Framework for Respect for Human Rights

NEC’s CEO oversees initiatives based on the NEC Way and the NEC Group Human Rights Policy. In addition, the corporate officer in charge of sustainability promotion and officers involved with promoting sustainability management (officers involved in sustainability promotion) presents status reports on initiatives in line with the United Nations Guiding Principles on Business and Human Rights (UNGPs) to the Board of Directors, which monitors the progress of the initiatives.

NEC identifies salient human rights issues by continuously assessing actual or potential adverse impacts across the entire value chain. For each identified issue, a responsible corporate officer and relevant departments are assigned to advance human rights due diligence.

In addition, NEC has established grievance mechanisms for a wide range of stakeholders, including all employees of the NEC Group, including fixed-term contract employees, temporary employees, and part-time employees, as well as business partners, customers, and local residents.

Approach to Human Rights

The NEC Group believes that conducting corporate activities with respect for human rights is essential to fulfill its Purpose. With this in mind, it has positioned respect for human rights as one of our guiding Principles. The NEC Group Code of Conduct clearly defines it as a standard that every individual, from officers to employees, is required to uphold.

In addition, 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. We ensure that this policy is thoroughly communicated to all officers and employees (including fixed-term contract employees, temporary employees, and part-time employees) of NEC Corporation and its consolidated subsidiaries.

NEC Group Human Rights Policy

NEC established the NEC Group Human Rights Policy in 2015. Furthermore, in 2022, the policy was revised, and these revisions clearly show senior management’s commitment to respect for human rights as well as its governance system, as required by the UNGPs. The revision was approved by our President and reported to the Board of Directors in the same year. After the revision, the President issued a message to all NEC Group officers and employees regarding the update to the human rights policy. In formulating the revised version of the policy, NEC held talks with a wide range of internal and external stakeholders, including labor unions, experts from the International Labour Organization (ILO), international NPOs, investors, and lawyers specializing in human rights and business.

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. In 2023, the Company revised the policy to reflect the addition of “a safe and healthy working environment” to the ILO Core Labour Standards. In 2024, the Risk Control and Compliance Committee confirmed that no revisions were needed.

The NEC Group Human Rights Policy applies to all officers and employees of NEC and its consolidated subsidiaries, including all employees of the NEC Group, including fixed-term contract employees, temporary employees, and part-time employees. The NEC Group also encourages its suppliers, business partners, and customers to understand this policy and share our commitment to respect for human rights. The policy elaborates the following principles:

Respect for the Rights of Children

NEC strives to prevent and mitigate adverse impacts of its products and services on children based on its support of the United Nations Convention on the Rights of the Child and the Children’s Rights and Business Principles¹, 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 labor 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.

Responding to the Modern Slavery Act

With approval from the Board of Directors, since fiscal year 2019, NEC Corporation, NEC Europe including NEC (UK) Ltd., NEC Software Solutions UK Limited, and Netcracker Technology EMEA Limited have published 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.

Human Rights Due Diligence

Human Rights Impact Assessment

NEC has been conducting human rights impact assessments since fiscal year 2019 in order to further improve the effectiveness of its human rights due diligence. Since fiscal year 2020, it has also been promoting initiatives focused on salient human rights issues.

For the four themes based on salient human rights issues (listed to the right), initiatives are being promoted under the leadership of the respective corporate officers and relevant departments. Progress is reported to and discussed by the Risk Control and Compliance Committee as part of companywide risk management. NEC engages in ongoing dialogue with stakeholders and discloses information in a timely and appropriate manner. Please refer to the linked pages for details on each initiative.

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.
The Company is working to ensure the implementation and operation of these regulations.

Human Rights Risks Related to Geopolitical Situations and Conflicts

There is a risk that products and services could be used to violate human rights in conflict regions. For that reason, the Company identifies high-risk regions with respect to human rights based on the OECD States of Fragility 2025² list, and it screens information of customers in those regions with regard to human rights and corruption, as well as confirming the intended use of products and services prior to engaging in transactions. NEC also reviews sanctions lists, which include organizations and individuals that are subject to human rights-related sanctions, of the United Nations, the U.S. Department of the Treasury’s Office of Foreign Assets Control, and other countries. The Company contractually or otherwise requires customers without a human policy to implement measures equivalent to the NEC Group Human Rights Policy through contracts or other means, thereby working to prevent human rights risks from arising.

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 Health and Safety

The NEC Group is committed to ensuring the health and safety of its employees, while striving to maintain and improve a comfortable and supportive work environment. NEC Group prohibits all forms of harassment, including power harassment and sexual harassment, and aims to foster a culture of mutual acceptance of diversity. In addition, NEC refers to international standards and ensures proper wage payment, working hour management, and the protection of leave rights for employees in accordance with the laws and regulations of the relevant jurisdiction.

Stakeholder Engagement on Human Rights

Dialogue with Stakeholders

Please see the linked pages below for further details on dialogue.

NEC Sustainability Advisory Committee

Since fiscal year 2022, the Sustainability Advisory Committee has been held at NEC Corporation for the CFO and the officers in charge of sustainability management promotion. It conducts regular discussions with external sustainability experts. At committee meetings, Ms. Asako Nagai from Business for Social Responsibility (BSR) shares the latest trends regarding responses to human rights-related risks, and each participant shares their awareness of various issues before discussing response measures.

Engagement Related to AI and Human Rights

NEC has opportunities to engage with external experts at the NEC Digital Trust Advisory Council, whose members include lawyers and social sector representatives including international NPOs. The Company also maintains regular dialogue with the European Parliament and Japanese government agencies.

Supplier Engagement

NEC provides opportunities for dialogue with suppliers on human rights initiatives through exchange meetings and study sessions.

Engagement with Employees

Through initiatives such as cross-industry networking events for women aimed at career development and unconscious bias training, employees are given opportunities to personally reflect on understanding and embracing diverse values and cultures. In addition, to ensure health and safety and promote comfortable workplace environments, health and safety committee members selected by each division, labor union representatives, and employee representatives meet every month at health and safety committees to discuss new safety and health measures and health-related policies.

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. NEC also joined The Valuable 500, a global initiative promoting the inclusion and empowerment of people with disabilities, in 2019. Since 2020, NEC became a member of BSR, which has a strong record of supporting response to human rights issues in the global ICT industry. The Company acquires information on the latest trends and examples from seminars and study sessions, which inform its activities to improve and enhance initiatives on global human rights issues.

Human Rights Training and Awareness-Raising

NEC provides awareness-raising activities including training for all officers and employees responsible for respect for 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. Please see the linked pages for future details.

Training for Employees

(1) Promoting Awareness of the Human Rights Policy and Business and Human Rights
Annual web-based training is provided on business and human rights (previously diversity and human rights; renamed in fiscal year 2026). In fiscal year 2025, the training was conducted for employees, dispatched workers, and contract employees of NEC Corporation and its 15 consolidated subsidiaries in Japan, with completion rates of 90.8% for NEC Corporation and 95.5% for the subsidiaries. The human resources departments of all consolidated subsidiaries outside Japan distribute training material with the same content.

(2) Inclusion and Diversity Awareness

(3) AI and Human Rights Awareness
Annual web-based training is conducted for NEC Group officers and employees. In fiscal year 2025, the training was provided to NEC Corporation and its 14 consolidated subsidiaries in Japan. The completion rate was 97%.

Training for Suppliers

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. The Company has whistle blowing systems that allow stakeholders to report information anonymously. It will keep the identity of any whistleblower and the content of any whistleblowing report confidential. The Company ensures that whistleblowers are protected against unfair treatment or retaliation in any form. Aside from NEC Group employees, these systems serve as contact points for a multitude of stakeholders, including business partners and local communities. To further strengthen the grievance mechanism, NEC has 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 JEITA and the Business and Human Rights Lawyers Network (BHRL), an association of lawyers.

NEC Compliance & Integrity Hotline

In October 2024, we launched a whistle blowing system using NAVEX’s third-party reporting system to accept reports from employees of NEC Corporation and its business partners. Starting in April 2025, the scope of the hotline has expanded to include Group companies and their business partners in and outside Japan.
Measures to protect whistleblowers are in place, and anonymous reporting is also supported.

Please see below for more details.

HR Hotline for Employees in Japan, Including Contract Employees

The Human Resources (HR) Hotline is intended for use by all those working for the NEC Group, including dispatched workers and contract employees. The system comprises an anonymous consultation desk operated by a third-party organization, as well as a point of contact set up at the human resources departments of each business office and at each business unit, with reports possible by phone or by email in Japanese and English.

NEC expanded the scope of reporting since fiscal year 2025 to include consultations regarding harassment, discrimination such as human rights violations, as well as violations of labour-related laws and regulations and violations of internal personnel-related regulations. The name of the whistle blowing system was therefore changed from the Human Rights Hotline to the Human Resources (HR) Hotline.

The Company is working to raise awareness of the whistle blowing system through various efforts that include officer messaging for eliminating harassment and web-based training. As of October 2024, functions have been integrated into the NEC Compliance & Integrity Hotline. Now, affiliates in and outside Japan are gradually being incorporated into this unified hotline.

Hotline for Employees Outside of Japan, Including Contract Employees

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

Employees at each subsidiary in the EMEA region can report witnessed or suspected wrongdoing, including modern slavery, through Safecall, a third-party 24-hour confidential reporting line.
As of April 2025, reports can also be submitted via the NEC Compliance & Integrity Hotline.

Compliance Hotline for Business Partners

NEC collects human rights-related reports from suppliers through the Compliance Hotline, which is operated by a third-party organization. EMEA suppliers can report concerns via contact points that are operated internally by subsidiaries in the EMEA region, the Legal Division of NEC Europe, or Safecall. As of October 2024, we have integrated the functions of the Compliance Hotline into the NEC Compliance & Integrity Hotline. This integration is also being rolled out in phases across Group companies in and outside Japan starting in April 2025. Reports submitted via JaCER are also accepted.

Customer Communications Center for Customers and Local Residents

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

Whistle Blowing Systems’ Operational Status

In fiscal year 2025, a total of 150 cases were reported to the HR Hotline including harassment, human relations and work environment-related cases.

Relevant divisions work together to resolve the contents of consultations to the HR Hotline, which are also reported to the Risk Control and Compliance Committee for the ongoing enhancement of awareness so as to prevent recurrence.

In fiscal year 2025, no reports related to forced labour or human trafficking were made to the HR Hotline, Hotline for Employees Outside of Japan, the Compliance Hotline, the Customer Communications Center, or through JaCER concerning human rights issues.

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

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

FY2025 Goals

Progress, Achievement, and Issues

FY2026 Goals