Governance

Framework for Respect for Human Rights

NEC’s President oversees initiatives based on the NEC Way and the NEC Group Human Rights Policy. Furthermore, the corporate officer in charge of sustainability promotion presents status reports on initiatives aligned with the United Nations Guiding Principles on Business and Human Rights (UNGPs) to the Board of Directors, which monitors their progress.
NEC identifies salient human rights issues by continuously assessing actual or potential adverse impacts across the entire value chain. For each identified issue, a responsible corporate officer and relevant departments are assigned to advance human rights due diligence.
In addition, NEC has established grievance mechanisms for a wide range of stakeholders: all employees of the NEC Group (including contract employees), business partners, customers, and local residents.

NEC Way
Compliance (Whistleblowing System)

Thought Process

Our Approach to Respecting Human Rights

1. NEC Group Human Rights Policy

NEC established the NEC Group Human Rights Policy in 2015. Furthermore, in 2022, the policy was revised, and these revisions clearly show senior management’s commitment to respect for human rights as well as its governance system, as required by the UNGPs. The revision was approved by its President and reported to the Board of Directors in the same year. After the revision, the President issued a message to all NEC Group corporate officers and employees regarding the update to the human rights policy. In formulating the revised version of the policy, NEC held talks with a wide range of internal and external stakeholders, including labor unions, experts from the International Labour Organization (ILO), international NPOs, investors, and lawyers specializing in business and human rights.
This policy, as well as our initiatives to promote respect for human rights based on it, will be reviewed annually and updated or revised as necessary. In response to growing global expectations, NEC published a revised version in July 2026 that updated, among other things, its approach to employee working hours and wages.
The NEC Group Human Rights Policy applies to all corporate officers and employees of the NEC Group, including contract employees.
The NEC Group also encourages its suppliers, business partners, and customers to understand this policy and share our commitment to respect human rights. The policy elaborates the following principles:

• 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, social position, 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 groups¹ .

• 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 the development and provision of products and services that take into consideration human rights issues such as invasion of privacy and discrimination, the NEC Group aims not only to prevent and mitigate adverse impacts on society but also to maximize the social value that the NEC Group provides.

• 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, the NEC Group will seek ways to respect the principles of internationally recognized human rights.

  • International Bill of Human Rights consisting of the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights
  • The International Labour Organization (ILO) Core Labour Standards that consist of ten fundamental conventions in five categories: freedom of association and the effective recognition of the right to collective bargaining, the elimination of all forms of forced or compulsory labour, the effective abolition of child labour, the elimination of discrimination in respect of employment and occupation, a safe and healthy working environment
  • United Nations Guiding Principles on Business and Human Rights (UNGPs)
  • The Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct
  • International Labour Organization (ILO) Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy

1. People in vulnerable positions refers to women, children, people with disabilities, sexual minorities, unemployed persons, indigenous peoples, ethnic minorities, migrant workers, refugees, and others who are particularly susceptible to poverty, discrimination, and prejudice, and more likely to be adversely affected by environmental changes such as climate change.

NEC Group Human Rights Policy

2. Respect for the Rights of Children

NEC strives to prevent and mitigate adverse impacts of its products and services on children based on its support of the United Nations Convention on the Rights of the Child and the Children’s Rights and Business Principles² , which mention the rights of vulnerable children, in addition to the international standards embedded in the NEC Group Human Rights Policy.
In accordance with the Guidelines for Responsible Business Conduct in Supply Chains, NEC endeavors to abolish child labour from its supply chains and promote business activities and corporate citizenship activities that are based on consideration for human rights—including the rights of children.

2. Established by UNICEF, the UNGC, and Save the Children in 2012

Guidelines for Responsible Business Conduct in Supply Chains

3. Responding to the Modern Slavery Act

With approval from the Board of Directors, since fiscal year 2019, NEC Corporation, NEC Europe including NEC (UK) Ltd., NEC Software Solutions UK Limited, and Netcracker Technology EMEA Limited have published statements to the effect that they will report on measures related to the United Kingdom’s Modern Slavery Act 2015, which is aimed at preventing slave labour and human trafficking.

NEC Group Statement for Modern Slavery Acts

4. Procedures for Termination of Employment Contracts, Including Voluntary Retirement

If it becomes unavoidable to terminate an employment contract before its completion, NEC respects workers’ rights by engaging in good-faith discussions with workers and providing a reasonable and appropriate notice period.

Risk Management

Human Rights Due Diligence

1. Human Rights Impact Assessment

NEC has been conducting human rights impact assessments since fiscal year 2019 in order to further improve the effectiveness of its human rights due diligence. Since fiscal year 2020, it has also been promoting initiatives focused on salient human rights issues.

1.1. Process for Identifying Salient Human Rights Issues

• Fiscal Year 2019
  Together with Ernst & Young ShinNihon LLC, the Company conducted a quantitative human rights impact assessment for the NEC Group’s main businesses in accordance with the UNGPs.
• Fiscal Year 2020
  Based on the results of the fiscal year 2019 evaluation, the Company utilized the human rights risk data of international NPO Business for Social Responsibility (BSR) to compile a list of NEC’s human rights issues.
  Through dialogue with multiple external experts, including NPOs and other organizations in the social sector, NEC identified salient human rights issues: new technologies and human rights (AI and human rights); labour in supply chains; and employee health and safety. These were reported at a fiscal year 2021 meeting of the Board of Directors.
• Fiscal Year 2021
  BSR conducted interviews with 22 divisions, mainly business divisions, from a third-party perspective. These were conducted to confirm the specific details of issues including business activities, management systems, and workplace issues. The list of human rights issues was updated to better reflect the actual situation.
• Fiscal Year 2022
  Based on the fiscal year 2021 interviews, BSR conducted a gap analysis at the corporate level that compared practices at the NEC Group with the UNGPs and practices at leading global companies. This provided a visualization of issues within the NEC Group. NEC newly identified “human rights risks related to geopolitical situations and conflicts” as a salient human rights issue.
• Fiscal Year 2025
  To evaluate initiatives related to the salient human rights issue of employee health and safety and identify future challenges, BSR conducted a fact-finding survey of the NEC Group based on the UNGPs.
  
  For the four themes based on salient human rights issues below, initiatives are being promoted under the leadership of the respective corporate officers and relevant departments. Progress is reported to and discussed by the Risk Control and Compliance Committee as part of company-wide risk management. NEC engages in ongoing dialogue with stakeholders and discloses information in a timely and appropriate manner. Please refer to the linked pages for details on each initiative.
  
  (1) AI and Human Rights
  In executing its AI business, NEC has formulated company-wide regulations covering policies for the appropriate protection of basic human rights such as privacy, their structure, planning, implementation, inspection and revision. The Company is working to ensure the implementation and operation of these regulations.
  
  AI and Human Rights
  Personal Information Protection and Privacy
  
  (2) Human Rights Risks Related to Geopolitical Situations and Conflicts
  There is a risk that products and services could be used to violate human rights in conflict regions. For that reason, the Company identifies high-risk regions with respect to human rights based on the OECD States of Fragility 2025³ list, and it screens information of customers in those regions with regard to human rights and corruption, as well as confirming the intended use of products and services prior to engaging in transactions. NEC also reviews sanctions lists, which include organizations and individuals that are subject to human rights-related sanctions, of the United Nations, the U.S. Department of the Treasury’s Office of Foreign Assets Control, and other countries. The Company requires customers without a human rights policy to implement measures equivalent to the NEC Group Human Rights Policy through contracts or other means, thereby working to prevent human rights risks from arising.

3. OECD States of Fragility 2025: The OECD evaluates each country’s risk status and response capability across six dimensions: economic, environmental, political, security, societal, and human.

(3) Human Rights in Supply Chains
NEC is promoting activities with a risk-based approach, in accordance with the steps set out in OECD Due Diligence Guidance for Responsible Business Conduct.

Supply Chain Management

(4) Employee Safety and Health
The NEC Group, in line with international standards including the ILO Core Labour Standards, strives to ensure the safety and health of its employees, and to maintain and improve a comfortable and employee-friendly workplace.
The NEC Group appropriately manages working hours, strives to reduce excessive overtime, and guarantees employees’ rights to leave. In addition, the NEC Group complies with statutory minimum wages and endeavors to pay wages at a living wage level that exceeds such minimum standards. We will not tolerate any form of harassment including power harassment and sexual harassment and foster a culture of inclusion and diversity.

Occupational Health and Safety
Inclusion and Diversity

Stakeholder Engagement on Human Rights

1. Dialogue with Stakeholders

Please see the linked pages for further details on dialogue.

1.1. NEC Sustainability Advisory Committee
Since fiscal year 2022, the Sustainability Advisory Committee has been held at NEC Corporation for the CFO and the corporate officers in charge of sustainability management promotion. It conducts regular discussions with external sustainability experts. At committee meetings, Ms. Asako Nagai from Business for Social Responsibility (BSR) shares the latest trends regarding responses to human rights-related risks, and each participant shares their awareness of various issues before discussing response measures.

• 2nd meeting, May 2022: The Progress of Sustainability Promotion and Our Response to Human Rights Risks under Purpose-driven Management
• 6th meeting, Jun. 2024: Sustainability Strategies That Contribute to Corporate Value Enhancement
• 7th meeting, Mar. 2025: The Essence of Sustainability Management in an Era of Rapid Change
• 8th meeting, Sep. 2025: Sustainability-related Risks and Opportunities in NEC’s Sustainability Management

1.2. Engagement Related to AI and Human Rights
NEC has opportunities to engage with external experts at the NEC Digital Trust Advisory Council, whose members include lawyers and social sector representatives including international NPOs. The Company also maintains regular dialogue with the European Parliament and Japanese government agencies.

AI and Human Rights

1.3. Supplier Engagement
NEC promotes human rights due diligence through collaboration and co-creation with suppliers, using document checks and third- and second-party audits. In addition, to support sustainability initiatives among suppliers, NEC provides opportunities for human rights-related training and conducts awareness-raising activities.

Supply Chain Management

1.4. Engagement with Employees
To ensure health and safety and promote comfortable workplace environments, health and safety committee members selected by each division, labor union representatives, and employee representatives meet every month at health and safety committees to discuss new safety and health measures and health-related policies.

Inclusion and Diversity
Occupational Health and Safety

2. Participation in Initiatives on Human Rights

NEC participates in a variety of human rights initiatives. The Company uses the latest trends and case studies gained through these activities to improve and enhance its initiatives on global human rights issues.

• NEC Corporation and NEC Europe participate in the UN Global Compact Local Network Human Rights Due Diligence Working Group
• Joined The Valuable 500, an international initiative promoting the active participation of people with disabilities (2019–present)
• Member of BSR, which has extensive experience supporting global ICT companies in addressing human rights issues (2020–present)

Inclusion and Diversity

3. Human Rights Training and Awareness-Raising

NEC provides awareness-raising activities including training for all corporate officers and employees responsible for respect for human rights, in order to deepen their awareness in terms of respect for human rights and to promote their understanding of global trends on human rights issues. Please see the linked pages for further details.

3.1. Training for Employees
(1) Promoting Awareness of the Human Rights Policy and Business and Human Rights

• Web-based training is provided on business and human rights
• NEC Europe provides Sustainable Procurement e-learning

Occupational Health and Safety

(2) Inclusion and Diversity Awareness

• Development program for potential female managers
• Cross-industry networking events for women operated by four companies, including NEC
• Unconscious bias content provided in new employee training, mid-career hire training, new people manager training, and company-wide web-based training
• Web-based training on Inclusion and Diversity
• JobRainbow D&I Certification Level 3 as I&D training for seneior director-level employees and above
• One NEC Women’s Career Forum 2025, a career event for female employees at the assistant manager and staff (non-managerial) levels across the NEC Group

Inclusion and Diversity

3.2. Training for Suppliers

• Supplier Diversity Forum aimed at promoting diversity in the supply chain
• Information about seminars on “business and human rights” hosted by international organizations, governments, and industry associations provided through the supplier portal

Supply Chain Management

Grievance Mechanism

In light of international human rights principles, including the UNGPs, NEC respects the right to remedy and works to correct issues through appropriate responses based on prompt and accurate investigations into the causes whenever human rights violations or risks of violations arise. The Company has whistleblowing systems that allow stakeholders to report information anonymously. It will keep the identity of any whistleblower and the content of any whistleblowing report confidential. The Company ensures that whistleblowers are protected against unfair treatment or retaliation in any form. Aside from NEC Group employees, these systems serve as contact points for a multitude of stakeholders, including business partners, customers, and local communities.
To further strengthen the grievance mechanism, NEC has participated in the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) since its planning stage, a cross-industry initiative launched by the Japan Electronics and Information Technology Industries Association (JEITA) and the Business and Human Rights Lawyers Network (BHRL), an association of lawyers.

1. NEC Compliance & Integrity Hotline

In October 2024, we launched the NEC Compliance & Integrity Hotline, a whistleblowing system using NAVEX’s third-party reporting system, to accept reports from employees of NEC Corporation and its business partners.
The hotline consolidates multiple domestic and international reporting channels that previously existed in order to improve convenience for whistleblowers. Through centralized management of whistleblowing information, NEC is working to enhance Group governance and standardize the quality of responses to reports. During fiscal year 2026, the scope was expanded to cover all consolidated subsidiaries in and outside Japan and their business partners.
Measures to protect whistleblowers are in place, and anonymous reporting is also supported.

Please see below for more details.

Compliance (Whistleblowing System)
Supply Chain Management

2. Customer Communication Center for Customers and Local Residents

NEC collects human rights-related reports from customers and residents of local communities through the NEC Customer Communication Center.

NEC Customer Communication Center
Customer Relationship Management

3. Whistleblowing Systems’ Operational Status

In fiscal year 2026, a total of 325 cases were reported to the NEC Compliance & Integrity Hotline, including harassment, human relations, and work environment-related cases.
Relevant divisions work together to resolve the contents of consultations to the hotline, which are also reported to the Risk Control and Compliance Committee for the ongoing enhancement of awareness so as to prevent recurrence.
In fiscal year 2026, no reports related to forced labour or human trafficking were made to the NEC Compliance & Integrity Hotline, the Customer Communication Center, or through JaCER concerning human rights issues.

Number of hotline consultations and reports (Data Collection)

Metrics and Targets

FY2027 Goals

1. Review of the NEC Group Human Rights Policy in Line with the UNGPs

2. Promotion of Human Rights Due Diligence

• Establishment of human rights due diligence regulations
• Human rights risks associated with geopolitical conditions and the impact of conflict: Continue customer due diligence
• Periodic review of salient human rights issues

Inclusion and Diversity
Occupational Health and Safety
AI and Human Rights
Supply Chain Management

3. Increase Awareness of the NEC Compliance & Integrity Hotline

FY2026 Goals

1. Promotion of Employee Understanding of the Latest Developments in Global Human Rights

• For employees of NEC Corporation and its consolidated subsidiaries in Japan (including dispatched workers and contract employees): Continue to hold web-based training on business and human rights (Target completion rate: 96%)

2. Promotion of Human Rights Due Diligence

• Regular review of the NEC Group Human Rights Policy in line with the UNGPs and further penetration within the NEC Group (Target completion rate: 80%)
• Conduct in-house awareness events on the theme of human rights in conjunction with NEC Compliance Day
• Human rights risks associated with geopolitical conditions and the impact of conflict: Continue customer due diligence
• Periodic review of salient human rights issues

3. Increase Awareness of the NEC Compliance & Integrity Hotline

FY2026 Results

1. Promotion of Employee Understanding of the Latest Developments in Global Human Rights

• For employees of NEC Corporation and its consolidated subsidiaries in Japan (including dispatched workers and contract employees): Held web-based training on business and human rights with a completion rate of 90.9%

2. Promotion of Human Rights Due Diligence

• Regular review of the NEC Group Human Rights Policy in line with the UNGPs and further penetration within the Group (Completion rate: 90.9%)
• Human rights risks associated with geopolitical conditions and the impact of conflict: Continue customer due diligence
• Periodic review of salient human rights issues

3. Increase Awareness of the NEC Compliance & Integrity Hotline