Respect for Human Rights

Our Policy

We support international norms such as the International Bill of Human Rights, the International Labour Standards of the International Labour Organization, the United Nations Guiding Principles on Business and Human Rights, and the principles of the United Nations Global Compact.

In FY2017, we issued the INPEX Group Human Rights Policy to clearly define our commitment to respecting human rights and fulfill our responsibilities in this regard. In accordance with that policy, we implement measures to address the human rights of all stakeholders in each country and region where we operate, including stakeholders in our supply chains. The policy prohibits all forced labor and child labor and affirms our respect for freedom of association and protection of the right to organize.

To comply with the United Kingdom Modern Slavery Act 2015, since FY2016 we have annually issued a statement on our website to disclose the policies, structures, and measures that we have in place to prevent slave labor and human trafficking within the Company and throughout our supply chain.

In addition, since FY2021, INPEX Australia has annually prepared and issued the INPEX Australia Modern Slavery Statement pursuant to the Modern Slavery Act (Australia) 2018 (Cth) to detail the potential risks and measures taken to prevent the occurrence modern slavery in our Australian business activities.

Management Structure

Our approach to human rights is outlined in the INPEX Group Human Rights Policy approved by our Board of Directors. The Compliance Committee—chaired by the Board-appointed officer in charge of compliance—reports to the Board of Directors on human rights-related risks and performance.

The INPEX Group Human Rights Policy, Sustainability Principles, Business Principles, and Code of Conduct require all of our officers and employees not only to comply with laws and regulations but also to respect social norms and act with high moral values. Our Code of Conduct makes the following statements concerning human rights.

• We recognize that human rights are important rights that derive from the dignity of individuals, and we respect the human rights of individuals in relevant countries.
• We respect international norms, and we are careful to avoid being involved in any act that may infringe human rights.
• We do not discriminate based on factors such as race, skin color, gender, sexual orientation, gender identity, age, creed, religion, birth, nationality, disabilities, or educational background.
• We do not force employees to work against their will, and we do not cause children to work.

The Compliance Committee—which comprises Executive Directors, Executive Officers, and other members and is chaired by the officer in charge of compliance—meets regularly to ensure corporate ethics and behavior are in accordance with the above statements. The General Administration Unit, which serves as the secretariat of the Compliance Committee, regularly holds liaison meetings of representatives from each business unit to promote the aforementioned human rights initiatives, including the prevention of harassment.

Human Rights Due Diligence

Since FY2016, we have been conducting human rights due diligence at our Japan-based and overseas sites as part of efforts to enhance our human rights management. Conducted in line with the INPEX Group Human Rights Policy, we have applied this due diligence to all seven of our operational sites in three countries as of the end of 2022. The due diligence covers human rights risks to our own employees, women, children, indigenous people, migrant workers, third-party employees, and local communities.

In addition, we have continued discussions with each site to ensure implementation of the PDCA cycle through the following actions. In FY2022, we revised our human rights questionnaires for surveys and conducted surveys and interviews at our sites in Japan and, for the first time, the United States. The survey in Japan showed improvement in the management of child or forced labor risks. The assessment conducted in the United States considered salient human right risks and the practices in place for managing those risks. While our assessments found no material risks, we nonetheless continue our efforts to strengthen our human rights risk management.

In FY2022, with no operational sites requiring a human rights-related mitigation plan, there were similarly no remediation actions required.

Desktop Investigation

• Utilize the database of RepRisk—a provider of the ESG risk research and analysis—and identify potential instances of human rights violations in the oil and gas sector in the following five areas: child labor, forced labor, freedom of association and right to collective bargaining, employment discrimination, and social discrimination
• Classify the country risk of the areas in which we operate into three levels (high/medium/low) based on documents issued by Verisk Maplecroft and other research organizations

Interview Surveys

• Conduct surveys and interviews—with reference to the Global Compact Self Assessment Tool for the Ten Principles of the United Nations Global Compact—at all of our sites to understand the status of responses to human rights risks identified through the desktop investigation
• Reviewed the survey content in FY2022

Examination and Implementation of Action Plans

• Confirm the status of management of human rights risks, based on the assessment mentioned above
• Provide feedback on the assessment results to each site and discuss future actions, such as widely disseminating the INPEX Group Human Rights Policy and providing human rights education
• Continue to provide human rights education to employees to strengthen respect for human rights based on assessment results

Human Rights Due Diligence in Projects

For the projects for which INPEX serves as the operator, we manage social and environmental risks—including human rights-related risks—based on the Performance Standards of the International Finance Corporation (IFC), which are a globally recognized benchmark for environmental and social risk management. IFC Performance Standard 2—Labor and Working Conditions covers child labor, forced labor, working conditions, and grievance mechanisms.

The due diligence process previously described aligns with this performance standard.

Compliance with these standards within Ichthys LNG operations is monitored through regular reports and audits.

We also conduct due diligence of the projects in which we participate as a non-operator. In FY2020, we surveyed the operators of each project based on our human rights due diligence to confirm the status of their human rights initiatives. In FY2023, we will use similar surveys to reconfirm the status of new projects and the latest initiatives of projects covered last time.

Salient Human Rights Risks

We invited an external human rights expert to conduct a human rights risk assessment on the projects for which we serve as the operator. The key objectives of the assessment were as follows:

• Identify salient human rights risks
• Identify issues for human rights risk management

The assessment used the Human Rights Impact Assessment tool, which draws on RepRisk’s database and documents from Verisk Maplecroft and other research organizations.

The salient human rights risks identified are as follows:

• Child labor
• Forced labor
• Impact on cultural heritage and traditional culture
• Infringement on the rights of local communities
• Discrimination in recruitment and employment
• Environmental damage impacting local communities

We also investigated human trafficking, equal pay, and other human rights risk areas through a risk identification and assessment process. Considering geographical and other characteristics of our business operations, and the risk assessments already conducted, these areas were not deemed to be salient human rights risks for the Company.

The assessment also analyzed the operational structure of our management system, including the PDCA cycle and monitoring, as well as the state of the INPEX Group Human Rights Policy.

Human Rights Initiatives

We are committed to creating processes and systems to identify and address modern slavery risks in our operations and supply chain

In FY2021, our Australian subsidiaries issued their first Modern Slavery Statement in compliance with the Australian Modern Slavery Act 2018. Our Australian-based employees have also participated in a human rights working group with other resources industry members, helping to devise the questions for a supplier self-assessment questionnaire designed to standardize the assessment of suppliers’ modern slavery risks. We have since integrated this assessment into our own supplier selection process.

Also, in FY2021, we held a seminar on human rights inviting external presenters to speak to suppliers of our Japan-based sites. As an initiative at our domestic and overseas sites, we posted human rights awareness posters to spread our human rights policy to our suppliers. We are engaged in ongoing efforts to incorporate modern slavery risk management in our policies, procedures, and operational management.

Human Rights Impact Assessments

For the Abadi LNG Project in Indonesia, we have examined and assessed the human rights requirements of the IFC Performance Standards as part of environmental and social impact assessments currently being conducted. Our efforts to date for addressing human rights at each step in those assessments are summarized as follows:

We plan to develop internal regulations and documents related to human rights, including the requirements of the Voluntary Principles on Safety and Human Rights (VPSHR), and establish a Social Management System.

Raising Awareness of Human Rights

In FY2017, to deepen awareness of the importance of considering the human rights of various stakeholders as we go about our day-to-day business, we conducted human rights training for all officers and employees. We have continued providing this training for all new officers and employees since that time.

As a member of the Ipieca Human Rights Working Group, we collaborate on activities such as reviews of supply chain human rights due diligence guidelines, and information sharing on the prevention of child labor, forced labor, and other forms of modern slavery.

Risk Mitigation Efforts and Remediation Actions

We take the following actions to mitigate risks identified through our human rights due diligence activities:

• Review of salient human rights risks and survey content: We regularly conduct these reviews so we can more precisely monitor the risks and the actions to address them.
• Interview follow-up: We conduct follow-up interviews at sites where areas requiring improvement were identified in the initial interview.

Grievance Mechanism

We actively respond to inquiries, complaints, and grievances from all stakeholders—both internal and external—at all of our Japan-based and overseas sites. Internally, we operate a whistleblower system for the early detection of violations of human rights, discrimination, harassment, and other compliance violations.

In FY2022, ten reports related to human rights, discrimination, and harassment were received in Japan, all of which were handled appropriately in accordance with the Compliance Structure Operating Regulations and Whistleblowing Rules. For the year ending December 31, 2022, there had been no confirmed cases of serious compliance violation, and three of the reports relating to suspected human rights, discrimination, and harassment violations remained under investigation. There were no human rights, discrimination, and harassment violations among the reported cases subject to disciplinary action as stipulated in the Code of Conduct.

We have a dedicated page on our website for handling inquiries and grievances from external stakeholders—including local residents and suppliers—and we respond to their feedback in a timely and appropriate manner.

In Indonesia, in addition to the website, we provide support by facilitating telephone calls in the local language.

In Australia, a procedure has been established for community engagement and grievance handling to appropriately address inquiries and grievances received from local communities concerning human rights and compliance.

In FY2022, no human rights complaints were received in Japan, Indonesia, and Australia.

Improvement of the Work Environment

Aligned to our Code of Conduct, we strive to create a sound work environment for our employees, which is in part achieved through fair working hours and fair income.

We ensure that standard working hours at all of our sites in Japan and overseas are a maximum of 48 hours per week, and any overtime work is performed with the consent of the employee concerned.

We also pay wages to all employees at a level that exceeds the living wage of the site where they work.

Dialogue between Labor and Management

Our labor agreement with the INPEX Labor Union stipulates that the union possesses the right to organize, the right to bargain collectively, and the right to act collectively. Our overseas offices also have forums for discussions on labor issues between management and labor representatives.

We strive to maintain and develop a healthy labor and management relationship by regularly providing opportunities for these parties to exchange views and ideas on a wide range of issues in addition to labor issues, such as challenges faced by the Company and future prospects.

In addition, at offices in Japan, biannual labor-management meetings are held jointly with five labor union branches, and close communication and dialogue between labor and management is also conducted at the branch level.

We provide appropriate notification in advance of any operational changes that will significantly affect employees.

No complaints have been received from the union since it was formed in 2008.