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 regularly presents status reports on initiatives in line with the UNGPs to the Board of Directors, which monitors the progress of the initiatives.

NEC and its consolidated subsidiaries (hereinafter, the NEC Group) conduct regular assessments and identify any actual or potential adverse human rights impacts that may occur either through their own activities or as a result of their business relationships. Through these assessments, the NEC Group identifies its salient human rights issues, and appoints an officer and a department in charge for each human rights issue to promote 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.

For details, see Risk Management (including Opportunity Generation): Human Rights Due Diligence andGrievance Mechanisms.

Approach to Respect for 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 the Principles outlined in the NEC Way, a shared policy which expresses the behavior that we value as a company, and clearly stipulates the requirement of respect for human rights in all situations by everyone, from NEC Group officers to employees.

The NEC Group respects fundamental human rights in every aspect of its corporate activities and will not allow any act that may be prejudicial on the grounds of race, beliefs, age, social position, family origin, nationality, ethnicity, religion, gender and sexual orientation, gender identity, or disability, or any act that may offend the dignity of any individual, such as bullying, harassment, child labour, or forced labour.

The NEC Group also recognizes its responsibility for the potential impacts that its corporate activities may have on human rights of all people, including vulnerable groups. In addition, the NEC Group, as an ICT provider, strives to promote data protection and privacy, respect for freedom of expression, and the proper use of new technologies.
Through the development and provision of products and services that take into consideration human rights issues such as invasion of privacy and discrimination, the NEC Group aims not only to prevent and mitigate adverse impacts on society but also to maximize the social value that it provides.

Based on the aforementioned philosophy, the NEC Group upholds international human rights standards relevant to its businesses and technologies, including those established in the following documents. Where national laws in the relevant jurisdiction conflict with internationally recognized human rights, the NEC Group will seek ways to respect the principles of internationally recognized human rights.

The NEC Group Human Rights Policy details our approach.

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. Furthermore, in June 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 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, NEC held talks with a wide range of internal and external stakeholders, including labour unions, experts from the International Labour Organization (ILO), international NPOs, investors, and lawyers specializing in human rights and business. In 2023, the Company also revised the policy to reflect the addition of “a safe and healthy working environment” to the ILO Core Labour Standards.

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 parttime 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. 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.

Approach to Human Rights

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 Principles,¹ 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 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 2019 in order to further improve the effectiveness of its human rights due diligence.

Initiatives to Address Salient Human Rights Issues

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 2022² 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 rights policy or other appropriate systems to implement measures equivalent to the NEC Group Human Rights Policy in order to preclude human rights risks.

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 Occupational Health and Safety (hereinafter, OH&S) Management System. In fiscal 2024, NEC conducted self-assessment checks to strengthen management of OH&S and ascertain the status of initiatives to promote respect for human rights. Based on the results of those checks, the Company identified subsidiaries outside Japan where awareness of human rights policies is insufficient and worked to raise awareness at those subsidiaries. NEC Group prohibits all forms of harassment, including power harassment and sexual harassment, and aims to foster a culture of mutual acceptance of diversity. The Corporate Human Rights Promotion Committee established by the Company in 1997 continues its activities to promote human rights awareness, including the prohibition of discrimination and the prevention of harassment.

Stakeholder Engagement on Human Rights

Dialogue with Stakeholders

NEC Sustainability Advisory Committee

Since fiscal 2022, the Sustainability Advisory Committee has been held at NEC Corporation for the CFO and the officers in charge of sustainability 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.

Engagement with Suppliers

NEC provides opportunities for dialogue with suppliers on human rights initiatives through exchange meetings and study sessions. In fiscal 2024, it provided an opportunity for dialogue with external experts on the topic of supply chain sustainability.

Engagement with Employees

Approaches such as the NEC Women’s Day 2024 online event in honor of International Women’s Day and unconscious bias training have provided employees with opportunities to make understanding and accepting different values and cultures a personal responsibility. In addition, to ensure health and safety and promote comfortable workplace environments, health and safety committee members selected by each division, labour 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.

In 2019, NEC also joined The Valuable 500, an international initiative dedicated to promoting the active participation of people with disabilities.

Additionally, in 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.

Awareness-Raising Related to the NEC Group Human Rights Policy and Employee Safety and Health

NEC conduct online diversity and human rights training every year for all employees, including dispatched workers and temporary employees, of NEC Corporation and 13 of its consolidated subsidiaries in Japan. In addition, the human resources departments of all consolidated subsidiaries outside Japan distribute training materials with the same content as those used in Japan.

Diversity and human rights training and completion rates are as follows:

In addition, as a seminar related to Compliance Day, several NEC advisors, including a former director-general of the Ministry of Justice’s Human Rights Bureau, conducted a webinar for NEC Corporation and consolidated subsidiaries in Japan with the theme of “Business and Human Rights: Insights into the Impact on Companies from Human Rights Violations Based on Recent Cases.” In a survey of 149 in-person participants, 27.5% responded it was “better than expected” and 72.5% responded it was “as expected,” indicating a 100% satisfaction rate.

In addition, NEC Corporation also conducts online training on the theme of AI and human rights every year for its employees. The fiscal 2024 completion rate was 95%.

Training at NEC Corporation

Training for Suppliers

Grievance Mechanisms

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 whistleblowing 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 wide range of stakeholders, including temporary employees, 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 Japan Electronics and Information Technology Industries Association (JEITA) and the Business and Human Rights Lawyers Network (BHRL), an association of lawyers.

HR Hotline for Employees in Japan, Including Temporary Employees

The Human Resources (HR) Hotline is intended for use by all those working for the NEC Group, including dispatched and temporary 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 site and at each business unit, with reports possible by phone or by email in Japanese and English.

NEC expanded the scope of reporting since 2024 to include consultations regarding harassment, human rights violations and discrimination, as well as violations of labour-related laws and regulations and violations of internal personnel-related regulations. The name of the hotline was therefore changed from the Human Rights Hotline to the HR Hotline.

The Company is working to raise awareness of the whistleblowing system through various efforts that include officer messaging for eliminating harassment and online training.

Hotline for Employees Outside of Japan, Including Temporary Employees

For NEC’s consolidated subsidiaries outside Japan, regional headquarters also set up whistleblowing 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.

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.

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.

Whistleblowing Systems’ Operational Status

In fiscal 2024, a total of 109 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 2024, no reports related to forced labour or human trafficking were made to the HR Hotline, Hotline for Employees Outside of Japan, the Compliance Hotline or the Customer Communications Center.

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

FY2024 Goals, Progress, Achievements and Issues, and FY2025 Goals

FY2024 Goals

Progress, Achievements and Issues

FY2025 Goals