The SMM Group has set forth a policy on human rights aligned with the SMM Group Corporate Philosophy and the SMM Group Code of Conduct. In determining the policy, opinions were sought both from within the Group, as well as from outside experts. The policy prescribes compliance not only with domestic laws and ordinances relating to human rights, but also with various international standards. Furthermore, we plan to appeal to outside parties with whom the SMM Group has a relationship to prevent human rights problems arising. There were no reports of discrimination encroaching on human rights during FY2009.
We now plan to push ahead with education of employees throughout the SMM Group.
The SMM Group’s policy on human rights, in accordance with the SMM Group Corporate Philosophy and the SMM Group Code of Conduct, has been established as follows.
We gain knowledge of current conditions through questionnaires sent out to affiliates in Japan and overseas. Survey findings indicated no reports of child labor or forced labor during FY2009.
Human rights seminars are held regularly with primary objectives being to deepen awareness of potential human rights issues in the workplace and to prevent them from occurring. These seminars are held mainly for directors and managers at Head Office divisions, while seminars at business divisions and district divisions target a broader range of employees.
We will be looking to enhance human rights education further having established the SMM Group Policy on Human Rights.
To prevent sexual harassment, each business facility has a dedicated consultation office and a designated sexual harassment prevention promotion officer. No incidents falling under the category of sexual harassment were reported during FY2009.

Central Labor-Management Conference
Workers' unions formed at SMM branch offices and facilities of subsidiaries and affiliates in Japan of the SMM Group carry out activity under the umbrella of the Federation of Sumitomo Metal Mining Workers Union (Sumikoren). In principle, all regular employees join workers' unions in accordance with union shop agreements. In order to build up healthy labor-management relations based on mutual trust, in which company and union mutually respect the other party's position, labor-management council meetings, or labor-management discussions, are held at least once a month with unions at each branch or Group company. The Central Labor-Management Conference, a meeting between SMM management and executives of Sumikoren unions, is held once a year around March.
We also implement questionnaires to ascertain conditions relating to the establishment of workers' unions overseas. In addition, we visit overseas business facilities in order to observe the labor-management situation in those locations first-hand and to exchange information.
Various committees comprising members from labor and management are set up to tackle matters deemed important to both sides so that the views of both labor and management can be reflected in revisions to, or the additional formulation of, a wide range of measures. Management endeavors to act in good faith, for example in providing sufficient advance notice in the case of business reforms that will have a significant impact on employees.
With an eye to bringing management and frontline operations closer together, the president visits business facilities in person to engage in dialogue with front-line employees. In FY2009, he visited every SMM facility.
Another method for receiving feedback from employees involves the gathering of requests and opinions through a self-submission system executed in conjunction with annual interviews with immediate superiors. Under the system, employees submit a "suggestion to management." We plan to summarize these suggestions for circulation among officers.
One initiative relating to the Six Key CSR Areas, headed by the Communication Subcommittee, was the implementation in March 2010 of an employee awareness survey targeting all employees (including limited-term and nonregular employees who had worked for at least a year at the time of the survey) at workplaces under SMM's direct control.
The purpose of the survey was to find out what employees feel about the activities, culture, environment and other aspects of the company as a way to identify issues that concern them and determine the causes, then to link findings to an action plan aimed to make SMM a "good company." An outside research company was employed to carry out the survey to ensure as much objectivity as possible in ascertaining the facts, to constructively reflect expert opinions in action plans, and to enable comparisons with other companies. The response ratio was 94.6%, which is high compared to ratios generally recorded by research companies.
We now plan to provide feedback on survey findings to employees via Intranet notice boards, in-house bulletins and other methods, and also to analyze the issues from an overall perspective, looking for example at workplace circumstances such as communication, operation and systems, then utilize that information to formulate and implement new measures and make improvements.