of the business and human rights principles, the Government endeavors to contribute to the promotion of shared recognition and understanding among the relevant ministries and agencies, to enhance cooperation among the relevant ministries and agencies, and to ensure inter- ministerial policy coherence. Through the wide publication of the NAP, the Government aims to enhance business enterprises' understanding and awareness of business and human rights and to promote more efforts and cooperation by and among business enterprises. Through these measures, the Government expects to promote responsible business activities; contribute to the protection and promotion of human rights for society as a whole, including international society; enhance trust in and the reputation of Japanese business enterprises; and contribute to ensuring and enhancing the international competitiveness and sustainability of Japanese business enterprises.

(9) Currently, the COVID-19 pandemic has been spreading across borders and economic and social disruption has affected human rights in every part of the world. In particular, the most vulnerable segments of society have been severely impacted. Under these circumstances, UN Secretary-General António Guterres emphasized the importance of positioning human rights at the center of measures both in the current fight against COVID-19 and during the post-pandemic recovery. He also highlighted, towards the recovery phase, building "more equal, inclusive and sustainable economies and societies that are more resilient in the face of pandemics."

In the area of business and human rights, the Working Group on the issue of human rights and transnational corporations and other business enterprises (also referred to as the UN Working Group on Business and Human Rights) issued a statement stressing that the UNGPs are applicable to the context of the COVID-19 pandemic and focusing on the role of government to ensure responsible business conduct and on the business responsibility to respect human rights. Furthermore, the UN Working Group highlighted that "making real progress in implementing the UNGPs will better prepare us for the next crisis" and pointed out the need for "better collaboration involving all actors, with responsible governments and businesses leading the way" to realize the intent of the UNGPs. The need for ensuring responsible business conduct in the context of a global crisis such as the COVID-19 pandemic has been shared widely in the international community, as recognized by the adoption of the business and human rights resolution by consensus at the 44th session of the HRC (July 2020).

In response to the COVID-19 pandemic, OECD and ILO indicated that COVID-19 exposed vulnerabilities in company operations and supply chains regarding working conditions. Considering these global trends, the Government believes that it is more important than ever to steadily implement the UNGPs and the NAP to ensure responsible business activities with a view to promoting further efforts to realize the SDGs based on the principle of human security.

2 Positioning of the NAP: Links with International Documents, including the UNGPs and the Sustainable Development Goals (SDGs)

(1) Having endorsed the UNGPs, through the NAP formulation, the Government set out to ensure steady implementation of the UNGPs. The NAP was designed based not only on the UNGPs, but also relevant international instruments, such as the OECD Guidelines for Multinational Enterprises and the ILO MNE Declaration.

(2) The Government holds that the promotion and protection of human rights and the realization of the SDGs are interrelated and mutually reinforcing, as stated in Resolution 37/24 on the Promotion and protection of human rights and the implementation of the 2030 Agenda for Sustainable Development adopted at the 37th session of the HRC in March 2018. The Government considers the NAP formulation to be one of the measures to achieve the SDGs, and clearly mentioned its intention to formulate the NAP in the SDGs Implementation Guiding Principles Revised Edition, which was adopted at the 8th session of the SDGs Promotion Headquarters held in December 2019.

(3) The Cabinet-approved Growth Strategy 2018 in June 2018 also refers to encouraging progressive undertakings by companies in Japan through the NAP formulation process. The Growth Strategy further refers to protecting human rights through the development of an environment for accepting foreign nationals, including the improvement of their working environments.

3 Objectives to be Achieved through the Launch and Implementation of the NAP

As stated in Section 1 "Introduction: Increasing International Attention to Business and Human Rights and the Need for NAPs," the Government endeavors to promote shared recognition and understanding among the relevant ministries and agencies, to ensure inter-ministerial policy coherence, and to enhance cooperation. Through the wide publication of the NAP, the Government aims to enhance business enterprises' understanding and awareness of business and human rights, and to promote more efforts and cooperation by and among business enterprises. Through these measures, the Government aims to promote responsible business activities; contribute to the protection and promotion of human rights for society as a whole, including international society; and enhance trust in and the reputation of Japanese business enterprises while contributing to ensuring and enhancing their international competitiveness and sustainability. Further details are provided below.

(1) To protect and promote human rights for society as a whole, including international society

Based on the state duties, including those described in the UNGPs, to protect human rights, the Government launched the NAP as a measure for implementing various commitments to the international community, including compliance with international human rights treaties Japan has ratified and respect for internationally recognized principles (including the principles concerning the fundamental rights set out in the ILO Declaration on Fundamental Principles and Rights at Work (the ILO Declaration)). Also, by promoting responsible business activities in Japan or overseas, the NAP aims to contribute to the protection and promotion of human rights of people who are adversely affected by business activities regardless of their locations whether in Japan or overseas, and to the protection and promotion of human rights for society as a whole, including international society. In doing so, special attention is to be paid to the rights, the needs, and the risks faced by individuals belonging to groups at risk of becoming socially vulnerable or left behind. It is noted that for the purpose of this NAP, "human rights" should include consideration of the impact of environmental degradation and respect for human rights in supply chains.

(2) To ensure policy coherence in relation to business and human rights

With society placing increasing emphasis on business and human rights, business enterprises are required to ensure that their business activities comply with relevant laws and regulations. At the same time, the Government places emphasis on endeavoring to further improve the effectiveness of policies by ensuring coherence of relevant policies and enhancing inter-ministerial cooperation. In relation to this, the NAP aims to clarify relevant laws, regulations, policies, and future measures planned to promote inter-ministerial cooperation.

(3) To ensure and enhance the international competitiveness and sustainability of Japanese business enterprises

Respecting human rights in business activities could address adverse impacts on human rights, contribute to society, lead to avoidance and management of corporate risks, and also lead to gaining more trust from the international community and better reputations among global investors. Based on this, the NAP aims to contribute to ensuring and enhancing the international competitiveness and sustainability of Japanese business enterprises. The Government expects Japanese business enterprises to fulfill their responsibilities to respect human rights and to resolve issues with effective grievance mechanisms. The Government further aims to foster an environment where Japanese business enterprises implementing such measures are fairly evaluated.

(4) To contribute to achieving the SDGs

As stated in Section 2 "Positioning of the NAP: Links with International Documents, including the UNGPs and the SDGs," the achievement of the SDGs and the protection and promotion of human rights are interrelated and mutually reinforcing. In this connection, the Government aims to contribute to realizing a sustainable and inclusive society where "no one will be left behind" through the implementation of the NAP.

4 The NAP Formulation Process

(1) As stated below, the business and human rights agenda covers a vast range of areas and diverse group of stakeholders. Keeping this in mind, during the NAP formulation, the Government put considerable effort into making the NAP realistic and effective by figuring out the circumstances surrounding business and human rights in Japan and comprehensively considering possible measures that could be taken.

(2) In the initial stage, the Government carried out a baseline study for the purpose of assessing the current landscape of Japanese legislation and policies related to business activities, which all relevant ministries and agencies participated in. This was followed by ten consultation meetings with leading organizations in the business sector and the labour sector, bar associations, academia, and civil society to ascertain the situation. For the business sector, the Government made efforts to ensure the participation of SMEs in order to have their views, as SMEs account for 70% of all employment in Japanese society.

(3) Taking into account the results of the baseline study, the Inter-Ministerial Committee was established to promote coordination among the relevant ministries and agencies. An Advisory Committee and a Working Group were also established to include a wide range of views. A series of discussions were held to learn the views of the aforementioned sectors and consumer organizations. Subsequently, priority areas were identified to be incorporated in the NAP, and the NAP was launched. In the process of formulating the NAP, public comments were invited, and seminars were held in Japan. Opportunities were also provided to exchange views with overseas experts, including members of the UN Working Group on Business and Human Rights and the Head of the OECD Centre for Responsible Business Conduct, Directorate for Financial and Enterprise Affairs.

Chapter 2. Action Plan

1 Fundamental Principles of the NAP

Achieving the aims mentioned in Chapter 1 Section 3 "Objectives to be Achieved through the Launch and Implementation of the NAP" will require encouraging various stakeholders, including the Government and businesses, to take action. It will also require establishing necessary frameworks through the NAP.The following five priority areas are considered particularly important for the Government to implement the NAP with the understanding and cooperation of relevant stakeholders.

(1) In promoting understanding and awareness of business and human rights among government ministries and agencies, government-related entities, and local public entities, it is important to ensure coherence of legislation and policies and to enhance inter-ministerial cooperation.

(2) To ensure that business enterprises understand and comply with relevant legislation and policies, it is vital to promote their understanding and awareness of business and human rights. In particular, promoting understanding and awareness among SMEs, which have limited human and physical resources, is critical to increasing the effectiveness of the NAP.In addition to the Government's own awareness-raising efforts, the Government recognizes that tools and resources provided by international organizations and various stakeholders could also contribute to the efforts of businesses to address human rights. Having recognized that, the Government also believes that it is necessary to foster an environment that enables business enterprises to access necessary information for addressing issues in the area of business and human rights.

(3) Promotion of understanding and awareness of human rights throughout society is also needed to encourage further efforts on the business and human rights agenda by business enterprises. For this, the Government intends to continue its human rights education and awareness-raising efforts.

(4) With the globalization and diversification of business activities, business enterprises need to note that the international community demands business enterprises to not only implement good practices in business and human rights within their own organization, but also to respect human rights in their domestic and global supply chains. Accordingly, the Government will strive to develop concrete mechanisms to promote human rights within business, utilizing tools provided by international organizations, existing information disclosure frameworks, and initiatives for providing information to business enterprises.

(5) Remedial procedures (judicial and non-judicial remedies) have been established to address human rights violations in business activities. The Government intends to continue to assure access to judicial remedies and make improvements where necessary. It also utilizes multiple efforts regarding non-judicial remedies, including consulting services based on specific laws and regulations (e.g., workers, persons with disabilities, and consumers) as well as remedial procedures. These include the Japan Bank for International Cooperation (JBIC) Guidelines for Confirmation of Environmental and Social Considerations, the Japan International Cooperation Agency (JICA) Guidelines for Environmental and Social Considerations, the Nippon Export and Investment Insurance (NEXI) Guidelines on Environmental and Social Considerations in Trade Insurance, and the Japanese National Contact Point (NCP) under the OECD Guidelines for Multinational Enterprises (the Japanese NCP). The Government intends to secure access to these non- judicial remedies and make improvements where necessary.

2 Areas of the NAP

The UNGPs categorize relations between business and human rights into three pillars, namely: the State duty to protect human rights; the corporate responsibility to respect human rights; and access to remedy. Accordingly, the NAP categorizes relevant measures in a structured manner based on the following three perspectives.

Measures of the Government as an Actor regarding State Duty to Protect Human Rights

This section lists a series of government measures contributing to the protection and promotion of human rights for society as a whole, including international society, through implementing the human rights treaties that Japan has ratified and various commitments to the international community such as respecting, promoting, and realizing the principles concerning the fundamental rights set out in the ILO Declaration.

Measures of the Government Promoting Corporate Responsibility to Respect Human Rights

While a pillar of the corporate responsibility to respect human rights in the UNGPs involves measures by businesses themselves, this section mainly focuses on government measures to promote corporate responsibility to respect human rights.

Measures regarding Access to Remedy

This section mentions government measures to ensure access to judicial and non-judicial remedies whenever human rights violations in business activities occur.

Among the aforementioned three perspectives, several matters are more suitable to be addressed through a cross-cutting lens. Accordingly, this section starts with such "cross-cutting areas," followed by specific points pertaining to the three perspectives. Each of the following sections presents a summary of the existing framework and relevant measures, and the basic direction regarding the existing framework and measures, before going on to list future measures planned.

(1) Cross-Cutting Areas

A. Labour (Promotion of Decent Work)

(Existing framework /Measures taken)

As measures that have already been conducted in the labour area, the Government made efforts to realize decent work by promoting labour policies to respect, promote, and realize the four principles concerning the fundamental rights stated in the ILO Declaration, namely: (1) freedom of association and the effective recognition of the right to collective bargaining; (2) the elimination of all forms of forced or compulsory labour; (3) the effective abolition of child labour; and (4) the elimination of discrimination in respect of employment and occupation. For example, protection and promotion of the rights of workers are promoted through labour related legislation applicable to workers regardless of nationality, race, and ethnicity such as: the Labour Standards Act (Act No. 49 of 1947); the Industrial Accident Compensation Insurance Act (Act No. 50 of 1947); the Act on Securing, Etc. of Equal Opportunity and Treatment between Men and Women in Employment (Equal Employment Opportunity Act) (Act No. 113 of 1972); and the Mariners Act (Act No. 100 of 1947).

More recently, the revision of laws, including the Act on the Comprehensive Promotion of Labour Policies, and the Employment Security and the Productive Working Lives of Workers (Labour Policies Comprehensive Promotion Act) (Act No. 132 of 1966) in 2019 has resulted in new requirements for employers to establish necessary measures regarding employment management, such as the provision of counseling services, to prevent the abuse of authority, or so-called "power harassment," in the workplace. The revision of these laws has also strengthened preventive measures against sexual harassment, such as the prohibition of disadvantageous treatment by an employer against employees who report.

Along with globalization, increasing attention has been brought to the treatment of foreign workers. Appropriate implementation of the Technical Intern Training Program and protection of technical intern trainees are being promoted based on the Act on Proper Technical Intern Training and Protection of Technical Intern Trainees (Technical Intern Training Act) (Act No. 89 of 2016) enacted in November 2017 as well as on bilateral agreements with sending countries.

B. Promotion and Protection of Children's Rights

(Existing framework /Measures taken)

As measures that have already been conducted, the Government has supported initiatives in the area of education that leads to eradication of child labour and measures against trafficking in persons by contributing to the UN Trust Fund for Human Security and international organizations. In addition, the Government has supported initiatives to enhance measures against trafficking in persons and protection of such victims mainly in Southeast Asian countries, through technical cooperation by JICA and contributions to various UN agencies. Furthermore, the Government has been making contributions to and participating in the Asia-Pacific regional framework, the "Bali Process on People Smuggling, Trafficking in Persons and Related Transnational Crime" (hereinafter referred to as the Bali Process). The Government has also taken part in the WePROTECT Global Alliance to End Child Sexual Exploitation Online. Moreover, the Government reaffirmed the G20 commitment to eradicate child labour and various forms of modern slavery in the G20 Osaka Leaders' Declaration and the G20 Labour and Employment Ministers' Declaration, both compiled by Japan as the chair. For these initiatives, sufficient attention has been paid to gender perspectives considering that a large number of the victims involved are women and girls.

At national level, the Government has started to formulate a national action plan to end violence against children jointly with civil society and businesses, as a pathfinding country for the Global Partnership to End Violence Against Children (GPeVAC). The action plan is being drafted through respecting the opinions of children obtained through an online survey called "Comments from Children." In addition, relevant ministries and agencies cooperate to develop a better Internet use environment for young people through means such as the enhancement of initiatives concerning protection of young people, including filtering, in accordance with the Act on Development of an Environment that Provides Safe and Secure Internet Use for Young People (Act No. 79 of 2008, hereinafter referred to as the "Act on Development of Internet Use Environment for Young People") as well as the Basic Plan. Furthermore, the Government works on the eradication of child sexual exploitation such as child prostitution or the production of child pornography, in accordance with the Basic Plan on Measures against Child Sexual Exploitation with a view to eliminating such abuse by the Tokyo 2020 Games.

C. Human Rights Associated with the Development of New Technologies

(Existing framework /Measures taken)

As measures that have already been conducted, when consulted about the information on human rights violations, such as defamation and privacy infringement on the Internet, the Government has advised victims on the methods for requesting the disclosure of the sender's information and the deletion of the information by providers. In case the victims find it difficult to recover from the damage caused by abusive content, efforts are made to remedy the damage by requesting providers to delete such abusive information. With respect to these initiatives, sufficient attention is paid to take into account gender equality perspectives as well as diversity and inclusiveness.

With respect to discrimination issues, including hate speech, initiatives to resolve discrimination, including on the Internet, are being promoted in accordance with the objective of laws, including the Act on the Promotion of Efforts to Eliminate Unfair Discriminatory Speech and Behavior against Persons Originating from Outside Japan (Act No. 68 of 2016), the Act on the Promotion of Elimination of Buraku Discrimination (Act No. 109 of 2016), and the Act on Promotion of Measures for Realization of a Society in which the Pride of the Ainu People is Respected (Act No. 16 of 2019).

In terms of the development of artificial intelligence (AI), a Council for Social Principles of Human-centric AI was established for the purpose of considering the basic principles for implementing and sharing AI in society in a better way under the AI Strategy Expert Meeting for Strength and Promotion of Innovation. As a result of the review by the Council, the Social Principles of Human-centric AI, which comprise three basic values and seven principles were established in March 2019.

D. Rights and Roles of Consumers

(Existing framework /Measures taken)

Goal 12 of the SDGs is to "ensure sustainable consumption and production patterns." Accordingly, the creation of sustainable economies and societies requires action by consumers alongside businesses and governments. The Government works on realizing the rights of consumers in accordance with the Basic Consumer Act (Act No. 78 of 1968) that sets forth the responsibilities of the government, local governments, and businesses for the protection and promotion of consumers' interests. Ethical consumption is the concept of consuming in a way that is considerate of people, society, and the environment, while incorporating the perspectives of regional revitalization and employment. In raising awareness on ethical consumption, explanations on social problems such as child labour and environmental issues are provided at workshops for children and using educational tools (leaflets, posters, and video) to introduce people to a manner of consuming that could lead to the resolution of such problems. In addition, the Government promotes "consumer-oriented management," which refers to businesses operating with awareness of their own social responsibilities and thereby promoting changes in consumer behavior. Furthermore, consumer education is promoted at school and through social education to create a consumer citizen society in accordance with the Act on Promotion of Consumer Education (Act No. 61 of 2012).

E. Equality before the Law (Persons with Disabilities, Women, Persons of Diverse Sexual Orientation and Gender Identity, and Other Groups)

(Existing framework /Measures taken)

The Constitution of Japan sets forth the principle of equality before the law and there shall be no discrimination in political, economic or social relations because of race, creed, sex, social status or family origin. Various laws have prohibited discrimination, as stated below.

With respect to persons with disabilities, the Act for Eliminating Discrimination against Persons with Disabilities (Act No. 65 of 2013, hereinafter referred to as the "Disability Discrimination Act") prohibits governments and businesses from engaging in unfair discriminatory treatment on the grounds of disability, and prescribes that they are required to provide reasonable accommodation (companies must endeavor to provide reasonable accommodation). The Act on Employment Promotion Etc. of Persons with Disabilities (Act No. 123 of 1960) prohibits businesses from taking discriminatory measures in the area of employment based on disability and requires provision of reasonable accommodation.

With respect to women, the Equal Employment Opportunity Act prohibits discrimination against workers on the grounds of sex at each stage of employment management, and the Act on the Promotion of Women's Participation and Advancement in the Workplace (Act No. 64 of 2015, hereinafter referred to as the "Women's Participation Act") encourages initiatives to promote women's participation and advancement in the workplace.

Furthermore, the Basic Act for Gender Equal Society (Act No. 78 of 1999) lists "Respect for the human rights of men and women" as one of the pillars for realizing a gender-equal society. The Basic Plan for Gender Equality has been formulated in accordance with the Basic Act, and related measures have been implemented based on this plan. Internationally, the Government supports promotion of women's empowerment, including through various declarations at G7 and G20 Summits, and moreover has engaged in further promotion of women's participation in society, including the workplace by organizing the World Assembly for Women (WAW!).

In addition, a survey on business enterprises' initiatives ensuring diverse sexual orientation and gender identity was conducted and a report on the survey results and case studies was prepared and published to promote accurate understanding on diverse sexual orientation and gender identity in the workplace.

With respect to the Ainu indigenous people who inhabit areas around the northern part of the Japanese Archipelago, especially in Hokkaido, the Act on Promotion of Measures for Realization of a Society in Which the Pride of the Ainu People is Respected (Act No. 16 of 2019) prohibits discrimination on the grounds of Ainu identity.

In the area of employment, Article 22 of the Constitution of Japan prescribes that "every person shall have freedom to ... choose his occupation to the extent that it does not interfere with the public welfare." In addition, the freedom of choice of occupation is guaranteed in both the Employment Security Act (Act No. 141 of 1947), which prescribes that "every person may freely choose any job, provided that it does not conflict with the public welfare," and the Mariners' Employment Security Act (Act No. 130 of 1948), which prescribes that "every person may freely choose occupation as a mariner on an appropriate vessel corresponding to the person's ability and license or certificate in possession, or qualifications based on trainings received or experience."

Unfair or discriminatory treatment against particular users is prohibited within the areas of residence, places or services intended for public use (hotels, restaurants, cafes, cinemas, and use of transportation).

F. Acceptance of and Coexistence with Foreign Nationals

(Existing framework /Measures taken)

In recent years, the number of foreign nationals residing and working in Japan has been increasing, and there is a greater need for realizing a society where Japanese and foreign nationals can live safely and comfortably together through properly accepting foreign nationals and realizing a society of coexistence. Under these circumstances, the Government has taken the position of accepting foreign nationals who have status of residence, including Convention refugees and third-country resettled refugees as members of society without isolating them. To fully develop an environment where foreign nationals can enjoy the same public services and live without undue anxiety just as Japanese nationals do, the Ministerial Conference adopted the "Comprehensive Measures for Acceptance and Coexistence of Foreign nationals" (hereinafter referred to as "Comprehensive Measures") in December 2018, and compiled a further document titled "Enhancement of "Comprehensive Measures" (hereinafter referred to as "Enhancement Measures") in June 2019. The Comprehensive Measures were revised in line with the direction of the Enhancement Measures in December 2019, under which the Government has worked together to steadily promote the relevant measures.

Moreover, in July 2020, in consideration of the situation of implementation of related measures, the Comprehensive Measures were revised from the perspective of further enhancing and encouraging the environment for acceptance of foreign nationals.

(2) Measures of the Government as an Actor regarding State Duty to Protect Human Rights

A. Public Procurement

(Existing framework/Measures taken)

As measures that have already been conducted, the public procurement procedures have been implemented appropriately, including the implementation of international commitments, in accordance with various laws and regulations, including the Public Accounting Act (Act No. 35 of 1947).

In particular, the Government has promoted enhanced awareness by companies for respecting human rights and the environment in accordance with the Act on Promotion of Procurement of Goods and Services from Disability Employment Facilities by the State and Other Entities (Act No. 50 of 2012, hereinafter referred to as the "Act on Priority Procurement Promotion for Persons with Disabilities"), the Women's Participation Act, the Act on Prevention of Unjust Acts by Organized Crime Group Members (Act No.77 of 1991), and the Act on Promotion of Procurement of Eco-Friendly Goods and Services by the State and Other Entities (Act No. 100 of 2000, hereinafter referred to as the "Act on Promoting Green Procurement").

Furthermore, the revision of the Act on Promoting Quality Assurance in Public Works (Act No. 18 of 2005) in 2019 set forth the obligations of the commissioning entity, such as setting appropriate periods for construction projects and ensuring that they are allocated evenly throughout the year as opposed to being concentrated in the same period. The revision also included a new requirement for a wide range of surveys regarding public works to be carried out. In addition to this, the Construction Business Act (Act No. 100 of 1949) and the Act for Promoting Proper Tendering and Contracting for Public Works (Act No. 127 of 2000) were revised in 2019 to promote work style reform in the construction industry, including redressing long working hours (e.g. appropriate construction period) and improvement of treatment of workers at construction sites.

B. Development Cooperation and Development Finance

(Existing framework / Measures taken)

The Development Cooperation Charter adopted by the Cabinet in 2015 promotes human security, including fundamental human rights, as one of the basic policies for development cooperation. In addition, the Charter requires that sufficient attention is being paid to the protection of fundamental human rights in recipient countries to ensure the appropriateness of development cooperation, and that efforts are being made to ensure appropriate operation. When engaging in development cooperation projects, internationally established human rights standards, including the international human rights treaties, have been respected. Particular attention has been paid to human rights of socially vulnerable groups, such as women, indigenous people, persons with disabilities, and minorities. Nevertheless, further efforts are required in this regard.

JICA, JBIC and NEXI have introduced guidelines for environmental and social considerations. Along with them, necessary information disclosure procedures and related grievance procedures have been introduced to consider the impact of projects on human rights, the environment, and society. As a contract requirement, the Standard Instruction to Bidders and Form of Bid used for JICA's Official Development Assistance (ODA) Loans and Grants contains a contract clause to comply with labour related laws and regulations of the recipient countries that include respect for human rights.

The JBIC Guidelines for Confirmation of Environmental and Social Considerations examine not only the impact of JBIC projects on human health, safety, and the natural environment but also social concerns, including respect for human rights as environmental and social considerations required for the projects. JBIC has been encouraging borrowers and related parties to take into account environmental and social considerations through loan agreements as necessary.

Furthermore, the National Action Plan for the implementation of the UN Security Council Resolution 1325 and related resolutions on Women, Peace and Security incorporates the following elements in all activities in the areas of peace and security, humanitarian assistance, and recovery: women's participation and empowerment; measures corresponding to women's needs; promotion of gender equality; and protection of women's human rights.

C. Promotion and Expansion of the Business and Human Rights Agenda in the International Community

(Existing framework /Measures taken)

Considering the Government fundamentally values the protection and promotion of fundamental human rights that are universal values, the Government has engaged in the implementation of international human rights treaties at national level. The Government has actively participated in activities and discussions at the HRC and international human rights treaty bodies, contributed to the protection and promotion of human rights in the international community such as the UN human rights mechanisms, and moreover, engaged in human rights dialogue with several countries.

In the areas directly related to business activities, the Government has incorporated clauses concerning social issues, including labour and the environment in some of the EPAs and investment treaties that Japan has signed or ratified in a manner consistent with trade rules such as those of the World Trade Organization (WTO), and promoted shared understanding between signatories on values to be respected, such as securing appropriate labour standards and conditions and protection of the environment. For example, the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (TPP11 Agreement) includes an independent Labour Chapter and Environment Chapter as well as provisions on women's participation, and the Japan-EU Economic Partnership Agreement (EPA) includes a Trade and Sustainable Development Chapter. On top of this, the Japan-EU EPA also stipulates that the parties shall convene joint dialogue with civil society, establishing that civil society shall play a certain role through exchange of opinions on themes such as trade and sustainable development, the environment, and labour.

D. Human Rights Education and Awareness-Raising

(Existing framework / Measures taken)

The Government has developed the Basic Plan on Human Rights Education and Human Rights Awareness Raising pursuant to the Act on the Promotion of Human Rights Education and Human Rights Awareness-Raising (Act No.147 of 2000), based on which it has been promoting various forms of human rights education and awareness-raising. In particular, human rights education and awareness-raising seminars for SMEs have been organized across Japan to broaden awareness of business and human rights among businesses.

In order to encourage business enterprises to take action, it is also important to strengthen society's understanding of business and human rights. In this respect, civil society, legal communities and various groups all have an important role to play.

(3) Measures of the Government Promoting Corporate Responsibility to Respect Human Rights

A. Measures Related to Domestic and Global Supply Chains and Promotion of Human Rights Due Diligence Based on the UNGPs

(Existing framework/Measures taken)

With increased interest in responsible business conduct, the OECD Guidelines for Multinational Enterprises, which Japan adheres to, added a new chapter on business responsibility on respect for human rights in its 2011 edition. In addition, OECD has launched due diligence guidance specific to sectors such as minerals, agriculture, garments, and footwear. In 2018, the OECD Due Diligence Guidance for Responsible Business Conduct was published as a practical tool that businesses can use regardless of the sector. The Government has been engaged in promoting the above Guidelines and Guidance to businesses.

The ILO promotes dialogue and cooperation between business enterprises and stakeholders based on the ILO MNE Declaration, which is a guideline for achieving decent work through supply chains, and this is considered as an initiative that mutually supplements human rights due diligence. In this connection, the Government raises awareness of the ILO MNE Declaration.

Japan's Stewardship Code and Corporate Governance Code refer to grasping the status of investee companies and corporate information disclosure to promote sustainability initiatives, including elements of ESG issues. In addition, the Stewardship Code, which was revised again in March 2020 also includes reference to consideration on sustainability when holding dialogue between institutional investors and investee companies. Furthermore, the Guidance for Collaborative Value Creation was published as a guideline for dialogue and disclosure on voluntary and proactive initiatives of companies on non-financial information, including ESG factors.

Under the Women's Participation Act, businesses that regularly employ 301 or more workers are obligated to: (1) understand the status of women's participation and advancement in business enterprises and analyze issues; (2) establish, notify, disseminate, and publish an action plan incorporating quantitative goals and initiatives based on the understanding of the status and analysis of issues; and (3) publish information on the company concerning women's participation and advancement in the workplace. These initiatives were enhanced with the partial revision of the Women's Participation Act in May 2019.

With respect to the environment, corporate initiatives are being promoted with the establishment of the Environmental Reporting Guidelines. In August 2020, the "Introductory Guide on Environmental Due Diligence along the Value Chains: Referencing the OECD Guidance" was issued as a manual, including points to note in conducting environmental due diligence in relation to risk management and value chain management stated in the Environmental Reporting Guidelines. The Guidelines state that human rights are integral to address some measures regarding environmental issues, and explains that environmental due diligence is required as part of responsible business conduct and integrated with human rights.

In terms of awareness-raising activities and support, studies and research have been conducted by relevant institutions, including the Institute of Developing Economies of the Japan External Trade Organization (IDE-JETRO) and the Business Policy Forum, Japan. The results have been issued for the benefit of business enterprises.

For Japanese business enterprises engaging in overseas businesses, contact points for Japanese business enterprises (Japanese business support officers) have been established at Japanese embassies and consulates to enhance support for Japanese business enterprises' overseas expansion.

Among international organizations, ILO provides information to both company managers and workers on how to better align business operations with international labour standards and build good industrial relations through the ILO Helpdesk for Business on International Labour Standards.

In addition to the above, international initiatives, including the Extractive Industries Transparency Initiative and measures against Illegal, Unreported and Unregulated fishing are being implemented, and Japan makes an active contribution to such initiatives.

B. Support for Small and Medium Enterprises (SMEs) regarding Business and Human Rights

(Existing framework /Measures taken)

SMEs play an important role in Japan's economy, providing most employment and contributing to local communities and the lives of residents as the key player in society, while also having a role in supply chains. Because SMEs include a wide range of companies in terms of size, sector, and business category, the Government will implement business and human rights efforts with input from the SMEs that reflects the diversity of these enterprises. The Government also recognizes the need to engage in awareness-raising activities to increase understanding and implementation by SMEs, while also being considerate of SMEs' position in business transactions.

(4) Measures regarding Access to Remedy

Judicial and Non-Judicial Remedy

(Existing framework/Measures taken)

As a remedy for human rights violations by business enterprises, the Government intends to ensure accountability and remedies through the pursuit of criminal responsibility, damage claims, and administrative measures undertaken based on relevant laws, including the Penal Code (Act No.45 of 1907), the Civil Code (Act No.89 of 1896), the Product Liability Act (Act No. 85 of 1994), and the Labor Tribunal Act (Act No. 45 of 2004).

In relation to access to these remedies, the Japan Legal Support Center (the JLSC) makes efforts to ensure access to judicial remedies by providing legal aid services, such as free legal consultations for Japanese nationals and foreign nationals lawfully residing in Japan who have no financial means.

Non-judicial remedies such as the following have been established: consulting services based on individual legislation (e.g., workers, persons with disabilities, consumers); remedial procedures such as Objection Procedures Based on JBIC Guidelines for Confirmation of Environmental and Social Considerations, JICA Objection Procedures Based on Guidelines for Environmental and Social Considerations, and NEXI Objection Procedures on Guidelines on Environmental and Social Considerations in Trade Insurance; and the Japanese NCP under the OECD Guidelines for Multinational Enterprises based on the international framework. In addition, pursuant to the Act on Promotion of Use of Alternative Dispute Resolution (Act No.151 of 2004) private dispute resolution procedure services (mediation conducted by private enterprises) are certified. This Act prescribes special rules such as suspension of prescription and discontinuation of litigation proceedings that can be applied subject to certain requirements when using the aforementioned services, thereby improving their utility. Furthermore, human rights consulting services and relief procedures are being offered at Legal Affairs Bureaus and District Legal Affairs Bureaus.

As measures based on specific legislation, frameworks have been established in specific areas, including for workers and persons with disabilities.

Consultations involving consumer complaints and mediation for the settlement of consumer complaints are also being provided under the Consumer Safety Act (Act No. 50 of 2009).

(5) Other Measures

In addition to measures aligned with the three pillars of the UNGPs, the Government contributes to measures against various issues expected in relation to business and human rights through the following measures.

Chapter 3. Governments, Expectations towards Business Enterprises

1 The NAP refers to the Government's initiative, which are to be undertaken with the understanding and cooperation of relevant parties. The Government believes that the understanding and cooperation of the businesses is of particular importance in promoting responsible business activities in Japan and overseas, and has thus outlined its expectations for the business enterprises in this section.

2 The Government expects Japanese enterprises, regardless of their size and sector of industry, to respect internationally recognized human rights and the principles concerning the fundamental rights set out in the ILO Declaration; introduce the process of human rights due diligence based on the UNGPs and other related international standards; and engage in dialogue with stakeholders, including those that are part of supply chains. Furthermore, the Government expects Japanese business enterprises resolve issues through effective grievance mechanisms. *3*

Reference: According to the UNGPs, in order to meet corporate responsibility to respect human rights, business enterprises should have in place the following policies and processes.

1 A human rights policy      UNGPs 16

Business enterprises need to show a policy commitment to meet their responsibility

to respect human rights.

2 Human rights due diligence      UNGPs 17-21

In order to identify, prevent, mitigate and account for how they address their

impacts on human rights, business enterprises need to assess adverse human rights

impacts, address the findings, track responses, and communicate how impacts are

addressed. This series of processes is called "human rights due diligence."

3 Provision of remediation      UNGPs 22

Where business enterprises identify that they have caused or contributed to

adverse impacts, they should provide for or cooperate in their remediation through

legitimate processes.

Chapter 4. Framework for Implementation and Review of the NAP

1 The NAP covers a period of five years between FY2020 and FY2025.

2 An Inter-Ministerial Committee will be established following the launch of the NAP, and ministries and agencies will implement relevant measures.

3 The Inter-Ministerial Committee will follow the progress of implementation of the NAP on annual basis. In the follow-up process, the Committee will endeavor to use objective indicators, to the extent possible, including existing evaluation indicators that have been used by the relevant ministries and agencies. In addition to the measures listed in the NAP, new relevant measures introduced after the launch of the NAP will also be reviewed in the follow-up process.

4 The Inter-Ministerial Committee will, particularly during the first year, discuss the following points. For this, the Inter-Ministerial Committee will promptly commence its work after the launch of the NAP.

(1) Consider methods for effective and sustainable follow-up (including the discussion on appropriate evaluation indicators).

(2) Consider what information is sought by business enterprises in corporation with industry groups and other organizations to ensure that the implementation of the NAP contributes to the introduction of human rights due diligence by business enterprises, as indicated in Chapter 3 under "Government's Expectations towards Business Enterprises." Examples of such information could include successful and problematic cases and necessary steps to take going forward. The aforementioned "implementation of the NAP" particularly refers to publication of and awareness-raising for the NAP, and provision of information on the NAP for business enterprises, as mentioned in Chapter 2.2. Areas of the NAP (3) Measures of the Government Promoting Corporate Responsibility to Respect Human Rights.

(3) Consider providing opportunities for business enterprises to air their views in cooperation with industry groups and other organizations, to monitor to what extent human rights due diligence has been promoted as a result of the formulation and implementation of the NAP.

5 Aiming at around three years from the issuing of the NAP, the Inter-Ministerial Committee will exchange views on the relevant international trends and the status of efforts by Japanese business enterprises.

6 Towards the revision of the NAP five years after being rolled out, approximately four years from the launch of the NAP, the Inter-Ministerial Committee will start working on revising the NAP, while taking into account the views of stakeholders.

7 In promoting the steps above, promptly after the launch of the NAP, the Inter-Ministerial Committee will establish a framework for continued dialogue between relevant ministries and agencies and stakeholders based on a trusting relationship (including opportunities to monitor the status of the NAP's implementation) A summary of the views exchanged between relevant ministries and agencies and stakeholders will be made public.

Appendix I. Lists of Members of the Advisory Committee for the NAP on Business and Human Rights and the Working Group for the NAP on Business and Human Rights

1 Members, Advisory Committee for the NAP on Business and Human Rights *Japanese-alphabetical order

2 Members, Working Group on the NAP on Business and Human Rights

Appendix II. References

1 International Instruments

■ Guiding Principles on Business and Human Rights: Implementing the United Nations "Protect, Respect and Remedy" Framework (2011)

https://www.mofa.go.jp/files/000055037.pdf

■ OECD Guidelines for Multinational Enterprises(2011 Edition)

https://www.mofa.go.jp/mofaj/gaiko/csr/pdfs/oecd_gm.pdf

■ ILO Declaration on Fundamental Principles and Rights at Work(the ILO Declaration) (1998)

https://www.ilo.org/declaration/thedeclaration/textdeclaration/lang--en/index.htm

■ Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy (the ILO MNE Declaration) - 5th Edition (2017)

https://www.ilo.org/wcmsp5/groups/public/---ed_emp/---emp_ent/---multi/documents/ publication/wcms_094386.pdf

■ 2030 Agenda for Sustainable Development (2015)

https://www.mofa.go.jp/mofaj/gaiko/oda/sdgs/pdf/000101401.pdf

■ UN Global Compact (2000)

https://www.unglobalcompact.org/what-is-gc/mission/principles

■ Children s' Rights & Business Principles (2012)

https://www.unicef.org/csr/theprinciples.html

2 G7, G20 Leaders' Declarations

■ G7 Summit 2015 in Schloss Elmau: Leaders' Declaration (2015)

https://www.mofa.go.jp/files/000084020.pdf

■ G20 Summit 2017 in Hamburg: Leaders'Declaration(2017)

https://www.mofa.go.jp/files/000271291.pdf

3 National Policy Documents

■ Growth Strategy 2018 (2018)

https://www.kantei.go.jp/jp/singi/keizaisaisei/pdf/miraitousi2018_en2.pdf

■ SDGs Implementation Guiding Principles Revised Version (2019)

https://www.mofa.go.jp/mofaj/gaiko/oda/sdgs/pdf/kaitei_2019_en.pdf

Ministry of Foreign Affairs Website: "Business and Human Rights"

https://www.mofa.go.jp/fp/hr_ha/page23e_000551.html

{*1* The Ten Principles of the UNGC include the following principles in the areas of Human Rights and Labour:

Principle 1. Businesses should support and respect the protection of internationally proclaimed human rights

Principle 2. Businesses should make sure that they are not complicit in human rights abuses

Principle 3. Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining Principle 4. Businesses should uphold the elimination of all forms of forced and compulsory labour

Principle 5. Businesses should uphold the effective abolition of child labour

Principle 6. Businesses should uphold the elimination of discrimination in respect of employment and occupation}

{*2* The courts also conduct various trainings on human rights, including on human rights treaties and international human rights laws, at the Legal Training and Research Institute, which is in charge of training for judges.}

{*3* For example, the UNGPs state that business enterprises should have in place (1) a policy commitment to meet their responsibility to respect human rights; (2) a human rights due diligence process to identify, prevent, mitigate and account for how they address their impacts on human rights; and (3) processes to enable the remediation of any adverse human rights impacts they cause or to which they contribute. The OECD Due Diligence Guidance states that due diligence is "the process enterprises should carry out to identify, prevent, mitigate and account for how they address these actual and potential adverse impacts in their own operations, their supply chain and other business relationships." ILO MNE Declaration states that enterprises, including multinational enterprises "should carry out due diligence to identify, prevent, mitigate and account for how they address their actual and potential adverse impacts that relate to internationally recognized human rights." Keidanren provides specific examples for corporations to "clarify policies for respecting human rights and reflect them in business activities" in the Implementation Guidance on Charter of Corporate Behavior.}