Respecting Human Rights
NSK’s Approach
NSK creates value that contributes to solving social issues, such as outstanding products and services that help create a smoother, safer society and protect the global environment. For the Company to grow sustainably, we believe that it is important to respect the individuality and potential of each employee and to create engaging workplaces.
To that end, NSK supports and respects international norms, such as the Universal Declaration of Human Rights and the Guiding Principles on Business and Human Rights. Also, the NSK Human Rights Policy as well as NSK Code of Corporate Ethics stipulates what officers and employees of the NSK Group should practice regarding human rights and labor, and requires them to respond. We also promote initiatives, such as diversity, equity and inclusion (DE&I), to create an organization and culture in which diverse employees can demonstrate their abilities. Furthermore, we aim to reflect the content stipulated in the NSK Human Rights Policy and the NSK Code of Corporate Ethics in the NSK Supplier CSR Guidelines and work with our suppliers to address human rights and labor issues.
System
The organization responsible for promoting the NSK Group’s human rights initiatives is the Human Resources and General Affairs Division HQ. This role includes the responsibility of strengthening human rights risk management across the NSK Group. And, each functional headquarters, including human resources and general affairs, procurement, manufacturing strategy, quality assurance, and legal and compliance, collaborates globally in the practice of human rights due diligence (HRDD) for both the NSK Group and procurement partners.
In addition, the Human Resources and General Affairs Division HQ shares and discusses regional issues with regional headquarters outside Japan to develop responsive measures, too. It also promotes human rights education for all global employees. Moreover, it regularly holds NSK Human Rights Meetings as a venue for sharing information across the Group. Important matters discussed at these meetings and progress on HRDD initiatives are reported and shared with the management team.
System for Promoting Respect for Human Rights (As of FY2023)
NSK Group Initiatives
Following the UN Guiding Principles on Business and Human Rights, the NSK Group manages human rights risks using the HRDD (Human Rights Due Diligence) process described below.
Risk Assessment
In fiscal 2021, we identified NSK’s key human rights risks with reference to human rights issues expressly stated in NSK’s codes and guidelines, information and indications from Japan’s Ministry of Justice, NGOs, research firms, and major customer CSR guidelines. In fiscal 2022, we conducted 14 interview sessions with external experts and NSK’s several functional division headquarters in Japan and regional headquarters outside Japan. Considering human rights risk cases emerging in related industries and the lists of corporate efforts evaluated by international initiatives, we identified and prioritized NSK’s key human rights risks.
Targets and Initiative Results
| Period | Targets | Initiative Results |
|---|---|---|
| FY2024 | 1. Conduct HRDD on business activities, and strive to identify, assess, and remedy adverse human rights impacts. | - |
| 2. Promote awareness of human rights policy among NSK Group employees, and promote respect for human rights through collaboration with business partners. | - | |
| 3. Strengthen efforts to ensure respect for human rights in business activities, including collaborating with suppliers and integrating human rights risk management into internal processes. | - | |
| FY2023 | 1. Conduct HRDD on business activities, and strive to identify, assess, and remedy adverse human rights impacts. |
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| 2. Promote awareness of human rights policy among NSK Group employees, and promote respect for human rights through collaboration with business partners. |
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| 3. Conduct questionnaire surveys of all major suppliers in high-risk areas for sites in Japan, local subsidiaries outside Japan, and consolidated subsidiaries to grasp the actual situation of human rights issues in the supply chain. | Conducted a CSR engagement survey on 90% of major suppliers in Japan in FY2023, provided feedback, and identified and assessed adverse impacts. Also now conducting the survey on suppliers outside Japan and planning to provide feedback after collecting responses. | |
| FY2022 | 1. Formulate and publish human rights policy. | Published the NSK Human Rights Policy on Japanese and global (English) websites in October 2022. |
| 2. Disseminate human rights policy and promote respect for human rights through collaboration. |
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| 3. Identify NSK’s key human rights risks and formulate an HRDD action plan. |
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Responses to Individual Issues
Legal Compliance and Corporate Ethics
In addition to stipulating “prohibition of discrimination, cultivation of a sound workplace” and “respect of fundamental rights at work” in its Code of Corporate Ethics, NSK publishes the NSK Compliance Guidebook, which explains the matters to be observed in the languages of each country. The Guidebook is distributed to officers and employees. We also regularly hold in-house training to promote understanding.
Establishing a Compliance Hotline (Whistleblowing System) and Consultation Channels
NSK aims to identify and correct illegal and fraudulent activities at an early stage. If an employee or officer discovers illegal or potentially fraudulent activity, the Company requests that he or she makes a report to the internal or external whistleblowing points of contact. The whistleblower can make a report anonymously so that he/she will not face any repercussions. Any act that violates relevant laws and regulations or the NSK Code of Corporate Ethics will be subject to disciplinary action based on company regulations. In addition, the risk assessments conducted annually for all business establishments include items such as risks related to acts that violate laws and regulations and the NSK Code of Corporate Ethics, and risks related to occupational safety and the supply chain. As a result of these assessments, we take measures to mitigate the risk for items that are judged to be of high importance.
Labor-Management Relations Based on Dialogue
For NSK to grow sustainably as a corporate group committed to high-quality manufacturing, we believe it important to look at employment from a long-term perspective and to continuously hire and develop outstanding human resources in the countries and regions where, for example, our production, sales, and development sites are located.
Hiring employees in an appropriate manner in accordance with international norms and local laws, the NSK Group regards a healthy relationship between labor and management as indispensable. We guarantee the right of employees to communicate directly with management (labor-management dialogue) without fear of retaliation, intimidation, or harassment. Also considering it important to create a work environment where each employee feels motivated and can develop, we carry out employee awareness surveys, which are aimed at measuring employee engagement and compliance awareness and take measures to address identified issues.
Creating Workplaces Where Diverse Human Resources Can Demonstrate Their Abilities
In the NSK Code of Corporate Ethics, we spell out our commitment to “prohibition of discrimination, cultivation of a sound workplace,” and establish this guideline for action: “Personnel must respect the rights of individuals and must not unfairly discriminate on the basis of race, appearance, belief, gender, lineage, ethnicity, nationality, age, marital status, physical disability, or other inappropriate reason. In addition, personnel must avoid engaging in acts that cause offense to the recipient.” Specific initiatives include offering seminars and consultation services for employees regarding respect for diverse gender identities and sexual orientations and preventing discrimination and harassment of LGBTQ+ people.
Supporting Hidden Diversity: LGBTQ+ (SOGI)
Promoting Safe, Secure, and Comfortable Workplaces
Supply Chain Initiatives
NSK distributes copies of its NSK Supplier CSR Guidelines, which contain the matters to be observed regarding human rights and labor, to all its suppliers and requests implementation by them. In addition to asking all suppliers who have a direct business relationship with the NSK Group to take their own actions and promote procurement activities that take human rights into consideration, by means of these guidelines we are aiming to further advance our efforts to upstream suppliers. In addition, we regularly conduct CSR self-assessments and provide feedback to everyone about any issues that have come to light so that they can help improve the level of their activities.
Occupational Health and Safety Management
NSK has positioned safety as one of its core values. Under our safety philosophy and policies, we proactively advance workplace safety and health activities that support manufacturing. NSK strives to create workplaces where employees can work safely, securely, and comfortably.
Occupational Health and Safety Management System (related site)
Quality
NSK has positioned quality as one of its core values. We seek to practice manufacturing that earns customer delight worldwide, whether with products, services, or information provided. To enhance design quality, manufacturing quality, supplier quality, and ultimately market quality, NSK has established a Quality Council chaired by the Head of the Quality Assurance Division HQ to oversee group-wide quality management.
Environment
In 1997, NSK established the NSK Environmental Policy to reflect its commitment to help protect the global environment across all of its business operations, as stated in the NSK Mission Statement. It develops products and services that help reduce environmental impact and promotes business operations to reduce environmental impact across its value chain. NSK’s Environmental Code of Conduct sets out seven guidelines for action by officers and employees: ensuring environmental compliance, fighting global warming and climate change, conserving resources and practicing recycling measures, developing and popularizing environmentally friendly products, conserving biodiversity, reducing use of environmentally hazardous substances, and communicating with stakeholders.
Environmental Management (related site)
Fighting Global Warming and Climate Change (related site)
Resource Conservation and Recycling Measures (related site)
Biodiversity Conservation (related site)
Reducing Use of Environmentally Harmful Substances (related site)
Addressing Conflict Mineral Issues
As a policy, NSK prohibits the use of conflict minerals*1 in its products. Conflict minerals are those which come from the Democratic Republic of the Congo and its neighboring countries which can be the source of funding and benefits to illegal armed groups that violate human rights. Moreover, whenever investigation reveals concerns about conflict minerals in the supply chain, we take measures to prevent the use of the relevant parts or raw materials.
Some NSK products, including electronic components used in vehicle electric power steering systems, contain metals such as tin and tantalum. These materials are subject to the US conflict minerals rule*2. For this reason, NSK conducts annual conflict mineral surveys in cooperation with relevant parts and raw material suppliers. This includes tracing relevant materials back through the supply chain to the refineries and countries of origin. The NSK surveys conducted up through fiscal 2022 have revealed no presence of conflict minerals that could be a source of funding for armed conflict.
*1 Four conflict minerals (tantalum, tin, tungsten, and gold) originating in the Democratic Republic of the Congo and surrounding countries, which can be the source of funding for the activities of illegal armed groups in the region.
*2 A rule that requires companies listed in the United States to investigate the potential use of conflict minerals in products, and to officially submit the results and publicly disclose them every year. While NSK is not listed in the United States where the rule applies, we still conduct conflict mineral surveys and share the information with customers.