SUBARU promotes CSR procurement activities through the Purchasing Committee, which is composed of the procurement departments of the Automotive Business and Aerospace Company, and chaired by the Managing Executive Officer and Chief General Manager of the Purchasing Division.
The action policy of the Purchasing Committee is to facilitate fair procurement practices and encourage CSR at suppliers. The committee oversees efforts to address environmental, social, and governance (ESG) issues in procurement and shares the latest relevant information. By integrating any management issues identified into our action plans and implementing a plan-do-check-act (PDCA) cycle, we help to ensure fair trade between SUBARU and its business partners as well as cooperative CSR procurement throughout the supply chain. We have also been promoting CSR procurement on a global scale in collaboration with Subaru of Indiana Automotive, Inc. (SIA) , our local production plant in the U.S.

CSR Procurement System

Targets and Metrics

The SUBARU Group is strengthening its CSR initiatives in cooperation with business partners toward sustainable procurement on a global scale.

• Building relationships with business partners from CSR perspectives
  We aim to strengthen our relationship by conducting due diligence in accordance with international standards such as the OECD Due Diligence Guidance for Responsible Business Conduct and by establishing and operating a grievance mechanism.

• Promotion of fair trade on a continuous basis
  We are promoting initiatives for fair trade by thoroughly disseminating our voluntary action plan and thoroughness plan.

• Conducting conflict minerals, mica, and cobalt surveys
  We conduct investigations in compliance with international norms and standards, such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Approach to Risks and Opportunities

The SUBARU Group procures parts and materials from numerous suppliers, and we recognize that the stability of our procurement activities is an important foundation for our business operations. Fluctuations in raw material prices in cases where the Group is dependent on specific raw materials and suppliers, as well as disruptions in the supply chain and tight supply-demand balance in the event of emergencies such as natural disasters, fires, and cyberattacks suffered by suppliers, could affect the Group’s management and financial position. Therefore, the SUBARU Group strives to ensure stable procurement by reducing the impact of fluctuations through adjusting the amount of raw materials used, checking suppliers’ quality assurance capabilities and management conditions, and building a procurement business continuity plan (BCP).
However, procurement is not limited to securing supplies. It is also closely related to corporate social responsibility and sustainability. When human rights violations or unethical conduct occur in the supply chain, there is a risk of violating international regulations and damaging our brand. Therefore, we have established the SUBARU Supplier CSR Guidelines and are working to identify risks and support improvements through awareness-raising and due diligence for our suppliers. We are taking actions to establish a sustainable procurement system that includes responsible mineral procurement and consideration for biodiversity.
Furthermore, through these initiatives, strengthening relationships of trust with our suppliers and actively addressing human rights and environmental issues contribute to enhancing the trust of our customers and investors both in Japan and overseas. This also leads to the creation of business opportunities, such as the joint development of new technologies and materials through collaboration with business partners and the development of products with high environmental performance. The SUBARU Group views procurement not only as a conduit for risk management but also as a starting point for value creation, and is working to achieve sustainable manufacturing.

Promoting Fair Trade

SUBARU maintains compliance with laws and regulations such as the Antimonopoly Act and the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors. SUBARU also carries out fair trade promotion initiatives based on Automobile Industry Fair Trade Guidelines. As part of these efforts, SUBARU conducts regular education for its employees and has set up a consultation service targeting suppliers in its supply chain to spread awareness. In 2020, we took the Partnership Formation Oath for the purpose of coexistence and prosperity of both large companies and SMEs.
The Aerospace Company conducts a survey for its business partners regarding satisfaction with its Purchasing Department. This allows better understanding of the current status of fair and proper transactions, including human rights considerations such as the conduct of those in charge of procurement at SUBARU, from the standpoint of its business partners.
For employees, we provide legal and regulatory training and other programs for those in charge of procurement to elevate their understanding of proper business practices.

FYE March 2025 Training on Fair Trade and ESG

The SUBARU Group is working to build a sustainable supply chain by ensuring fair trade and strengthening education programs that incorporate environmental, social, and governance (ESG) perspectives. In particular, we believe it is important to establish systematic programs tailored to the roles of both our suppliers and internal procurement staff.

(1) Education for suppliers
In accordance with the SUBARU Supplier CSR Guidelines, the SUBARU Group strives to enhance educational opportunities with its business partners with the aim of sharing value and building sustainable business relationships.

• Procurement Policy Briefings: Briefings on our CSR procurement policies for management of suppliers (once a year)
• Responsible Mineral Procurement Briefings: Briefings on responsible mineral procurement when requesting mineral surveys (once a year)
• CSR Procurement Briefings: Briefings on CSR procurement during Supplier CSR Surveys (once a year)

(Companies)

(2) Internal education (for procurement departments)
SUBARU Group has established a training system, including the following, tailored to different ranks and positions with the aim of fostering appropriate business practices and ESG awareness among procurement staff:

• Training for new employees: Understanding our CSR procurement policies, basics of human rights, environment, and compliance, basics of fair trade (annual)
• Training for transferees: Same as above (ad-hoc)
• All ranks: CSR education (sharing of CSR education content with suppliers) (once a year), comprehension tests for compliance, Sustainability Newsletter (ad-hoc)
• Education for CSR procurement promoters: External training at the United Nations Development Programme “B+HR Academy” and other institutions (at least once a year)

We will continue to review and enhance these educational systems on an ongoing basis as a means of building trust with suppliers and strengthening the entire supply chain.

Automotive Business Purchasing Division

(Employees)

Aerospace Company Supply Chain Management Department

(Employees)

*

Years with zero employees are those with no new graduate hires or new transferees.

• Consultation service for promoting fair trade (Japanese version only)
• Partnership Formation Oath (Japanese version only)

SUBARU Supplier CSR Guidelines

To promote SUBARU’s CSR procurement and help our suppliers conduct CSR activities, we created, and in FYE March 2012 began application of, the SUBARU Supplier CSR Guidelines. They are based on the CSR Guidelines for Suppliers of Japan Automobile Manufacturers Association, Inc. (JAMA), and incorporate our CSR policy.
At SUBARU, compliance with these guidelines is one of the criteria in our supplier selection. We request that our direct suppliers (Tier 1) manage risks related to human rights, the environment, and corporate governance throughout the entire value chain, including upstream suppliers (Tier 2), to address a wide range of sustainability risks.

Guideline Formulation/Major Revision History

FYE March	Description
2012	Guidelines formulated
2014	Guidelines made company-wide and global, including for all suppliers of the Aerospace Company
2016	Content revised to incorporate the non-use of raw materials that engender social problems, such as conflict minerals*1. Also revised guidelines in the form of a joint edition with overseas affiliate Subaru of Indiana Automotive, Inc., confirming the integration of our procurement policy
2021	Incorporated the SUBARU Global Sustainability Policy, Human Rights Policy*2, and Fundamental Procurement Policy (revised edition)
2023	Formulated and published the Responsible Mineral Procurement Policy
2025	Requested all Tier 1 suppliers to submit an agreement to comply with the guidelines

*1

Conflict minerals: Minerals for which there is concern regarding participation in unjust acts, such as support for non-governmental armed groups, human rights violations, or illegal acts. In Dodd-Frank Act of the U.S., tin, tantalum, tungsten, and gold are specified as minerals for which there is concern that they may be a source of funding for armed groups in the Democratic Republic of the Congo and surrounding countries.

*2

Identifying and addressing human rights risks in the supply chain is part of SUBARU Group’s Company-wide efforts based on its Human Rights Policy. An overview of the policy, system, and monitoring is disclosed in “Respect for Human Rights.”

Respect for Human Rights

SUBARU Supplier CSR Guidelines

Six Topics in the SUBARU Supplier CSR Guidelines

SUBARU promotes our procurement activities based on the following basic approach.

Supplier CSR Briefing and CSR Survey

At the Supplier CSR Briefing, we present corporate policies such as the SUBARU Supplier CSR Guidelines in keeping with the OECD Due Diligence Guidance for Responsible Business Conduct. At these briefings, we clearly communicate SUBARU’s approach to sustainable procurement, including human rights, the environment, and compliance, and provide English-language materials to promote understanding among our major global suppliers. We take care to ensure that briefings are not just one-way distributions of our CSR Guidelines, but rather lead to substantial support for their practice through explanation and dialogue.
In addition, through our Supplier CSR Survey, we monitor and evaluate any negative impacts on human rights, labor, the environment, and compliance at our suppliers, and provide improvement support and follow-ups as necessary.
This series of processes is an important practical element of supply chain CSR due diligence within the SUBARU Group. It was launched in FYE March 2016 and has been conducted continuously every year since FYE March 2018.
In FYE March 2025, we targeted 605 automobile-related suppliers (including 396 in parts and raw materials, and 209 in equipment and jig tools) to attend CSR briefings. All target suppliers provided responses to the survey.
In June 2024, we also conducted a briefing and survey for our suppliers focused on climate change.
The details and results of our actions are as follows.

Number of Suppliers Assessed in the CSR Survey Conducted in the Automotive Business Unit

(Companies)

Supplier CSR Briefing

In the Suppliers CSR Briefings held with suppliers, we presented the importance of promoting CSR in addition to human rights and environmental preservation, details about the SUBARU Group’s CSR-related policies and activities, and made specific requests such as compliance with the SUBARU Supplier CSR Guidelines.

Supplier CSR Survey (Monitoring/Corrective Support)

The Supplier CSR Survey consists of the following three types of surveys, which evaluate the CSR initiatives of our suppliers from multiple perspectives.

• SUBARU supplier CSR check sheet
  Surveys are conducted via SUBARU supplier CSR check sheets, evaluating suppliers’ CSR systems, CSR initiatives for their suppliers, and compliance with the SUBARU Supplier CSR Guidelines covering human rights, labor, and the environment. In FYE March 2025, we identified four suppliers with potential compliance issues in their initiatives, and conducted follow-up interviews that confirmed that the suppliers were taking appropriate actions to address these issues. The above survey and evaluation results are referenced in supplier selection.
• Survey on employment of non-Japanese skilled workers in Japan
  We conducted a survey regarding the employment of non-Japanese personnel by our suppliers, examining wage levels, payment methods, working hours, Article 36 Agreement on overtime work and working on holidays (Labour Standards Act) in Japan, insurance, pensions, health checkups, living conditions, passport possession, Japanese language education, daily life guidance, and industrial accidents. Six suppliers were identified as having potential issues. Follow-up investigations were conducted with the six companies. In all cases, the conclusion was that there were no issues with treatment regarding non-Japanese worker human rights and labor.
• Survey on human rights initiatives
  We conducted a survey on the implementation of human rights due diligence by our suppliers and within the supply chain, information on the origin of high-risk raw materials in case risk has been identified through due diligence, including country, region, ethnicity, company name, other specific details, and the results of addressing these risks. This survey identified one supplier with potential issues. Follow-up interviews with said supplier confirmed that there were no problems with the content of their initiatives.

In the Aerospace Company, we continued to conduct the Supplier CSR Survey for suppliers in FYE March 2024 and confirmed that there were no issues.
We will continue our activities in FYE March 2026 and beyond.

Consultation Service for Non-Japanese Workers

In addition to our existing consultation service for promoting fair trade, in FYE March 2023 we endorsed and cooperated with the supply chain human rights initiative, Japan Platform for Migrant Workers towards Responsive and Inclusive Society (JP-MIRAI), on the establishment of a consultation service for foreign workers in the supply chain in Japan. As background to this, employees of the Purchasing Division, including the general manager in charge, took part in JP-MIRAI’s “Consultation and Relief Pilot Project for Foreign Workers.”
We continued our participation with the “Collaborative Program for Companies Responsibly Hosting Foreign Migrant Workers,” which marked the full-fledged implementation of the program in FYE March 2024, targeting local business partners.
We provide support in 22 languages^* for the consultation service, the area of the program that SUBARU is involved in. This service is available not only for non-Japanese but also Japanese workers employed by business partners.
The consultation service covers a wide range of topics, from gathering information about daily life in Japan to addressing concerns related to human rights and labor issues. For matters that cannot be resolved through the consultation service, we provide accompanying support through consultations with specialists such as lawyers, or utilize the Tokyo Bar Association’s Alternative Dispute Resolution (ADR) for added assistance. This ensures a fair and transparent approach through third-party involvement.
We held a briefing for relevant business partners on the procedures for using the consultation service and requested that they disseminate the information among their employees.
This program, including the consultation service, is designed to be an effective and reliable complaint handling channel that reflects the opinions of stakeholders (suppliers, worker organizations, etc.) gained from dialogue.

*

Easy Japanese, English, Chinese, Korean, Thai, Vietnamese, Indonesian, Malay, Tagalog, Nepali, Myanmar, Khmer, Mongolian, Sinhalese, Hindi, Bengali, Portuguese, Spanish, German, French, Italian, and Russian

JP-MIRAI’s “Collaborative Program for Companies Responsibly Hosting Foreign Migrant Workers”

Responsible Mineral Procurement

The SUBARU Group has no intention of colluding in the infringement of human rights and environmental destruction by procuring and using conflict minerals. As a member of the Japan Automobile Manufacturers Association (JAMA), we have been actively participating in collaborative efforts addressing conflict minerals since FYE March 2015.
In FYE March 2025, we conducted a conflict minerals survey with 401 suppliers of components and raw materials for automotive mass production and repair. In addition, we expanded the scope of our cobalt survey, which had been conducted for some business partners until 2023, to include mica as a new target mineral, and conducted mica and cobalt surveys expanding the number of companies surveyed to the same 401 business partners as in the conflict minerals survey. We will work to roll out surveys regarding minerals other than these conflict minerals (tin, tantalum, tungsten, and gold).

We codified our Responsible Mineral Procurement Policy in May 2022 as follows. Going forward, SUBARU’s policy is to work toward “No use of materials engendering social problems” in partnership with our customers and suppliers as our social responsibility in procurement activities.

Number of Business Partners Assessed in the Conflict Mineral Survey Conducted in the Automotive Business Unit

(Companies)

Established in May 2022

Environmental Policy Initiatives for Business Partners

We distribute the SUBARU Supplier CSR Guidelines and SUBARU Green Procurement Guidelines to our business partners and ask them to familiarize themselves with and comply with our basic environmental policies. Furthermore, when selecting new business partners, we confirm that they have established an environmental management system based on our guidelines. We also held internal study groups on decarbonization for Purchasing Division staff to familiarize them with SUBARU’s environmental policies.

SUBARU Green Procurement Guideline

The SUBARU environmental policies state that “Our procurement activities reflect consideration for biodiversity and other aspects of environmental protection.” Accordingly, we promote the procurement of parts, materials, and services from business partners who implement business activities that consider the environment. In addition, SUBARU has expressed in the SUBARU Green Procurement Guidelines its expectations for business partners regarding environmental initiatives. The guidelines primarily request cooperation in the following nine areas:

Compliance with these guidelines is considered a necessary criterion for selecting business partners, and we request that they establish an environmental management system based on acquisition of third-party ISO 14001^*1 certification. We recommend new business partners to acquire ISO 14001 certification. For those facing difficulty acquiring ISO 14001, we review their compliance status by having them submit voluntary assessment reports based on our EMS.
Currently, all Tier 1^*2 business partners have ISO 14001 certification or equivalent environmental management systems in place. To those business partners who have passed our voluntary examination, SUBARU makes inquiries or performs audits as necessary and requests them to continue efforts toward early acquisition of third-party certification for environmental management.

*1

International standard for environmental management systems (EMS) established by the International Organization for Standardization (ISO). It is a management system standard to certify that an organization considers the environment and has built a system for continuously reducing environmental impact.

*2

Companies that directly supply parts to car manufacturers. They are primary business partners. Tier 2 business partners are companies that supply Tier 1 with those parts that make up the Tier 1 company parts.

• SUBARU Green Procurement Guidelines
• Green Procurement Guidelines Aerospace Company version^*3

*3

The SUBARU Green Procurement Guidelines and the Green Procurement Guidelines Aerospace Company version are concrete forms of topic “(3) Environment” in the SUBARU Supplier CSR Guidelines.

Climate Change Initiatives

With the aim of decarbonizing our supply chain, we continued to receive reports on total CO₂ emissions from 294 business partners in FYE March 2025, and we have also received roadmaps for achieving carbon neutrality. As a result, a 45% reduction in emissions is expected by FYE March 2036 compared to FYE March 2017. To achieve this, we also conducted on-site interviews with some of our business partners about their plans to understand the status of their specific initiatives, share information on issues they face, and reconfirm SUBARU’s commitment to working together with them to address their requests.

Management and Reduction of Environmentally Hazardous Substances Contained in Parts

SUBARU complies with laws and regulations concerning substances of concern in each country, including the REACH regulation^*1 and ELV Directive^*2. We perform usage surveys regarding chemical substances contained in parts to our business partners as necessary and continue to perform management of those substances. In addition, we are sequentially switching from materials that are prohibited by laws, regulations, or self-regulations such as industrial norms to alternative materials, and are working to reduce environmentally hazardous substances.
In addressing the REACH regulation, we disclose information about substances of very high concern (candidate substances for regulation) on our homepage for users of SUBARU vehicles in Europe.

*1

REACH regulation: European regulation on chemical substances requiring all chemical substances to be subject to management or restriction measures commensurate to the risk that they pose to humans and the environment.

*2

The End-of-Life Vehicles (ELV) Directive: European Union (EU) directive brought into force in 2000 to reduce the environmental impact from the scrapping of end-of-life vehicles in the EU. It aims to prohibit the use of hazardous substances and reduce the generation of waste by encouraging the reuse and recycling of end-of-life vehicles and their parts.

Procurement with Consideration for Biodiversity

SUBARU surveys the use of biological resources, including cowhide and plant-derived materials, to ensure no negative impact on the ecosystem during procurement of raw materials. In FYE March 2025, we conducted due diligence through interviews with one rubber part manufacturer.

Communication with Suppliers

In our Automotive Business, we host online Policy Briefings every spring to share policies on development, quality, procurement, and production with our suppliers. At subsequent events with suppliers, we hold face-to-face meetings to update information and listen to unfiltered opinions from them, which leads to improvements in our initiatives.

During FYE March 2025, the Aerospace Company held the SUBARU Status Report Meeting for our suppliers in May, and a New Year’s business briefing for 312 suppliers in January.
During FYE March 2026, we held the SUBARU Aerospace Company Overview Briefing in May. A SUBARU Aerospace Company Partner Conference is scheduled for October, and we will continue our activities to deepen cooperation with our suppliers.