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Respecting Human Rights

Policy on Respecting Human Rights

As a company that operates businesses globally, NEC is committed to reducing and preventing any negative impacts its corporate activities may have on the human rights of its stakeholders. Also, by making use of ICT, including social implementation of AI and utilization of biometrics and other data, we believe that we can provide the social values of safety, security, fairness and efficiency.

Guided by the NEC Way’s Principles, which express the behavior that we value as a company, NEC is dedicated to “Uncompromising Integrity and Respect for Human Rights,” while the NEC Group Code of Conduct governs the individual conduct of everyone from executives to employees by clearly requiring respect for human rights in all situations. NEC has also detailed its policy for respecting human rights across its entire value chain in the NEC Group Human Rights Policy.

NEC has identified four salient human rights issues by continuously evaluating actual and potential negative impacts on human rights, including indirect impacts not only of the NEC Group but also its suppliers and others. We are working to prevent and mitigate risks related to these issues. Furthermore, as a member of the ICT sector, we recognize one of these salient human rights issues, “Provision and Utilization of AI with Respect for Human Rights as the Highest Priority (AI and Human Rights),” as a priority management theme from an ESG perspective— materiality. As such, in addition to compliance with laws and regulations, NEC also plans to develop and supply products and services that are considerate of the different privacy needs of various countries and regions due to cultural perspectives and that are sensitive to human rights issues, such as discrimination. Through these means, NEC will strive not only to minimize adverse impacts on society but also to maximize social value.

NEC Group Human Rights Policy

In 2015, NEC formulated the NEC Group Human Rights Policy, declaring its intention to advance initiatives to promote respect for human rights across its entire value chain through dialogue and consultation with stakeholders and by implementing human rights due diligence.1 Furthermore, in June 2022, the policy was revised and these revisions clearly show senior management’s commitment to respecting human rights as well as its governance system, as required by the United Nations Guiding Principles on Business and Human Rights (UNGPs). The policy was reported at the Board of Directors’ meeting held in fiscal 2023. In revising the policy, we held talks with a wide range of internal and external stakeholders, including labour unions, experts from the International Labor Organization (ILO), international NPOs, investors, and lawyers specializing in human rights and business.

The NEC Group Human Rights Policy applies to all officers and employees of NEC and its consolidated subsidiaries, including fixed-term contract employees, temporary employees, and part-time employees. We also encourage our suppliers, business partners and customers to understand this policy and share our commitment to respecting human rights. This policy, as well as our initiatives for promoting respect for human rights based on this policy, will be reviewed periodically and updated or revised as necessary.

The policy supports international human rights standards relevant to NEC’s businesses and technologies, including those established in the United Nations’ International Bill of Human Rights,2 the International Labour Organization (ILO) Core Labour Standards that consist of ten fundamental conventions in five categories, the UNGPs, the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, and the International Labour Organization (ILO) Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy. Moreover, the policy stipulates that where national laws in the relevant jurisdiction conflict with internationally recognized human rights, we will seek ways to respect the principles of internationally recognized human rights.

  • 1.
    A process that includes the assessment of risks and identification of issues caused by the Company’s business operations that have negative impacts on human rights, the response to these identified issues (their integration into management), the monitoring of the results, and the reporting of initiatives
  • 2.
    This refers collectively to the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Covenant on Civil and Political Rights that were adopted by the UN General Assembly

ILO Core Labour Standards that Consist of Ten Fundamental Conventions in Five Categories

Freedom of Association and the Effective Recognition of the Right to Collective Bargaining Freedom of Association and Protection of the Right to Organise Convention (No. 87)
The Right to Organise and Collective Bargaining Convention (No. 98)
Elimination of All Forms of Forced or Compulsory Labour Forced Labour Convention (No. 29)
Abolition of Forced Labour Convention (No. 105)
Effective Abolition of Child Labour Minimum Age Convention (No. 138)
Worst Forms of Child Labour Convention (No. 182)
Elimination of Discrimination in Respect of Employment and Occupation Equal Remuneration Convention (No. 100)
Discrimination (Employment and Occupation) Convention (No. 111)
Conditions for a Safe and Healthy Working Environment Occupational Safety and Health Convention (No. 155)
Promotional Framework for Occupational Safety and Health Recommendation (No. 187)

Respect for the Rights of Children

NEC strives to prevent and mitigate adverse impacts of its products and services on children in support of the United Nations Convention on the Rights of the Child and the Children’s Rights and Business Principles,3 which mentions the rights of vulnerable children, in addition to the international standards embedded in the NEC Group Human Rights Policy.

In accordance with the Guidelines for Responsible Business Conduct in Supply Chains, NEC endeavors to abolish child labour from its supply chains and promote business activities and corporate citizenship activities that are based on consideration for human rights—including the rights of children.

  • 3.
    Established by UNICEF, the UNGC, and Save the Children in 2012

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

  1. Promote employee understanding of the latest developments in global human rights
  2. Promotion of Due Diligence in Human Resources

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

FY2023 Goals

  1. Promote employee understanding of the latest developments in global human rights
    • For employees (including dispatched workers): Continue to hold online training on Companies and Human Rights, and maintain a 90% completion rate
  2. Promotion of Due Diligence in Human Resources
    • Revise the NEC Group Human Rights Policy based on the UNGPs and spread awareness of policy throughout the value chain
    • Enhance governance system for addressing the risk of human rights infringements in the value chain and implement due diligence measures in high-risk regions from a human rights standpoint

Progress, Achievements and Issues

  1. Promote employee understanding of the latest developments in global human rights
    • Held online training on “Business and Human Rights” for employees with an 86% completion rate (including dispatched workers)
    • Implemented quarterly training for Human Rights Hotline staff using case studies
  2. Promotion of Due Diligence in Human Resources
    • In addition to training for all employees, conducted training and workshops for persons in charge of international operations related to high-risk areas, for the Legal and Compliance Division
    • Established a human rights impact assessment process for businesses in high-risk areas from a human rights perspective, and started risk mitigation measures for the Company and domestic affiliate companies

FY2024 Goals

  1. Promote employee understanding of the latest developments in global human rights
    • For employees (including dispatched workers): Continue to hold online training on Companies and Human Rights (target completion rate: 90%)
  2. Promotion of Due Diligence in Human Resources
    Monitor initiatives for addressing salient human rights issues
    • New technologies such as AI and human rights: Continue to strengthen AI governance in accordance with legal and regulatory trends in Japan and abroad
    • Human rights risks associated with geopolitical conditions and the impact of conflict: Establish a human rights impact assessment process for businesses in high-risk areas from a human rights perspective, and start risk mitigation measures for international affiliate companies
    • Labour in supply chains: Continue acquiring declarations from suppliers which account for 75% of the total consolidated procurement amount
    • Employee health and safety: Conduct regular management status surveys of employees in Group companies in Japan and abroad regarding human rights and occupational health and safety

Framework for Respecting Human Rights

The CEO of NEC Corporation oversees its human rights initiatives.
For salient human rights issues, a corporate officer is appointed to be in charge and promote human rights due diligence.
NEC promotes human rights initiatives in accordance with the UNGPs, with the Stakeholder Relations Department’s Sustainability Strategy Planning Office managing progress as secretariat.

The corporate officer in charge of sustainability promotion regularly presents status reports on initiatives to the Board of Directors, which monitors the progress of the initiatives. Furthermore, the Corporate Human Rights Promotion Committee, established in 1997, continues its work to promote activities that raise awareness of human rights, such as the elimination of discrimination and the prevention of harassment.

Promotion of Human Rights Due Diligence Focused on Salient Human Rights Issues

Initiatives to Address Salient Human Rights Issues

Working with multiple external experts, including NPOs and other organizations in the social sector, NEC has identified the following four salient issues and is promoting initiatives to address them.

New technology and human rights (AI and human rights)

In executing its AI business, NEC has formulated Companywide regulations covering policies for the appropriate protection of basic human rights (such as privacy), their structure, planning, implementation, inspection and revision. We are working to ensure the implementation and operation of these regulations.

Human rights risks related to geopolitical situations and conflicts

In export control, we confirm the intended use of products and services prior to transactions as well as identifying customers according to sanctions lists of the United Nations and other countries. The sanctions lists of individual countries include organizations and individuals that are subject to human rights-related sanctions, such as those set forth in the U.S.
Department of the Treasury’s Office of Foreign Assets Control sanctions list.
Furthermore, we have identified countries and regions with high human rights risks based on the OECD States of Fragility 20224 list, and we check information regarding human rights and corruption before engaging in transactions with customers in those areas. If risks are confirmed to be present, we prevent and mitigate risks with measures including written agreements, and report our findings to the Risk Control and Compliance Committee.

  • 4.
    OECD States of Fragility 2022: The OECD evaluates each country’s risk status and response capability across six dimensions: economic, environmental, political, security, societal and human

Labour in supply chains

NEC is promoting activities with a risk-based approach, in accordance with the steps set out in OECD Due Diligence Guidance for Responsible Business Conduct.

Employee safety and health

NEC conducts risk identification and implements countermeasures based on the NEC Group OH&S Management System.
In fiscal 2024, NEC started self-assessment checks to strengthen management of occupational health and safety at Group companies in Japan and abroad.

Going forward, we will continue to engage in dialogues and consultation with stakeholders, promote further efforts regarding respect for human rights, and disclose information in a timely and appropriate manner.

Grievance Mechanism

Grievance Mechanism

In the event of a violation or suspected violation of human rights, NEC will immediately and accurately investigate the facts and the causes of the incident and strive to take appropriate measures to resolve the matter.
We have a whistleblowing system that allows stakeholders to report information anonymously. We will keep the identity of any whistleblower and the content of any whistleblowing reports confidential. We ensure that whistleblowers are protected effectively against unfair treatment or retaliation in any form. Aside from NEC Group employees, this system serves as a contact point for a wide range of stakeholders, including temporary workers, business partners and local communities.
To further strengthen the grievance mechanism, we have participated in the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) at the investigation stage, a cross-industry initiative launched by the Japan Electronics and Information Technology Industries Association (JEITA) and the Business and Human Rights Lawyers Network (BHRL), an association of lawyers.

Human Rights Hotline (For Employees in Japan, Including Temporary Workers)

The Human Rights Hotline is intended for use by all those working for NEC, including temporary and part-time workers. The system comprises an anonymous consultation desk operated by a third-party organization, as well as a point of contact set up in the Human Resources and General Affairs Department of each business site and in each business unit, with reports possible by phone or by email in Japanese and English.

Hotline for Employees Outside of Japan (Including Temporary Workers)

For NEC’s consolidated subsidiaries abroad, regional headquarters also set up whistleblowing systems operated by third parties in each region, which are available for officers and employees to use in the local language (English, Spanish, Portuguese or Chinese).

Compliance Hotline (For Business Partners)

NEC receives human rights-related reports from suppliers through the Compliance Hotline, which is operated by a third-party organization.

Customer Communications Center (For Customers and Local Residents)

NEC receives human rights-related reports from customers and residents of local communities through the Customer Communications Center.

Employees at each subsidiary in the EMEA region can report witnessed or suspected fraud-related wrongdoing, including modern slavery, through Safecall, a third-party 24-hour confidential reporting line. Suppliers’ concerns can be reported via contact points that are operated internally by subsidiaries in the EMEA region, the Legal Division of NEC Europe, or Safecall.

Operational Status of the Human Rights Hotline

In 2020, we established a consultation desk operated by a third-party organization for employees of NEC Corporation in addition to the human rights hotline that already existed at NEC Corporation and its Group companies in Japan and abroad.
In 2021, we expanded the scope of this service to include employees at our Group companies in Japan.

We are working to raise awareness of the hotline with efforts that include officer messaging for eliminating harassment and online training.

Under these circumstances, in fiscal 2023 109 cases were reported to the Human Rights Hotline including harassment and human relations and work environment-related cases. There were no reports related to forced labour or human trafficking.
Related divisions work together to improve and resolve the contents of the consultations with the human rights hotline, and they are reported to the Risk Control and Compliance Committee in order to continue to raise awareness to prevent recurrence.

Engagement on Human Rights

Dialogue with Stakeholders

Since fiscal 2022, the Sustainability Advisory Committee has been held at NEC Corporation for the CFO and corporate officers involved in promoting sustainability to conduct regular discussions with external sustainability experts.
At the second committee meeting, Ms. Asako Nagai from Business for Social Responsibility (BSR) shared the latest trends regarding responses to human rights-related risks, and each participant shared their awareness of various issues before discussing response measures.

Participation in Initiatives on Human Rights

NEC Corporation and NEC Europe participate in the Working Group on Human Rights Due Diligence run by the UNGC Local Network.

In 2020, we also became a member of BSR, which has a strong record of supporting responses to human rights issues in the global ICT industry. We acquire information on the latest trends and examples from seminars and study sessions, which inform our activities to improve and enhance initiatives on global human rights issues.

Responding to Modern Slavery Acts

With approval from the Board of Directors, since fiscal 2019 NEC Corporation and NEC Europe have published declarative statements to the effect that they will report on measures related to the United Kingdom’s Modern Slavery Act 2015, which is aimed at preventing slave labour and human trafficking.

Furthermore, in fiscal 2021 and fiscal 2022, with the approval of the Board of Directors, NEC Corporation and NEC Australia Pty Ltd also published a declarative statement of their intention to comply with Australia’s Modern Slavery Act 2018.

Human Rights Training and Awareness-Raising

NEC provides awareness-raising activities including training for all officers and employees responsible for respecting human rights, in order to deepen their awareness in terms of respect for human rights and to promote their understanding of global trends on human rights issues.

Training at NEC Corporation

  • Training to spread awareness of human rights is held annually for all employees, including temporary and non-temporary workers (fixed-term and part-time workers). This training follows themes such as “Companies and Human Rights,” “Human Rights Issues in the Biometrics Business and NEC Initiatives,” and “Diversity and Human Rights.” (fiscal 2023 completion rate: 86%)
  • We used case studies to provide training on the key points of labour management and harassment prevention for newly appointed Group managers and those who are in management
  • For employees performing hiring interviews, we introduced example cases and ensured that everyone had a clear understanding of points to keep in mind during Q&A sessions, in order to maintain fair hiring decisions and equal opportunity in the workplace. The course was attended by approximately 700 people.

Training at NEC Corporation and its Group Companies in Japan

We held a program on “Harassment and Respecting Human Rights” as part of our training for newly appointed corporate officers, and 64 people attended.

Training at NEC Group Companies

NEC Corporation provides access to the human rights training program to its group companies in Japan, including security contractors.

Training Focused on the Downstream Value Chain

In fiscal 2024, we conducted training focused on the downstream value chain as a response to geopolitical risk, which was added to our list of salient human rights risks in fiscal 2023.

  • Invited an expert from the international NPO BSR to give a lecture to all employees on “Responding to Human Rights Risks in the Downstream Value Chain.” Furthermore, for persons responsible for international operations in high-risk areas, conducted workshops for learning about human rights risk case studies and risk reduction measures at other global companies, and for considering NEC’s response measures.
  • Invited an external lawyer to hold training for the Legal and Compliance Division on legal and regulatory trends relating to business and human rights, the current status of legal affairs and compliance operations for promoting human rights due diligence, and points to keep in mind when making and entering into contracts.
The picture of workshops for for persons responsible for international operations in high-risk areas