Nikon Human Rights Policy

Effective Date: April 1, 2019

Nikon (Nikon Corporation and all of its subsidiaries worldwide) has aten principles of the United Nations Global Compact. We also support thecorporate philosophy of “Trustworthiness and Creativity”. Respecting

United Nations Guiding Principles on Business and Human Rights and strive

human rights forms the basis necessary to gain trust from stakeholders andto operate in line with them.

generate value for society.
We recognize that our business activities may impact the human rights ofThe Nikon Code of Conduct specifies our overarching position on respect forinternal and external stakeholders. We strive to avoid infringing on human

human rights. The Nikon Human Rights Policy (this policy) complements

rights, or contributing to their infringement. If an adverse impact on human

our Code of Conduct and further outlines our approach to human rights

rights is directly linked to our operations, products or services by ourissues related to our business activities.

business relationships, we will work with relevant parties including ourprocurement partners and other business partners, and seek to exercise

This policy applies to all of Nikonʼs directors, officers and employees. We

our leverage to prevent or mitigate such adverse impacts.

also expect our procurement partners and other business partners tounderstand and uphold the principles of this policy. Implementation of thisWe comply with applicable local laws and regulations wherever we operate.

policy is supervised by the Sustainability Committee of Nikon Corporation

Where local laws conflict with international human rights standards, we will

which includes several members of our Board of Directors.

comply with local laws, while seeking ways to honor the principles ofinternationally recognized human rights to the greatest extent possible.

1. Commitment to respect human rights
2. Conducting human rights due diligence
We are committed to respecting human rights as set out in the International
Bill of Human Rights and the International Labour OrganizationʼsIn line with the United Nations Guiding Principles on Business and Human

Declaration on Fundamental Principles and Rights at Work, and support theRights, we will assess human rights risks in our business, and work toNikon Human Rights Policy

Nikon Human Rights Policy
prevent and mitigate any identified adverse human rights impacts withrights, and work to enhance our organizational structure and systems forwhich we are involved. Where we identify that we have caused oreffective implementation of this policy. We will also regularly and publicly

contributed to an adverse human rights impact, we will endeavor todisclose our progress towards implementing this policy.

remediate such impact through appropriate processes.
3. Human rights issues particularly relevant to our businessWe are committed to engaging with stakeholders whose human rights maybe affected by our operations, in a timely manner, in order to understandWe recognize that addressing the following human rights issues linked to ourand address their human rights challenges.

business operations constitutes an essential component of our social responsibility.

We have established a reporting and consulting system for directors,-Prohibition of Forced Labor and Child Labor: we do not engage in any

officers and employees so that we could identify and address any violation

forced labor (including any form of human trafficking) or child labor.

or potential violation of the Nikon Code of Conduct including issues related
For external stakeholders, we have several channels of-Elimination of Discrimination and Harassment: we strive to eliminate

inquiry through which concerns related to our business operations can bediscrimination and harassment, and to prevent their associated negativeraised including human rights issues. We will continue to work towards

impacts to an individualʼs dignity, our workplace environment, and/or ourestablishing effective grievance mechanisms.

business operations.

We will provide adequate training to ensure our directors, officers and-Occupational Health and Safety: we maintain a healthy and safe work

employees are able to implement and comply with this policy.

environment. We comply with the applicable laws and regulations related

to human rights.

to occupational health and safety and seek to prevent occupational
We will monitor the results of our actions concerning respect for human

Nikon Human Rights Policy

accidents wherever we operate.

Nikon Human Rights Policy-Freedom of Association and the Right to Collective Bargaining: we4. Approval

respect the basic labor rights regarding freedom of association and theright to collective bargaining in accordance with the applicable laws andThis policy has been approved by the Board of Directors of Nikon

regulations of the countries where we operate.

Corporation.

-Working Hours and Wages: we comply with laws and regulations related
to working hours and wages of the countries where we operate.
-Right to Privacy: we acknowledge that processing personal data in aproper manner is critical, and therefore we comply with laws andregulations related to personal data protection wherever we operate.
Furthermore, we continue to enhance our efforts to put in place necessary

ⅰ The International Bill of Human Rights is the general term referring to three documents: theUniversal Declaration of Human Rights and its corresponding two international treaties, namely
the International Covenant on Civil and Political Rights, and the International Covenant onEconomic, Social and Cultural Rights. The Universal Declaration of Human Rights was adopted at
the U.N. General Assembly in 1948 as a common standard of achievement for all people and allnations, and sets out fundamental human rights to be universally protected.
ⅱ The ILO Declaration on Fundamental Principles and Rights at Work sets out the following four
categories as minimum labor standards to be protected: freedom of association and the right toand appropriate management systems in order to ensure personal data iscollective bargaining, elimination of all forms of forced or compulsory labour, the effective

secured and protected.

abolition of child labour, and the elimination of discrimination in respect of employment andoccupation.
ⅲ The UN Global Compact specifies ten principles that companies should implement within their-Human Rights Issues in the Supply Chain: we respect the human rights

sphere of influence for the four categories of: Human Rights, Labour, Environment, andof workers in our supply chain, and promote respect for their human rights.

Anti-Corruption.

We recognize issues concerning mineral procurement, such as humanⅳ The UN Guiding Principles on Business and Human Rights offer authoritative guidance on “Stateduty to protect human rights“, “Corporate responsibility to respect human rights“ and “Access torights abuses and environmental destruction, and continue our efforts toremedy“, outlining the standard for States and business to prevent and address the risk ofpromote responsible sourcing.

adverse impact on human rights linked to business activity.

Nikon Human Rights Policy