Human Rights Due Diligence of Epson Group

Human Rights Due Diligence

Epson has established a process for respecting human rights in accordance with the United Nations Guiding Principles on Business and Human Rights (hereinafter referred to as the Guiding Principles). Epson has established the Epson Group Human Rights Policy, and is continuously implementing activities to identify and investigate adverse human rights impacts to extract problems and issues, across the value chain including group companies and business partners, to prevent and redress them. We monitor the results or progress of these prevention and redress activities on an as-needed and regular basis and report and disclose them appropriately 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
    • Materials such as the 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 again identified the areas in which human rights violations are particularly likely to occur at our company at present as issues related to labor as well as occupational health and safety as shown in the table below concerning our own and Group employees, dispatch workers, supplier employees, on-site service vendor employees, migrant workers; Asia in terms of geography; and manufacturing in terms of business category. 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 Targets Major Adverse Impacts Specific Examples of Special Attention
Our own and Group
Employees
Dispatch workers
Supplier employees
On-site service vendor employees
Migrant workers
Forced labor -The burden of employment-related agency fees, placement fees, and other expenses
-Passport custody
-Compulsory overtime
-Freedom to resign
Young workers -Overtime, night work, hazardous work
Overwork -Violations of laws and internationally recognized human rights norms regarding working hours, and long working hours that are detrimental to health.
Wages and Benefits -Non-payment of wages for overtime hours
-Non-payment or reduction of 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]

Epson conducts CSR self-assessment annually in compliance with the RBA Code of Conduct and the survey form. After joining the RBA in April 2019, Epson is promoting activities to raise awareness of the RBA Code of Conduct to the Group, as well as conducts CSR self-assessment annually at its facilities, domestic affiliates, overseas subsidiaries, and suppliers in compliance with the RBA survey form on an ongoing basis. The results of the CSR self-assessment survey are reported to the RBA. Each business location, company, and supplier identify where adverse human rights impacts are located and develop corrective plans to redress and mitigate the identified adverse impacts.

Overview of 2024 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 - June 2024
Identification of issues and corrective actions: July 2024-.
Target Locations Seiko Epson business Locations 11 facilities
Domestic affiliates: 8 companies (6 manufacturing companies and 2 sales and other companies)
Overseas offices 45 companies (15 manufacturing subsidiaries and 30 sales and other companies)
Addressing Adverse Impacts Develop a corrective action plan and work on redress and mitigation with the support and cooperation of the relevant headquarters departments in charge.


Results for 2024 (summary)
In 2024, Seiko Epson conducted CSR self-assessment in accordance with the fully revised RBA SAQ.
The results of CSR self-assessment at each Seiko Epson facility, domestic affiliate, and overseas affiliate showed no high-risk *.  
 *High-risk is defined as a score of less than 60 points.
The responses from each site were reviewed by the RBA supervisory department at the head office and the relevant supervisory department, and no issues that fall under priority non-conformances were found. In the proces of the examination, we communicated with each site regarding any points of uncertainty and provided feedback to each site individually regarding areas that require correction.
There were two common issues at many of the sites that were not adequately addressed.

Matter Support
Reasonable accommodation for persons with disabilities The head office supervisory department will disseminate guidelines to all sites on the meaning of this concept and the approach to dealing with it, and promote understanding of the concept.

Conducting evacuation drills during the hours when it is dark outside

The supervisory department at the head office is currently discussing with the department at the head office in charge of disaster prevention countermeasures about an announcement on the implementation of the drill.

We will continue our efforts to further disseminate Group policies, Group regulations, rules and guidelines, etc. to each of our sites to ensure that the risk of serious human rights violations continues to be controlled.

(Reference) The following table shows the results (risk levels based on scores) of CSR self-assessment (self-assessment in accordance with the RBA SAQ before revision) in the Epson Group from 2020 to 2023. As a result of annual corrective activities, we believe that the overall risk level is decreasing year by year.

* Low risk: Evaluation points are above 85, and actions are being takenoverall at the level required by the RBA Code of Conduct.
Medium-risk: Evaluation points are more than 65 and equal to or below 85, and there are items for which actions are not taken at the level required by the RBA Code of Conduct, and voluntary improvement is necessary.
High Risk:  Items with a score of 65 or less, and items that do not meet the required level of the RBA Code of Conduct require improvement and monitoring of results.


Click here for more information on detailed CSR evaluation in the supply chain


3. Monitoring of Results and Progress  (Process of respect for human rights described above ④) [Guiding Principle 20]

With the involvement of management, each facility, company, and supplier of Seiko Epson and its affiliates are working to redress or mitigate adverse human rights impacts per corrective plans. For serious adverse impacts, the relevant supervisory department at the headquarters confirms the completion of the remediation.
Epson continues to conduct the CSR self-assessment survey once a year to check the status of correction of non-compliance with the RBA Code of Conduct at each company and facility. Furthermore, seven of Epson's main manufacturing sites in Southeast Asia and China (as of May 2024) had voluntarily undergone RBA's Validated Assessment Program (VAP) audits on an ongoing basis to identify and correct issues from a third-party perspective and improve the level of their activities. To date, Epson has obtained the Platinum recognition, which is awarded when a company achieves a perfect score (200 points) with no RBA Code of Conduct nonconformities, at the production site in Indonesia, Malaysia, Thailand, China, and the Philippines.

Locations currently certified Platinum and Gold


The following are some of the major examples of adverse human rights impacts identified in FY2023 as a result of CSR assessment surveys or RBA VAP audits within the Group, which have been addressed or are being addressed on an ongoing basis.

Adverse impacts Place of Occurrence Status of addressing
Long working hours by employees of business partners Business partners Discussed corrective measures with business partners, and actions have  been taken.
Workers bear the recruitment fees Business partners Reimbursed
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 have been reviewed.


In addition, adverse human rights impacts that have been addressed and provided for remediation include the following

Adverse impacts Place of Occurrence Status of addressing
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 to the individual and changed to a process that does not require advance payment
Inadequate legal requirements in the  contract between staffing agencies and the employees they dispatch Staffing agency Update the contract to comply with the law
Failure to record overtime work Staffing agency Payment of unpaid overtime wages and improvement of the overtime work record system
Errors in the calculation of the amount of withholding at source Staffing agency Adjustment of withholding tax payments, updating of calculation system
Failure to pay legal reserves related to employees Business partners Discussions and improvements have been made with the business partner.
Failure to manage working hours Business partners Discussions and improvements have been made with the business partner.
Failure to pay overtime wages by contractors performing services on premises Business partners Overtime wages have been paid in accordance with the local laws

4. Communication and Reporting  (Process of respect for human rights described above ⑤) [Guiding Principle 21]

The status of our efforts to address the issues requiring corrective actions is reviewed annually by the responsible manager and reported on our website and in our Sustainability Report. Global efforts of the Epson Group are reported in a statement on modern slavery and human trafficking.

Epson Slavery and Human Trafficking Statement


To build and maintain good labor-management relations, Epson proactively provides information to employees and engages in sincere dialogue and discussions. Epson also communicates with customers about the status of Epson's efforts to respect human rights as needed.

New Initiatives in FY2023
Epson recognizes that the risk of human rights violations is highest in such areas as labor, health and safety, and in Japan, Epson has been particularly diligent in its ongoing efforts to combat harassment.

Click here to see our approach to harassment


In FY2023, we also conducted assessments in areas other than those. Specifically, we referred to the 25 categories presented by the Ministry of Justice as "areas of human rights that companies should respect," and selected eight of the following areas: “technology and AI”, “privacy”, “consumers’ rights”, “freedom of expression”, “rights of indigenous people and local residents”, “environment and climate change”, “intellectual property”, and “bribery and corruption”.  After considering the degree of difficulty in remediability and the scale and scope of impact, and considering the relevance to Seiko Epson’s corporate activities, four themes were established: AI, privacy, consumer’s rights, and environment and climate change.

Areas of Human Rights that Companies Should Respect

Prepared with reference to the "Approach required by companies for ‘Business and Human Rights’ today"  (Human Rights Protection Bureau, Ministry of Justice)


Of the four issues the following were discussed with the relevant divisions: the possible adverse impacts of human rights in general; the potential adverse impacts at Epson; laws, regulations, and general mechanisms and frameworks for preventing, stopping, and mitigating adverse impacts; mechanisms and frameworks at Epson; whether or not Epson has a consultation/reporting windows for stakeholders; and whether or not actual consultations/reports have been made.  As a result, we concluded that, although the use of AI, in particular, is currently limited within the company and no serious adverse impact has been observed, we have determined to continue monitoring it. This is because the technology is likely to develop dramatically in the future and have a significant impact on society, and secondly, because for Epson as well there are various possibilities for development, such as internal use and development of other businesses and incorporating it into products, and that these may have an impact on human rights. We will also continue to monitor the other three themes although no serious adverse impacts have been found to date.

Responding to Harassment by Customers

While there are legitimate complaints from customers requesting improvements regarding problems with products and services, there is a very small percentage of cases where requests or behavior that are inappropriate in light of social norms deny individuality or damage the dignity of the employees involved. These impede the continuous provision of services and lead to a deterioration in service quality.
Society's interest in this kind of customer harassment is growing. In fiscal 2024, Epson conducted a questionnaire survey and interviewed mainly with the sales and service divisions of Seiko Epson and its domestic affiliates. As a result, it was confirmed that some Epson employees were also victims of serious customer harassment, including adverse effects on the mind and body. In response to this, Epson has taken the following measures by referring to the  "Manual for Company Measures against Customer Harassment"  issued by the Ministry of Health, Labour and Welfare, and other sources.

・Epson established the "Epson Group Guidelines for Customer Harassment" (March 21, 2025) and disseminated them both internally and externally.
・In case we determine that any behavior constitutes customer harassment, we will take a firm stand against it. We may refuse to provide products or services or respond to customers. 
In addition, if customer harassment continues, if it is malicious, or if  it is judged that it violates criminal laws and regulations, we may deal with it in cooperation with the police, lawyers, etc.
・Employees who experience customer harassment are required to report it to their superiors and the organization takes action, and we have made it known that they can use the consultation desk.
・If necessary, we will give consideration to employees who have been affected, including mental care.
In addition, in order to prevent the Epson Group from causing harassment against its business partners, etc., we will reiterate and thoroughly inform Epson Group employees in harassment education and other activities.



*Please see below for information on the Epson domestic groups in scope.

Site

Domestic Subsidiaries and Affiliates