Policies, Regulations and Strategies

Respect for Human Rights

Human rights policy in line with the UN Guiding Principles on Business and Human Rights

The OLC Group is promoting effective initiatives to respect 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.
We are currently engaging in discussions regarding the implementation of human rights due diligence, drawing upon existing initiatives.

Formulation Process of the Human Rights Policy Statement

We discussed and revised our Human Rights Policy Statement by using the following process.

Dialogue with Experts


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.

・There is no need to start human rights due diligence from scratch. Instead, it is important to consider how existing initiatives can be built upon and leveraged.

Strategy to Respect Human Rights

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.


・Declined experience value due to insufficient diversity measures
・Manifestation of risks due to insufficient measures to ensure that human rights are respected


・Increased 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.


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 & inclusion” category of our ESG materiality areas. Matters related to the ESG materiality area of diversity & inclusion are discussed at the Corporate Conduct Committee chaired by the Director of the Corporate Strategy Planning Division (Executive Director and Executive Vice President Officer). Subsequently, the Sustainability Promotion Committee chaired by the Representative Director, Chief Operating Officer and President discusses in further detail the order of priority and resource allocation pertaining to related initiatives. The results are then reported to the Executive Committee and Board of Directors for deliberation.
The Corporate Conduct Committee also discusses the internal system for promoting human rights measures in a sustainable manner.
Reporting to the Corporate Conduct Committee are the Subcommittees on Diversity & Inclusion and Supply Chain Management, which respectively discuss and promote matters concerning customer diversity and sustainable procurement.
For each ESG materiality, we have set KGIs for 2030, KPIs for 2026 and KPIs under the 2024 Medium-term Plan to assess our progress. The progress status is reported to the Board of Directors and Executive Committee at least once a year.


Risk Management

Identification of key human rights issues

In conjunction with revising its human rights policy, the OLC Group has identified key human rights issues based on the following steps.


[Key human rights issues]
・Human rights issues in supply chains
・Human rights issues related to the environment and climate change
・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

Implementing Human Rights Due Diligence

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 are performing 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 will complete gap analyses and establish a sustainable structure for promoting human rights by FY 2024. 
In FY 2024 and beyond, we will review the key human rights issues based on the results of the gap analyses, and formulate a medium-term roadmap for the period leading up to 2030.
Our key human rights issues will be periodically reviewed in response to social circumstances and our progress of human rights due diligence efforts.

The key findings from the gap analysis within the three groups are outlined below.


Assessment and suggested preventive and remedial measures

Issues and future actions


・In reference to the eight criteria for a grievance mechanism set forth in the UN Guiding Principles on Business and Human Rights, assessed the effectiveness of the OLC Group’s contact points (helplines)

・Investigated the number and details of reports received by the OLC Group’s contact points

・Make those contact points aligned with global human rights standards, including giving consideration to vulnerable rights-holders

・Analyze the details of reports received by the contact points

Supply chain

The Subcommittee on Supply Chain Management identified high-risk resources and formulated a response policy

>Supply chain management

Conduct a desktop survey on resources linked to human rights risks


・The Subcommittee on Diversity & Inclusion determined the priority order of measures for customers

・Conducted a round-table session with LGBT individuals to discuss concerns that cause them discomfort or dissatisfaction, and started a review of our services to eradicate gender stereotyping

・Formulate an investment plan and determine concrete initiatives in line with the priority order

・Raise awareness of diversity by using our Diversity & Inclusion Handbook

Incorporating Human Rights Risks into Group-wide Risk Management

To address our 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, discerns 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 Corporate Strategy Planning Office, 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 Group’s strategy.
Risks related to human rights and diversity form part of the sustainability risks and are included in our strategic risks.


Indicators, Goals, Actions and Performances

Indicators and goals for ESG materiality to 2030

The OLC Group has set the following indicators and goals for the period leading up to 2030 in the ESG materiality area of diversity and inclusion, which also includes respect for human rights.

KGIs for 2030
・Build and implement a human rights due diligence process for determined key human rights issues
・Build systems for implementing business activities that respect diversity

KPIs under 2024 Medium-term Plan
・Conduct gap analyses on 11 key human rights issues in three groups—employees, supply chain, and customers—and identify areas in which initiatives for vulnerable rights-holders are insufficient
・Establish a sustainable internal structure for promoting human rights initiatives
・Distribute the Diversity & Inclusion Handbook to 100% of our employees
・Conduct a gap analysis on existing facilities/services and formulate and implement countermeasures

Installation of Contact Points (Helplines)

We have established a contact point for employees wishing to report any instances of improper conduct including any types of harassment and improper information management within or without our Group.
We also offer such contact points for each employment category and our Group company to make it easier for employees to seek counseling for any potential issues.
Furthermore, we also provide a dedicated contact point for suppliers as a means of identifying, at an early stage, any violation or suspected violation of compliance by an executive or employee of our 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 treatments.

In FY2022, we received a total of 445 reports. These reports varied in nature with 68% concerning human relations and communication, 18% about personnel systems and working conditionsinvolving violations of laws and rules, 12% involving violations of laws and rules, and the remaining 2% covered other topics.

Human Rights Education

To enable our employees to gain a deeper understanding of human rights and diversity, we seek to educate them by sharing information about human rights and diversity through in-house newsletters and the intranet.
In January 2023, we also started distributing to employees the Diversity & Inclusion Handbook, which summarizes our approach to diversity, along with model cases.
The Diversity & Inclusion Handbook is designed for all employees not only to read through, but also to share their feedback and engage in dialogues. The whole process, including the output by employees, aims to help them better understand diversity and inclusion and take concrete action.
We have already received feedback from across the 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
・Key points
・Sexual and gender minorities (SGM)
・Race, nationality, language and culture
・Religion & beliefs
・Model cases

Diversity & Inclusion Handbook
Diversity & Inclusion Handbook

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

Stakeholder Engagement relating to Human Rights

To acquire knowledge of key human rights issues and take effective measures for vulnerable stakeholders, our Subcommittee on Diversity & Inclusion, which reports to the Corporate Conduct Committee, hosted a round-table 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 the participants discussed potential improvements to restrooms as well as how to avoid gender-specific phrases when talking to people.


External experts
Ryo Tatsuki, Representative Director, General Incorporated Association LGBT-JAPAN 
Miyu Higashine


Takeshi Nozawa, CEO, EcoNetworks Co. 

At the discussion
At the discussion