Created in partnership with the Helpdesk on Business & Human Rights

ANA Group

Rightsholder Engagement Framework

The ANA Group, an airline group centering on the air transportation business, has been actively promoting efforts to respect human rights in line with the UN Guiding Principles on Business and Human Rights (UNGPs) since 2015 with a focus on robust engagement with rights-holders.

By establishing a management system aligned with the UNGPs, they have been progressively working towards integrating a framework that amplifies the voice of rights-holders throughout the operations of the business to the executive team. A pivotal aspect of this effort involves the integration of human rights due diligence and grievance mechanisms through the identification of common issues, fostering a trust base between rights-holders and the company and pursuing effective resolutions through direct dialogues. To facilitate this, they have engaged the independent third party, CRT Japan, for a consensus-building process between both parties.

In 2022, they were anonymously told that technical intern trainees had been illegally employed, and subsequently unfairly dismissed at Narita Airport. In response, in collaboration with the CRT Japan, the ANA Group initiated a comprehensive fact-finding investigation. This included a questionnaire survey with 124 technical intern trainees, followed by dialogues to identify instances of unfair treatment in detail. In response, the ANA group implemented a range of remedial measures. They increased opportunities for dialogue with workers to allow them to raise issues early. They also provided further explanations of work rules and regulations to ensure workers understood the company’s expectations. Furthermore, there were issues raised about living arrangements (workers sleeping in close quarters in dormitories) so single rooms were promptly provided to all those who requested them.

As the ANA Group moves forward, it will continue to fortify the trust base and sustain proactive engagement with rights-holders while collaborating with third-party organizations.


The case studies do not make any assessment of whether the measures presented meet the requirements of the UN Guiding Principles on Business and Human Rights (UNGPs). The aim is rather to demonstrate the feasibility of human rights due diligence management and to offer companies suggestions for their own implementation.

The inclusion of company examples is intended strictly for learning purposes and does not constitute an endorsement of the individual companies. Unless otherwise indicated, the content is not intended to reflect the official positions, views or opinions of the United Nations or the German Government.