Respect for Human Rights

Basic Approach

Top Message

In December 2017, the Nabtesco Group formulated the Nabtesco Group Human Rights Policy (hereinafter, "the Policy") based on the United Nations (UN) Guiding Principles on Business and Human Rights. While we had been implementing measures to respect human rights based on the Nabtesco Group Code of Ethics, we revised the Policy on June 1, 2021 with reference to international guidelines in order to respond to changing and growing social needs. Subsequently, on April 1, 2022, we revised the Policy again, following the revision of the Nabtesco Group Code of Ethics.

In recent years, respect for human rights in corporate activities has been attracting attention, and companies are playing an important role in human rights initiatives in business. The Nabtesco Group will invest a certain amount of financial resources to fulfill one of our targets pledged in the Medium-Term Management Plan, "Focus on Solving ESG Issues," thereby simultaneously delivering greater value to society and increasing our corporate value. We will continue to respect human rights as a corporate social responsibility.

This policy applies to all officers and employees of Nabtesco Group. The Nabtesco Group will also continuously work to increase its suppliers' and other business partners' understanding of this policy to promote respect for human rights in collaboration with them.

Representative Director,
President and CEO

Kazumasa Kimura

Human Rights Policy

Respecting human rights in all aspects of corporate activities is the basis of Corporate Social Responsibility (CSR). Nabtesco promote the respect of human rights, based on the International Bill of Human Rights established by the United Nations (UN), the ILO Declaration on Fundamental Principles and Rights at Work established by the International Labour Organization (ILO), and the UN Guiding Principles on Business and Human Rights.

In the "Nabtesco Group Code of Ethics," "respect for human rights" includes "support for international norms regarding human rights," "respect for diversity consisting of diverse cultures and values," "no child labor or forced labor," and these We have declared that we will thoroughly inform our employees and monitor the status of compliance.

In the Nabtesco Group Human Rights Policy, we commit to respecting basic human rights and ensuring that no form of discrimination based on race, skin color, belief, creed, religion, nationality, ethnicity, birthplace, gender, age, disability, gender identity, sexual orientation, marital status, family structure, social status, employment status or other factors; no form of harassment or bullying; nor any other act that may undermine personal dignity is conducted, permitted or tolerated. In particular, we have specifically demonstrates in the Nabtesco Group Human Rights Policy that clearly demonstrates our commitment to respect children's rights and to prohibit and not to use child labor and forced labor.

The Nabtesco Group Code of Ethics and Human Rights Policy are applied to the Group's business partners. We confirm labor management and compliance of our business partners prior to business transactions.

In particular, when trading with our suppliers, we request them to comply with the Nabtesco Group CSR-Oriented Procurement Policy as well as our Code of Ethics and Human Rights Policy. In addition, we check their human rights consideration in the SAQ survey on CSR-oriented procurement once a year.

Since FY2014, Nabtesco has been striving to create a sustainable society as a signatory of the United Nations Global Compact and as a supporter of the Universal Declaration of Human Rights.

Logo

Policy

Nabtesco Group Human Rights Policy

Nabtesco Corporation has established this Nabtesco Group Human Rights Policy as follows for the purpose of ensuring that all officers and employees of Nabtesco Corporation and its group companies (collectively, the "Nabtesco Group") act to promote respect for human rights.

1.Positioning and scope

This Policy, together with the Nabtesco Group CSR-Oriented Procurement Policy, complements the Nabtesco Group Code of Ethics. This policy applies to all officers and employees of Nabtesco Group.
The Nabtesco Group will also continuously work to increase its suppliers' and other business partners' understanding of this policy to promote respect for human rights in collaboration with them.

2.International Rules Concerning Respect for Human Rights

The Nabtesco Group is committed to pursuing efforts to promote respect for human rights in accordance with the spirit indicated in the International Bill of Human Rights established by the United Nations (UN), the ILO Declaration on Fundamental Principles and Rights at Work established by the International Labour Organization (ILO), and all other international rules concerning human rights, as well as in conformity with applicable international guidelines including the UN Guiding Principles on Business and Human Rights.

3.Responsibility to Respect Human Rights

The Nabtesco Group respects human rights in every respect in the context of its business activities. In the event that any of our business activities, including our products and services, has a negative impact on human rights, we will carry out appropriate responses for correction, thereby fulfilling our responsibility regarding respect for human rights.
The Nabtesco Group complies with human rights and labor laws of all relevant nations and makes efforts to ensure the safety and security of individuals and to avoid infringing upon human rights.

  1. (1)Prohibition of discrimination
    Discrimination based on race, skin color, belief, creed, religion, nationality, ethnicity, birthplace, gender, age, disability, gender identity, sexual orientation, marital status, family structure, social status, employment status or other factors will not be tolerated, nor will any act that undermines individual dignity in any other way.
    Also, we will provide all workers with fair and equal opportunities with regard to employment, training, promotion and compensation.
  2. (2)Prohibition of forced labor
    We will prohibit forced labor, compulsory labor, prison labor, labor by slavery and human trafficking and bonded labor, and we will not use any of these forms of labor. Based on the recognition that all labor should be voluntary, we will guarantee the freedom of workers to quit working for our company or terminate employment agreements with the company.
    Also, unless legally mandated, we will not retain, destroy, hide or confiscate workers' identity documents, passports, work permits, immigration applications and others, and we will not reject the use of these documents by the workers themselves.
  3. (3)Prohibition of child labor
    We respect children's rights. We will prohibit the labor and employment of workers aged younger than the legal working age set in each country and region where we operate and we will not use such workers.
    Whatever the case may be, we will not make young workers who have not reached the age of 18 work at night or overtime or engage in jobs that pose a threat to their health and safety.
    • *Children: Those younger than the legal working age
    • *Young workers: Those who have reached the legal working age and are younger than 24 years old
  4. (4)Prohibition of inhumane treatment
    We will prohibit the inhumane treatment of workers, including mental, physical and sexual abuse, corporal punishment and any type of bullying or harassment.
  5. (5)Wages and welfare
    We will comply with the laws and regulations on wages and others set in each country and region where we operate, including those on minimum wages, overtime wages and equal pay for equal work. Also, we will strive to pay living wages to workers and provide them with welfare benefits as mandated by laws and regulations.
  6. (6)Working hours and holidays
    We will strive to reduce overtime work and comply with the laws and regulations applied to working hours, break time, holidays and vacations in each country and region where we operate.
  7. (7)Freedom of association and collective bargaining
    We will respect workers' rights to form and participate in a labor union and to participate in collective bargaining and peaceful meetings.
    Also, we will provide workers with opportunities and environments to enable them to engage in dialogue with the management team about working conditions and business practices without fear of becoming subject to discrimination, revenge, threats, harassment and others.
  8. (8)Occupational health and safety
    We will comply with occupational health- and safety-related laws and regulations set in each country and region where we operate, toward building a safe, secure and healthy workplace environment.
  9. (9)Respect for local culture and customs and social contribution
    We will respect the culture and customs of each region and community where we operate.
    Also, we will engage in dialogue with local communities and society at large and conduct social contribution activities, volunteer activities, educational activities and local employment activities.

4.Human Rights Due Diligence

The Nabtesco Group carries out a human rights due diligence process to identify and assess its impacts on human rights and endeavors to mitigate human rights risks. In order to address impacts on or risks to human rights, we will also verify our human rights due diligence process and the effectiveness thereof on an ongoing basis.

5.Efforts to Address Human Rights Issues with Stakeholders

The Nabtesco Group will continuously work to increase its suppliers' and other business partners' understanding of this policy to promote respect for human rights in collaboration with them.

The Nabtesco Group respects the human rights of all of its officers and employees, treats each of them in a non-discriminatory manner and ensures impartiality in the context of employment, performance evaluation and all other aspects of human resources management, and develops a safe and secure work environment.

The Nabtesco Group will endeavor to keep shareholders and investors adequately informed of this Policy and the Nabtesco Group's various efforts to respect human rights.

The Nabtesco Group acknowledges that its business activities may affect regional communities in some way and thus endeavors to identify and assess human rights risks.

6.Reporting and Disclosure

The Nabtesco Group's efforts to respect human rights will be publicly disclosed in the form of an integrated report or in some other appropriate way.

7.Redress and Remedy

If any infringement of human rights caused directly or indirectly by the Nabtesco Group's business activities is recognized, the Nabtesco Group will promptly take steps to provide redress and remedy.

8.Introduction, Prevalence and Education

To ensure that this Policy is properly understood and reflected in business activities, the Nabtesco Group will provide education and training to all of its officers, employees and other personnel.

System

Human Rights Monitoring System

The Nabtesco Group's human rights promotion initiatives are headed by the Officer in Charge of Personnel Affairs and are organized mainly by the Personnel and Procurement Management Departments. More specifically, the Group establishes and revises human rights policies, constructs a system for human rights due diligence, identifies human rights risks that its business activities may pose on stakeholders, plans and takes mitigation and corrective actions, and discloses information about progress in the above activities. At the same time, human rights awareness-building activities are carried out for directors, officers and employees of the Group mainly by the Legal Affairs & Compliance Department, which implements compliance-related education and information provision programs, including those concerning human rights promotion, both inside and outside Japan by creating multiple language versions of the Nabtesco Group Code of Ethics and Handbook. A report on human rights-related issues and activities is submitted to the Management Committee each year after deliberations by the Management Materiality Committee.

Measures

Human Rights Due Diligence

We perform human rights due diligence in order to identify human rights risks associated with our business activities, and identify and assess its impact on human rights with the goal of controlling human rights risks. We also continuously verify the process itself and its effects of human rights due diligence in order to respond effectively to human rights impacts and risks.

Human Rights Due Diligence Process

Human Rights Due Diligence Process

Nabtesco's Human Rights due Diligence

Conducting Assessment of the Nabtesco Group

The human rights due diligence for the Nabtesco Group consist of the following four steps.

Step1:
Identify human rights issues that are deemed material in Nabtesco's business in light of international guiding principles on human rights and labor standards* as well as on the Nabtesco Group Human Rights Policy, and then create a survey form on human rights-related risks.
Step2:
Conduct a survey on human rights-related risks targeting all Group companies within and outside Japan.
Step3:
Check the details of the survey forms on human rights-related risks submitted by Group companies and conduct a follow-up survey for the bases for which it is revealed through the survey that there are some human rights-related concerns and issues to be checked.
Step4:
Conduct the follow-up survey, and then in cooperation with the related departments as required, give instructions to the bases (excluding those for which no problems have been identified in the survey) so that they will take necessary corrective actions.

*The International Bill of Human Rights established by the United Nations (UN), the ILO Declaration on Fundamental Principles and Rights at Work established by the International Labour Organization (ILO), and the UN Guiding Principles on Business and Human Rights.

Survey on human rights risks

Survey period June-July 2024
Survey targets 52 group companies (100% coverage rate for number of employees)
Survey method Questionnaire on human rights risks
Survey content 56 items regarding eight topics (i.e. management system, employment discrimination, juvenile labor, forced labor, working conditions, freedom of association, collective bargaining right, occupational health and safety and local communities)

* Added items identified as potential human rights risks (namely, young workers, migrant workers, human trafficking, equal remuneration) from the 2024 investigation.

Survey results No immediate and material risks found either at home or abroad
Result reporting Survey results were reported to executives at a meeting.

Human Rights Issues Identified as the Targets of the Human Rights Risk Survey

Human rights issues identified as the targets of the human rights risk survey Stakeholders with particularly strong relevance Reasons why identified human rights issues are deemed material
Management system
  • :Group employees
  • :Business partners
  • :The human rights management system may not be in place
  • :Risk associated with the lack of awareness and understanding of human rights (i.e., potential complicity in human rights violations in countries and regions where there is a gap between local laws, customs and international standards)
Employment discrimination
  • :Group employees
  • :Business partners
  • :Risk of discrimination against race, sexgender, nationality, religion, etc.
  • :Risk of harassment (sexual harassment and power harassment)
Child labor
  • :Group employees
  • :Business partners
  • :Risk of child employment in supply chains in developing countries
Forced labor
  • :Group employees
  • :Business partners
  • :Risk that foreign workers will be required to keep their identification cards in employment
  • :Long working hours due to excessive quotas may become de facto forced labor
Labor conditions
  • :Group employees
  • :Business partners
  • :Risk of not paying adequate wages for work
  • :Risk of improper management of working hours
Freedom of association
and collective bargaining right
  • :Group employees
  • :Business partners
  • :Possible lack of dialogue and communication with representatives of workers and labor unions, etc.
Labor safety and health
  • :Group employees
  • :Business partners
  • :Possibility that safety and health are not secured
  • :Risk of occupational accidents involving death or serious injury at manufacturing sites
Local communities
  • :Business partners
  • :Local inhabitants
  • :Possible failure to implement measures to achieve sustainable development with local communities

As for the human rights risk survey conducted in 2022, we conducted follow-up investigations based on the results of the survey in 2023. A follow-up investigation to the 2024 human rights risk survey will be conducted in 2025.

The Nabtesco Group's Human Rights Due Diligence (History)

2017
Conducted a country risk survey targeting countries in which the Nabtesco Group has its bases. As a result, bases in India, China, Thailand and some other countries were categorized into bases in high-risk countries based on the data provided by Verisk Maplecroft.
2018
Conducted the human rights survey (A) mainly targeting 41 Group companies located in the countries that had been categorized into high-risk countries in the country risk survey.
2020
Conducted the human rights survey (B) on the 13 Group companies in Europe, Singapore and some other regions that had not been surveyed in the 2018 survey.((A)+(B)= Employee coverage rate of 100%)
As a result, we detected no serious risks or incompliance with local laws and regulations or with international norms for both (A) and (B).
2020
Conducted a follow-up survey targeting the 41 bases in high-risk countries that had been surveyed in 2018 in the human rights survey (A) and the remaining 13 companies surveyed in the human rights survey (B) in 2020.
2022
Conducted a survey targeting all 53 Group companies in Japan and abroad (with the employee coverage rate reaching 100%).
2023
Conducted follow-up surveys for the items of concern that had been identified based on the results of the human rights risk survey conducted in 2022.
2024
Conducted a survey targeting all 52 Group companies in Japan and abroad (with the employee coverage rate reaching 100%).

Follow-Up Surveys and Corrective Actions
Measures to Reduce Human Rights-Related Risks

Nabtesco will remain diligent in implementing improvement measures and follow-up investigations, seeking to mitigate its human rights risks. According to the detailed analysis of the human rights risk survey results, we detected no serious risks or incompliance with local laws or regulations or international norms that required urgent attention. However, the analysis results caused us to have the following concerns about human rights, and in response we implemented measures as detailed below.

Implementation period July 2023
Number of bases for which we have concerns (about human rights-related risks) 12 bases
Number of risks 14
Follow-up surveys and corrective actions
  1. 1.Found out the answers that were negative or implied uncertainties through the detailed analysis of the human rights survey results.
  2. 2.Conducted a follow-up survey on each of the bases that had submitted such answers to check the current situation.
  3. 3.Received answers from all the bases.
  4. 4.Of them, 12 bases were revealed to face problems.
  5. 5.Gave instructions on necessary corrective actions for the items of concern.

Concerns and corrective actions

  Concerns Corrective actions
1 Safety and health risk assessments are not conducted on a regular basis. Gave instructions to urge the bases to create the management criteria for the risk assessment, implement preventive measures against the occurrence of occupational accidents and conduct the risk assessment on a regular basis.
2 Evacuation drills against fires are not conducted on a regular basis Gave instructions to urge the bases to make employees aware of the evacuation route and conduct the drill on a regular basis.
3 Failure to manage working hours Gave instructions to urge the bases to help employees acquire multiple skills to share roles for more effective use of their working hours and reduce employees' working hours by measures such as giving necessary advice and make necessary reports on their working hours at monthly meetings.
4 Failure to provide employees with necessary education Gave instructions to urge the bases to provide employees with necessary education through e-learning.
5 Others Gave instructions to urge the bases to establish a safety and health environment at each of their facilities.

Survey on the Acceptance and Treatment of Foreign Technical Intern Trainees

In light of the fact that multiple cases of human rights violations have been reported regarding foreign nationals working as technical intern trainees in Japan, we conducted a survey on the acceptance and treatment of foreign technical intern trainees at Nabtesco Group companies in Japan. As a result, it was confirmed that one Group company had accepted foreign technical intern trainees and had been treating them in an appropriate manner. By conducing this survey on a regular basis, we will monitor for any issues regarding the human rights of foreign technical intern trainees accepted by the Group and if an issue is identified we will work to mitigate any negative impacts on the human rights of the trainees.

We have prepared the statement of our corporate philosophy, employment agreement and the manual on the use of the company's dormitory in the mother language of the foreign technical intern trainees working at our facilities and are supporting them in working and living in Japan, including providing them with financial support to sit for Japanese language examinations and assisting them with daily life matters. We also made it possible to employ foreign nationals having skills suitable for long-term employment with the status of residence of "specified skilled worker" and have already employed some individuals with that status of residence.

In November 2022, in order to make further improvements regarding our acceptance and treatment of foreign workers including technical intern trainees, we joined the Japan Platform for Migrant Workers towards Responsible and Inclusive Society (JP-MIRAI), which was established with the Japan International Cooperation Agency (JICA) and others serving as the secretariat. We will continue to improve and enhance our measures to protect the human rights of foreign nationals working as technical intern trainees in Japan.

Survey period June 2024
Survey target 12 Nabtesco Group companies in Japan
Survey purpose Examine the situation regarding the acceptance and treatment of foreign technical intern trainees by the Nabtesco Group
Survey method Questionnaire survey conducted using a survey form on the acceptance and treatment of foreign technical intern trainees
Evaluation method Self-evaluation on 32 items under a total of seven themes (living environment, housing, working environment, occupational health and safety, working conditions, forced labor, and others)
Response (1) Number of respondents: 12 companies;
(2) Number of companies that have accepted foreign nationals as technical intern trainees: One;
(3) Number of trainees accepted by the company: 143
Results Based on the survey results, it was confirmed that technical intern trainees had been treated appropriately by the company accepting them.
As for the requests made by the trainees (such as for the provision of a place and equipment in which to keep their belongings), we have already met them. In line with the guidelines, corrective recommendations and advice given for the implementation of the foreign technical intern trainee system, we will continue to improve and enhance our measures to protect the human rights of the trainees.
Result reporting Survey results were reported to executives at a meeting.

Conducting Assessment of Suppliers

Nabtesco has conducted the SAQ* (CSR questionnaire) survey every year since FY2014 to identify human rights risks among its suppliers. Furthermore, the company conducts interviews (second-party assessments) with high-volume suppliers who have low human rights and environmental scores on the SAQ and lack GHG reduction targets. For those human rights risks that are determined to require correction, we plan the corrective action plans and follow up on their implementation on an ongoing basis.

The content of the second-party assessment is reviewed and updated as needed, with elements of human rights due diligence and environmental due diligence added when the CSR Procurement Policy was revised in 2020, and a second-party assessment check sheet created independently by the company was introduced in FY2022. On top of that, we added elements of labor and health and safety related to human rights, respectively.

In FY2023, we sent the SAQ to all 1,600 primary suppliers. As a result of analyzing the suppliers who responded to the SAQ, 26 (2.2%) suppliers were identified as having human rights risks, and we followed up by conducting the second-party assessment (interview), including ESG risk items such as the environment. As a result, 20 (77%) of the suppliers identified as having human rights risks showed improvement.

*SAQ: Self Assessment Questionnaire

Contact Points for Human Rights-related Consulting

Contact point for human rights-related issues

We have a contact point for human rights-related issues and a hotline for business partners as introduced on our official website:

Hotline for business partners (including suppliers, etc.)
Internal reporting system

The Nabtesco Group offers an internal reporting system to receive reports on harassment (including bullying) and all the other forms of human rights violations.

Prevention of Child Labor and Forced Labor

As a signatory of the United Nations Global Compact and as a supporter of the Universal Declaration of Human Rights, the Nabtesco Group is committed to respecting children's rights as described in the Convention on the Rights of the Child, Children's Rights and Business Principles, and other related global frameworks.

Through human rights risk assessments, we confirmed that there were no instances of child labor or forced labor within the Group, and that Group companies employ people in compliance with the labor laws of the relevant governmental authorities.

In China, where many of our production facilities are located, we have dispatched an employee in charge of personnel or legal affairs to the corporation supporting the management of Group companies in China, and provided local employees with a consulting service for personnel and labor affairs. To prevent local child labor specifically, we have revised the rules of Group companies, conducted training regarding them, and amended the minimum age for employment to be 18 across the Group.

Training

We annually conduct training with a focus on the prevention of harassment in addition to providing employees within and outside Japan with general compliance-related training.

In FY2022, we held a training session on the theme, "Business, human rights and SDGs/ESG" by inviting a lecturer from outside the company. In the session, our inside directors, executive officers and departmental managers were briefed on the approach to be taken by companies to compliance issues.
We plan to enhance our training on the theme of human rights.

Supporting the My Declaration of Human Rights Initiative by the Ministry of Justice

The Nabtesco Group has published its "My Declaration of Human Rights" as a supporter of the My Declaration of Human Rights initiative promoted by the Ministry of Justice of Japan.

The initiative aims to realize a society where everyone respects each other’s human rights, through declarations by companies, organizations, and individuals which express that they will take actions to respect human rights.

My Declaration of Human Rights Initiative Logo