Human Rights Due Diligence of Epson Group
Human Rights Due Diligence
Epson has established a process for respecting human rights in line with the United Nations Guiding Principles on Business and Human Rights. We have established the Epson Group Human Rights Policy, and continue to identify and assess adverse human rights impacts on the value chain, including our business partners. We investigate these impacts to identify issues and challenges, and take action to prevent, mitigate, and remediate them. We monitor the results or progress of these actions on an ongoing and regular basis, and report and disclose them appropriately both internally and externally.

Concrete Actions
1. Human Rights Impact Assessment (Identification of adverse impacts) (Process of respect for human rights described above ②)[Guiding Principle 18]
In FY2023, we again conducted an impact assessment and identified adverse human rights impacts. The following information was referenced in the assessment
-
- Recognition and knowledge through the Responsible Business Alliance (RBA) activities over the past 4 years (CSR self-assessment and RBA audits)
- Status of occurrence, consultation, and reporting of internal and supply chain incidents
- Literatures such as Ministry of Economy, Trade and Industry's "Guidelines for Respecting Human Rights in Responsible Supply Chains, etc," and "Practical Reference Materials," and information obtained through participation in the Keizaijin Caux Roundtable Stakeholder Engagement Program, etc.
As a result, we have re-identified that the areas where human rights abuses are particularly severe and likely to occur at Epson are the labor and occupational health and safety issues listed in the table below related to Seiko Epson Corporation's employees, Epson Group company employees, agency workers, supplier employees, on-site service vendor workers, and migrant workers as well as Asia in terms of region and manufacturing in terms of business type. The "specific examples of particular concern" are listed by referring to the RBA Code of Conduct and past incidents within the Epson Group.
| High-priority candidates for action | Major Adverse Impacts | Specific Examples Requiring Particular Attention |
|---|---|---|
| Employees of Seiko Epson Corporation and Epson Group Temporary staff Supplier employees On-site service vendor workers Migrant workers |
Forced labor | - Intermediary fees, recruitment fees, and other expenses related to employment - Confiscation of passports - Forced overtime - Freedom to leave work or terminate employment |
| Young workers | - Overtime, night shifts, and work that jeopardise the health, safety or morals | |
| Overwork | ・ Violations of laws and regulations regarding working hours, including long working hours that could harm health, and internationally recognized human rights standards | |
| Employee Welfare Programs | - Unpaid overtime wages - Non-payment or deductions from wages as a disciplinary measure |
|
| Inhuman treatment | - Harassment | |
| Discrimination | - Discrimination in dismissal and treatment - Pregnancy tests, dismissal of pregnant women |
|
| Occupational Health and Safety | -Hazardous and noxious working environment -Protection of female workers -Protection of workers in emergency situations |
2. Prevention and Mitigation of Adverse Impacts (Process of respect for human rights described above ③) [Guiding Principle 19]
Every year, Epson promotes awareness and dissemination of RBA Code of Conduct within the group, and in accordance with the RBA SAQ (self-assessment), conducts an annual CSR self-assessment at Seiko Epson business, domestic and overseas subsidiaries, and major suppliers. The results of the CSR self-assessment are reported to the RBA. Based on the results of the CSR self-assessment survey, each Seiko Epson business, subsidiaries, and supplier takes steps to provide relief to victims if human rights violations are found, and develops plans to address the identified negative impacts on human rights, aiming for prevention, mitigation, and reduction.
Overview of the 2025 CSR self-assessment (Epson Group Locations)
| Topic | Description |
|---|---|
| Questionnaire |
RBA Self-Assessment Questionnaire (SAQ) - Facility Risk Questions - Facility Control Questions |
| Survey Contents |
RBA Code of Conduct Section A Labor Section B Health and Safety Section C Environment Section D Ethics Section E Management System |
| Implementation Period | Survey: April to June 2025 Identification of issues,remediation, prevention, and mitigationefforts: July 2025 onward |
| Target Locations |
Seiko Epson business Units: 15 business units *In 2025, the scope of this program was expanded to include small-scale business and affiliated companies, in addition to non-manufacturing companies within Seiko Epson's business sites and domestic subsidiaries. |
| Addressing Adverse Impacts | Formulate a plan to addressand work on prevention and mitigation with the support and cooperation of the relevant supervisory departments at the head office. |
Results for 2025 (Summary)
Since 2024, we have been conducting CSR self-assessment in accordance with the completely revised RBA SAQ.
As a result of the CSR self-assessment, as in 2024, there were no high-risk* business locations at any of Seiko Epson's business sites or domestic and overseas affiliates.
* High risk is defined as a score of less than 60 points.
Furthermore, after a thorough review of the responses from each location by the RBA (Resource Balance Analysis) department at headquarters and other relevant departments, no serious issues such as legal violations were found. During the review process, we communicated with each location regarding any questions or concerns and provided individual feedback on matters that needed to be addressed.
We continue to address the following two points, which are common to many of our locations:
| Matter | Response |
|---|---|
| Reasonable accommodation for persons with disabilities | Head Office supervisory department issued guidelines to all sites on the meaning of this concept and the approach to addressing it, and held global meetings to promote understanding. |
|
Conducting evacuation drills during the hours when it is dark outside |
At the Head Office supervisory department,we are considering the implementation of trainingwhile taking into account the priorities of eachsite and other factors. |
We will continue to promote the further penetration of Group policies, Group regulations, rules, guidelines, etc. to each site, and will continue to work to prevent and avoid serious human rights violation risks.
Verification of Compliance with the RBA Code of Conduct (Mock Audit)
In addition to conducting RBA self-assessments at its major business sites, Seiko Epson also has experts conduct mock audits to verify compliance.
Overview of the mock audit
Timing: December 2024
Site: Hirooka Plant (Nagano Prefecture)
Method: Content and method in accordance with the RBA VAP audit criteria (document review, on-site survey, worker interviews)
Auditor: Third party with RBA associate auditor qualification
The mock audit did not reveal any serious adverse human rights impacts, but it did identify some nonconformities with the RBA Code of Conduct. As a member of the RBA, we are discussing the nonconformities with the relevant supervisory departments, formulating a corrective action plan, and taking voluntary action. The status of these actions is reported to management on an ongoing basis.
3. Monitoring of Results and Progress (Process of respect for human rights described above ④) [Guiding Principle 20]
Each Seiko Epson business unit and affiliated company, under the involvement of executive management, is working to prevent, mitigate, and reduce negative human rights impacts in accordance with remediation and response plans. The relevant departments at headquarters will monitor the remediation and prevention, mitigation, and reduction of significant negative impacts until their completion.
At Epson, we conduct an annual CSR self-assessment survey to check the prevention, prevention, and mitigation status of non-conformities to RBA Code of Conduct at each company and business site. Furthermore, in order to identify and address issues from a third-party perspective and improve the level of our activities, our seven main manufacturing bases located in Asia (as of May 2026) continue to undergo RBA's VAP (Validated Assessment Program) audits. To date, Epson has obtained "Platinum Certification," which is awarded when there are no non-conformities to RBA Code of Conduct and a perfect score (200 points), at production site in Indonesia, Malaysia, Thailand, China, and the Philippines.
As a result of CSR assessment surveys or RBA VAP audits, the main issues that were identified within the Epson Group in FY2025 and for which we implemented remediation, mitigation, prevention, and/or precautionary measures are as follows.
| Adverse impacts | Place of Occurrence | Status of addressing |
|---|---|---|
| Failure to test the wearing state of respiratory protective equipment | manufacturing company | Tests and preventive measures have been implemented(review of test implementation rules) |
| Factory where fire alarm is not audible | manufacturing company | Install additional visible fire alarms |
| Expired medicines in first-aid kits | manufacturing company | Exchange of the relevant pharmaceutical products and measures to prevent recurrence (review of inspection rules) |
We have also remediated, prevented, and mitigated the following types of issues:
| Adverse impacts | Place of Occurrence | Status of addressing |
|---|---|---|
| Delay in payment of wages to retirees | manufacturing company | Changed payment date in accordance with laws and regulations (within 3 days from the date of retirement) (system to be modified) |
| Failure to maintain safety equipment (eye washers) | manufacturing company | Replace with fixtures that meet legal requirements |
| Insufficient number of paid leave granted to former dispatch workers | manufacturing company | Revised the calculation method for paid leave based on laws and regulations and granted the shortfall. |
| Not testing drinking water (tap water) quality | manufacturing company | Inspection procedure was set in accordance with laws and regulations, and inspection was completed. |
| Failure to equip manufacturing machinery with safety devices | manufacturing company | Equipped with safety devices for such machines in accordance with laws and regulations |
| Violation of the Law concerning Worker Dispatching | Manufacturing company | Keep outsourced operations within the scope of the law. |
| Improvement of the emergency exit doors on the factory evacuation route | Manufacturing company | The structure of the relevant emergency exit doors has been reviewed. |
| Brokerage/recruitment fees to agencies paid by migrant workers | Manufacturing company | Stopped migrant workers' burden and reimbursed to workers |
| Custody of migrant workers’ passports | Manufacturing company | Thoroughly prohibit passports from being kept in custody |
| Agreement process with workers regarding overtime | Sales company | Clarification of the process for requesting overtime work |
| Advance payment by the applicant for the cost of medical examinations at the time of hiring | Manufacturing company | Reimbursed the employee for expenses already incurred, andchanged the process to one that does not requirereimbursement of expenses in the future. |
| Inadequate legal requirements in the contract between staffing agencies and the employees they dispatch | Staffing agency | Update the contract to comply with the law |
In FY2025, Epson's manufacturing site in Malaysia underwent an S-VAP for Forced Labor audit conducted by the RBA. The audit revealed the following serious nonconformities with the RBA Code of Conduct:
・Foreign migrant workers employed by an on-site service provider were found to have paid recruitment fees (S-VAP audit standard A1.1).
・Work permits of employees of an on-site service provider were found to be invalid (A1.1.4).
・The passports of foreign migrant workers employed directly by Epson were retained by a recruitment agency until the date of departure. In addition, the passports of foreign migrant workers employed by an on-site service provider were retained by the on-site service provider (A1.3).
We have now initiated remedial and preventive actions in accordance with an approved corrective action plan by the RBA.
4. Communication and Reporting (Process of respect for human rights described above ⑤) [Guiding Principle 21]
The status of efforts to address adverse impacts on human rights is reported on the website and in the sustainability report after being reviewed by executive management every year. The global efforts of the Epson Group are also reported in the Statement on Modern Slavery and Human Trafficking.
To respect human rights related to labor and occupational health and safety, and to build and maintain good labor-management relations, Epson actively provides information to employees and engages in sincere dialogue and discussions.
Furthermore, regarding complaints and inquiries from dispatch worker and other employees working on Seiko Epson business, we will discuss them through their respective companies, and Seiko Epson also have a system in place to directly receive individual inquiries.
Other salient human rights issues
At Epson, we have identified the areas where the negative impact on human rights is particularly serious and where human rights violations are likely to occur as being related to labor and occupational health and safety issues concerning our own and Group employees, dispatch workers, supplier employees, on-site service company employees, and migrant workers, particularly in Asia and in the manufacturing sector. We are also addressing other significant human rights issues.
Responding to Harassment by Customers
While customer inquiries may include legitimate complaints seeking improvement regarding issues with products or services, in a small portion, inappropriate demands or behavior in light of social norms may undermine the dignity or dignity of the staff we respond. These actions hinder continuous service provision and lead to a deterioration in service quality.
Public interest in such customer harassment is increasing.
In fiscal year 2024, Epson conducted a survey and interview, focusing on the sales and service departments of Seiko Epson and its domestic affiliates. As a result, it was confirmed that some Epson has suffered serious customer harassment damage, including adverse effects on physical and mental health.
In June 2025, the Act on Promotion of Comprehensive Labor Policies was revised (effective October 2026), and business are required to take necessary measures in employment management to prevent customer harassment. Epson refers to this law and the Ministry of Health, Labour and Welfare's business "Guidelines on Measures Employers Should Take in Employment Management Regarding Issues Arising from Issues Arising from Customers in the Workplace," and has taken the following measures.
・We established the "Epson Domestic Group Customer Harassment Guidelines" (March 21, 2025) and have been disseminated both internally and externally.
・If Seiko Epson determines that there is behavior that constitutes customer harassment, we will respond with a firm and decisive attitude.
・We may refuse to provide products or services or customer service. Also, if customer harassment continues, is malicious, or violates criminal laws,
If it is possible to make a judgment, we may coordinate with the police, lawyers, and others to address the situation.
・Employees who experience customer harassment report to their supervisors and take organizational measures, while also informing employees about the use of consultation services.
・If necessary, we will provide mental care and support to employees who have been harmed.
・In fiscal year 2025, we will conduct training for executives and supplement the "Epson Domestic Group Customer Harassment Guidelines" to provide concrete
To develop the approach to response and the specific operations for customer interactions, we have established the "Response Guidelines."
・To prevent harassment of business partners by the Epson Group, we include training for procurement staff, and also provide services to Epson Group employees,
We are reminding and thoroughly promoting these information.
*Please see below for information on the Epson domestic groups in scope.
AI Governance Initiatives
Epson is also advancing the use of AI in products and operations. To properly utilize AI and address negative impacts such as human rights violations, we are establishing a global AI governance system, conducting risk assessments when introducing and using AI, and working to ensure transparency, fairness, and safety.
Initiatives to Prevent Harassment
Epson recognizes that areas such as labor practices and occupational health and safety carry the highest risk of human rights abuses. In Japan, we are particularly committed to ongoing efforts to address harassment and continue to take proactive measures in this regard.