Nikon Group Slavery and Human Trafficking Statement for the fiscal year ended March 2018
This statement is made pursuant to the United Kingdom Modern Slavery Act of 2015. The Nikon Group,Nikon Corporation and its consolidated subsidiaries (“Nikon”, or “we”), endeavours to ensure that there areno human rights violations through our own business operations or our supply chains. We hereby provide
this disclosure statement regarding our activities to prevent and tackle modern slavery and humantrafficking.
a. Overview of the company, business and supply chain
Nikon has been engaged in various business fields, such as Imaging Products (digital cameras andinterchangeable lenses), Precision Equipment (FPD lithography and Semiconductor lithography), HealthcareEquipment (microscope and retinal diagnostic imaging equipment), and other businesses, based on theopto-electronic and precision technologies which Nikon has developed since its establishment in 1917.
Nikon manufactures and sells such equipment and apparatuses. Details of our company and businessinformation can be found on the “Corporate Information” page of the Nikon Corporation’s website.
Our business activities in the UK consist of product manufacturing, sales and/or services by our groupcompanies: Nikon U.K. Ltd., Optos plc, Nikon Metrology UK Ltd. and X-Tek Systems Ltd.
Nikon’s product parts and a small portion of the final products are supplied from external procurement
partners in and outside of Japan. There are approximately 1,700 procurement partners as of the end ofMarch 2018. More than ninety percent (calculated by the transaction amount in which country their
headquarters are located) of the procurement partners are based in Japan, China and Thailand.

b. Policies related to modern slavery and human trafficking
In the fiscal year ended March 2018 (“Period”) we consolidated our previous “Nikon Corporate Social
Responsibility (CSR) Charter” and “Nikon Code of Conduct” in January 2018 to create a new “Nikon Code ofConduct” effective as of April 2018. This Nikon Code of Conduct presents our basic stance on social
responsibility and serves as the standard for conduct by each individual who works for Nikon. We havereinforced sections related to human rights by addressing “Respect for Human Rights” and “Social
Responsibility in the Supply Chain” and clarifying our stance against forced labour and child labour not onlywith respect to Nikon, but also our suppliers and business partners.
As for our supply chain, in August 2015 we published the “Nikon CSR Procurement Standards” (asamended in August 2016), which is our guideline to promote Nikon’s stance on CSR throughout our supply
chain, and we require our procurement partners to comply with it. The Standards are based on the RBA(Responsible Business Alliance) Code of Conduct, which is the global standard for the electronics industry
and articulates the prohibition of “forced, bonded (including debt bondage) or indentured labour,
involuntary prison labour, slavery or trafficking of persons”.
In response to issues related to conflict minerals in the Democratic Republic of Congo and its neighbouring
countries, we established “Policy on Conflict Minerals”, a policy of not using conflict minerals mined orintermediated by armed forces violating human rights in the area, which addresses our stance to endeavour
not to engage in human rights violations including modern slavery and human trafficking.
We also support the 10 principles of the United Nations Global Compact.
These group policies related to modern slavery and human trafficking are also applicable to our UK groupcompanies listed above.

c. Due diligence process related to modern slavery and human trafficking
d. Risk assessment and risk management related to modern slavery and human trafficking
e. Measurement by appropriate indicators and effectiveness of steps to endeavour to ensure that slaveryand human trafficking is not taking place
Within Nikon, we conduct human rights and labour monitoring surveys annually to ensure child andforced labour practices are not occurring. For the Period, we continued our efforts from the fiscal yearended March 2017 (“Previous Period”) to confirm any presence of migrant workers and ascertain actual
conditions in manufacturing companies in Asia (excluding Japan), where such workers are generally at highrisk for harsh labour conditions.
In Japan, we turned our attention to human rights issues raised internationally with respect to labour byforeign technical trainees (“Trainees”). We ascertained by the above monitoring survey that Trainees fromThailand had been accepted at three companies during the Period. These companies conducted selfassessments with respect to typical actions and conditions presenting a human rights infringement risk,
including whether the company withheld passports or demanded working hours beyond what is permitted
under law and internal regulations. These companies confirmed that there were no cases of such withheld
passports, unlawful working hours or any other typical actions and conditions.
For Nikon employees, we have internal as well as regional or local external hotline(s) by which they areable to report when they become aware of an actual or potential violation of the Nikon Code of Conduct.
Our employees can use the hotline(s) anonymously.
In our supply chain, we endeavour to assess modern slavery and human trafficking risks by requesting ourprocurement partners to comply with the Nikon CSR Procurement Standards and also by conducting
periodical monitoring.
Since we began in the Previous Period to request that our procurement partners submit a declaration
letter to confirm they comply with the Nikon CSR Procurement Standards, we have collected 620 such lettersby of the end of the Period.
In the Period, we also conducted a self-assessment survey among 209 major procurement partners tocheck compliance with the Nikon CSR Procurement Standards. We made an effort to expand our scope by
selecting companies we did not survey in the Previous Period based on risk assessment criteria such as
location, business type, annual transaction volume, length of business partnership and type of contract.
After compiling all the response data, the responses from those partners were weighed for questions related
to serious risks in human rights and safety areas and evaluated for potential risks. As a result, we identified
three potentially high risk companies and after advanced notice we conducted on-site audits of thesecompanies using third party auditors in February 2018. The three companies are located in China andThailand. The results of the audits identified some issues for correction, mainly in the area of labour andhealth and safety, and we requested rectification. We identified ten other companies as relatively high risk,
and while we did not elect to conduct audits we instructed them in writing to make improvements in theareas where the Nikon CSR Procurement Standards were not satisfied. We demanded that all 13 companies
submit action plans for our approval, and they are taking actions in accordance with such plans.
13companies to which we requested rectification by on-site audits or letters during the Previous Period
reported to us that they completed corrective actions within the Period.
Nikon will continue disclosing the number of companies for which we conduct self-assessment survey oron-site audits to check compliance with the Nikon CSR Procurement Standards, as indicators to measureprogress.
Further, in the Period, Nikon Corporation engaged a global nonprofit organisation specialised insustainability issues to assess Nikon’s current overall CSR procurement activities. The assessment included areport on industry benchmarks as well as suggestions for the future. After re-confirming challenges related
to Nikon’s supply chain based on such assessment, we drafted an improvement plan outlining future action
items incorporating its suggestions.

In light of conflict mineral issues, we endeavour to prevent human rights violations such as modern slavery
and human trafficking, with our Policy on Conflict Minerals, conducting investigations of our productcomponents to ensure conflict minerals are not used in our products.
Our UK group companies listed above are also participating in these efforts as members of the Nikon Group.
f. Training and Capacity building related to modern slavery and human trafficking
To deepen understanding of the importance of human rights and how it ties into our business, we rolled
out an e-learning course in Japan in the Period for 6,392 executives and employees, who are likely to be in
the position to give instructions to and receive feedback from our group companies abroad. We believe it iscritical that those in such positions should have awareness of international human rights trends and theNikon’s stance and the relevant policies. For the e-learning course, we selected case studies which we
deemed are most relevant and familiar to those target audience such as actual cases from electronics
industry’s supply chain and Trainees in Japan.
For supply chain, every year we explain the contents of the Nikon CSR Procurement Standards toemployees of our procurement department/section and procurement partners. In the Period, we held
explanatory sessions in meetings such as the Supply Chain Subcommittee, whose members included
department managers of the quality control or the procurement department of each business unit, andbriefing sessions conducted in Japan, China and Thailand for procurement partners as well as our employees
who were responsible for procurement. The explanation included international trends related to humanrights issue in supply chains, such as the United Kingdom Modern Slavery Act. For the Period in the European
region, we also provided e-learning sessions on the Nikon CSR Procurement Standards mainly to employeesof the UK group companies listed above who were responsible for procurement units, as well as theirrespective procurement partners. In total, 118 employees and 671 procurement partners attended thesebriefings and e-learning sessions.
This Statement was reviewed and approved by the Nikon Corporation’s Board of Directors on 7 September
2018.
Further, this Statement was reviewed and approved by Nikon U.K. Ltd.’s Board of Directors on 8 August
2018, Optos plc’s Board of Directors on 24 August 2018, Nikon Metrology UK Ltd.’s Board of Directors on 8August 2018, and X-Tek Systems Ltd.’s Board of Directors on 8 August 2018.
13 September 2018

Kazuo Ushida
President
Representative Director
Nikon Corporation13 September 2018

John Walshe
Managing Director
Nikon U.K. Ltd.

13 September 2018

Robert Kennedy
Director and Chief Executive Officer
Optos plc
13 September 2018

Hajime Kosawa
Director & President
Nikon Metrology UK Ltd.

13 September 2018

Jeff Walker
Director & President
X-Tek Systems Ltd.