Policy on AI and Human Rights

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

In addition to facilitating compliance with relevant laws and regulations around the globe, the Companywide principles guide our employees to recognize respect for human rights as the highest priority in each and every stage of our 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 three following initiatives:

Furthermore, based on the Companywide principles, NEC has defined “Provision and Utilization of AI with Respect for Human Rights (AI and Human Rights)” as one of its management priority themes from an ESG perspective—materiality.

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

Medium- to Long-term Targets and Priority Activities

(Scope: NEC Corporation unless otherwise specified) Period: April 2021 to March 2026
M: Major non-financial indicators related to “materiality”

M: Promote business activities that respect human rights as AI becomes a part of society

FY2023 Goals, Progress, Achievements and Issues, and FY2024 Goals

FY2023 Goals

Progress, Achievements and Issues

FY2024 Goals

Implementation Framework for AI and Human Rights

In executing its AI business, NEC has formulated Companywide regulations covering the policies, structure, planning, implementation, inspection, and revision aspects of appropriate protection of privacy and basic human rights (“AI governance”). We are working to ensure the implementation and operation of AI governance in order to provide appropriate protection of privacy and other basic human rights. The relationship between the AI governance officer (CDO), the Risk Control and Compliance Committee, the Board of Directors and the External Expert Council is positioned as our corporate governance, and we coordinate with various external and internal divisions and functions to address AI governance.

We have established the Digital Trust Business Strategy Department to create and promote Companywide strategies to incorporate the notion of respect for human rights into business operations in relation to AI utilization. The department promotes business operations that respect human rights through measures that include the establishment of internal systems and training for employees to incorporate the Companywide principles into our business operations, while also strengthening links with relevant divisions and Research & Development Division. Furthermore, we have created checklists for human rights and privacy considerations, and are carrying out these checks at every stage from the planning phase onwards.

AI Governance Framework

External Expert Council

The Digital Trust Advisory Council includes external experts with specialist knowledge of legal systems, human rights, privacy, and ethics. As an advisory council under the AI governance officer, we consult with experts on our policy and initiatives for advice on strengthening our governance, which we reflect in our initiatives. Through the council, the Company is able to incorporate diverse external opinions and strengthen its response to emerging issues related to AI utilization.

Risk Mitigation Initiatives

To realize Companywide principles, NEC is working to ensure it has a timely grasp of trends in factors such as laws and regulations and social acceptability. Meanwhile, in our execution of business, we are working on a risk mitigation process, which involves identifying risks and implementing countermeasures, talent development to develop employees’ understanding of risk, and stakeholder engagement to incorporate diverse external opinions into our activities.

As we engage in these initiatives, we respond to changes in the environment surrounding AI and human rights and revise our rules and our implementation of measures in accordance with the agile governance framework set out in the Governance Guidelines for Implementation of AI Principles announced by the Ministry of Economy, Trade and Industry in July 2021. We are also working to ensure compliance with laws, regulations and guidelines in Japan and abroad.

Risk Mitigation Process

To ensure appropriate utilization of AI in each phase, such as the planning and proposal, design and development, and operation and maintenance phases, NEC conducts risk checking and countermeasures from various perspectives, including fairness, accountability, transparency, privacy and proper utilization. In our risk checks for each phase, we prepare guidelines and check sheets related to human rights and privacy considerations, coordinating with relevant departments to ensure that our initiatives observe laws and regulations and respect human rights.

In addition, to promote appropriate AI utilization by our customers and business partners, we use our know-how and knowledge to provide design samples and support the publication of usage goals.

Talent Development

We conduct the following training for employees and officers of NEC Corporation and affiliated companies in Japan and abroad so that they can act appropriately with respect for human rights in business operations, in accordance with the Companywide principles.

Web-based Training

Internal Lectures

Grievance Filing Mechanism

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

Engagement on AI and Human Rights

In order to respond to social trends, such as laws, regulations and social acceptability, NEC builds partnerships and collaborates with various stakeholders.

Digital Trust Advisory Council

The Digital Trust Advisory Council, a panel of experts established in fiscal 2020, incorporates on an ongoing basis the diverse opinions of external experts in human rights, privacy, and ethics, as well as the legal system, to strengthen our response to new issues that arise in relation to the use of AI.

At its fiscal 2023 meeting, the council exchanged opinions on our policies for strengthening AI governance based on trends in domestic and international laws and regulations and society’s expectations and demands, as well as how to appropriately disseminate information, and our approach to our responsibilities in dealing with stakeholders in the value chain. The points raised in these discussions were used as a guide in establishing systems and processes to strengthen risk mitigation measures.

Collaboration with Various Stakeholders

We are actively collaborating with various stakeholders in Japan and abroad in industry, government agencies, international organizations, and academia, with a view to building a framework for an AI society. We also participate in symposiums.

Participation in the Digital Transformation (DX) Summit, a G7 Digital and Tech Ministers’ Meeting Official Public-Private Event

In April 2023, NEC participated in a panel discussion on the theme of “AI and Governance” at the DX Summit held in Shibukawa City, Gunma Prefecture, sponsored by the Ministry of Economy, Trade and Industry and the World Economic Forum. We introduced NEC’s approach and initiatives related to the utilization of AI, including generative AI, as well as important aspects for utilization of trustworthy AI.

Participation in GPAI Summit 2022

In November 2022 NEC participated in a side event of the GPAI Summit 2022, held in Tokyo, where we introduced our initiatives on the session theme of “Outlook on AI Governance in Japan, Singapore, and the U.K.”

Public comment submitted regarding the National Institute of Standards and Technology’s AI Risk Management Framework

NEC stated our agreement with activities to create a framework for mitigating AI risks throughout the lifecycle, in relation to the AI Risk Management Framework (AI RMF) creation process developed by the National Institute of Standards and Technology (NIST). We also stated our opinion that it is important that such a framework conforms with related international standards, and that a full range of case studies be provided for implementation. The NIST’s AI RMF 1.0 was announced in January 2023.

Formulation of the Guidebook on Corporate Governance for Privacy in Digital Transformation (DX) ver. 1.2 in Collaboration with the Ministry of Economy, Trade and Industry and the Ministry of Internal Affairs

We participated in the formulation of the Guidebook on Corporate Governance for Privacy in Digital Transformation (DX) ver. 1.2, which gives an overview of what actions companies should take to establish privacy governance.

Public Comment Submitted Regarding the Regulatory Framework Proposal on AI

We submitted a public comment containing our opinions on the European Commission’s proposal for a comprehensive regulatory framework for AI, the first of its kind in the world. In the public comment, we stated our agreement with the proposal’s advocacy of human-centered rules and respect for basic rights, as well as its push to clarify measures to be implemented as part of utilizing AI. We also stated the importance of discussing an international framework.