Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Materiality 7

Business Activity

Environment＞ Building a Resilient Supply Chain

Society/Labor＞ Respecting Human Rights

Governance＞ Diversity, Equity ＆ Inclusion

Corporate Citizenship Activities＞ Employeesʼ Health and Safety

Respecting Human Rights
Reason for Prioritization【Activity Policies】

As companies do business in a more globalized way, the potential that they infringe on human rights increases day by day,and companies are now required to take action to minimize and prevent these infringements. Companies must also work toensure that human rights are respected for all stakeholders, including those in the supply chain and their employees, in theirbusiness activities.

■ Nikon Human Rights Policy【Organizations】■ Sustainability Committee

Commitment
As an organization doing business on a global scale, the Nikon Group is profoundly aware of the importance of respecting
human rights in its business activities. We recognize that one of our significant responsibilities to society is addressing humanrights issues with sincerity. In accordance with the Nikon Human Rights Policy and with respect to the seven human rights
issues specified in this policy, we will implement human rights due diligence steadily based on the UN Guiding Principles
on Business and Human Rights and advance initiatives to respect the human rights of all people involved in our businessactivities, including those in the supply chain, as well as constantly inspect for new risks. We will also foster a corporate culturethat respects human rights so that all employees of the Nikon Group will conduct their business activities with integrity andrespect human rights in accordance with this policy and relevant laws and regulations.

Toshikazu Umatate
Representative Director and President

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity＞ Building a Resilient Supply Chain

Environment＞ Respecting Human Rights● Fiscal Year 2022 Materiality Goals and Results
Goals for Fiscal Year 2030

What Nikon Needs to Do

Implement public relations and marketing
activities that take human rights into
consideration

Enhance conformity with the RBA Code of
Conduct

Governance＞ Diversity, Equity ＆ Inclusion

Corporate Citizenship Activities＞ Employeesʼ Health and Safety

Self-evaluation ○ : Achieved △ : Measures started but not yet achieved
RelatedSDGs

Spread awareness of human rights and of the
Nikon Human Rights Policy
Ensuring that the principles embodied by
the Nikon Human Rights Policy are instilled
throughout the value chain, and that themeasures outlined by the policy are properly
implemented
Ensuring that the RBA Code of Conduct
is instilled in every company in the Nikon
Group, and is strictly observed

Society/Labor

Scope

Goals for Fiscal Year 2022

Results for Fiscal Year 2022

Self-Evaluation

Conduct risk assessments from both business and corporate
perspectives as part of human rights due diligence

New business areas: Conducted interviews and feedback on business activities and theirrisks
Corporate divisions: Developed an improvement plan to address the findings of the RBA
VAP audit○

Continue to educate all employees on human rights

Implemented human rights education for employees as plannedOﬀered human rights e-learning to all employees in Japan, with a 92% participation rate○

Education on respect for human rights related to communication

Implemented an educational event on the theme of Communications with an Inclusive
Perspective of Human Rights Handbook
Implemented education on the handbook through human rights e-learning○

Educate related department employees on the RBA Code of Conduct

All eligible employees received training on the RBA Code of Conduct○

Conduct self-checks at each Nikon plant and Group manufacturing
companies in Japan and outside Japan

Conducted self-checks and analyzed results for target plants and Group manufacturing
companies in Japan and outside Japan○

Nikon Group

8,10,16

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity＞ Building a Resilient Supply Chain

Environment＞ Respecting Human Rights

Society/Labor

Governance＞ Diversity, Equity ＆ Inclusion

Corporate Citizenship Activities＞ Employeesʼ Health and Safety

Human Rights Initiatives
Basic Approach
In our business activities, the Nikon Group is directly andindirectly involved in the human rights of a variety of
stakeholders. It is for this reason that our stance, whichemphasizes respect for the human rights of all these people,
is clearly enunciated in "2. Respect for Human Rights" of the
Nikon Code of Conduct. Furthermore, we have established our
Nikon Human Rights Policy in order to clearly show how weaddress human rights issues related to our business activities
under our Code of Conduct. The Nikon Human Rights Policy
sets forth fundamental principles for us to practice in linewith the UN Guiding Principles on Business and Human
Rights, which were adopted by the United Nations in 2011.
The policy was created through internal discussions withmajor relevant departments and incorporating advice fromexternal experts, and was established after approval by the
Board of Directors.
The Nikon Group has other policies and standards in place
specific to individual human rights issues, including the
Nikon Group Privacy Protection Statement, the Nikon CSR
Procurement Standards, and the Responsible Minerals
Sourcing Policy. Nikon also supports the 10 Principles of
the UN Global Compact, and we continue to implement
measures aimed at realizing Principles 1 and 2 (Human
Rights) and Principles 3 through 6 (Labour).

SystemNikon Code of Conduct (nikon.com)
https://www.nikon.com/company/sustainability/
management/codeofconduct/code_of_conduct_EN.pdf
Nikon Human Rights Policy
https://www.nikon.com/company/sustainability/societylabor/human-rights/human_rights_policy.pdf*Nikon Human Rights Policy (Japanese) is a provisional translation of the
Nikon Human Rights Policy (English).

Nikon Group Privacy Protection Statement
https://www.nikon.com/privacy/privacy_policy.htm
Nikon CSR Procurement Standards
https://www.nikon.com/company/corporate/
procurement/csr/
Responsible Minerals Sourcing Policy
https://www.nikon.com/company/sustainability/societylabor/supply-chain/Responsible_Minerals_Sourcing_
Policy.pdf
Joining the UN Global Compact（➡ p.014）

In the Nikon Group, the Nikon Human Rights Policy
is implemented under the supervision of Nikonʼs
Sustainability Committee, which includes several membersof the Nikon Board of Directors. Instructions from theSustainability Committee are handled by the Corporate
Sustainability Department, which functions as thesecretariat for the Corporate Sustainability Department,
together with related departments and committees. In thecase that an emerging issue is identified, we will enhance
our organizational framework and systems as necessary
by consulting these departments and other appropriate
departments as necessary.
With the Nikon Group, we have reporting and consulting
systems in place by company or by region. Any Group
employee can use these systems to report violations of the
Nikon Code of Conduct (including issues related to humanrights). For external stakeholders, we have several channels of
inquiry, including contact points for suppliers and customer
support, a hotline dedicated to conflict minerals issues, etc.
Main Committees and Departments in Charge of Human Rights
Issues（➡ p.110）
Code of Conduct Hotline (Reporting and Consulting System)（➡ p.133）
Inquiries (Procurement, CSR Procurement, Green
Procurement)
https://www.nikon.com/company/corporate/
procurement/form/
Responsible Minerals Sourcing Hotline
https://www.nikon.com/company/sustainability/societylabor/supply-chain/form/

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity＞ Building a Resilient Supply Chain● Main Committees and Departments in Charge of

Human Rights Issues

Environment＞ Respecting Human Rights

Society/Labor

Governance＞ Diversity, Equity ＆ Inclusion

Corporate Citizenship Activities＞ Employeesʼ Health and Safety● Major Human Rights Initiatives by the Nikon GroupFY1997

Established the Business Conduct Committee (currently the Compliance Committee)

FY2001

Established the Nikon Code of Conduct, which touches on respect for human rights
Established the Code of Conduct Hotline

FY2004

Established the Nikon Charter of Corporate Behavior, clearly stating respect for human rights as the basic approachof the Nikon Group

FY2006

Established the CSR Committee (currently the Sustainability Committee) to integrate CSR-related activities, including
respect for human rights, and create a company-wide promotion system

FY2007

Revised the Nikon Charter of Corporate Behavior and newly established the Nikon CSR Charter (revised content
regarding respect for human rights)
Established the Nikon Procurement Partner’s CSR Guidelines, clearly stating our approach to CSR in procurement,
including respect for human rights, and what we expect of our procurement partners
Joined the United Nations Global Compact (UN Global Compact)

Contact points for employee reporting andconsulting system

FY2010

Launched monitoring surveys to manage human rights and labor standards globally for Group companies

FY2011

Established the Policy on Conflict Minerals and established a hotline for conflict minerals

Information Security
Department

Privacy (including protection of personal
information)

FY2012

Launched conflict minerals survey and disclosure of survey results

Bioethics Review
Committee

FY2014

Joined the Responsible Minerals Initiative (RMI)*

Bioethics

FY2015Abolished the Nikon Procurement Partner’s CSR Guidelines and established the Nikon CSR Procurement Standards,
and launched CSR assessments and CSR audits

Supply Chain
Subcommittee

Human rights issues in the supply chain(labor, conflict minerals, etc.)

FY2016

Launched disclosure of compliance statement with the UK Modern Slavery Act

FY2018Integrated the Nikon CSR Charter and Nikon Code of Conduct integrated into a new Nikon Code of Conduct toserve as the Group's unified standard
Joined the Responsible Business Alliance (RBA)

FY2019Established the Nikon Human Rights Policy

FY2020

Launched streaming of the message from the president for Human Rights Day in the internal newsletter

FY2021Created the Communications with an Inclusive Perspective of Human Rights handbook

FY2023

Established the Nikon Global Diversity, Equity & Inclusion Policy

Committees And
Departments In Charge

Main Issues Handled

Sustainability Committee

General human rights issues (supervising
implementation of the Nikon Human
Rights Policy)

Human Resources
Department

Prohibition of forced labor and childlabor, elimination of discrimination andharassment, occupational health andsafety, wages, working hours, freedom of
association and collective bargaining rights,
etc., with respect to Nikon employees

Administration Department*The name of the organization on joining was the Conflict-Free Sourcing Initiative (CFSI). Its name was changed in 2018.

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity＞ Building a Resilient Supply Chain

Initiatives for Preventing Human
Rights Violations
Human Rights Risk Assessment
In the process of developing the Nikon Human Rights
Policy in fiscal year 2019, the Nikon Group implemented arisk assessment to identify significant human rights issues
for the Group. This assessment used international humanrights standards as a reference, benchmarking Nikon's
situation against industry peers and reviewing past humanrights violations reported in business domains where
Nikon is active.
As a result of this assessment, we identified the following
seven human rights issues as particularly important to ourbusiness, specifying them as such in the Nikon Human
Rights Policy: Prohibition of Forced Labor and Child Labor,
Elimination of Discrimination and Harassment, Occupational
Health and Safety, Freedom of Association and the Rightto Collective Bargaining, Working Hours and Wages, Right
to Privacy, and Human Rights Issues in the Supply Chain.
Since establishment of this policy, we have been working toenhance our efforts to address these issues and, if necessary,
review our efforts.
In the event of any major changes in management,
including in the scope of our business, or if it is deemedotherwise necessary to review these important issues, wetake steps needed for review, including deliberation by the
Sustainability Committee.
In fiscal year 2022, we interviewed the persons responsible
for the new Contract Cell Manufacturing business andImaging Solutions business to capture human rights
risks of stakeholder in each activity of the value chain
and examine risk severity and frequency. This assessment

Environment＞ Respecting Human Rights

Society/Labor

Governance＞ Diversity, Equity ＆ Inclusion

Corporate Citizenship Activities＞ Employeesʼ Health and Safety

revealed no serious human rights risks in these new
businesses. We will continue to conduct regular interviews,
not only for new businesses.

Initiatives for RBA（➡ p.015）
Risk Management for Information Assets and Cybersecurity（➡ p.145）

Monitoring

Other related measures
Promoting CSR Procurement（➡ p.101）

In the Nikon Group, we conduct human rights and labormonitoring surveys for Group companies each year in order
to continuously improve how we address human rights. The
results of these surveys are reported to the Sustainability
Committee, which provides instructions for further
confirmation or corrective actions to prevent the occurrence
or recurrence of human rights violations. No major problems
were identified in the surveys for fiscal year 2022.
In addition, Nikon has joined the Responsible Business
Alliance (RBA) and uses the self-assessment tool for RBA
Code of Conduct compliance to monitor human rights risk.
In fiscal year 2022, our Group manufacturing companies
in and outside Japan, as well as Nikon plants, conductededucation on the RBA Code of Conduct and self-assessments,
analyzed results, and repeated their self-assessments. These
assessments revealed no major problems. In fiscal year 2023,
based on the results of these self-assessments, we plan todevelop initiatives to ensure more appropriate compliancewith the Code of Conduct.
In addition, given the current tendency toward more
restrictive laws and regulations related to personal
information protection in various countries and regions, weare enhancing our measures for appropriate handling of
personal information to ensure that it is securely managed.

Responsible Minerals Sourcing Report 2022 (Results ofthe 2021 Survey)
https://www.nikon.com/company/sustainability/societylabor/supply-chain/Responsible_Minerals_Sourcing_
Report_2022_Survey.pdf

Details of the Human Rights and Labor Survey
Date: End of each fiscal year
Target: Group companies (including non-consolidated
companies)
Content:● Presence of child labor (prohibition of forced labor),
working environment for young workers and trainees(state of acceptance, type of employment/acceptance,
work tasks, methods of age verification at the time ofhiring/acceptance, state of compliance with respective
local laws)● State of employment of migrant workers and foreigntechnical trainees/specified skilled foreign workers,
presence of explanation of employment work
conditions before hiring, state of company burden forhiring expenses● State of compliance with laws and regulations relating
to minimum wages and working hours● State of occupational accidents (outside Japan)

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity＞ Building a Resilient Supply Chain

Human Rights Training
The Nikon Group works to disseminate information and raiseawareness about human rights among our executives andemployees.
Every December, for Human Rights Day, a message fromthe president is distributed to all employees throughthe internal newsletter and other means. In fiscal year
2022, this message was themed on diversity, equity andinclusion (DEI), as well as unconscious bias, with the intent
of creating attractive workplaces. We also occasionally
include human rights topics in our quarterly sustainability
newsletter to raise employee awareness.
Furthermore, the Nikon Group in Japan conducts an annual
e-learning course on human rights. In fiscal year 2022, course
materials covered the history of human rights, the relationshipbetween business and human rights, DEI, unconscious bias,
and inclusive language, with a 92% attendance rate. Each
year, sustainability divisions at our regional headquarters also
lead e-learning courses on human rights at Group companies
outside Japan.
In addition to this, we produced and disseminated theCommunications with an Inclusive Perspective of Human
Rights Handbook with the aim of improving the levelof human rights-conscious marketing communication
throughout the Group. The handbook helps to improve thequality of a range of operations thanks to content useful not
only in marcom (marketing communications), but in otherareas as well. In addition, we held the Events for World Human
Rights Day 2022 in December 2022, mainly for employees
in Japan. These events lasted about a month, and many
employees participated in various programs, including a quizon DEI, lectures by outside experts, and a talk event on thetheme of Communications with an Inclusive Perspective ofEnvironment＞ Respecting Human Rights

Human Rights Handbook.
We also provide presentations about the importance ofhuman rights issues to our procurement partners as well as
persons in charge of procurement within the Nikon Group.
Promoting CSR Procurement（➡ p.101）

Society/Labor

Governance＞ Diversity, Equity ＆ Inclusion

Corporate Citizenship Activities＞ Employeesʼ Health and Safety

Compliance with the
UK Modern Slavery Act
The Nikon Group has released a statement on its website inaccordance with UK Modern Slavery Act (enacted in 2015).
Nikon Group Slavery and Human Trafficking Statement for
Fiscal Year 2021 (Tentative Translation)
https://www.nikon.com/company/sustainability/societylabor/human-rights/uk-modern-slavery2022.pdf

Image from Events for World Human Rights Day 2022

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity＞ Building a Resilient Supply Chain

Environment＞ Respecting Human Rights

Society/Labor

Governance＞ Diversity, Equity ＆ Inclusion

Corporate Citizenship Activities＞ Employeesʼ Health and Safety

Labor Relations
The Nikon Group respects basic labor rights and iscommitted to human rights as described in the Nikon
Human Rights Policy following the International Labor
Organizationʼs (ILOʼs) Declaration on Fundamental
Principles and Rights at Work.
At Nikon, the Nikon Labor Union has been organized,
which is a member of the Japanese Association of Metal,
Machinery, and Manufacturing Workers (JAM), itself mostly
made up of employees of SMEs in the metal and machineindustries. As of March 31, 2023, the Nikon Labor Union
had 4,067 members, and 78.8% of Nikon employees weremembers of the union. When implementing measuresrelated to the personnel system or work styles, we strive forfull consultation with the Nikon Labor Union. Nikon also
holds joint study meetings with the Nikon Labor Union,and exchanges opinions as necessary.
At Group companies in Japan, Nikon Labor Union branchor employee-elected representatives are responsiblefor discussing with their company. At Group companies
outside Japan, issues are discussed either by the companyʼs
in-house union or through consultations with an outsidelabor union to which employees belong. At companies
where there is no labor union, we hold briefings for all
employees, dialogue with employee groups, and face-toface meetings with individual employees.
When ordering an employee to change the job description
and/or work location, the Nikon Group will discuss with theirunion or employee representative and informs the employee
within a sufficient period of time.

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