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AI and Human Rights
Governance
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 an AI governance framework centered on the Chief Digital Officer (CDO: the AI governance officer) and the Digital Trust Business Strategy Department.
As the department responsible for AI governance, the Digital Trust Business Strategy Department 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 AI governance themes.

Strategy
Policy on AI and Human Rights
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:
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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 priority management themes from an ESG perspective—materiality, and has also identified it as an important human rights issue.
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Continue to develop advanced technology and talent to further promote AI utilization with respect for human rights as the highest priority
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Engage with a range of stakeholders to build partnerships and to collaborate with closely in relation to AI utilization
Risk Management (Including Opportunity Generation)
Overview
To realize 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.
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 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 Business Strategy Department collaborates with relevant departments to implement measures according to the severity of the human rights risks posed by AI utilization.
Furthermore, to support appropriate AI utilization by its customers and partners, the Company leverages its know-how and expertise to provide design samples regarding the disclosure of the purpose of use, and to hold study sessions at technology providers.
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.
Web-based Training
- NEC provides online 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 2024: 95%)
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 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.
Stakeholder Engagement
NEC is collaborating and cooperating with various stakeholders to address social trends such as legal regulations and social acceptability.
For details, please see “Engagement Related to AI and Human Rights.”
Engagement Related to AI and Human Rights
NEC Digital Trust Advisory Council (External Expert Council)
Composed of external experts who have specialized knowledge of the legal system, human rights, privacy, and ethics, the NEC Digital Trust Advisory Council is convened as an opportunity for NEC’s CDO (AI governance officer) to consult with these external experts (council members) in order to strengthen the Group’s response to new issues associated with AI utilization and to advance and improve NEC’s initiatives through dialogue.
As both a generative AI user and platform provider, NEC consulted about initiatives for and contributions to society’s implementation of generative AI at the council’s July 2023 meeting. Drawing on the opinions of council members, the Company will consider how to formulate NEC’s generative AI vision to engender a social consensus on a future where innovation is driven by the utilization of generative AI. In addition, when laws, regulations, and guidelines are revised,
NEC will update its views to provide recommendations that leverage its knowledge and expertise.
At the council’s February 2024 meeting, an interim report on the fiscal 2024 operational status of NEC’s AI governance was presented. NEC also consulted with the council regarding the implementation of the Companywide Principles in response to changes in the external environment, and about the Company’s response to international AI regulations and guidelines. Based on the opinions of the council members, NEC will explain its recognition and response to new risks associated with AI utilization, clearly relating them to the Companywide Principles. Furthermore, in interpreting laws and regulations, NEC will also take into account cultural and value considerations, and when providing technologies it will respond appropriately according to the circumstances of the recipient.
Collaboration with Various Stakeholders
Exchange of Opinions with a Delegation of the European Parliament’s Committee on Internal Market and Consumer Protection (IMCO)
In May 2023, an IMCO delegation visited NEC headquarters for an exchange of opinions about AI governance, including NEC’s initiatives.
Participation in the Discussion on Developing the AI Guidelines for Business , and Introduction of NEC’s Initiatives
NEC participated as a member in the AI Governance Review Committee, an affiliated meeting of Japan’s Ministry of Internal Affairs and Communications’ Conference toward AI Network Society and contributed to the discussion on the Draft AI Utilization Principles and the development of guidelines. Also, NEC’s initiatives were introduced in a column in the new guidelines released by the Ministry of Internal Affairs and Communications and the Ministry of Economy, Trade, and Industry in April 2024.
A Publication Detailing NEC’s Digital Ethics
NEC has compiled its knowledge and expertise in a publication detailing its AI governance initiatives.
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.
Indicators and Goals
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: Major non-financial indicators related to materiality
M: Promote business activities that respect human rights as AI becomes a part of society
FY2024 Goals, Progress, Achievements and Issues, and FY2025 Goals
FY2024 Goals
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Continue to strengthen AI governance based on trends in laws and regulations in and outside Japan
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Maintain dialogue with a variety of stakeholders
Progress, Achievements and Issues
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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 them with relevant in-house personnel and reflected them in operations
- Initiated AI governance based on the Ministry of Economy, Trade and Industry’s Governance Guidelines for Implementation of AI Principles
- Reflected the risk of human rights violations resulting from generative AI in NEC’s AI governance framework
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Maintain dialogues with a variety of stakeholders
- Continued to acquire knowledge from experts by convening the NEC Digital Trust Advisory Council, and reflected it in initiatives
- Utilized the Company’s knowledge and know-how to provide opinions and suggestions in the process of considering the formulation of laws, regulations, and guidelines in and outside Japan, and some of those opinions and suggestions were reflected in guidelines
- Introduced the Company’s AI governance initiatives to customers and external stakeholders
FY2025 Goals
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Continue to strengthen AI governance based on trends in laws and regulations in and outside Japan
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Maintain dialogue with a variety of stakeholders
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Strengthen response to new risks associated with technological advances