Nippon Yusen Kabushiki Kaisha
Slavery and Human Trafficking Statement 2023/24
This statement is made by Nippon Yusen Kabushiki Kaisha (“NYKK”) and published pursuant tosection 54(1) of the Modern Slavery Act 2015 with the approval of the Board of Directors of NYKK.
It sets out the actions taken by NYKK for the financial year ended March 31, 2024, (“FY2023”) toprevent modern slavery and human trafficking within NYKK, its subsidiaries and affiliates(together the “NYK Group”), and their supply chains.

Introduction
As part of its dedication to conducting its business lawfully and ethically, NYKK, as the head companyof the NYK Group, is fully committed to ensuring that no form of modern slavery or human trafficking
occurs in its business and supply chains. We have a zero-tolerance approach to modern slavery andare committed to implementing and enforcing effective systems and controls to ensure that modernslavery does not occur in our organization or within our wider supply chains.
This is our ninth Slavery and Human Trafficking Statement. It builds on our past initiatives todemonstrate our continued commitment to addressing modern slavery and other human rights issues
throughout our global operations and supply chains. We are proud of our efforts to date but are
mindful that our program must continually improve to fulfill our commitments to ensure that no formof forced or compulsory labor takes place within our business.
As detailed below, NYKK has continued to work to eradicate forced labor and human trafficking in its
global business and supply chains by advancing its human rights initiatives. In FY2023, we conducteda human rights impact assessment in some business projects where the risk of modern slavery could
potentially have been high and took appropriate remediation measures as deemed necessary.

About NYK GroupOverview
The NYK Group, headquartered in Tokyo, Japan, is a leading global provider of transport and logistics
services. Established over 135 years ago, the NYK Group is active in more than 59 countries and has
over 35,000 staff working worldwide.
The NYK Group’s activities include a liner and logistics business (comprising liner shipping, air cargotransportation, and logistics), bulk shipping, real estate, and other business services.
In the UK, NYK Group Europe Limited (“NGE”) acts as the Regional Management Office (“RMO”) inEurope.

Supply Chain
Our business relies on diverse partners and suppliers, including fuel companies, shipowners, shipmanagement companies, ship-recycling companies, and agents.

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Our Commitment to Human Rights
Policies
We recognize our responsibility to respect human rights and have embedded it in NYK Group’s
Business Credo1 and our Code of Conduct2. We are committed to ensuring that the rights of all
people affected by our business are respected.
NYK Group Human Rights Policy3, in line with the UN Guiding Principles on Business and HumanRights, sets out our principles for respecting human rights. It applies to all NYK Group executives andemployees, and we encourage our suppliers, contractors, agents, and other parties involved in ourbusiness and supply chain to comply with this policy.
As a global shipping company, NYKK fully commits to the Maritime Labour Convention 2006 (“MLC”)
in which the elimination of all forms of forced or compulsory labor is set out as one of the seafarers’
fundamental rights. We also actively work with the UN Global Compact in its initiatives to promotemore sustainable and people-centred maritime shipping.
To ensure that all those involved in our supply chains comply with our ethical standards, NYKK has
established the CSR Guidelines for Partners and Suppliers4. Beyond compliance with all applicable laws
and regulations, the CSR Guidelines detail our expectations of business partners and suppliers to meet
NYKK’s standards in areas including fair employment practices, health and safety, and human rights.
Any form of forced labor and human trafficking is expressly prohibited. The NYK Group asks allbusiness partners and suppliers not only to comply with the Guidelines themselves but also to require
an equivalent standard from their suppliers.

Governance
NYKK continuously works to strengthen its governance framework for human rights across the NYK
Group. Groupwide policies on ESG management, including human rights, are discussed at the ESG
Strategy Committee (the “Committee”), whose members include executive officers representing eachregional headquarters and external advisors. The Committee meets every two months and provides
advice and recommendations on ESG matters to the Management Meeting and the Board of Directors.
As human rights cover a wide range of issue areas, the responsibility of managing each area is assigned
to respective functions, including human resources and procurement. The ESG Management Groupsupervises group-wide initiatives and works with relevant functions to effectively advance our efforts.
We regularly receive expert advice from Caux Round Table Japan (“CRT Japan”) to strengthen ourefforts to promote human rights in line with the UN Guiding Principles.

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NYK Group’s Business Credo
Code of Conduct
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NYK Group Human Rights Policy | NYK Line
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CSR Guidelines for Partners and Suppliers
22Human Rights Due Diligence
The NYK Group understands that corporate activities, including the supply chain, could have a direct
or indirect adverse impact on human rights. NYKK continually exercises human rights due diligenceacross the NYK Group in the following procedures: identify and assess the Group’s activities that haveor may have an adverse impact on human rights, seek to grasp the Group’s human rights issues toprevent and mitigate the risk of adverse impact and implement appropriate remedial measures, verify
the effectiveness by follow-up monitoring, and disclose the process and the results for review. Rightsholder-oriented collaboration, continuous learning, and improvement through human rights due
diligence are the heart of our approach. More information on our human rights initiatives can be foundhere.5

Assessing Human Rights Risks and Impacts
In FY2022, we first identified and assessed adverse human rights impacts using external knowledge
and data, including Verisk Maplecroft’s data, and analyzed “who could potentially be subject todifferent types of human rights violations in our business projects” through management-levelinternal workshops facilitated by CRT Japan. In the analysis, we examined our business projects andsupply chains and identified high-risk projects and issue areas. Respective group companies orsuppliers who manage the rights holders in question gave us on-the-ground understanding andcooperation.
In FY2023, we conducted human rights impact assessments on three of the five business projects withhuman rights themes that we had identified, specifically, oceangoing shipping, automotive logistics,and ship recycling, in countries where the Group was assumed to have a major impact. A third party,CRT Japan, carried out interviews and questionnaires. Considering both our understanding of actualor potential human rights violations and an assessment of the severity of the adverse human rights
impacts (scale, scope, and irremediability), we identified salient human rights issues, including modernslavery.

Taking Action
Based on the results of the impact assessments, NYKK asked the group companies and suppliers that
directly manage the rights holders to address the identified salient human rights issues andappropriately follow up on their progress.
The table below shows identified salient issues and remediation measures:
BusinessRights Holders(Companyimplementingmeasures)

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Salient Human
Rights Issues

Future Initiatives Under Consideration/ Initiatives
Implemented or in Progress

Human Rights Initiatives

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Oceangoingshipping

Automotive
logistics

Ship recycling

Seafarers(NYK-Fil Ship
Management,Inc.)

Workers(NYK India PrivateLimited)

Workers(PHP Ship Breaking& Recycling
Industries Limited)

Discriminationin theworkplace[Scheduled] NYK-Fil will explain to seafarers that thedifference in treatment in terms of pay for different
nationalities is not due to “nationality-based
discrimination,” but rather due to the living standard in
the seafarers’ native countries for supporting theirfamilies (i.e., living wages). In terms of meals, NYK-Filwill also clarify that the budget per person is the samefor all, regardless of nationality.

Occupational
health andsafety[Scheduled] NYK-Fil will continue the “HealthcareProgram” to create a working environment and culture
where seafarers can report their injury or illness to thecompany without fear of missing out on boarding
opportunities.

Access toremedy[Scheduled] Confidentiality of information should bemaintained in “Assist Me,” NYKSM’s grievancemechanism for seafarers, so that informers’ personal
information and grievances are kept confidential. As
the operator of “Assist Me,” NYKSM will reconfirm with
NYK-Fil how information is being managed and discuss
improvements.

Others[Scheduled] NYK-Fil will consider how to continually
respond to seafarers’ requests regarding benefits andalso continue to raise awareness about lesser-known
schemes.

Decent wages

NYK India has provided explanations of salary rules,
including the pay raise system, to all workers employedthrough the supplier partners.

Modernslavery

NYK India demanded supplier partners executeappointment letters with each worker employedthrough the supplier partners, as required by Indianlaw, and pay slips in a language each worker canunderstand.

Access toremedy

To enhance the effectiveness and transparency of“Samvaad,” a place to engage with workers and also
used as a grievance mechanism for workers, NYK India
delineated the flow of the grievance mechanism.

Modernslavery

PHP has enriched the content of existing statutory
appointment letters so that workers engaging in ship
recycling can properly understand workers’ risks andrights before starting the duties. With all workers, PHP
has decided to sign employment contracts thatindicate workers’ risks and rights.

Occupational
health andsafety,
employability,
access toremedy

PHP established the workers’ education center “Sromik
Shikkha Kendro,” outsourcing its operation andmanagement to a local NGO, and began providing
literacy education for workers.

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Occupational
health andsafety

Others

PHP began offering workers more comfortableuniforms and protective equipment. PHP also installed
a water cooler in the yard facility and provides rest
areas with benches and parasols, in addition to restingrooms with bedding, in the workshop.
PHP applied heat-resistant paint on the dormitory roof
to make the dormitory cooler for better comfort. The
company is also installing a turbine ventilation fan on
the roof for better indoor ventilation. In addition, PHP
planted about 40 trees in front of the employee
dormitory as a cover from direct sunlight.
PHP has started constructing a new dormitory withbathrooms and air conditioning for supervisors, site
supervisors, and other mid-level workers.
PHP is discussing the possibility of providing housing
for workers with families.

Training and Raising AwarenessTo ensure the NYK Group’s directors, officers, and employees have a good understanding of humanrights issues, including the risks of modern slavery and human trafficking, in our business and supply
chains, we integrate human rights in a number of training and e-learning programs. These programs
enable our staff to understand the core principles of human rights, the NYK Group’s related policies
and programs, and, most importantly, how they can play their part in identifying and reporting
possible signs of modern slavery. In FY2023, a total of 8,131 NYK Group employees participated in oure-learning program. This represents a participation rate of 95%.
Moreover, we share the lessons learned from our human rights due diligence process within our groupand with our business partners and suppliers. We strongly believe that sharing these experiences willcontribute to better understanding and provide a solid foundation to promote respect for humanrights in our business and supply chain.

Stakeholder Engagement
Since 2012, we have been participating in the Stakeholder Engagement Program (Human Rights Due
Diligence Workshop) organized by CRT Japan. Discussion on a wide range of human rights issues withparticipating companies, experts, and representatives of NGOs/NPOs, as well as other organizations,helps to deepen our understanding. This workshop also gives us an opportunity to work with otherlogistics companies to identify sector-specific human rights issues.

Monitoring
The table below shows our 2022 agenda published in the previous statement and the progress madeon those action points during the year.
2022 Agenda

Progress5Implementing remedial action for the humanrights issues identified in the FY2022 humanrights impact assessment through appropriate
means, tracking effectiveness, and disclosing
the progress and results

Further strengthening and integration of its due
diligence program, including human rights
impact assessments based on UN Guiding
Principles on Business and Human Rights andsupplier management processes in an improved
global third-party risk management program

We conducted human rights impact assessments on
three of the five business projects with human rights
themes that we had identified, specifically,oceangoing shipping, automotive logistics, and ship
recycling. We asked the Group companies andsuppliers that directly manage the rights holders toaddress the identified salient human rights issues,
including modern slavery, and follow up on theirprogress. The process and progress were disclosed on
our website.
We continued discussion on the integration.

Enhancing internal communication channels in
respect of human rights issues

Internal communication between relevant
departments and group companies has beenenhanced through the human rights due diligenceprocess.

Enhancing human rights due diligenceprocedures

We conducted human rights due diligence, including
human rights impact assessments, and learned a lot ofpractical lessons.

Establishing a grievance mechanism andremediation mechanism specifically aimed athuman rights

We worked with the group companies, where humanrights impact assessments were carried out, toenhance the effectiveness of their grievancemechanism in line with the UN Guiding Principles.
We shared the lessons learned from our human rights
initiatives in the Group.

Enhancing awareness within the NYK Group in
respect of human rights issues
Developing a set of model clauses addressing
modern slavery and human rights issues for use
in new vendor contracts

We continue to work to develop the model clauses.

Further promoting transparency of the shiprecycling process through NYKK’s participationin the Ship Recycling Transparency Initiative

We continue to work on it.

Looking Ahead
NYKK will actively take steps towards ensuring that modern slavery and human trafficking have noplace in the company’s businesses and supply chains by advancing our human rights initiatives.
In 2024, we will continue to integrate human rights into our business practices while exploring apossibility to establish a reliable communication channel for rights holders. Specifically, we will do thefollowing:• Continue to conduct human rights due diligence in the five business projects identified in2022;• Work on implementing an effective grievance mechanism;• Promote collaboration; and• Work on revising CSR Guidelines for Partners and Suppliers.
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Executive Board Approval
This Statement constitutes our Modern Slavery Statement for the financial year ended March 31, 2024.
NYKK will continue to assess the effectiveness of the measures we take, and we will regularly review
and refine our policies and procedures in relation to modern slavery and human rights.
This Statement was adopted by the executive board of Nippon Yusen Kabushiki Kaisha on July 25, 2024.
July 2024:

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Takaya Soga
President,
Representative Director,President and Chief Executive Officer,
Nippon Yusen Kabushiki Kaisha

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