NEC Group Human Rights Policy
April 2015
revised in April 2023
Our Approach to Respecting Human Rights
NEC Corporation and its consolidated subsidiaries (the “NEC Group”) aim to fulfill theGroup’s Purpose of creating the social values of safety, security, fairness, and efficiency topromote a more sustainable world where everyone has the chance to reach their full potential
while engaging in dialogue and co-creation with stakeholders.
The NEC Group believes that conducting corporate activities with respect for human rights
is essential to fulfill its Purpose.
With this in mind, we have 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 acompany, and we clearly stipulate 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, socialposition, 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 labor, or forced labor.
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.
The NEC Group, as an ICT provider, also strives to promote data protection and privacy,
respect for freedom of expression, and the proper use of new technologies. Through thedevelopment and provision of products and services that take into consideration human rightsissues such as invasion of privacy and discrimination, the NEC Group aims not only to preventand mitigate adverse impacts on society but also to maximize the social value that the NECGroup provides.
Upholding International Standards
Based on the NEC Group’s approach outlined above, the NEC Group upholds international
human rights standards relevant to the NEC Group’s businesses and technologies, including
those established in the following documents. Where national laws in the relevant jurisdiction
conflict with internationally recognized human rights, we will seek ways to respect the1principles of internationally recognized human rights.
⚫

International Bill of Human Rights consisting of the Universal Declaration of HumanRights, the International Covenant on Civil and Political Rights, and International
Covenant on Economic, Social and Cultural Rights⚫

International Labour Organization (ILO) Core Labour Standards that consist of ten
fundamental conventions in five categories: freedom of association and the right tocollective bargaining, the elimination of all forms of forced or compulsory labour, theeffective abolition of child labour, and the elimination of discrimination in respect ofemployment and occupation, a safe and healthy working environment⚫

The United Nations Guiding Principles on Business and Human Rights (UNGPs)⚫

The Organization for Economic Co-operation and Development (OECD) Guidelines forMultinational Enterprises⚫

International Labour Organization (ILO) Tripartite Declaration of Principles concerning
Multinational Enterprises and Social Policy

Purpose and Scope of the NEC Group Human Rights Policy
This NEC Group Human Rights Policy (this “Policy”) details the NEC Group's policy for
respecting human rights across its entire value chain.
This Policy applies to all officers and employees of the NEC Group, including fixed-termcontract employees, temporary employees, and part-time employees. The NEC Group also
encourages its suppliers, business partners, and customers to understand this Policy and share
our commitment to respecting human rights.
This Policy as well as our initiatives for promoting respect for human rights based on thisPolicy will be reviewed periodically and updated or revised as necessary.
Our Policy
Governance
The CEO oversees the initiatives based on this Policy. In addition, the corporate officer incharge of sustainability promotion regularly presents status reports on initiatives to theBoard of Directors, which monitors the progress of the initiatives.
Human Rights Due Diligence
The NEC Group conducts human rights due diligence based on this Policy and inaccordance with the following structure and processes under the UNGPs.

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a.

Impact assessment: The NEC Group conducts regular assessments and identifies
any actual or potential adverse human rights impacts that may occur either throughits own activities or as a result of its business relationships. Through theseassessments, the NEC Group identifies its salient human rights issues, and seeks toprevent and mitigate risks.

b.

Actions to prevent and mitigate adverse impacts: The NEC Group regularly
assesses any actual or potential impacts, and the results of the assessments areincorporated into the process of the NEC Group’s business activities to enableappropriate actions, including education and awareness training.

c.

Dialogue with stakeholders: In pursuing the initiatives set forth in this Policy, theNEC Group engages in regular dialogue with rights holders who might actually orpotentially be affected and other stakeholders including external experts.

d.

Information disclosure: The NEC Group regularly checks the progress of its
initiatives, promotes improvements, and discloses the results of its human rights due
diligence in a timely and appropriate manner.

Remedy and Grievance Mechanism
In the event of a violation or suspected violation of human rights, the NEC Group will
immediately and accurately investigate the facts and the causes of the incidents and strive
to take appropriate measures to resolve the matter.
The NEC Group has a whistleblowing system that allows stakeholders to report
information anonymously. The NEC Group will keep the identity of any whistleblower andthe content of any whistleblowing reports confidential. The NEC Group ensures thatwhistleblowers are protected effectively against unfair treatment or retaliation of any form.
Salient Human Rights Issues
The NEC Group, together with several external experts, including non-profit organizations
from the civil society sector, has identified the following four areas as our salient issues andreported them to the Board of Directors. The NEC Group will continue its efforts to addressthese issues.
1.

New technologies and human rights (AI and Human Rights):Information and communication technology (ICT) is evolving at an ever-increasing paceand poses a risk of causing human rights abuses that could not have been foreseen in thepast. The NEC Group formulated the “NEC Group AI and Human Rights Principles”, a setof guidelines in relation to the application and utilization of AI and biometrics data among
ICT. The NEC Group promotes initiatives in line with these principles.

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2.

Human rights risks related to geopolitical situations and conflicts:
The NEC Group identifies high-risk areas related to human rights on a regular basis andas appropriate, referring to indicators of international organizations and other third parties
and considering the opinions of external experts. The NEC Group works to prevent andmitigate the risk of being involved in human rights abuses in the high-risk areas.

3.

Labor in supply chains:
The NEC Group believes that collaboration and co-creation with its suppliers are essential
to creating social value. The NEC Group requests that its suppliers understandthe ”Guidelines for Responsible Business Conduct in Supply Chains” and take responsible
corporate actions in line with the guidelines. The NEC Group will continue to work with its
suppliers to resolve human rights issues related to labor in the supply chains.

4.

Employee safety and health:
The NEC Group strives to ensure the safety and health of its employees, maintain, andimprove a comfortable and employee-friendly workplace. We will not tolerate any form ofharassment including sexual harassment and foster a culture that recognizes diversity.
Referring to international standards, the NEC Group properly pays wages and manages
working hours in accordance with the laws and regulations of the relevant jurisdiction, andguarantees the right of employees to paid leave.
Supporting Policies
NEC Way
New technologies such as AI and Human Rights
AI and Human Rights Principles
NEC Privacy Policy
Quality and Safety Philosophy
Labor in the Supply Chain
NEC Group Procurement Policy
Guidelines for Responsible Business Conduct in Supply ChainsOccupational Health and Safety
NEC Group Safety and Health Policy
NEC Group Health Declaration
This is a translated version of the NEC Group Human Rights policy in Japanese.

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