Respecting Human Rights

Approach and Initiatives

We at Epson believe that respecting human rights in everything we do is an essential part of our corporate responsibility. This commitment is reflected in our purpose and the Epson Way. We established Policies Regarding Human Rights and Labor Standards of the Epson Group in 2005 based on the United Nations Global Compact, and we have been practicing conduct that is aligned with the 2011 United Nations Guiding Principles on Business and Human Rights ("the Guiding Principles"). In April 2019, we joined the Responsible Business Alliance (RBA), a non-profit organization that supports the rights and welfare of workers and communities affected by global supply chains, and we and our suppliers conduct our business in line with the RBA Code of Conduct.

Epson is continually strengthening its measures to support human rights in response to new challenges in the ever-changing global business environment. Epson Group, The Policies Regarding Human Rights and Labor Standard, was re-established and approved by the board of directors as the Epson Group Human Rights Policy on April 1, 2022, based on the United Nations Guiding Principles on Business and Human Rights.

Epson's human rights initiatives are spearheaded by Seiko Epson's DE&I strategic promotion department under the supervision of the executive officer in charge of human capital & well-being management. They work in concert with corporate supervisory departments and the HR departments of our global affiliates to guide initiatives to prevent human rights abuses and unjust labor practices. Epson uses the Epson Group Human Rights Policy and the RBA Code of Conduct to identify potential human rights risks such as child labor, forced labor, other exploitative labor, workers' rights abuses and unfair labor conditions, discrimination, and inhumane treatment including harassment. Seiko Epson and Epson Group companies conduct an annual CSR assessment survey to evaluate and mitigate these human rights and labor risks*. Workers and the labor union and other labor groups are important stakeholders, and Epson Group companies engage them in genuine dialog and discussions based on local labor practices and so forth.

* Results of the FY2022 CSR assessment showed that there were no major cases of human rights violations in the form of child labor, forced labor, discrimination, and the like, either at Epson or its Group companies.

We have been educating people particularly in the human resources departments at Seiko Epson and Epson Group companies at home and abroad about the RBA Code of Conduct and its requirements, and in 2021 we also held study sessions to familiarize members of the board, personnel in Seiko Epson's corporate functions, and certain personnel at our global affiliates with the revised Epson Group Human Rights Policy. In the 2022 fiscal year, we conducted an online course for all officers, employees, contract employees, and temporary staff, who work at Seiko Epson and all other group companies in Japan, to raise awareness of human rights and prevent human rights abuses. Through this course, participants learned about the fundamentals of business and human rights, as well as about Epson's efforts to respect human rights, which are essential for conducting global business. The number of employees and workers completed the course was 16,539 as of March 2023. Understanding of business and human rights issues was deepened further by holding a human rights seminar led by an outside expert. The seminar, which any employee could attend, incorporated information on things such as recent trends and case studies.

Epson has set up the Epson Helpline and various other channels that can be used to report harassment, long working hours, and other concerns involving issues such as human rights and labor. Incidents related to human rights violations such as harassment and labor are reported to executive management once a year, and these incidents and the company's response to them are shared with middle managers periodically. We then disclose these incidents company-wide through our in-house magazine to raise awareness of them and work to prevent similar incidents from occurring and recurring. If a major incident of harassment occurs, we make sure to report that to our group companies. There have been no particular omissions in these reports over the past few years.
Furthermore, Epson has whistleblowing systems that customers, investors, people in the local community, and other stakeholders can use to report grievances, which Epson then appropriately addresses.

We are working on these human rights risks throughout the Epson Group because we consider them to be a key sustainability topic. To also address potential human rights issues in the supply chain, we have our socially responsible procurement supervisory department notify and educate suppliers regarding Epson's human rights policies and code of conduct. We also have them assess risks and drive improvements where needed. Finally, we have established whistleblowing systems that suppliers can use to report human rights abuses.

Epson Slavery & Human Trafficking Statement

Epson issues annual slavery and human trafficking statements. These statements disclose Epson's modern slavery and human trafficking policy and report the results of actions taken to eradicate these from the supply chain pursuant to the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, and the U.S. California Transparency in Supply Chain Act 2010 (SB 657).

Human Rights Due Diligence

Epson continually practices human rights due diligence as based on the United Nations Guiding Principles on Business and Human Rights. Group companies as well as business partners fall within the scope of this process. Human rights due diligence concerns human rights risks like forced labor, child labor, harassment, and discrimination in value chains connected to the business activities of product development, manufacturing, and sales. The due diligence process seeks to identify and study potential and emerging adverse impacts on human rights, isolate the problems, and correct, improve, and prevent them.

The human rights due diligence process in Epson's business is as follows:

  1. Establish policies
  2. Identify adverse impacts on human rights and assess their impact
  3. Plan improvements and stop, prevent, and mitigate negative impacts
  4. Monitor results and progress
  5. Communicate and report
  6. Take remedial action

Specific aspects of human rights due diligence are as follows:

(1) Establishing policies and making commitments
Epson Group Human Rights Policy (revised in 2022)
Epson respects the human rights set forth in the International Bill of Human Rights and in the ILO Declaration on Fundamental Principles and Rights at Work. Our human rights initiatives are compliant with the United Nations' Guiding Principles on Business and Human Rights. In particular, as a regular member of the Responsible Business Alliance (RBA), Epson is obligated to observe the RBA Code of Conduct and various standards and procedures which it enacted with reference to those international human rights norms.

(2) Method of identifying and assessing adverse impacts on human rights
When we assess adverse impacts on human rights, we focus particularly on employees of Seiko Epson Corporation and Epson Group, temporary workers, on-site vendors' employees, supplier employees, and migrant workers, because of all Epson stakeholders (customers, shareholders and investors, local communities, business partners, NGOs and non-profits, employees, etc.), it is they who should be given greatest priority in terms of human rights.

High-priority groups Adverse Impacts of business activities Assessment method
Employees of Seiko Epson Corporation and Epson Group Freedom of employment (forced labor), young workers, working hours, wages and benefits, humane treatment (harassment, etc.), discrimination, freedom of association

Self-assessment of compliance to RBA requirements

Temporary workers Same as above Same as above
On-site service vendors' employees Same as above Same as above
Suppliers' employees Same as above Same as above
Migrant workers Same as above Same as above

Epson administers a CSR self-assessment questionnaire compliant with the RBA Code of Conduct and SAQ template. We started asking suppliers in turn to fill it out in FY2015 and began asking overseas manufacturing sites to do so in FY2017. Since then, we have continued taking similar annual CSR self-assessment questionnaire of business sites, Group companies in Japan and overseas, and suppliers.

(3) Improvement plans, and stopping, preventing, and mitigating adverse impacts
We instruct companies and business sites to take action to correct, improve, or mitigate adverse impacts identified by the CSR self-assessment questionnaire. We analyze the answers on the questionnaire, identify where a site is not in conformance with the code of conduct, and provide guidance for the corrective actions we request. Sites formulate and implement their own corrective action plans to address the observations. Progress on correcting major nonconformances is monitored until completion is confirmed.

The following are examples of adverse impacts on human rights that have been identified, corrected, improved, or continuously addressed within the Epson Group in FY2022:

  • Nonpayment of overtime by an on-site service contractor
  • Inadequate management of working hours
  • Nonpayment of legally required employee contributions (contractor)
  • Nonconforming emergency exit door along a factory evacuation route

The following are examples of human rights risks that we have addressed to date:

  • Requiring migrant workers to pay broker and recruitment fees to recruitment agencies
  • Holding migrant workers' passports
  • Agreement process with workers regarding overtime work
  • Long working hours
  • Contracts between a labor agent and its workers did not meet all legal requirements.
  • Inadequate overtime records (labor agent)
  • Error in the calculation of withholding amounts (labor agent)
  • Workers were required to temporarily pay the cost of a physical checkup on behalf of their employer at the time of employment

(4) Monitoring
Epson continues to take CSR self-assessment questionnaire once a year and to confirm improvements being made by companies and sites that do not meet the RBA Code of Conduct. Moreover, major manufacturing sites voluntarily undergo the RBA's Validated Assessment Program (VAP) audit. These assessments help the subject company accurately grasp how well they are conforming to the RBA Code of Conduct and identify issues for correction and improvement.

(5) Communication and reporting
Each year, after the responsible executive officer has reviewed the results and progress of efforts to carry out improvement plans, the findings are disclosed on the web and released as a Sustainability Report. We also report on the Epson Group's global initiatives in our Epson Slavery & Human Trafficking Statement.

(6) Taking remedial action
Epson has set up a whistleblowing system that are particularly geared toward employees of Seiko Epson Corporation and Epson Group, temporary workers, on-site vendors' employees, supplier employees, and migrant workers, as well as stakeholders including customers, investors, and local communities. We respond appropriately to any grievances.

CSR Self-assessments by Epson Group Companies

Epson has all its Epson Group plants, offices, and companies around the world complete a self-assessment questionnaire to evaluate their performance with respect to CSR requirements since 2017. The purpose of the SAQ is to identify and address risks and potential threats in areas such as human rights.
Every year since joining the Responsible Business Alliance (RBA) as a regular member in April 2019, Epson has used the RBA Self-Assessment Questionnaire (SAQ) to assess Epson Group compliance with RBA requirements and has reported the results to the RBA. The questionnaire is based on the RBA Code of Conduct and consists of 400 questions concerning human rights, labor, health and safety, environmental issues, ethics, and management systems for them. The RBA mandates that manufacturing sites complete a self-assessment. However, Epson uses the same SAQ to also evaluate its sales sites and other plants, offices, and subsidiaries so that all are held to the same standard.

Questionnaire content

Major category
Minor category examples
A: Labor Freely chosen employment, young workers, working hours, wage and benefits, humane treatment, non-discrimination, freedom of association
B: Health and safety Occupational safety, occupational injury and illness, dormitory & canteen, etc.
C: Environmental Environmental permits & reporting, pollution prevention & resource reduction, hazardous materials, wastewater & solid waste, air pollution, energy consumption & greenhouse gas emissions, etc.
D: Ethics Business integrity, intellectual property, fair business, advertising & competition, responsible sourcing of minerals, privacy, etc.
E: Management system Company commitment, management accountability & responsibility, risk assessment & risk management, training, supplier responsibility, etc.

SAQ overview

Items Details
When the SAQ is conducted April - June, 2023
Surveyed business units 11 Seiko Epson facilities
8 domestic affiliated companies (6 manufacturing companies and 2 sales companies)
49 overseas subsidiaries (17 manufacturing companies and 32 sales and other companies)
Questionnaire form RBA Self-Assessment Questionnaire (SAQ)
Analysis August  - September, 2023
Corrective action Plants, offices, and subsidiaries will begin taking corrective action from Oct. 2023
Status check The status of corrective action will be checked by having companies complete another SAQ in April 2024

Rankings based on SAQ scores

Risk rank Assessed points Explanation
Low risk 86-100 pts. It basically meets the requirements of the RBA Code of Conduct.
It is able to independently correct weaknesses.
Medium risk 66-85 pts. It does not meet all the requirements of the RBA Code of Conduct but is able to independently correct weaknesses.
High risk 65 pts. or less It needs to be monitored based on an improvement plan to meet the requirements of the RBA Code of Conduct.

2023 SAQ results

Risk rank Total score Seiko Epson Domestic affiliates Overseas subsidiaries Grand total
Manufacturing Sales and others total Manufacturing Sales and others total
Number of
% Number of
% Number of
% Number of
% Number of
% Number of
% Number of
% Number of
Low risk 86-100 pts. 11 100 6 100 2 100 8 100 17 100 23 72 40 82 59 87
Medium risk 66-85 pts. 0 0 0 0 0 0 0 0 0 0 9 28 9 18 9 13
High risk 65 pts. or less 0 0 0 0 0 0 0 0 0 0 0 0 0 0  0 0
Total 11 100 6 100 2 100 8 100 17 100 32 100 49 100 68 100


- All Epson plants, offices, and Group companies were found to be either middle risk or low risk as a result of the CSR self-assessment questionnaire. No serious human rights, compliance or ethics problems were found.
- In the 2022 fiscal year, 14 sales sites were found to be medium risk. The Seiko Epson Head Office thus took the following actions to enable these sites to earn a low-risk rank so that the score of all of those 14 sales sites was improved and 5 of them became low risk:
(1) Familiarized the sites with Epson Group regulations and provided guidance to meet them
(2) Explained the SAQ questions and corrected answers where the answers did not match the actual situation

In total, the number of middle-risk sites decreased from 20% in the previous year to 13% this year.

- In the 2023 fiscal year, we will build further awareness and understanding of Group policies, Group regulations, rules, guidelines and so forth at our business sites to eliminate potential priority non-conformances and further reduce the number of medium-risk sites.

Initiatives to Prevent Power Harassment

Power Harassment Prevention Training

Epson seeks to create a fair and pleasant working environment. Toward this end, we have set up a harassment advisory service and are addressing claims to prevent and stamp out harassment. Power harassment prevention training seminars have been rolled out to Epson Group companies. Every year, we have all personnel, including those in non-management roles, take an annual online harassment prevention course. Meanwhile, we also provide echelon-based training seminars tailored to executive management, middle management, leaders, and employees preparing to work overseas, respectively. In training sessions for middle managers, we reiterate the magnitude of the impact from power harassment. These sessions are an opportunity for participants to share incidents through discussions and to consider the necessary measures against them. Training sessions for executive managers are opportunities for the top management of organizations to personally think about how to create organizations with no power harassment. In addition, since FY2021, we have been working to create a power-harassment-free organizational climate by taking individually tailored action in each workplace. This action takes many forms, including individual follow-up with workplaces in which health management information indicates that stress levels are high and the establishment of consultation services for managers.

Anger Management Training

Anger management training is said to be an effective way to prevent so-called power harassment (abuse of authority at work).
Seiko Epson has provided anger management training sessions since FY2015 to teach employees skills needed to control feelings of anger at work. We have held echelon- and department-based anger management training 670 times up to the end of FY2022. An introductory course teaches people the skills they need to defuse their anger and improve their control long-term, while a course in constructive criticism teaches managers and others effective communication skills. More than 11,000 Epson Group employees in Japan have taken a course. By providing its people with the proper training and skills, Epson hopes to eliminate power harassment from the workplace.

This initiative has been recognized externally. We received the 1st Japan Angermanagement Business Leadership Award Grand Prize for it from the Japan Anger Management Association in June 2023.

Security Personnel Trained in Human Rights

Seiko Epson outsources security operations to security companies and asks them to train those employees in human rights policies or procedures. In FY2022 we conducted a CSR self-assessment questionnaire to confirm that thoses suppliers, as well as other suppliers of indirect materials, provided human rights training to those people.