Norwegian transparency act statement
for
Miki JFC AS
(01.07.2024 – 30.06.2025)
1 INTRODUCTION
In Miki JFC AS («Miki JFC» or the “Company”) we’re committed to conduct our business in a sustainable manner, in accordance with socially responsible and ethical principles. We strive to be a responsible buyer and supplier and conduct regular due diligence in line with the Norwegian Transparency Act and the OECD Guidelines for Multinational Enterprises, to identify and handle any negative impacts on fundamental human rights and decent working conditions related to our operations or our supply chain. The result from our due diligence is accounted for in our Human Rights Due Diligence Report which is published on our website annually. Requests for information from the public regarding how we address any adverse impact on human rights and/or decent working conditions can be submitted using our contact form at our website.
2 KEY INFORMATION ABOUT THE COMPANY
2.1 About the Company, ownership structure and organization
Miki JFC AS with registration number 994 796 518 is a private limited liability company. Validly registered and existing according to Norwegian company law.
The Company was established in Norway and is fully owned by JFC INTERNATIONAL (EUROPE) GmbH located in Germany. JFC INTERNATIONAL (EUROPE) GmbH is part of Kikkoman group.
The Company is located in Bærum municipality and have 15 employees.
2.2 Products, services and market
Miki JFC’s primary business is the importation and distribution of oriental food products and in particular, Japanese food productions, in the Norwegian market.
2.3 Person responsible for this report
The person responsible for the due diligence assessment in Miki JFC and this report is:
Hitoshi Fukuhara, General Manger, e-mail: oslo@jfc.eu.
2.4 Our policies and procedures for managing risks related to human rights
The following guidelines and procedures help us conduct our business in a responsible manner:
2.5 Supply chain
The company sources a wide range of products from suppliers around the world including related companies within the Kikkoman Group and third-party suppliers. The company sources a wide range of products and services from suppliers and business partners around the world including related companies within the Kikkoman Group and third-party suppliers. Approximately 83 % of our products and services are sourced from Norwegian and European suppliers and business partners, while approximately 14 % is sources from suppliers and business partners from Asian countries.
3 MAPPING AND RISK ASSESSMENT
3.1 Methodology
Last year, we conducted our Human Rights Due Diligence assessment by forming an overall risk profile of our upstream and downstream activities, and then we prioritized the most significant risk areas for more thorough mapping and handling of findings. The assessment and prioritisation of risk was based on the severity and likelihood of adverse impacts.
No actual adverse impacts were identified. However, potential significant risks for adverse impacts were identified in the suppliers located in China and South Korea (with a high risk of workers and human rights violations) for food/beverage and seafood items in the areas of forced labour, child labour, wages and environment/health/safety because of its geographical and industrial nature and situation. We acknowledged that we need more information about those suppliers.
This year, we carried out a Human Rights Due Diligence assessment by inviting 16 suppliers deemed to pose potential significant risks of adverse human rights impacts to complete a detailed Supplier Questionnaire. The questionnaire is structured into nine thematic sections, comprising a total of 53 questions addressing various aspects of human rights and decent working conditions.
3.2 Findings
Of the suppliers requested to complete the questionnaire, 88% provided full responses to all questions. Another 6% submitted incomplete responses, while the remaining 6% failed to respond by the designated deadline.
No actual adverse impacts were identified in the answers. However, potential significant risks for adverse impacts were identified in several suppliers.
Although the number of such cases was limited, the absence of codes of conduct, relevant policies, HSE audits, and risk assessments was noted among several suppliers. Based on their responses to other parts of the questionnaire, no actual instances of human rights violations or inappropriate working conditions were identified. However, the absence of a formal code of conduct and related policies creates ambiguity regarding standards of appropriate behaviour, which may lead to important decisions related to human rights and working conditions being overlooked. Furthermore, without conducting risk assessments, it is not possible to proactively identify and mitigate potential issues, thereby increasing the likelihood of serious human rights or labour-related problems arising in the future.
Section 6 – Child labour and youth employment
There was a response indicating the absence of procedures to prevent child labour simply because it is not being practiced. However, this approach lacks preventive measures and presents a potential risk of child labour occurring.
Section 7 – Collective bargaining and worker representation
Although differences exist depending on the country and company, it was confirmed that at least the companies that responded to the questionnaire allow employees the freedom to join unions and engage in collective bargaining.
Section 9 – Whistleblowing
It was confirmed that, with the exception of one supplier, a whistleblowing system is in place. The absence of such a system can increase the likelihood of misconduct or violations being concealed, potentially leading to a decline in employee morale, and thus can be considered a potential risk.
There were no responses that could be considered as potential risks in Section 3 (Working conditions), Section 5 (Forced labour) and Section 8 (Local communities and indigenous people). In Section 4 for working environment, no potential risks were identified overall, aside from the aforementioned incomplete HSE audit.
4 MEASURES TO STOP OR LIMIT RISKS
4.1 Methodology and chosen measures
The potential risk of adverse impacts on fundamental human rights and decent working conditions identified in the previous section shall be addressed by implementing appropriate measures to cease actual adverse impacts or mitigate significant risks of adverse impact. In the assessment of which measures to implement, we have been considering our connection to the negative impacts and our ability to influence them.
The suppliers who either submitted incomplete responses or failed to respond to the questionnaire by the deadline are based in Western Europe where the risk of human rights and labour issues arising is relatively low due to the presence of various regulations, as well as cultural and business practices. In addition, a review of the suppliers’ official websites indicates that established management systems and whistleblower mechanisms are in place. As such, the potential for significant adverse human rights impacts is considered low. Nevertheless, follow-up actions will be taken with these suppliers. Should they continue to demonstrate unwillingness to cooperate, the possibility of discontinuing procurement from them will ultimately be considered.
We will individually pursue further action on the suppliers whose situations and conditions are not considered optimal, for example, lack of polices, routines and standard. While the process may require time, we will continue to stress the importance of establishing and formalizing codes of conduct and related policies to these suppliers. Through ongoing engagement, we aim to encourage their implementation and thereby reduce associated risks. In cases where no meaningful progress is observed, the reduction or discontinuation of procurement will be considered as a possible course of action.
This year’s Human Rights Due Diligence assessment was limited to our direct suppliers. Nevertheless, as part of our broader risk prevention and mitigation strategy, we acknowledge the need to obtain greater transparency regarding suppliers that source products from third parties rather than producing them directly. Although no adverse human rights impacts were identified among our direct suppliers during this year’s assessment, this does not necessarily indicate the absence of such risks further upstream in the supply chain. Therefore, we will expand our Human Rights Due Diligence efforts to include the suppliers of our suppliers. In parallel, we will enhance our procurement framework to increase direct sourcing from manufacturers. By engaging manufacturers as direct suppliers, we aim to improve transparency regarding their operational practices and management systems, thereby enabling more effective risk mitigation.
We have had Kikkoman/JFC EU Group Code of Conduct as group level. To strengthen and clarity its connection with the local duties and responsibilities more, the company issued Miki JFC AS Code of Conduct, Miki JFC AS Anti-Bribery and Anti-Corruption Policy and Miki JFC AS Fair Competition Policy.
To increase employee awareness, all the above mentioned polices have been prominently posted within the office to help ensure an understanding of internal policies.
We have a contact point for customers, suppliers and the public to contact us with any requests regarding the Norwegian Transparency Act. Such requests can be submitted using the contact form easily available on our website.
5 CONTACT
For questions about this report or how we work to respect fundamental human rights and decent working conditions, please contact Hitoshi Fukuhara, General Manager by email: oslo@jfc.eu.
***
Bærum, 19/06/2025
On behalf of Miki JFC AS
The board od directors:
Toshiyuki Ogawa – Chairman
Harald Niclas Tøsti – Board member
General Manager:
Hitoshi Fukuhara – General Manager