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.

We have established the ESG Management Committee to determine the Groupwide policies on ESG management, including the promotion of human rights. Since fiscal 2021, the committee has met quarterly and included the president 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. Also, the UN Global Compact Promotion Subcommittee,^*1 one of the subordinate organizations of the ESG Management Committee, conducts preliminary discussions and then submits proposals to the committee.
The ESG Management Committee collaborates with the ESG Management Promotion 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, 2022)

1. *1UN Global Compact Promotion Subcommittee
   In fiscal 2022, we reorganized the former Global Compact Promotion Committee established in 2010 as the UN Global Compact Promotion Subcommittee. The purpose of the subcommittee is to promote the United Nations Global Compact (UNGC) and to establish systems based on it in the Company and its Group companies. The subcommittee meets quarterly. Through global human resource surveys, as well as processes for human rights due diligence, the subcommittee 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.

More Information:

• Continuing to Evolve ESG Management

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.

Ship Recycling Workers (India)

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

To avoid violations of human rights, NYK has enlightened all employees and board members about human rights issues, discrimination, harassment, and global trends in human rights, etc., through various training programs such as e-learning, new employee training, training for newly appointed managers and expatriates, and overseas senior management training. NYK has also proactively promoted respect for human rights through articles on the company bulletin board and striven to raise human rights awareness on the annual Human Rights Day and during Human Rights Week in December.

Outside the office, NYK has participated in the Mitsubishi Human Rights Enlightenment Committee organized by Mitsubishi group companies and a breakout session on human rights organized by Global Compact Network Japan. These study groups comprise over 20 companies, and the discussions and lectures with participants on human rights issues has helped NYK deepen its understanding.

In fiscal 2020, LGBT and SOGI (sexual orientation, gender identity) rights protection were featured in the group's e-learning to raise employee awareness of human rights.
During Human Rights Week in December, NYK provided education on the main themes of "business and human rights," "NYK's human rights initiatives."

Survey Results on Human Rights Awareness in FY2021 (6,949 response)

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 panels on display 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 additionally hosted an event that used virtual reality to allow visitors to experience the challenges faced by refugees.

NYK also projected the Universal Declaration of Human Rights panel 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. The event was hosted by Amnesty International Japan, and NYK sponsored the film festival in hopes of raising interest in human rights issues in Japan.

NYK has an Ethics & Compliance Hotline for reports and consultations - not only for internal reports but also reports on human rights, discrimination, harassment, fraud, unethical or unlawful conduct, and improper employee conduct in business activities. This hotline allows the company to prevent or correct problems, and to quickly take appropriate remedial action.
The hotline is available to all NYK Group employees at all times via telephone or email, and is designed to protect confidentiality and anonymity and allow direct consultation with external lawyers.In fiscal 2019, a new LGBT consultation service was set up to provide a system for LGBT and related personnel to discuss any workplace worries or difficulties.

As corporate human rights initiatives have become more important, NYK has started to promote LGBT/SOGI measures. In December 2019, sexual orientation gender identity, or SOGI, was added to the NYK Code of Conduct, and NYK's CSR Guidelines for Partners and Suppliers has also been updated.
The NYK Human Resources Group also invited JobRainbow to conduct LGBT training sessions for HR members, including the board member in charge of HR, and the sessions included a virtual reality experience to examine the challenges faced by the LGBT community.
Since April 2021, we have held a Diversity and Inclusion training program for new employees. Through face-to-face talks, lectures on basic LGBT issues, and group work, each new employee was able to gain new awareness and recognize the importance of diversity and acceptance. In addition, through the company's e-learning educational activities and the establishment of an LGBT consultation service, we promote understanding of LGBT and SOGI issues to all employees.