AI and Human Rights: Social

Implementation Framework for AI and Human Rights

NEC has formulated the NEC Group AI and Human Rights Principles (the “Companywide Principles”) in line with the NEC Group Human Rights Policy to guide employees in recognizing respect for privacy and human rights as the highest priority in its business operations in relation to social implementation of AI and utilization of biometrics and other data (“AI utilization”).

NEC incorporates initiatives based on the Companywide Principles into corporate governance, and under the direction of the Risk Control and Compliance Committee overseen by the Board of Directors, it has established a governance framework centered on the Chief Digital Officer (CDO: the AI governance officer) and the CDO Office Digital Trust Strategy Office.

As the department responsible for governance related to AI and human rights, the Digital Trust Strategy Office oversees an internal system that sets out the basic matters that officers and employees must comply with to ensure respect for human rights in business activities related to AI utilization.

The Company has also established the NEC Digital Trust Advisory Council composed of external experts as an advisory framework for themes related to human rights and new technologies such as AI.

AI and Human Rights Strategy

In addition to facilitating compliance with relevant laws and regulations around the globe, the Companywide Principles guide employees in recognizing respect for human rights as the highest priority in each and every stage of business operations in relation to AI utilization, and enable them to take action accordingly.

In accordance with the Companywide Principles, the NEC Group is committed to the following three initiatives:

Ensure that AI is utilized appropriately by NEC Group employees, customers, and partners
Continue to develop advanced technology and talent to further promote AI utilization with respect for human rights as the highest priority
Engage with a range of stakeholders to build partnerships and to collaborate with closely in relation to AI utilization

Furthermore, based on the Companywide Principles, NEC has defined “Provision and Utilization of AI with Respect for Human Rights as the Highest Priority (AI and Human Rights)” as one of its priority management themes from an ESG perspective—materiality, and has also identified it as a salient human rights issue.

NEC’s Management for Sustainability (Approach to Materiality)

Risk Mitigation Initiatives

NEC understands that the social implementation of AI and the utilization of biometrics and other data can enrich people’s lives, but also recognizes that it may give rise to human rights issues such as privacy infringement and discrimination depending on how it is used or if used unintentionally. Furthermore, while the expansion of AI utilization is expected to lead to business growth, there is also a possibility that it will damage NEC’s reputation or result in a decline in sales if privacy violations occur. In line with the Companywide Principles, in the execution of business, NEC is working on a risk mitigation process, which involves identifying risks and implementing countermeasures, talent development to improve employees’ risk literacy, and stakeholder engagement to incorporate diverse external opinions into Company activities.

NEC is implementing these initiatives in accordance with Japanese and international laws, regulations, and guidelines.
In particular, the Company is flexibly reviewing its internal rules and operations in response to changes in the external environment in accordance with the agile governance approach set out in the Governance Guidelines for Implementation of AI Principles announced by the Ministry of Economy, Trade and Industry in July 2021, and the AI Guidelines for Business announced by the Ministry of Internal Affairs and Communications and the Ministry of Economy, Trade and Industry in April 2024 as the successor to these. Specifically, the Company is conducting risk assessments and reviewing measures based on an understanding of trends in AI-related laws, regulations, and guidelines in Japan, the United States, Europe, and other countries, along with other issues including consumer acceptance of the use of AI.

Risk Mitigation Process

NEC identifies significant human rights risks arising from AI and biometric authentication technologies and concerns in the use of AI and biometric authentication technologies, and establish companywide rules that stipulate the governance framework and fundamental compliance issues. The Company also prepares guidelines, manuals, and risk checklists that stipulate countermeasures and operational flows. During each phase from planning to operation, the Digital Trust Strategy Office collaborates with relevant departments to implement measures according to the severity of the human rights risks posed by AI utilization. Documents and operational processes for risk responses are continuously revised to reflect the expanding use of generative AI and biometric authentication, as well as changes in relevant laws and regulations in Japan and abroad. In addition, NEC aims to promote the appropriate use of AI throughout society by providing practical know-how and insights gained through our risk mitigation initiatives to our customers and partners. These efforts include offering consulting on the development of risk mitigation processes, providing design samples for disclosing the purposes of AI use, and organizing educational workshops for customers and partners.

Talent Development

NEC has created definitions outlining work related to AI and human rights and clarified the required skills and proficiencies.

Furthermore, the following training is conducted for officers and employees of NEC Corporation and affiliated companies in and outside Japan so that they can act appropriately with respect for human rights in business operations, in accordance with the Companywide Principles.

Completion Rate for Training on AI and Human Rights (Data Collection)

Web-based Training

NEC provides web-based training once a year for employees, including temporary and dispatched employees, covering basic matters including the importance of AI technology and AI ethics, trends in related laws and regulations, human rights and privacy considerations associated with AI utilization, and the Companywide Principles and operations. (Completion rate in fiscal year 2025: 97%)

Internal Lectures

NEC invites external experts to give lectures for persons in the Company involved in promoting the AI business. At these lectures, examples that have given rise to social criticism and other case studies are shared, and participants can learn more about points to keep in mind when providing services, and how to address them.
Since fiscal year 2022, NEC has held lectures by external experts to deepen management’s understanding of international trends related to AI and human rights as a way to ensure that respect for human rights is a component of the Company’s decision-making.

Materials and videos related to web-based training and internal lectures are published on the internal website, allowing employees to access the content at any time and deepen their understanding.

Stakeholder Engagement

NEC is collaborating and cooperating with various stakeholders to address social trends such as legal regulations and social acceptability.

NEC Digital Trust Advisory Counci（l External Expert Council）

To strengthen the NEC Group’s response to emerging challenges associated with AI utilization, the AI Governance Officer convenes the NEC Digital Trust Advisory Council. This Council engages external experts with specialized knowledge in legal systems, human rights, privacy, and ethics to provide guidance on the Group’s initiatives. Since 2019, the Council has met twice annually, fostering continuous dialogue with its members to advance and enhance NEC’s efforts in responsible AI governance.

At the Council meeting held in July 2024, discussions focused on approaches to mitigating human rights risks in global AI and biometric authentication businesses, as well as effective messaging strategies for communicating these businesses. Council members shared the following insights and recommendations.

To effectively identify human rights risks specific to each country or region, it is essential to understand not only data- and AI-related laws, but also the broader legal systems and cultural contexts of that society. In particular, understanding the relationship between constitutional frameworks and legal systems, as well as the cultural values rooted in constitutional principles, is especially important.
In risk responses, it is important for the head office to actively participate in the governance of local subsidiaries and to establish mechanisms that enable swift and appropriate information gathering and response in the event of an incident.
In communicating as a social value innovator, it is essential to tailor our services and messaging to reflect the diverse values across countries and regions. For example, in Japan, social value and the resolution of societal issues are emphasized, whereas in Europe and the United States, individual values tend to be prioritized.

At the Council meeting held in March 2025, discussions focused on potential human rights risks associated with the introduction of AI agents and the necessary measures to address them. Council members shared the following insights and recommendations.

Excessive reliance on AI may undermine human responsibility and moral judgment. Considering the risk that humans could become nominal figures who merely bear responsibility for AI-generated outcomes, it is essential to thoughtfully design the relationship between humans and AI systems.
Even when the goals assigned to AI are appropriate, it is important to recognize that the optimal means selected by AI to achieve those goals may still result in unintended human rights violations.
When multiple AI agents move in cooperation, it is important to clarify where responsibility lies in the event that issues arise.

Based on the insights gathered through the Council meetings held in fiscal year 2025, we will work to mitigate human rights risks and communicate our message in a manner that takes into consideration the characteristics of each country and region when developing AI and biometric authentication businesses. NEC will also endeavor to promote AI utilization with respect for human rights as the highest priority by advancing measures to address potential risks arising from new applications of AI, such as AI agents.

Collaboration with Various Stakeholders

Knowledge Sharing on AI, Human Rights, and Privacy

Since 2018, Keio University Global Research Institute (KGRI) and NEC have engaged in joint research to investigate and analyze the foundational philosophies and political processes underlying data protection legislation across various countries and regions, drawing on their respective constitutional frameworks and cultures. In fiscal year 2025, NEC collaborated on the publication of a book to widely disseminate the outcomes of this research and co-hosted a symposium to further promote public understanding. Additionally, since July 2024, NEC has joined the Keio University X Dignity Center as a corporate supporter. The Center was established to explore the evolving meaning and value of “dignity” in the age of AI and to share insights with the global community. NEC will continue to advance collaborative research through this partnership.

Contribution to the Formulation and Revision of the AI Guidelines for Business

NEC participated as a member of the Ministry of Internal Affairs and Communications’ Conference toward AI Network Society and its affiliated AI Governance Review Committee, actively contributing to the formulation and subsequent revisions of the AI Guidelines for Business. These guidelines were jointly published by the Ministry of Internal Affairs and Communications and the Ministry of Economy, Trade and Industry in April 2024, with updates released in November 2024 (Version 1.01) and March 2025 (Version 1.1).

Active Engagement in Knowledge Exchange and Collaborative Problem Solving through Industry Associations

NEC actively engages in the activities of industry associations such as the Data Society Alliance and the AI Governance Association, contributing to cross-company knowledge exchange and collaborative discussions aimed at addressing issues related to AI risks and governance. In addition, NEC supports the development of policy proposals concerning the future direction of AI-related regulations and systems.

NEC Endorses the AI Guidelines for Business (Japanese language only)

Grievance Mechanism

The NEC Customer Communication Center (CCC) has been established as a comprehensive contact point in Japan for receiving inquiries from customers regarding NEC products, systems and services.

Customer Relationship Management

Medium- to Long-term Goals, Priority Activities and Progress, Achievements, and Issues

Medium- to Long-term Goals, and Priority Activities

(Scope: NEC Corporation unless otherwise specified) Period: April 2021 to March 2026

M: Indicates the main non-financial targets related to materiality.
M: Promote business activities that respect human rights as AI becomes a part of society

FY2025 Goals, Progress, Achievements and Issues, and FY2026 Goals

FY2025 Goals

Continue strengthening governance in response to evolving legal and regulatory trends in Japan and abroad
Continue engaging in dialogue with a diverse range of stakeholders
Enhance responsiveness to emerging risks driven by technological advancement

Progress, Achievement, and Issues

Continue to strengthen AI governance based on trends in laws and regulations in and outside Japan
- Analyzed trends in laws, regulations, and guidelines in Japan, the United States, and Europe, shared insights with relevant internal stakeholders, and incorporated them into operations.
- Provided explanations on the latest legal and regulatory trends through web-based training and internal lectures
Maintain dialogues with a variety of stakeholders
- Continued to gain insights from experts through the NEC Digital Trust Advisory Council and incorporated them into initiatives
- Leveraged the Company’s expertise to offer input and recommendations during the formulation of laws, regulations, and guidelines in Japan and abroad
- Introduced the Company’s initiatives to customers and external stakeholders
Strengthen response to new risks associated with technological advances
- Assessed potential human rights risks posed by AI agents and explored appropriate response measures
- Revised and expanded documents and reviewed operational processes to address risks arising from the growing use of generative AI and biometric authentication

FY2026 Goals

Continue strengthening governance in response to evolving legal and regulatory trends in Japan and abroad
Continue engaging in dialogue with a diverse range of stakeholders
Enhance responsiveness to emerging risks driven by technological advancement

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AI and Human Rights

Governance