Governance

Occupational Health and Safety Framework

Our General Affairs Department formulates Occupational Health & Safety (OH&S) Policy Action Guidelines, annual targets, and key initiatives for the NEC Group. In promoting these initiatives and with the goal of realizing these targets and measures, NEC Corporation develops and implements specific measures at each business site and consolidated subsidiaries in Japan and manages progress through internal audits and management reviews. In addition, health and safety committees or health committees (hereinafter, “health and safety committees, etc.”) meet each month in line with laws and regulations to ensure health and safety and maintain safe, healthy, and supportive workplaces. Committee members include health and safety committee representatives, labor union representatives, employee representatives, occupational health professionals, and registered nurses. They share information on the status of labour accidents and the targets for each fiscal year. They also discuss new health and safety countermeasures and health-related measures,among other matters.
In promoting anti-harassment measures for NEC Group employees, a dedicated team within the Employee Relations Department is working with the Corporate Legal Department and other departments to foster an organizational culture of ethical standards, and is striving for early detection, early resolution, and the development of measures to prevent recurrence, as well as working to prevent problems from occurring in the first place. The status of initiatives is reported to the Risk Control and Compliance Committee chaired by the CRCO for discussion.

Strategy

The Company is working to secure, maintain, and improve a working environment where people can work safely and healthily as a foundation for realizing its Purpose. To promote these efforts, we have established the NEC Group Safety and Health Policy. This policy, which was formulated based on dialogue with the labor union and approved by the Chief Human Resources Officer (CHRO), the executive officer in charge, applies not only to NEC Group corporate officers and employees, but also to business partners and any other parties whose health and safety should be considered, in an effort to foster a culture of safe and healthy work. In addition, the action guidelines under this policy stipulate that the company and employees shall actively consult with each other and that employees’ opinions shall be heard for the smooth operation of the business and improvement of the employees’ lives.

Furthermore, we have established the Occupational Health & Safety Management Regulations with the aim of enhancing the quality of our health and safety activities, and have established the NEC Group Occupational Health and Safety Management System. We also conduct related risk assessment and monitoring, as well as preventive measures and countermeasures. In the wider NEC Group, NEC Solutions (China) Co., Ltd., NEC (UK) Ltd.,NEC Australia Pty Ltd, NEC Iberica S.L., NEC Nederland B.V., Networks & System Integration Saudi Arabia Co. Ltd.,and PT NEC Indonesia have acquired ISO 45001 certification.
In addition, in 2023, the Company established the Harassment and Discrimination Prevention Regulations, which define prohibited harassment and discrimination and clarify its policy of taking strict action against violators. Furthermore, we strive to prevent harassment and discrimination by making these regulations known to all employees and taking necessary measures and actions.

The NEC Group listens carefully to the opinions and requests of customers, business partners, and other stakeholdersinvolved in the NEC Group’s business activities, and strives to maximize the value it provides.
At the same time, conduct that exceeds reasonable and socially acceptable standards may harm the working environment of employees and affect the stable and continuous provision of services.
To protect the safety, rights, and dignity of its employees, the NEC Group will respond appropriately to customer harassment as an organization.

Basic Policy on Customer Harassment

Information regarding ensuring the soundness of construction projects is provided below.

Quality and Safety (Construction Work Project Management)

Risks and Opportunities in Occupational Health and Safety

Based on the results of a corporate-level employee-related impact assessment conducted by BSR in fiscal year 2026,NEC identified the key risks and opportunities associated with occupational health and safety during the period covered by the Mid-term Management Plan 2030.

“Ensuring Employee Safety and Health Promotion (Employee Safety and Health)”

1. Impact on the Environment and Society

1.1. Negative Impact

• Illness and workplace accidents caused by long working hours of employees, including dispatched workers
• Resignations due to harassment and declining workplace morale

2. Financial Risks and Opportunities

2.1. Risks
We have been addressing this as a priority risk since the Mid-term Management Plan 2025 period, and while the likelihood of large-scale risk occurrence is low, reputational risk can be assumed if human rights violations are caused.

Materiality during the Mid-term Management Plan 2025 period is as follows:

“Diverse Human Resource Development and Cultural Transformation”

1. Risks

• Long working hours
• Harassment

2. Opportunities

• Greater organizational strength through improved employee engagement

Risk Management

Evaluation and Identification of Occupational Health and Safety Risks

Every year, the Company evaluates the risks of our facilities and equipment based on the NEC Group Occupational Health and Safety Management System. In addition, every month, industrial physicians and the labor union conduct workplace patrols, exchange opinions with workplace representatives, and gather information through listening to opinions to identify risks. Also, important matters such as a major disaster or pandemic are handled by the Business Continuity and Disaster Recovery Headquarters attended by executives, such as NEC’s President or directors. The headquarters decides on important themes each year, reviews the flow for countermeasures, and conducts drills. (See our response to the pandemic in the section on “Risk Management (Crisis Management and Business Continuity)”.)

Risk Management (Crisis Management / Business Continuity)

Risk Management in Occupational Health and Safety

NEC’s General Affairs Department oversees risk management for NEC Corporation as a whole, while the Regional Affairs Department oversees risk management for each region. The General Affairs Department’s internal organization,the Regional Affairs Department, serves as the coordinating office for day-to-day occupational health and safety operations and initiatives. Specifically, the Regional Affairs Department holds health and safety committee meetings,etc. in each region and communicates details of their discussions and deliberations internally. It also receives inquiries from a wide range of employees and organizations as the internal contact desk, leading to improvements.
We provide a channel for exchanging information with subsidiaries outside Japan to share safety confirmation information during disasters.

Initiatives to Optimize Working Hours

The Company aims to maximize team performance and enhance the ability to execute strategies by creating a work environment where each employee can work in good mental and physical condition and be healthy and energetic. Therefore, we have positioned the constant long working hours as an important risk theme and are overseeing risk management to optimize working hours.

• Improving work literacy by issuing Work Style Guidelines and a Work Rule Hand Book that outlines the duties and rules that the company and employees must fulfill in order to properly manage work and health, as well as by conducting web-based training
• Labour management training for people managers
• Promoting proper understanding of working hours through visualization of PC operation status and linkage with work management systems
• Supporting the practice of appropriate management by visualizing workload status through an attendance-status dashboard
• Sending out alert emails and displaying PC pop-up messages reminding workers of overtime and holiday work
• Establishing and operating a monitoring process for organizations and individuals who are found to be working long hours in order to understand the causes of high workloads and implement measures to eliminate them

Status of and Measures for Labour Accidents and Disasters

Labour accidents at NEC Corporation and its consolidated subsidiaries in Japan are mostly minor, such as tripping on stairs at train stations or falling on the street during business trips or sales calls. When a labour accident occurs, the person responsible for monitoring labour accidents checks on the status of the person or persons affected by the accident, determines the cause, and implements measures to prevent a recurrence as needed, as laid out in the Company’s escalation rules. Furthermore, even for minor labour accidents such as tripping or falling, the details and countermeasures are shared throughout the Company via health and safety committees, the intranet, and other means. We strive to prevent labour accidents that could be caused by natural disasters, for example, calling on employees to remain at home or to return home early if a typhoon or heavy snowfall is forecast.
In fiscal year 2026, we have not identified any instances of serious labour accidents or serious violations of laws and regulations from related organizations.

Indicators for Occupational Health and Safety (Data Collection)

Training and Awareness-Raising for Occupational Health and Safety

Occupational health and safety trainings and training completion rates are as follows.

Training and Awareness-Raising for Occupational Health and Safety (Data Collection)

Risk Management Related to Human Rights

1. Evaluation, Identification, Training and Awareness-Raising of Harassment Risks

The Company uses a questionnaire from a web-based training program conducted for all employees on the topics of compliance and business and human rights to identify risks of harassment in the workplace. Workplaces considered to be of high risk are reported to the CHRO and CRCO, and follow-up measures to prevent recurrence are conducted through face-to-face training to stop harassment from occurring in the first place.

Trainings on harassment are as follows.

In addition, NEC uses internal digital signage to clearly communicate appropriate and inappropriate behaviors related to harassment prevention, helping to raise employee awareness and foster a healthy and respectful workplace culture.

Implementation rate of human rights assessments (Data Collection)

2. Conducting Human Rights Due Diligence Across NEC Group companies

The NEC Group has identified “employee safety and health” as one of its salient human rights issues based on the human rights impact assessment with reference to the United Nations Guiding Principles on Business and Human Rights, and the CHRO is responsible for addressing this issue. Recognizing that employees are also stakeholders in the value chain, we conduct periodic annual written surveys of labour practices and the status of health and safety initiatives at our sub-subsidiaries in Japan and overseas. Survey items are developed with reference to JEITA’s Responsible Business Conduct Guidelines and the Responsible Business Alliance (RBA) Code of Conduct. In the fiscal year 2026 survey, we have confirmed that there are no significant risks across all companies surveyed, including confirmation that there is no child labour, that workers are at least 18 years old when hired, and that even if workers under 18 years old are hired, they are not involved in abuse or hazardous work.

• Number of companies surveyed: 48 in Japan and 49 overseas
• Employee coverage rate through document survey: Approx. 74.9%

3. Implementation of Business and Human Rights Training

We provide web-based Business and Human Rights training in both Japanese and English to promote awareness of human rights in business activities and strengthen efforts to prevent harassment.
In the post-training questionnaire for fiscal year 2025, 35.2% of the respondents answered that they were aware of the NEC Group Human Rights Policy but had never read it, so we improved the training content to ensure the policy is known to all employees in fiscal year 2026.

4. Participation in Initiatives on Occupational Safety and Human Rights

• NEC Corporation has continuously participated in the Human Rights Due Diligence (HRDD) Working Group and the Supply Chain Working Group organized by the Global Compact Network Japan since fiscal year 2015.
• Participated in the “Professional Development Program for In-house Specialists on Respect for International Human Rights and Labour Standards” jointly organized by the United Nations Global Compact Network Japan and the ILO in fiscal year 2025.

Employee Engagement

1. One NEC Survey

To realize our Purpose, we are promoting the transformation into strong individuals and organizations that continue to evolve, in which each employee continues to take on the challenge of self-transformation and the organization rapidly creates value. Under Mid-term Management Plan 2025, we promoted initiatives with a target engagement score of 50%. Looking ahead to 2030, we aim to enhance corporate value through employee growth and ambition, and have set a goal of achieving a high level of engagement at the Global Top Tier (top 25th percentile). As part of this effort, we conduct the global One NEC Survey once a year for all employees both in and outside Japan.
The survey includes items on Strive (employees’ desire to contribute proactively), employees’ sense of accomplishment through work, their connection to the Company’s Purpose and goals, and well-being-related and work-related stress items. Through this survey, we quantitatively assess the organization’s state and work to improve it based on employees’ feedback.

Employee engagement index (Data Collection)

Response to Serious Global Health and Safety Issues

1. Infection Countermeasures

At the Company and our 24 consolidated subsidiaries in Japan, we have set up a consultation desk for health issues (including infectious diseases) at the Wellness Promotion Center. In addition, we provide notifications regarding infection prevention on the intranet and education and awareness through web-based training on health and safety and working styles, and provide financial assistance for seasonal influenza vaccinations and various other types of vaccination as part of infection prevention measures.
When employees are sent on assignment outside Japan, we make them aware of the need to be mindful of and receive vaccinations for infectious diseases that are common in the local area, such as tuberculosis and malaria, which must be reported. In addition, we pay careful attention to employees’ health management during transit and after their return to Japan.

Metrics and Targets

FY2031 KPIs

(Scope: NEC Corporation unless otherwise specified, Period: April 2026 to March 2031)
M: Indicates the main non-financial targets related to materiality.

M: Target engagement score for FY2027: 50%

FY2027 Goals

• Implementation rate of health assurance measures for employees who worked long hours: 100%
• Follow-up rate for individuals with health concerns based on periodic health checkups and stress check results: 100%

FY2026 Goals and Results

1. FY2026 Goals

1.1. Maintain Occupational Health and Safety Levels in a Diverse Work Environment

• Enhance understanding of training on workstyle rules and health and safety (90% or more)
• Continue to conduct self-assessment checks of working practices and health and safety for NEC Group employees.
• Continue to monitor (once a year) and follow up on the Group’s global health and safety activity status
• Strengthen measures to combat excessive work for employees of NEC Corporation and its consolidated subsidiaries in Japan
• Strengthen governance by activating communication with Group companies
• Promote the NEC Group Occupational Health and Safety Management System

2. FY2026 Results

2.1. Maintain Occupational Health and Safety Levels in a Diverse Work Environment

• Enhanced understanding of training on workstyle rules and health and safety: 99.6%. Conducted a self-check on working style within training
• Based on RBA standards, conducted a written survey on labour practices and health and safety of the NEC Group: 48 in Japan and 49 overseas
• Monitored employees with long working hours who pose health-risk concerns, considered improvement measures to eliminate long working hours, and followed up accordingly.
• For combined factors of long working hours, high health risk, and harassment, strengthened collaboration with relevant organizations and promoted risk elimination activities
• Held semiannual meetings (September and February) for consolidated subsidiaries in Japan to promote the NEC Group Occupational Health and Safety Management System and also conducted exchanges of opinions with occupational safety and health personnel, etc., of each company. In addition, newly built a shared portal site for occupational safety and health personnel and health managers/health promoters, improving communication infrastructure across the Group.
• Incorporated ISO 45001 elements into the NEC Group Occupational Health and Safety Management System and applied it to NEC Corporation and consolidated subsidiaries in Japan (application will begin in FY2027)