Respect for Human Rights

■Overview of human rights due diligence

Human Rights Policy

In order to further promote human rights initiatives, we have formulated a Human Rights Policy in which all Group employees share common sense of values related to human rights and which serves as the basis for their day-to-day activities and business activities. In doing so, we are making efforts to ensure that human rights are respected. Based on the Human Rights Policy, we will address human rights issues which are gaining more and more global attention, as exemplified by the Sustainable Development Goals (SDGs) and the UK’s Modern Slavery Act, and fulfill our corporate responsibility for respecting human rights.

Outline of Human Rights Policy

• 1．NTN will respect internationally-recognized human rights.
• 2．NTN will not violate the human rights of others.
• 3．NTN will respond appropriately to any negative impacts its business activities may have on human rights.

Responding to human rights risks in employees

Sound labor-management relations based on labor-management consultations

We strive to share the content of each measure between labor and management in a forum where labor and management can exchange information with each other. We hold quarterly "Labor-Management Roundtable Meetings," in which executive managers provide thorough explanations about the Business Management Policy, management environment, and other topics to the labor union and listen to the views of the labor union. In addition, we hold labor-management committee meetings as appropriate according to each measure that leads to improvement of "motivation to work" and "ease of work," with the aim of exchanging opinions to deepen mutual understanding and deciding on work styles that lead to improvement of attractiveness of a place to work.

Survey of foreign workers

We will investigate the working condition of employees in our group, grasp the actual condition of foreign workers, and respond to issues identified.

Responding to human rights risks in the supply chain

Correspondence to forced labor and child labor (Conflict mineral surveys)

Incomes from the mining of tin, tantalum, tungsten and gold (3TG) in the conflict areas of the Democratic Republic of the Congo (DRC) and neighboring countries could be a source of capital for armed forces, which could lead to human rights infringement, illicit mining and smuggling. In April 2016, we established our CSR Procurement Guidelines, upholding the policy of "Responsible mineral procurement," to continuously monitor whether the mineral resources contained in materials and components used in our products are mined from conflict and high-risk areas.
In the fiscal year ended March 2022, we traced back through our supply chain of 256 business partners to identify the material smelters, and more than 93% of such partners reported that they do not use any conflict minerals. We will continue to conduct this survey periodically.
Companies listed on U.S. Stock Exchanges are required to disclose any use of conflict minerals under the U.S. Dodd-Frank Act. Based on the results of the above survey, we respond to inquiries from our customers regarding conflict minerals.
As human rights issues are gaining attention globally, corporate awareness of such issues is growing. Regardless of the U.S. Dodd-Frank Act, the number of companies voluntarily eliminating the use of conflict minerals is increasing as shown in the chart below.

■Number of conflict mineral surveys (responding to requests from customers)