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POLICY FOR RESPONSIBLE BUSINESS CONDUCT

 

1    Introduction

At Toyota Norge AS (“Toyota Norge”), we are committed to respecting universal human rights and decent working conditions as set out in the United Nations Guiding Principles on Business and Human Rights” (UNGP), the International Covenant on Economic, Social and Cultural Rights of 1966, the International Covenant on Civil and Political Rights of 1966 and the ILO's conventions on fundamental principles and rights at work (together “International Human Rights”). We respect the rights of our employees, workers in our supply chain, and others who may be affected by our activities.

The objective of this policy for Responsible Business Conduct (“RBC policy”) is to describe Toyota Norge’s commitment to respecting International Human Rights, and how we implement measures to cease, prevent or mitigate potential and actual adverse impacts on International human rights that Toyota Norge may cause or contribute towards, or that are directly linked with Toyota Norge’s operations, products, or services. The RBC policy sets out guidelines and principles for how we will continue to protect and improve the human rights of our employees, customers, and all people involved in and affected by our business activities.

The Toyota Group has several governing documents for sustainability and RBC issues that also applies to Toyota Norge. This includes the Guiding Principles at Toyota, Toyota Motor Corporation’s Code of Conduct and Supplier Sustainability Guidelines, and Toyota Motor Europe’s Sustainable Purchasing Guidelines. This RBC policy shall be read and construed in conjunction with these policies.

2       Commitment

This RBC policy is the basis for our compliance with International Human Rights obligations together with the laws and regulations of the countries in which we operate within. In operations where there is a difference between the national and international standard for human rights, we will adopt the higher standard of the two.

All leaders and managers within Toyota Norge are responsible for setting the right tone at the top to cultivate compliance with the Norwegian Transparency Act (Act 2021-06-18-99) (in Norwegian: Lov om virksomheters åpenhet og arbeid med grunnleggende menneskerettigheter og anstendige arbeidsforhold (Åpenhetsloven)) (hereinafter the “Transparency Act”) and to ensure that Toyota Norge complies with International Human Rights standards.

The automotive industry is supported by numerous people, including local communities, suppliers, business partners such as dealers, customers, etc. Hence, we recognize that our business operations could be at risk to potential and actual human rights impacts. We seek to uphold the human rights of others and shall address any human rights infringements that may arise from our business operations by taking responsibility for them.

We expect our suppliers and business partners to also respect International Human Rights. Our requirements and expectations towards suppliers and business partners are described in Toyota Norge’s Supplier Code of Conduct. We also seek to make contractual agreements with our suppliers and business partners that require them to respect universal human rights in their work for Toyota Norge, as appropriate to the nature of their work for us.

3    Human Rights Due Diligence

3.1    General

In order to fulfil the responsibility to respect International Human Rights, we have established and will continuously implement a human rights due diligence system, in order to identify, prevent, and mitigate negative human rights impacts from our business operations. The due diligence will be carried out in line with the OECD Due Diligence Guidance for Responsible Business Conduct and the Transparency Act.

3.2    Embedding RBC into policies and management systems

Toyota Norge has reviewed existing policies on RBC issues (Code of Conduct, Supplier Code of Conduct, anti-bribery and corruption guidelines) to align with the Transparency Act and the standards of the OECD Guidelines. Additionally, Toyota Norge has developed and adopted this RBC policy in order to articulate Toyota Norge’s commitment to respecting International Human Rights in the enterprise, and expectations towards suppliers and business partners on this area. The RBC policy will be made publicly available on Toyota Norge’s website.

The RBC policy will be communicated to employees and other workers at Toyota Norge. Toyota Norge has assigned responsibility across the enterprise for implementing all parts of the RBC policy into Toyota Norge’s management systems. Necessary training will be provided for workers in Toyota Norge in order to help them understand and implement the RBC policy into relevant business units. We also ensure that this policy is incorporated within the necessary processes, such as each function’s policies and guidelines, so as to become institutionalized across all of our corporate activities.

3.3    Materiality analyses

Toyota Norge carries out scoping exercises in order to identify the most significant and relevant RBC risks amongst Toyota Norge’s own business and operations, including the activities of the supply chains and business partners. The initial screening is based on risk factors such as high-risk areas and high-risk industries/products. Based on the findings of this exercise, Toyota Norge will initiate more thorough assessments of the most significant RBC risk areas. Whenever Toyota Norge or enterprises in the supply chain makes significant changes, the initial scoping exercise will be updated with new and relevant information.

3.4    Assessments of prioritised risk areas

Toyota Norge will assess the prioritised risk areas based on several factors, such as the severity and scale of the risk, the extent to which Toyota Norge has directly or indirectly caused or contributed to the risk (or may cause or contribute to), the length of the relevant business partnership where the risk is found, and the possibility of using leverage towards the relevant supplier or business partner.

3.5    Cease, prevent and mitigate potential and actual adverse impact

If Toyota Norge identifies adverse impact on RBC issues that Toyota Norge is causing or contributing to, Toyota Norge shall without delay take action in order to prevent such activities to cause or contribute to adverse impact in the future. This can include taking steps to ceasing or correcting the relevant activity, reviewing existing policies, routines and contracts, and/or providing training for relevant workers and strengthening the management systems.

If Toyota Norge has caused or contributed to an adverse impact on human rights, we shall implement suitable corrective measures. Toyota Norge will go into dialogue with stakeholders that are impacted by the activity. We will also use our leverage towards suppliers and business partners in order to encourage them to implement measures to cease, prevent and mitigate potential and actual adverse impact in their supply chain.

Toyota Norge shall also monitor that corrective measures have been taken, and that they are effective. Additionally, Toyota Norge will track the effectiveness of Toyota Norge’s own commitments and due diligence activities. Additionally, Toyota Norge will continue to develop and operate a practical remediation mechanism by expanding the function of Toyota’s existing grievance mechanism which has been established in Japan, in addition toother regions.

In order to ensure that everyone in Toyota Norge is able and encouraged to report about breaches of our Human rights policies or other internal guidelines, Toyota Norge has developed a Procedure for reporting (Whistle Blowing) and handling of non-conformities policy. An important part of the policy is that no one shall suffer adverse employment consequences, harassment, discrimination or retaliation for making a claim in good faith of a violation of Toyota Norge’s policies. At Toyota Norge we foster an open-door policy and encourage employees to share their questions, concerns, suggestions or complaints with someone who can address them properly.

4    Stakeholder engagement

Engagement with internal and external stakeholders is of great importance throughout the entire due diligence process. Hence, Toyota Norge strives to communicate accurate and timely information on the due diligence processes, findings and plans through public dialogue, enhancing its corporate image and transparency. The information will be included in an annual statement pursuant to the Transparency Act. The annual statement will also include a description of Toyota Norge’s structure, area of operations and guidelines and procedures for human rights due diligence. The annual statement will be made easily accessible on Toyota Norge’s web page.

Toyota Norge listens to and respects its stakeholders’ criticisms and suggestions and incorporates these as appropriate into its businesses. If Toyota Norge may have caused or contributed to an adverse impact, we will engage with impacted or potentially impacted stakeholders and rightsholders. Additionally, when processing requests from stakeholders, Toyota Norge will provide adequate and comprehensible information in accordance with the Transparency Act, and – if necessary – follow up with reasonable assessments and measures.

5    Implementation and follow-up

This version of Toyota Norge’s Responsible Business Conduct policy was approved by the Board on 21.06.2022. Toyota Norge will ensure the complete implementation of this policy by continually tracking its progress and allowing for revisions to the policy if needed.

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6    References

Toyota Sustainable Purchasing Guidelines

https://www.toyota-europe.com/download/cms/euen/Sustainable Purchasing Guidelines_2016_tcm-11-1625593.pdf

Guiding Principles at Toyota

https://global.toyota/en/company/vision-and-philosophy/guiding-principles/

Toyota Motor Corporation’s Code of Conduct

https://global.toyota/pages/global_toyota/company/vision-and-philosophy/code_of_conduct_001_en.pdf

Toyota Motor Corporation’s Supplier Sustainability Guidelines

https://global.toyota/pages/global_toyota/sustainability/esg/supplier_csr_en.pdf

United Nations Global Compact

https://www.unglobalcompact.org

United Nations Universal Declaration of Human Rights

https://www.un.org/Overview/rights.htm

OECD Due Diligence Guidance for Responsible Business Conduct

https://www.oecd.org/investment/due-diligence-guidance-for-responsible-business-conduct.htm

ILO Core Conventions

https://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang--en/index.htm