Business and Human Rights 2025

JAPAN Trends and Developments Contributed by: Hideaki Roy Umetsu, Aki Tanaka, Aritsune Miyoda and Chihiro Tsukada, Mori Hamada

Background Japan’s progress following the introduction of the UNGPs Since the United Nations adopted the Guid - ing Principles on Business and Human Rights (UNGPs), countries around the world – particu - larly in Europe and North America – have made significant advances in integrating business and human rights considerations into their legal and policy frameworks. In contrast, Japan’s pro - gress in this area has been notably slower. For instance, the United Kingdom introduced its National Action Plan in 2013, and throughout the 2010s, many European countries and the Unit - ed States followed suit with their own National Action Plans. Legislative measures such as the UK’s Modern Slavery Act of 2015 and France’s Duty of Vigilance Law of 2017 further under - scored the growing international emphasis on corporate responsibility for human rights. During this period, however, Japan’s government took limited action to address business and human rights concerns. Despite this, significant social issues were emerging within Japan, particularly in the con - text of the Technical Intern Training Program ( ginou jisshu seido ). Foreign trainees were often required to pay excessive recruitment fees in their home countries and, upon arrival in Japan, faced poor working conditions and restrictions on changing employers, leading to cases of dis - appearance and exploitation. Additionally, Japa - nese companies with global operations became subject to foreign laws and regulations, either directly or through the expectations of their inter - national business partners. Foreign companies, motivated by their own legal obligations or vol - untary commitments to the UNGPs, began con - ducting human rights due diligence on Japanese suppliers. Consequently, Japanese companies found themselves compelled to address human

rights issues to comply with legal requirements and fulfil their social responsibilities. In response, a range of private sector initia - tives emerged. The Japan Federation of Bar Associations published “Guidance on Human Rights Due Diligence” for Japanese companies in 2015. The Japan Business Federation ( Kei- danren ) revised its Charter of Corporate Behav - ior in 2017 to include human rights provisions. In 2019, in collaboration with the BHR Lawyers Network Japan, the Global Compact Network Japan developed the “Engagement and Remedy Guidelines for Promotion of Responsible Busi- ness Conduct and Responsible Supply Chains,” providing practical guidance for Japanese com - panies on establishing and operating grievance mechanisms. Building on these private sector efforts, the Jap - anese government began to take more active steps. The National Action Plan was formulated in 2020, followed by the issuance of the “Guide- lines on Respecting Human Rights in Responsi- ble Supply Chains” (the “Guidelines” ) in 2022 – the government’s first comprehensive guidance in this field. In 2023, the Ministry of Economy, Trade and Industry published practical reference materials for the Guidelines, and the Ministry of Agriculture, Forestry and Fisheries issued guide - lines for food companies on respecting human rights. The National Action Plan is scheduled for revision in 2025. In recent years, serious human rights issues – including sexual abuse and sexual harassment – have come to light within Japan’s entertain - ment and media industries, drawing intense public scrutiny and sparking widespread soci - etal debate. Many companies utilize celebrities in their advertising campaigns or place adver - tisements with these media outlets, making

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