Respecting Human Rights

Basic Approach
Strategy
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Compliance with the UK Modern Slavery Act
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Basic Approach

The Nikon Group recognizes that our business activities may directly or indirectly affect the human rights of various stakeholders, and we clearly state our commitment to respect for human rights in the Nikon Code of Conduct.

As a specific guideline for the Code of Conduct, we established the Nikon Human Rights Policy and pursue efforts to respect human rights based on the UN Guiding Principles on Business and Human Rights. In fiscal year 2024, we conducted a human rights impact assessment with the advice of outside experts. The assessment identified six salient human rights issues for Nikon Group to prioritize in the value chain: health and safety, work environments, human rights issues in the supply chain, prohibition of child labor and forced labor, ethical use of AI, and access to remedy.
We have also established a cycle of improvement related to these issues that consists of continuous assessment, improvement, implementation, and monitoring, ensuring we engage in effective respect for human rights.

The Nikon Group has other policies and standards in place specific to individual human rights issues, including the Nikon CSR Procurement Standards and the Responsible Minerals Sourcing Policy.

Related Policies

Strategy

In accordance with the revised Nikon Human Rights Policy, amended in April 2025, we will establish a remedy mechanism, establish a governance system, and continue to improve human rights through stakeholder engagement. At the same time, we will ensure that we conduct human rights due diligence in line with the UN Guiding Principles on Business and Human Rights for the six salient human rights issues specified in this policy.

In fiscal year 2025, we introduced new initiatives that included the development of the Nikon Group AI Ethics Policy and a new consultation desk for all stakeholders.

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New Human Rights Grievance and Consultation Desk

In September 2025, the Nikon Group established a new Human Rights Grievance and Consultation Desk available to all stakeholders to report or seek advice on human rights issues related to the Nikon Group's business activities and value chain. This desk serves as a grievance mechanism based on international human rights norms such as the UN Guiding Principles on Business and Human Rights, and accepts consultations and reports not only from employees, but also from external parties, including business partners, outsourcing partners, and local communities.

The Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) operates the service and receives reports. The Nikon Group takes the lead in determining the appropriate course of action, communicating with the original reporter, and taking steps to resolve the matter. The Group assures the confidentiality of the reporter and the details of the report, prohibiting any detrimental treatment or retaliation with respect to the person submitting a report.

The Human Rights Grievance and Consultation Desk received and responded to four cases in fiscal year 2025, including cases received through the customer consultation desk.

Human Rights Grievance and Consultation Desk

Nikon Group AI Ethics Policy

The Nikon Group recognizes that while the use of AI technology can lead to business sophistication and the creation of new value, inappropriate use or management may lead to serious risks, including human rights violations and loss of social trust.

We formulated the Nikon Group AI Ethics Policy in April 2026 to clarify our approach to the development and use of AI technologies from the perspective of respect for human rights. In formulating the policy, we took into account domestic and international guidelines, regulatory trends. We also conducted interviews with business units to ensure that the content would align with actual practice. The AI Working Group ensured the technical appropriateness of the content, and worked with the Human Rights Subcommittee and related departments.

We intend to enhance the effectiveness of this policy through internal and external communication and education. We will continue to review the policy in light of changes in the social environment and technology surrounding AI.