1-14. The RBA (Responsible Business Alliance) Code of Conduct and Practical Human Rights Due Diligence

The Responsible Business Alliance (RBA) is a supply chain CSR code established by a global alliance of companies, primarily from the electronics industry, that calls for responsible business practices in areas such as human rights, labor, health and safety, the environment, and ethics. Member companies include major names like Apple, Intel, and Sony, and the RBA Code of Conduct has become the de facto industry standard. Understanding and adhering to this Code of Conduct is essential for Japanese companies to enter and maintain a presence in global supply chains.

The RBA Code of Conduct is divided into five pillars. 1) Labor: Prohibition of forced labor and child labor, elimination of discrimination, fair wage and working hour management, respect for freedom of association, etc. 2) Health and Safety: Prevention of accidents in the workplace, emergency response, hygienic facilities, and promotion of worker health. 3) Environment: Management of hazardous substances, energy conservation, waste reduction, and prevention of environmental pollution. 4) Ethics: Prohibition of bribery, transparency in information disclosure, and respect for intellectual property rights. 5) Management Systems: Policy formulation, risk assessment, audits and corrections, and the establishment of a reporting system for workers, etc. These are not mere declarations, but are required as specific compliance items in business partner audits and supplier contracts.

"Human rights due diligence" has become increasingly important in recent years. Based on the United Nations Guiding Principles on Business and Human Rights (UNGPs), this refers to a process by which companies identify, prevent, and correct human rights risks throughout their supply chains. Japanese companies are responsible for identifying and addressing human rights violation risks, such as forced labor, excessive labor, and discrimination, not only among their directly employed employees, but also among their subcontractors and raw material suppliers. Typical risk areas include working conditions in factories in Southeast Asia and China, and the issue of conflict minerals in mineral procurement.

The practical steps begin with policy formulation and risk assessment. Management clearly states the human rights policy and conducts risk mapping across the entire supply chain. Next, risks are identified through on-site surveys, supplier surveys, and audits. Based on the results, corrective measures are discussed with business partners, and, as necessary, trading terms are reviewed and support is provided for improvement. It is also important to establish a grievance mechanism for workers and a system that can respond to external criticism.

Human rights due diligence is not something that can be completed in one go; it requires a continuous cycle of improvement. It is effective to regularly evaluate the status of your company and your suppliers using third-party audits (such as VAP audits) based on the RBA Code of Conduct. If non-compliance is found during an audit, you must develop a corrective action plan (CAP) and establish a system to track progress.

Challenges facing Japanese companies include (1) a shortage of specialists in human rights due diligence, (2) limited influence over suppliers, and (3) a slow response to increasing demands for information disclosure both domestically and internationally. In Europe and the United States, legal regulations making human rights due diligence mandatory are already in place, and companies that do not comply adequately are at increased risk of being excluded from transactions.

In conclusion, the RBA Code of Conduct and human rights due diligence are international frameworks that require companies to take responsibility throughout their supply chains. Rather than merely complying formally, Japanese companies must establish effective mechanisms both internally and externally and disclose information with a high degree of transparency in order to gain the trust of the international community and enable sustainable business development.