Human Rights Policy

1. What is this policy?

2. Why do we need this policy?

• International Covenant on Civil and Political Rights (ICCPR), and
• the International Covenant on Economic, Social and Cultural Rights (ICESCR).

• conduct our business in a manner that respects the rights and dignity of all people, complying with our legal obligations
• respect that all employees have a right to reasonable work conditions and remuneration
• not use forced, compulsory or child labour or other forms of modern slavery in our operations
• not tolerate harassment, adverse discrimination, bribery or corruption in our operations
• require that relevant Employees maintain and enhance our commitment to human rights protection and receive appropriate human rights compliance training and guidance; and
• improve transparency within our business supply chains and operations, including disclosure of potential risk of modern slavery. The concept of ‘risk’ when referring to modern slavery refers to the risk to people, rather than risk to MUFG Pension & Market Services.

3. Who does the policy apply to?

The Policy applies to all Employees of MUFG Pension & Market Services.

We encourage our suppliers to conduct business in an ethical manner and to share our commitments in supporting human rights, and in eliminating modern slavery in their organisation and supply chain.

4. How to comply with this policy?

4.1. MUFG Pension & Market Services’ responsibilities

We are committed to conducting our business in accordance with all applicable laws and regulations and in a way that enhances our reputation in the market. Where local legislation conflicts with the principles and processes described in this Policy, we will comply with the law, while also seeking ways to uphold human rights principles within its operating environment.

MUFG Pension & Market Services will strive to:

• take steps to identify, prevent or address human rights impacts 
• undertake due diligence required to identify and manage human rights risks when assessing new client relationships and suppliers
• not conform with any requests to contribute to, or turn a blind eye to, any breaches of this Policy or of applicable laws related to human rights
• integrate relevant provisions regarding human rights into our supplier management, standard supplier contracts of existing suppliers and employee compliance training; and
• report periodically on our approach to human rights, and regularly review and update our approach. This includes monitoring current and emerging regulations related to human rights, such as those concerning modern slavery, and adapting our policies and practices accordingly.

4.2. Employee responsibilities

We expect every Employee to:

• comply with all relevant laws, including those related to human rights and workplace safety
• comply with this Policy, our Code of Conduct and Ethics and all MUFG Pension & Market Services policies covering aspects of human rights and ethical behaviour
• report all suspected breaches of this Policy in accordance with the Speak Up framework or seek guidance from your manager or an ELT member, or the Manager, Sustainability if unsure whether an activity breaches this Policy; and
• undertake relevant training on human rights where their role requires specific knowledge.

4.3. Regulatory obligations by jurisdiction

We have regulatory obligations under the UK and Australian modern slavery legislation to publish an annual statement on the risks of modern slavery in our operations and supply chains, and actions to address those risks. A summary of key regulation requirements is provided in annexure 1.

5. How will policy compliance be monitored?

5.1 Reporting/Monitoring

The Manager, Sustainability is responsible for maintaining records of the number and severity of breach reports and for monitoring this Policy’s effectiveness. This will be reported periodically to the ELT. A periodic report will be provided to the Board on the Policy’s effectiveness, major breaches if any, and remedial actions undertaken. 

Further detail regarding our approach to human rights and the number of Human Resources grievances, which may include aspects of human rights, can be found in our annual Sustainability Report and through our annual reporting of modern slavery statements.

5.2 Non-compliance

Failure to take reasonable steps to comply with this Policy may result in disciplinary action, up to and including termination of employment.

6. Are there any interrelated policies?

MUFG Pension & Market Services has a range of interrelated policies which cover our obligations as an employer, underpinned by our core values:

• Anti-Bribery and Anti-Corruption Policy
• Code of Conduct and Ethics 
• Complaints and Dispute Handling Policy 
• Discrimination and Equal Employment Opportunity (EEO) Policy 
• Diversity and Inclusion Policy 
• Fraud Prevention Policy
• Grievance Policy 
• Harassment Policy 
• Remuneration Policy 
• Sustainability Policy
• Sustainability Risk Management Policy
• Vendor Management Policy 
• Whistleblower Policy

8. Definitions

[Last Updated: November 2024]