• Approach and Actions for Respecting Human Rights
• Addressing identified human rights issues

Epson has declared in its Human Rights Policy that human rights should be respected not only by Epson but also by its suppliers. In line with the United Nations Guiding Principles(UNGPs) on Business and Human Rights [UNGPs 16(c)], our Human Rights Policy states our commitment to complying with UNGPs and respecting internationally recognized human rights as set out in the International Bill of Human Rights (the Universal Declaration of Human Rights and the two International Covenants). Moreover, as a member of the Responsible Business Alliance (RBA), we adhere to the RBA Code of Conduct, which calls for workers to be treated with respect and dignity, and we expect our suppliers to do so as well. 
Through these efforts, we aim to ensure that human rights are respected throughout the supply chain of Epson products.

1. Establish and Commit [UNGPs 16] (Step 1 in the process of human rights due diligence)

Epson believes that respecting human rights throughout its business operations is a fundamental corporate responsibility. This commitment is reflected in Epson Group’s Management Philosophy and Principles of Corporate Behavior. In 2005, we established “Policies Regarding Human Rights and Labor Standards” for the Epson Group based on the United Nations Global Compact, and we began practicing them the same year. 
In April 2019, we joined the Responsible Business Alliance (RBA), a non-profit organization that supports the rights and well-being of workers and communities affected by the global supply chain, and we are working with our suppliers to promote business activities in accordance with the RBA Code of Conduct. 

Furthermore, Epson is strengthening its human rights initiatives to respond to new challenges in the ever-changing global business environment. As part of this, we revised the Epson Group Management Philosophy and Principles of Corporate Behavior to align it with the United Nations Guiding Principles on Business and Human Rights, and renamed it the Epson Group Human Rights Policy by resolution of the Board of Directors on April 1, 2022. 

In addition, we established the Epson Group Supplier Guidelines, consisting of the RBA Code of Conduct and Epson's own policies. We ask our suppliers to comply with the Guidelines and to provide us with a written agreement to do so.

2. Human Rights Due Diligence [UNGPs 17-21] (Step 2 in the process of human rights due diligence)

Among all stakeholders involved in our business activities (including customers, shareholders and investors, local communities, business partners, NGOs and NPOs, and employees), we have found that, from a human rights perspective, addressing adverse impacts in the supply chain is currently a high priority.

Under the requirements for a Regular Member of the Responsible Business Alliance (RBA) on supplier management¹ , Epson verifies that its suppliers are compliant with each section in the RBA Code of Conduct (labor and human rights, health and safety, environment, ethics, and management systems). We work to remedy and redress any issues and ascertain whether suppliers are respecting the human rights of foreign migrant workers and residents. For over 10 years, we have been conducting annual human rights impact assessments using detailed CSR evaluations and other measures for our major suppliers. These include not only direct material suppliers such as parts and manufacturing contractors but also other business partners (on-site service providers, human resources agencies such as recruitment agencies and staffing agencies, logistics companies, etc.). In addition to a self-assessment questionnaire (SAQ) that suppliers complete on a designated form, the human rights impact assessments include on-site verification and audits based on the answers to the SAQ. The identified adverse impacts are remedied, corrective action plans are formulated, and recurrence prevention measures are taken. 

IIn addition to identifying adverse impacts through assessments, Epson recognizes the importance of reporting through grievance mechanisms and other means as measures for human rights impact assessment.
¹ Overview of RBA Regular Member obligations

3. Evaluation Results, Prevention/Remediation [UNGPs 18, 19] (Step 3 in the process of human rights due diligence)

Through the assessments, we identify adverse human rights impacts in the supply chain, ask suppliers to take preventive, remedial or mitigation measures, and verify their completion.

4. Monitoring [UNGPs 21] (Step 4 in the process of human rights due diligence)

Epson continues to conduct an annual SAQ to check supplier compliance with the RBA Code of Conduct. We have also received confirmation of compliance with the RBA Code of Conduct E12 (Supplier Responsibility) and D7 (Responsible Mineral Sourcing), among others, during ongoing VAP audits at Epson manufacturing sites. Indirect workers (including on-site security personnel, cafeteria staff employed by partner companies, and dispatched workers) are included in the scope of the audits, which are used as a means to identify adverse human rights impacts that we can then redress. 
In addition, information reported through grievance mechanisms and other channels is used as a means of measuring the effectiveness with which adverse human rights impacts are addressed.

5. Communication and Reporting (Step 5 in the process of human rights due diligence)

Every year, management reviews our progress and achievements in the area of human rights both in our supply chain and within our own companies. The results are then disclosed on the Web. Regarding modern slavery and human trafficking, Epson publishes an annual statement on the Modern Slavery Act of each country, including the United Kingdom, and reports on Epson Group's efforts to address this issue.

6. Remedy [UNGPs 22, 29, 30, and 31]

As a part of the grievance mechanisms, Epson Group companies worldwide have set up supplier reporting systems that suppliers can use to report or consult about issues. Reports can be made anonymously and in the local language, and we make it known that retaliation for reporting is strictly prohibited. We promote dialog and remedies as a member of the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER), a complaint-handling platform that complies with with UNGPs 30.

Epson has developed a program for suppliers who are high-priority targets for addressing adverse human rights impacts and is promoting activities worldwide.

1. Informing Suppliers of the Epson Supplier Code of Conduct and Obtaining an Agreement to Comply

The Epson Supplier Code of Conduct was revised in 2024 and is aligned with the latest RBA Code of Conduct. To ensure broad understanding among suppliers, we publish the Code of Conduct on our website, and Epson Group companies in Japan and abroad communicate the guidelines to all suppliers. We also obtain a written agreement to observe the Epson Supplier Code of Conduct from more than 3,000 supplier companies.

2. Education through human rights seminars

Every year, Epson conducts a human rights seminar for suppliers, inviting outside experts as guest speakers. 
At the seminar, in addition to the policy and status of Epson's initiatives, we provide information about Epson's approach to human rights as well as the latest domestic and international trends surrounding human rights. 

More than 300 suppliers participate in the seminar every year, and in FY2025 about 500 people from 300 companies attended.

＜Seminar program＞

3. Due Diligence through SAQs and Remediation

Epson has been conducting supplier due diligence for over 10 years. 
We use an SAQ to check compliance with the RBA Code of Conduct and to understand what our suppliers are doing with respect to human rights. In addition to checking the implementation status of human rights remedies, we provide feedback to each supplier on matters that require response, request that they take action, and confirm whether actions have been taken. The RBA Code of Conduct covers a wide range of human rights matters, particularly in the Labor section, but we also identify and evaluate particularly salient human rights issues based on the literature, such as the ILO Core Labor Standards and the principles of the United Nations Global Compact.

• Reimbursement of Foreign Workers for Recruitment Fees 
  An SAQ revealed a case in which foreign workers hired by a manufacturing contractor that operates at an Epson manufacturing site in Japan had paid recruitment-related fees (such as commissions, language training fees, and visa acquisition fees) in their home countries. 
  → Remedy and/or corrective action: We discussed the matter with the manufacturing contractor, which provided evidence showing that the workers were reimbursed. The manufacturing contractor also agreed to ensure that workers would not be charged recruitment fees in the future.
• Employment Contracts
  An SAQ revealed cases across multiple suppliers (in Japan, the Philippines, Indonesia, Myanmar, and Vietnam) where employment contracts had not been executed or copies of employment contracts had not been provided to workers. 
  → Remedy and/or corrective action: We asked the suppliers to execute employment contracts and provide copies to their workers. We later verified that the situation was remedied.
• Provision of days off
  A VAP audit of a manufacturing site in Thailand revealed that an on-site security services contractor had not been paying overtime wages and holiday pay and, moreover, had not been providing days off. 
  → Remedy and/or corrective action: We asked the contractor to provide overtime wages, holiday pay, and days off. We later verified that the situation was remedied.
  
  

Risk-based priority case (Malaysia, 2025)

The risk of human rights abuses involving foreign migrant workers was found to be high in Malaysia based on the findings of the 2025 human rights impact assessment. We therefore asked all suppliers in Malaysia to complete a human rights-focused SAQ. We asked suppliers to develop and submit corrective action plans for issues found based on the SAQ, and we continued to monitor the situation until verifying that corrective actions were completed.

• Companies that held workers’personal documents (such as passports) returned those documents and prohibited the future collection of such documents.
• Companies established policies regarding freedom of movement, religious accommodation, and protection of pregnant workers.
• Companies provided mechanisms to accept anonymous reports within their whistleblowing system.
  
  

4. Remedies through Supplier Reporting Channels [UNGPs 22, 29 and 31]

We accept reports from business partners in local languages, and we publicize and strictly enforce a policy of non-retaliation against whistleblowers. We strive to provide a reporting system that is easily accessible for all stakeholders. In addition to promoting system awareness and use through the Epson Group Supplier Guidelines and conferences, we also accept reports via our website. We assist in reaching remedies for adverse human rights impacts that are identified through reports from partners’ employees or their legitimate representatives as well as through audits. 

• Non-payment of wages due to unrecorded working hours
  Working hours were not recorded by an on-site manufacturing contractor due to a malfunction of the recording system, so the contractor did not pay overtime wages for that period.
  → Remedy and/or corrective action: We learned about this issue through a reporting channel, and we verified that the outstanding wages were paid and that corrective action was taken to prevent recurrence.
• Allegation of forced labor involving foreign migrant workers
  Allegations were made about forced labor involving foreign migrant workers at a component supplier in Malaysia.
  → Remedy and/or corrective action: We learned about this issue through a reporting channel, so we spoke with the supplier to gather the facts. We were able to verify that the supplier's site that was allegedly engaging in forced labor was not involved in the production of parts for Epson, nor was it involved in any other activities related to Epson. We also verified that the site that does produce parts for Epson did not employ, either directly or indirectly, any foreign workers. Furthermore, a CSR audit developed by the RBA and focused specifically on forced labor (S-VAP for forced labor) was conducted at the site that manufactures parts for Epson. While some management issues were identified, no instances of forced labor were found.