Aiming to promote effective initiatives for the respect of human rights in line with the Guiding Principles on Business and Human Rights (the “Guiding Principles”) endorsed by the UN Human Rights Council in 2011, the OLC Group revised its OLC Group Human Rights Policy Statement (the “Policy Statement”) in line with the Guiding Principles.
All employees are made mutually aware of the Policy Statement through the Business Guidelines, which set out specific standards of conduct that put compliance into practice.
Human rights training and awareness programs aligned with the Policy Statement are provided to employees joining the company or renewing their employment contracts, regardless of their employment category.
We also ask our suppliers to comply with our Policy Statement through the OLC Group Vendors Code of Conduct.
We are currently engaging in discussions regarding the implementation of human rights due diligence, drawing on existing initiatives.
The OLC Group has established the OLC Group Basic Policy on Harassment by Customers to ensure that the human rights of people engaged in our business are respected as well as to maximize customer satisfaction.
We discussed and revised our Human Rights Policy Statement by using the following process.
We held a dialogue meeting with experts to gain input on the draft of the revised Human Rights Policy Statement and our future human rights due diligence efforts.
Expert: Akiko Sato, Deputy Secretary General / Attorney at Law, Certified Non-profit Organization Human Rights Now
Facilitator: Takeshi Nozawa, CEO, EcoNetworks Co.
Main opinions:
- As the OLC Group’s business has a significant impact on society, its approach to respecting human rights is also expected to be highly influential in a positive way.
- The purpose of the Human Rights Policy Statement is to enable management to demonstrate its commitment to incorporating a human rights perspective as a fundamental pillar of the business.
- Given the vulnerability of employees to potential human rights violations, corporations should absolutely give priority to respecting the human rights of their employees.
- Human rights due diligence should be implemented to identify human rights risks faced by rights-holders. The failure to identify any risks can itself be considered a risk.
- No matter how much human rights due diligence is pursued, human rights risks will always remain. The purpose of human rights due diligence is to proactively identify these risks at an early stage and prevent the occurrence of serious consequences.
- In implementing human rights due diligence, it is also important to find ways to leverage and build upon existing initiatives.
Based on the OLC Group Human Rights Policy Statement, the OLC Group implements initiatives to respect the human rights of everyone involved in our business, as part of the “diversity, equity & inclusion” category of our ESG materiality areas. The Sustainability Promotion Committee, which is chaired by our Company’s President, discusses the order of priority and resource allocation pertaining to initiatives related to the ESG materiality area of diversity, equity & inclusion. The results are then reported to the Executive Committee and Board of Directors for deliberation.
We reviewed our internal system for promoting human rights measures, and shifted to a system in which the Compliance Committee discusses and reports on related initiatives from FY2025.
Should a serious human rights issue arise within our Company, or a serious issue be identified during the human rights due diligence process, the Compliance Committee secretariat conducts an investigation in collaboration with the relevant departments, promptly reports the findings to management and the corporate auditors. We also take appropriate corrective and remedial measures for each case.
For each ESG materiality, we have set goals as well as KPIs for 2030 and KPIs for 2027 to assess our progress. The progress status is reported to the Board of Directors and Executive Committee at least once a year.
Discussions were mainly themed on key items concerning our materiality, including our policy, the development of KPIs, and ongoing progress.
The OLC Group has established the direction of its initiatives as follows in view of the risks and opportunities related to respect for human rights.
[Risks]
・Declined guest experience value due to insufficient customer diversity measures
・Emergence of risk due to insufficient response to human rights protection
[Opportunity]
・Increasing guest experience value by adapting to changes in society and customer needs
To address changes in society and customer needs and respect diverse values in our business activities, we will implement structured measures to ensure that human rights are respected, review existing products and services, and build frameworks to give due consideration to diversity.
In conjunction with revising its human rights policy, the OLC Group has identified key human rights issues based on the following steps.
・Human rights issues in supply chains
・Human rights issues related to the environment and climate change
・Harassment
・Occupational health and safety
・Disparities in living wages and working conditions
・Discrimination (direct/indirect)
・Freedom of expression
・Gender (including LGBT)
・Human rights issues related to technology/AI
・Children’s rights
・Rights to access remedies
Based on the UN Guiding Principles on Business and Human Rights, the OLC Group implements human rights due diligence by performing the following steps: 1. Identify, analyze, and assess negative impact on human rights; 2. Prevent/mitigate the negative impact on human rights; 3. Conduct follow-up assessment on the effectiveness of the measures taken; 4. Externally disclose information.
Through this process, we are committed to engaging with stakeholders and promote remediation.
In order to “1. Identify, analyze, and assess negative impact on human rights,” we categorized the key human rights issues into three groups of employees, suppliers, and customers, and determined vulnerable stakeholders in each category. Based on this framework, we perform gap analyses (assessment and discussion for preventive and remedial measures). This process helps us identify areas where initiatives for vulnerable rights-holders are particularly insufficient.
We have completed gap analyses and established a sustainable structure for promoting human rights initiatives by FY2024.
From FY2025, we have started reviewing the key human rights issues based on the results of the gap analyses, and are formulating a medium-term roadmap for the period leading up to 2030.
The key findings from the gap analysis within the three groups are outlined below.
|
Group |
Identified issues, trends, and patterns |
Completed and planned measures |
Follow-up assessments of the effectiveness of measures |
|
Employees |
An internal investigation into the key human rights issue of harassment was conducted at Oriental Land. It found that no major problems exist within our management system at this point. In addition, a further investigation was launched into socially vulnerable rights-holders. It revealed that internal measures were in progress for “customer service representatives” and “student job applicants” at the time of the investigation. |
Regarding customer service representatives, we formulated the OLC Group Basic Policy on Harassment by Customers, and disclosed it to the public. We also provided on-site managers with training on customer harassment. Regarding student job applicants, we established the OLC Group Guidelines for Recruitment Activities and posted them on our recruitment webpage. We also established a dedicated contact point (helpline) and raised awareness among employees to ensure proper conduct when meeting job seekers in their capacity as alumni. |
We will conduct follow-up assessments of customer service representatives based on the results of a compliance questionnaire and cases reported to the employee contact point. Our follow-up assessments of student job seekers will be conducted based on reports received by the dedicated contact point. Expanding the scope of human rights due diligence to include Group companies is a KPI for 2027. As we strive to achieve this, we will also investigate each Group company’s management system. |
|
Suppliers |
In procuring specified raw materials used in the OLC Group’s business activities, we set targets and directions of initiatives for individual items. These take into consideration the items’ social impact—including human rights and occupational safety—as well as their environmental impact across the supply chain. |
In response to growing external demand, we assessed items already designated internally and conducted a desktop investigation under the supervision of external experts to identify any new resources that must be monitored. We assessed the risks associated with each item and internally confirmed their purchase prices and places of origin. Based on the results, we ascertained that no additional items needed to be monitored at this point. |
We will continue to monitor external demand and the internal situation. We will revise the list of designated raw materials and the direction of initiatives as necessary, taking into account environmental, social, and economic conditions. |
|
Customers |
The OLC Group strives to create an accessible theme park environment where all guests can enjoy themselves. Feedback from guests received at our guest contact point provides us with valuable information, which we share, analyze, and utilize group-wide to improve and develop our products and services. From a human rights perspective, we analyzed feedback received from FY2023 through FY2025 and identified no cases of serious human rights violations in theme park operations that required immediate corrective or remedial measures. Meanwhile, we identified cases that require close monitoring, although they were not immediately considered human rights violations. After discussing response measures with experts, we conducted an internal review and are working to make improvements. |
With regard to cases subject to close monitoring, we have been improving our facilities and operations by drawing on customer feedback to enable more guests to experience our offerings. Specific facility improvements include installing equipment that allows wheelchair users to remain in their wheelchairs at new attractions and installing this equipment in existing attractions during renovation. A range of operational initiatives are also in progress, including revising the rule that required guests with disabilities to be accompanied. |
When conducting analyses, we also perform follow-up assessments of the preceding fiscal year’s results. Over the three years since this initiative began, no serious human rights violations have been identified. Furthermore, we seek to effectively analyze a broader scope of customer feedback in follow-up assessments. To do so, we will revise our investigation design based on the analysis results for each fiscal year, improve investigation methods and processes, and conduct ongoing investigations |
To address the OLC Group-wide risks, we have established risk management cycles for individual risks to take prevention and response measures based on the OLC Group Risk Management Guidelines. The Risk Management Committee chaired by the Company’s President identifies and assesses all risks concerning our business activities, categorizes them into strategic risks and operational risks, and narrows them down to those that should be addressed with priority by their respective supervisory organization.
Prevention and response measures for strategic risks including sustainability risks are formulated and implemented by organizations in charge of individual risks. The Risk Management Committee, which oversees strategic risks, monitors their progress status, and compiles and reports the results to the Executive Committee and Board of Directors on an annual basis. The Board of Directors supervises the incorporation of countermeasures into the OLC Group’s strategy.
Risks related to human rights form part of the sustainability risks and are included in our strategic risks.
We have established a contact point for employees wishing to report any instances of improper conduct, including any types of human rights violations, harassment, and improper information management within or outside the OLC Group.
We also offer such contact points for each employment category and each OLC Group company, regularly informing employees of the helplines via internal posters and on the OLC portal to make it easier for them to seek counseling for any potential issues.
Furthermore, we also provide a dedicated contact point on our website for OLC Group suppliers as a means of identifying, at an early stage, any violation or suspected violation of compliance by an executive or employee of the OLC Group with regard to their relationship with a supplier.
In order to ensure the effectiveness of this whistleblower/consulter system, internal regulations clearly specify their anonymity, and that whistleblowers and consulters shall not receive unfair treatment.
In FY2025, we received a total of 681 reports. These reports varied in nature, with 72% concerning human relations and communication, 14% about personnel systems and working conditions, 12% involving violations of laws and rules, and the remaining 2% covering other topics.
|
FY2025 |
||
|
Number of reports received |
681 |
|
|
Details |
Human relations; communications |
72% |
|
Personnel systems; working conditions |
14% |
|
|
Violations of laws/rules |
12% |
|
|
Other |
2% |
|
To enable our employees to gain a deeper understanding of human rights and diversity, we seek to educate them across all employment categories by sharing information about human rights and diversity through in-house newsletters and the intranet, as well as by providing training and awareness programs when hiring or renewing their employment contracts.
In FY2024, in tandem with compliance education, we provided managerial staff and administrators with human rights education to ensure that they have a basic understanding of business and human rights.
In January 2023, we also started distributing to all employees the Diversity & Inclusion Handbook, which summarizes our approach to diversity, along with model cases.
We have received feedback from across the OLC Group, such as, “I was able to gain new perspectives on the due consideration required at work,” and “I have developed a better understanding through dialogues, which introduced me to new views.”
[Structure of Diversity & Inclusion Handbook]
・How to use this D&I Handbook
・Unconscious bias
・Stereotype
・Key points
・Disabilities
・Sexual and gender minorities (SGM)
・Children
・Race, nationality, language, and culture
・Religion & beliefs
・Model cases
- 拡大
- Diversity & Inclusion Handbook
As a part of our actions for the KPIs for 2027 for the ESG materiality area of diversity, equity & inclusion, we issued the Diversity, Equity & Inclusion Handbook by revising the Diversity & Inclusion Handbook. We are endeavoring to provide all our employees with learning opportunities.
The Normalization Creator Class for Park operation employees helps them understand the diversity of guests and cast members as well as develop the mindset and skills needed to accept their diversity.
[Structure of Normalization Creator Class]
・Understanding the concept
・Initiatives to promote diversity at Tokyo Disney Resort
・Situation experience
・Wheelchair experience at a Park
・Discussion
・Summary
In our endeavor to understand what requirements companies are expected to meet in terms of human rights due diligence, we invited external experts to address around 20 members of the Company’s human rights-related divisions at a lecture/discussion meeting held on the topic of business and human rights. At the session, participants learned about the basics of business and human rights as well as the latest trends around the world, including Japan, and discussed human rights issues that affect corporations with reference to global examples.
External experts:
Takeshi Nozawa, CEO, EcoNetworks Co.
Yoko Doi, Co-Founder, Social Connection for Human Rights
- 拡大
- At the discussion
With the aim of gaining a better understanding of children’s rights and business, an area profoundly relevant to our own activities, we hosted a lecture given by an external expert under the title, “Children’s rights and business: How to ensure children are included among company stakeholders.”
Participants acquired basic knowledge about laws and guidelines related to children’s rights worldwide, including Japan, and gained a better understanding of the impact of corporate advertising and marketing activities on children’s rights, and the behavior expected of companies. The lecture was followed by a panel discussion, which was led by the lecturer and an external expert and explored areas specific to our own business. The lecture was delivered online, with the participation of approximately 80 Group employees.
External expert:
Yumiko Horie, Head of Advocacy, Save the Children Japan
Handout for the lecture, “Children’s rights and business: How to ensure children are included among company stakeholders”
To acquire knowledge of key human rights issues and take effective measures for vulnerable stakeholders, we hosted a roundtable session with LGBT individuals. About 50 people participated in the discussion, where the LGBT guests shared the troubles they often face, in order to gain a deeper understanding of gender and sexual diversity. We also asked the guests to talk about what made them feel happy, disappointed, or dissatisfied when they were at our Theme Park or hotel, and the participants discussed potential improvements to restrooms as well as how to avoid gender-specific phrases when talking to people. We are drawing on insights gained from this session as stakeholder feedback to implement internal awareness activities and other initiatives.
External experts
Ryo Tatsuki, Representative Director, General Incorporated Association LGBT-JAPAN
Miyu Nakagawa
The OLC Group has set the following indicators and goals in the ESG materiality area of diversity, equity & inclusion, which also includes respect for human rights.
|
Direction of initiatives |
KPIs |
|
|
2030 |
2027 |
|
|
[Respect for human rights] Reduce risks and ensure relief for victims through continuous efforts in human rights due diligence and awareness raising [Respect for customer diversity] Examine focus areas in light of the business environment and implement initiatives accordingly [Respect for employee diversity] Examine focus areas in light of the internal and external environment and implement initiatives accordingly |
[Respect for human rights] Enhance human rights due diligence for designated key human rights issues and expand human rights due diligence among Group companies [Respect for customer diversity] Establish a framework that promotes respect for diversity in activities [Respect for employee diversity] Establish an environment that promotes respect for diversity and inclusion |
[Respect for human rights] ・Review key human rights issues based on gap analysis; implement corrections and remedies for vulnerable rights holders for newly identified key human rights issues; implement preventive measures ・Continue conducting human rights due diligence in fields of employees, suppliers, and customers, and initiate human rights due diligence at Group companies [Respect for customer diversity] ・Issue revised version of “Diversity & inclusion Handbook”; offer learning opportunities to all employees (100%) ・Engagement survey score for employees who respect diversity and act accordingly: 69 (OLC Group-wide) [Respect for employee diversity] ・Proportion of female managers: At least 25% (Oriental Land Co., Ltd.) ・Proportion of male employees who take childcare leave: At least 95% (Oriental Land Co., Ltd.) |
- Transferred leadership of human rights measures to the Risk Management Department, which oversees the Compliance Committee. This has established a centralized framework for human rights-related information management. Also, carried out human rights due diligence for employees, suppliers, and customers.
- Analyzed human rights issues based on the reports received via contact points, and discussed and implemented preventive measures based on the results.
- Formulated and externally disclosed the OLC Group Basic Policy on Harassment by Customers and the OLC Group Guidelines for Recruitment Activities. Also, provided internal training and awareness programs.