The NYK Group established the NYK Group Human Rights Policy based on the United Nations Guiding Principles on Business and Human Rights. We support and respect the United Nations International Bill of Human Rights, the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, international treaties and declarations related to the protection of human rights, including conventions on workers' human rights such as wages and working hours, the OECD Guidelines for Multinational Enterprises and the United Nations Declaration on the Rights of Indigenous Peoples, and the Ten Principles of the United Nations Global Compact.
To fulfill our responsibility to respect human rights of our stakeholders, this policy applies to all executives and employees of the NYK Group, and we encourage our suppliers, contractors, agents and other parties involved in our business and supply chain to comply with the policy.
This policy was approved by the Board of Directors on November 24, 2022, for its establishment and disclosure.

In February 2022, the Risk Management Committee adopted human rights violation risk as a new critical risk. The Risk Management Committee is convened twice a year and chaired by the president. The committee is composed of chief executives and the executive officer in charge of promoting ESG management, including four members of the Board of Directors. The committee identifies critical risks based on reports from each headquarters, determines the headquarters responsible for advancing countermeasures for each critical risk, and promotes risk mitigation activities for the entire Group.

The Group respects the human rights of all people involved in our business activities, and recognizes and respects various values and cultures as the foundation of our corporate activities.

To enhance its global business activities, NYK created the company's "CSR Guidelines for Partners and Suppliers," which requests the cooperation and understanding of business partners in promoting CSR activities concerning global social issues such as child labor, forced labor, environmental destruction, etc., in the entire supply chain.

In April 2023, we established the ESG Strategy Committee, which succeeded the ESG Management Committee, to determine the Groupwide policies on ESG management, including the promotion of human rights. Since fiscal 2023, the committee has met monthly and included the deputy chief executive of ESG Strategy Headquarters as its chair and executive officers representing each headquarters. In addition, an external advisor has been invited to the committee. The committee reports the proceedings of its meetings and provides advice and recommendations to the Management Meeting and the Board of Directors through the ESG Strategy Headquarters. Also, the UN Global Compact Promotion Committee,^*1 part of the ESG Strategy Headquarters, conducts preliminary discussions and then submits proposals to the headquarters.
The ESG Strategy Committee collaborates with the ESG Management Group and other relevant departments to promote human rights within this framework under top management leadership and commitment.
In fiscal 2022, the ESG Management Committee discussed reports on the Group's human rights initiatives and considered formulating a human rights policy. The committee shared the initiatives implemented and reconfirmed that the Group would pursue consistent efforts to promote human rights. The committee also proposed the Management Meeting and the Board of Directors to formulate a human rights policy. The Board of Directors discussed and approved the person responsible for the implementation of the human rights policy.

We regularly receive expert advice from a third party, Caux Round Table Japan (CRT Japan),^*2 to strengthen our efforts to promote human rights. Third-party expertise is applied at each phase of the implementation process to ensure objectivity and legitimacy. We hold regular bi-weekly meetings with CRT Japan to advance our efforts to promote human rights.

Framework for Promoting Human Rights Initiatives (As of April 1, 2023)

1. *1UN Global Compact Promotion Committee
   In fiscal 2023, we reorganized the former Global Compact Promotion Committee established in 2010 as the UN Global Compact Promotion Committee. The purpose of the committee is to promote the United Nations Global Compact (UNGC) and to establish systems based on it in the Company and its Group companies. The committee meets quarterly. Through global human resource surveys, as well as processes for human rights due diligence, the committee investigates business execution and matters that may violate the UNGC, confirms facts, and then discusses and determines any corrective measures.
2. *2Caux Round Table Japan (CRT Japan）
   A global network of business leaders working to realize a fair, free and transparent society. CRT Japan supports efforts in responsible business practices and human rights.

The Group understands that our corporate activities, including the supply chain, could have a direct or indirect adverse impact on human rights. Therefore, we follow the procedures outlined in the UN Guiding Principles on Business and Human Rights and exercise human rights due diligence. Specifically, we identify and assess the Group's activities that have or may have an adverse impact on human rights. Next, we seek to grasp the Group's human rights issues to prevent and mitigate the risk of adverse impact and to consider remedial measures. A follow-up assessment will be conducted to verify its effectiveness, and the process and the results will be disclosed. We implement the above continuous process.

Identifying Salient Human Rights Issues

In 2022, we with the support of Verisk Maplecroft* conducted an assessment to advance human rights due diligence. We have identified potential risk factors that can cause or contribute to human rights violations in our corporate activities. We have targeted three operations, namely, automotive logistics, oceangoing shipping (seafarers) and ship recycling (scrap workers), and assessed the risks of human rights violations in the countries or regions in which we operate these business activities.
Furthermore, we conducted a human rights due diligence workshop for managers of 10 groups of five relevant headquarters and divisions. The workshop, supported by CRT Japan, was held in June 2022 and brought together 26 managers. The purpose of the workshop was to receive feedback from our managers on the results of Verisk Maplecroft's assessment, based on their actual work. During the workshop, participants also discussed other business operations that form part of our supply chain in addition to the three mentioned above, including shipbuilding and port logistics. Based on their experiences, participants exchanged opinions, identified, analyzed and summarized the potential risk factors for human rights violations at each stage of the value chain at a practical level. Participants also shared future concerns and challenges associated with managing the risks of human rights violations, such as a lack of understanding of the real situation concerning indirect subcontractors within and outside Japan, and highlighted the importance of understanding the risks of human rights violations in the global supply chain.
Verisk Maplecroft's assessment and the human rights due diligence workshop identified the salient human rights issues for the NYK Group as follows:

Procedure for Identifying Salient Human Rights Issues

We will organize our initiatives for the identified salient human rights issues and share the understanding of those issues with NYK Group companies and suppliers to get the picture. As human rights issues are subject to change based on geopolitical risks, we are currently establishing a management system to quickly alert new human rights issues or those that require urgent attention.

• *Verisk Maplecroft
  A leading global risk analytics, research and strategic forecasting company.

Confirming the Status of Human Rights Management Practices

We are conducting interviews with relevant Group companies or headquarters to check on management practices of the identified salient human rights issues.

Oceangoing Shipping (seafarers)

The NYK Group is committed to protecting seafarers' rights by ensuring compliance with the requirements of Maritime Labour Convention 2006 (MLC, 2006), which sets out the basic rights of seafarers and occupational health and safety on board. We use our safety management system (SMS) that incorporates the requirements, and our assessment system to confirm the MLC compliance status of ship management companies and the ships they manage.
We recognize that seafarers' human rights concerns begin with recruitment and continue while they serve on board and even after they disembark, and that there are issues to be addressed at each phase. We are committed to conducting ethical recruitment practices prior to boarding; preventing violations of rights to occupational health and safety; ensuring the right to privacy, freedom of association, and collective bargaining; assuring decent working time; providing access to remedy; and preventing discrimination in the workplace while on board. Our initiatives after disembarkation include maintaining seafarer retention through employee engagement and improving the accessibility of financial services for seafarers. For more information on our initiatives, please see below.

• NYK Group Respect for the Human Rights of Seafarers[PDF:922KB]

Ship Recycling (Scrap Workers)

Ships owned by NYK and its Group companies are dismantled in ship recycling yards that meet NYK standards. In 2022, two of our ships were dismantled at the NYK certified ship recycling yard in Alang, Gujarat, India.
Ship recycling is a labor-intensive industry, and the majority of ship recycling yards are located in developing countries. Ship recycling practices can lead to human rights abuses, such as exposure of workers to toxic substances or occupational safety and health concerns. In April 2022, we commissioned a third-party body, CRT Japan, to investigate how a Group company manages and protects the working environment and human rights of ship recycling workers. We conducted an online interview with six management staff and site managers of NYK SHIPMANAGEMENT PTD LTD. who supervise or monitor ship recycling processes at an NYK certified ship recycling yard.

During the interview, we confirmed the initiatives that NYK SHIPMANAGEMENT PTD LTD. has taken to address human rights concerns among ship recycling workers. The following are the main issues that need to be confirmed with workers directly in the future:

• Discrimination in the workplace - During ship recycling processes, over two hundred workers come together from India nationwide. Ensure they are not discriminated against based on their culture, language, religion or place of origin.
• Modern slavery - Ensure that workers are not forced to sign an employment contract or pay a recruitment fee when they get a job through a third-party agent.
• Occupational health and safety - Personal protective equipment (PPE) is essential for the safety of workers. Ensure that employers supply or lease them for free to workers.

After the online interview, the results and the feedback were shared with NYK Shipmanagement Pte Ltd. In the future, we will ensure that rights holders* are properly engaged by conducting direct dialogues with ship recycling workers to understand the real situation from their perspective. Ship recycling is not year-round work, and it is only conducted for a limited period of time. Taking into account the ship recycling schedule, we will continue to monitor and assess the risks of human rights violations in the ship recycling operation on a regular basis. We will also ensure that ships owned by NYK and NYK Group companies are dismantled or recycled in an appropriate and safe manner, giving full attention to human rights issues.

• *Rights holders
  Rights holders, meaning holders of rights (human rights), are those groups and stakeholders who may be affected by corporate activities.

More Information:

• Ship Recycling: Safety and Environmental Initiatives

The NYK Group conducts education and enlightenment programs on human rights to promote activities in line with its human rights policy.

Enlightenment and Education for Executives and Employees

The NYK Group conducts human rights training for all executives and employees, including those of Group companies, through various programs such as e-learning, new employee training, and group trainings for expatriates, newly appointed managers, and newly appointed overseas senior management to instill in them an awareness of respect for human rights. We also aim to brief them on human rights risks in the Group's business and supply chain and the NYK Group's principles and rules regarding human rights. Every year, the NYK Group conducts human rights training through e-learning in three languages: Japanese, English and Chinese. We are working to deepen employees' understanding of the impact our Group's business can have on human rights, and we are making them aware of the NYK Group's commitment to respecting human rights. In fiscal 2022, a total of 7,541 NYK Group employees participated in our e-learning program. This represents a participation rate of 96%. The results of a follow-up awareness survey are as follows.

In addition, at training for new employees held in April and October every year, we brief employees on the importance of respecting human rights and remaining aware of human rights risks in their daily work. In fiscal 2022, the NYK Group conducted training for 115 new employees (new graduates and mid-career hires).
At group training sessions for expatriates, newly appointed managers, and newly appointed overseas senior management, we use actual examples of our initiatives for respecting human rights to brief employees on the latest trends in business and human rights as well as human rights issues in Japan and overseas.
Furthermore, to raise awareness of respect for human rights within NYK, we make staff aware of human rights issues through the company bulletin board every December during Human Rights Week. In fiscal 2022 "harassment" and "unconscious bias" were featured as main themes.

Through our membership in external networks and participation in study sessions, we gather the latest information on global trends and advanced cases concerning business and human rights, and we use this information and knowledge in internal education programs and initiatives for respecting human rights.
Since 2012, NYK has been participating in the Stakeholder Engagement Program (Human Rights Due Diligence Workshops) organized by CRT Japan. In this program, NGO/NPO representatives and human rights experts raise a wide range of issues centered on human rights issues that are attracting attention both in Japan and overseas. Based on the issues raised, the participating companies discuss prominent human rights issues and the importance of business activities for raising awareness of human rights and also identify and organize key human rights issues for each industry.

NYK is also a member of the Mitsubishi Human Rights Enlightenment Committee, which comprises Mitsubishi Group companies. The members participate in study sessions and share information on initiatives and the latest trends in respecting human rights.
NYK has also taken part in a human rights breakout session organized by Global Compact Network Japan and participates in study sessions, exchanges of opinion, and lectures on human rights issues with human rights managers of participating companies.

NYK provides various grievance mechanisms that can be accessed by all employees of the Group to promptly deal with possible infringements of human rights.
The consultation services arranged by NYK include the Yusen Chat Room, the Harassment Policy and Consultation Service, the Internal Reporting Consultation Service, and the Childcare and Nursing Care Consultation Service. Employees can also directly consult with the department in charge of receiving consultations and directly consult with an external lawyer anonymously. Through these services, we receive various reports and queries from employees not only concerning whistleblowing reports but also all kinds of issues related to human rights, discrimination, and harassment, which employees face in the workplace, either in the name of the employees or anonymously, according to their wishes. We attempt to early identify, resolve, and remedy the problems. In fiscal 2019, we set up a new LGBT Consultation Service where LGBT persons and stakeholders can seek consultation about their concerns and problems in the workplace.
Details of consultations and grievances are communicated to relevant departments, impartial investigations are undertaken, and remedial measures based on internal procedures are taken.
We are working to familiarize employees with these grievance mechanisms through our internal portal site and through training. During Human Rights Week, information on these services is posted on the company bulletin board.
In addition, when providing consultation, NYK strictly maintains the confidentiality of the person seeking consultation as well as relevant parties, and also guarantees that no person will be treated disadvantageously as a result of making a report or seeking consultation, except in cases where such action has been for unfair reasons or through inappropriate methods.
Furthermore, through the inquiry form on our website, we accept not only inquiries about services of the NYK Group but also inquiries about concerns and requests for consultation related to human rights from all stakeholders including business partners and their employees, local communities, and customers. We protect the privacy of parties seeking consultation and ensure appropriate confidentiality.

The NYK Human Resources Group invites external instructors to conduct LGBT training sessions for HR members, including the board member in charge of HR. We also run a diversity and inclusion (D&I) training program annually for new employees. Through face-to-face talks, lectures on fundamental LGBT issues, and group work, each new employee can gain new awareness and recognize the importance of diversity and inclusion.
In addition, we promote understanding of LGBT/SOGI through e-learning. We also provide an LGBT consultation service, conduct anonymous surveys, and invite LGBT experts to talk to employees. These initiatives aim to foster a greater understanding and acceptance of LGBT within our organizations.

2023 LGBT and SOGI Awareness Survey Results

We conducted an anonymous awareness survey on LGBT and SOGI for employees working at NYK and our Group companies in Japan.
The survey aimed to check employees' level of understanding of LGBT and SOGI and investigate matters such as "problems and concerns in the working environment" and "requests for specific training and study opportunities."
Based on th survey results, NYK will continue its efforts to create a workplace environment where every individual values diversity and where diverse human resources can play an active role.

NYK engages in initiatives to raise awareness of human rights through collaboration with external organizations.

Rainbow Communication Badge (RCB) Project

To further promote D&I initiatives within our organization, NYK supports the Rainbow Communication Badge (RCB) Project established by JobRainbow Co. Ltd., a company that supports LGBT job placement, education, and consulting services.
The RCB Project aims for an inclusive society without discrimination or prejudice. By wearing the Rainbow badge, we can create a reassuring environment for customers, business partners, and employees.
The recommended period for wearing the badge in 2023 was from April 22 to May 21, although NYK recommends wearing the badge throughout the year and has promotional displays with badges throughout the head office.
More information about NYK's participation in this project can be found at the following link (Japanese only).

More Information:

• Rainbow Communication Declaration (JobRainbow MAGAZINE)

Collaboration with Amnesty International Japan

Panel Exhibition of Universal Declaration of Human Rights at NYK Maritime Museum

The NYK Maritime Museum held a panel exhibition on human rights from January 18 to February 16, 2020, in collaboration with Amnesty International Japan. The display panels illustrated all 30 Articles of the Universal Declaration of Human Rights in approachable illustrations that had been translated to easy-to-understand Japanese.
The museum also hosted an event that used virtual reality to allow visitors to experience the challenges refugees face.

NYK also displayed a Universal Declaration of Human Rights digital slide show in the head office visitor space from November to December 2019 to coincide with Human Rights Week.

Sponsorship of Film Festival Hosted by Amnesty International Japan

On August 17, 2019, NYK sponsored a movie screening of “Fire at Sea,” or “Fuocoammare” in its original Italian. The documentary captures life on the Italian island of Lampedusa, a frontline in the European migrant crisis. Amnesty International Japan hosted the event, and NYK sponsored the film festival to raise interest in human rights issues in Japan.