Respecting Human Rights

Approach and Initiatives

Guided by the corporate purpose statement, Epson is committed to achieving a more sustainable future by addressing societal issues. Epson believes that respect for human rights from the standpoint of each individual is a prerequisite for achieving sustainability and is indispensable as the basis for all business activities around the world. On the other hand, however, Epson recognizes that its operations may cause or contribute to adverse impacts on human rights. Epson believes that respecting human rights in its business activities is an important responsibility that all companies must fulfill.

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.

Organizational structure

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. It is working in concert with corporate departments that supervise sustainability, RBA activities, supply chain CSR and human resources, and building a network with HR departments and related departments of our global affiliates to guide initiatives to prevent human rights abuses.

Epson Group Human Rights Policy

Epson made significant improvements to Policies Regarding Human Rights and Labor Standards of the Epson Group to further strengthen Epson’s human rights efforts in light of recent changes in the way that the international community views human rights and human rights issues. The new Epson Group Human Rights Policy took effect on April 1, 2022, following a resolution by the Seiko Epson Board of Directors pursuant to the Guiding Principles. Complementing Epson’s Management Philosophy and Principles of Corporate Behavior, the Epson Group Human Rights Policy clarifies the company’s approach to respect for human rights and serves as the highest-level guide in those efforts. Pursuant to this policy, Epson’s human rights efforts are focused primarily on the Epson Group and its supply chains.

Human Rights Due Diligence

Epson continually practices human rights due diligence as based on the Guiding Principles. Group companies as well as business partners fall within the scope of this process. Human rights due diligence concerns human rights risks in value chains connected to the business activities of product development, manufacturing, and sales. The due diligence process seeks to identify and study actual and potential adverse impacts on human rights, identify the problems, and prevent and mitigate them.

Epson’s human rights due diligence process is as follows:
1. Identify and assess adverse impacts
2. Make corrective action plan, and prevent, and mitigate adverse impacts
3. Track effectiveness of remediation of adverse impacts
4. Communication and reporting

1. Identify and assess adverse human rights impacts.

In the 2023 fiscal year, Epson again identified adverse human rights impacts and conducted an impact assessment. The information below was consulted for the assessment.

・Awareness and knowledge gained over the past four years through activities as a member of RBA (CSR self-assessments and RBA audits)
・The situation regarding incidents that occur internally and in the supply chain, and the reporting and discussion of such incidents
・Information obtained through publications such as Ministry of Economy, Trade and Industry's Guidelines for Respecting Human Rights in Responsible Supply Chains and its practical reference materials, as well as information obtained through participation in events such as the Caux Round Table (Japan) Stakeholder Engagement Program.

Labor and occupational health and safety were identified as areas that are particularly susceptible to human rights abuses, such as those listed in the table below that affect Seiko Epson’s own employees, Epson Group company employees, agency workers, supplier employees, on-site service vendor workers, and migrant workers. Asia and manufacturing were identified as a susceptible region and business type.

High-Priority Groups Main Adverse Impacts Examples Warranting 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, hazardous work

Overwork

· Violations of laws and internationally recognized human rights norms related to working hours, and long working hours that are detrimental to health

Wages and benefits

· Unpaid overtime wages

· Non-payment or deductions from wages as a disciplinary measure

Inhumane treatment

· Harassment

Discrimination

· Discrimination in dismissal and treatment

· Pregnancy tests, dismissal of pregnant women

Occupational health & safety

· Hazardous and harmful working environment

· Protection of women

· Worker protection in emergency situations



2. Formulate a corrective action plan to prevent or mitigate adverse impacts on human rights.

Since the 2017 fiscal year, Epson has had its overseas manufacturing sites complete a CSR self-assessment questionnaire (SAQ) that conforms to the RBA Code of Conduct and RBA SAQ. After joining the RBA in April 2019, Epson began educating the Epson Group about the RBA Code of Conduct and working to integrate it into Group operations. Epson has continued to ask Seiko Epson plants and offices, domestic and overseas Group companies, as well as suppliers to complete an annual CSR SAQ. This CSR SAQ conforms to the RBA SAQ and the results are reported to the RBA. Each Seiko Epson office, Group company, and supplier has a due diligence process to identify the location of adverse impacts on human rights and to develop corrective action plans to remedy or mitigate the identified negative impacts.

FY2023 CSR Self-assessments by Epson Group Companies

Items Details
Questionnaire content

A. Freely chosen employment, young workers, working hours, wage and benefits, humane treatment, non-discrimination, freedom of association, etc.

B. Health & Safety: Occupational safety, occupational injury and illness, dormitory & canteen, etc.

C. Environment: 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.

When the SAQ is conducted

Survey:April – June, 2023

Analysis and corrective action: July, 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 SAQ
Corrective action Formulate a corrective action plan, andprevent or mitigate adverse impacts on human rights under supervision of Seiko Epson corporate supervisory departments.


Summary of FY2023results:
- The FY2023 CSR SAQ showed that there were no high-risk Epson site.
- 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.

Changes in the CSR self-assessment results from FY2020 onward are as shown below. The risk level is decreasing as a result of corrective actions taken.

* Low risk: over 85 points, basically meeting the requirements of the RBA Code of Conduct, and is able to independently correct weaknesses.
Middle risk: over 65 and under 85 points, not meeting all the requirements of the RBA Code of Conduct, but is able to independently correct weaknesses.
High risk: under 65 points, needed to be monitored based on an improvement plan to meet the requirements of the RBA Code of Conduct.

3. Monitor results and progress.

Seiko Epson sites, Group companies, and suppliers have engaged management and are working to correct and mitigate adverse impacts on human rights in accordance with corrective action plans. The corporate supervisory department monitors the progress of corrective action to address significant adverse impacts and see them through to completion.
Epson continues to administer a CSR SAQ once a year to check corrective actions at Epson sites and address nonconformances to the RBA Code of Conduct. Furthermore, in order to identify and correct issues from a third-party perspective and enhance the level of actions being taken, seven of Epson’s main manufacturing sites (as of May 2024) located in Southeast Asia and China have been voluntarily undergoing audits under the RBA's Validated Assessment Program (VAP). So far, Epson’s manufacturing facilities in Indonesia, Malaysia, Thailand, China, and the Philippines have all earned Platinum or Gold recognition. Platinum is exclusively reserved for factories that are compliant with the RBA Code of Conduct and receive a perfect score of 200.

Epson sites that currently hold Platinum and Gold status

Site Name Main Products Manufactured Certification Expiration Date
(Country) (Score)
PT. Indonesia Epson Industry

Inkjet printers, large format printers, small printers, impact dot matrix printers

Platinum 28 February 2026
(Indonesia) (200)
PT. Epson Batam

Inkjet printer ink cartridges and ink bottles, scanners

Platinum

16 March 2025

(Indonesia) (200)

Epson Engineering (Shenzhen) Ltd.

Inkjet printers, large format printers, 3LCD projectors, industrial robots Gold 7 December 2024
(China) (196.5)



Below are some examples of situations that have an adverse impact on human rights that were identified in the 2023 fiscal year through CSR assessments or RBA audits and that have been remediated or are being addressed.

Situation Location How it Was or Is Being Addressed
Long working hours for a subcontractor’s employees On-site subcontractor Discussed and implemented corrective action with the subcontractor
Workers are charged recruitment fees On-site subcontractor Fees were reimbursed
Violation of the Worker Dispatch Act Manufacturing company Ensure outsourced operations within the scope of the law.
Nonconforming emergency exit door along a factory evacuation route Manufacturing company The structure of the emergency exit door has been changed.



The table shows examples of adverse human rights impacts that we have addressed and corrected to date.

Situation Location How it Was or Is Being Addressed

Requiring migrant workers to pay broker and recruitment fees to recruitment agencies

Manufacturing company Stopped requiring fees from migrant workers and reimbursed them
Holding passports that belong to migrant workers Manufacturing company Strictly prohibited the confiscation of passports
Agreement process with workers regarding overtime work Sales company Stated the process for requiring overtime
Workers were required to temporarily pay the cost of a physical checkup on behalf of their employer at the time of employment Manufacturing company Reimbursed the workers and changed the process to eliminate advance payment

Contracts between a labor agent and its workers did not meet all legal requirements.

Labor agent Modified the contract document to comply with the law
Inadequate overtime records Labor agent Paid the unpaid overtime wages and improved the overtime recording system
Error in the calculation of withholding amounts Labor agent Adjusted withholding payments and updated the calculation system
Unpaid statutory reserves for employees On-site subcontractor Discussed with the subcontractor and corrected
Inadequate working hours management On-site subcontractor Discussed with the subcontractor and corrected
Unpaid overtime wages for an on-site service vendor On-site subcontractor Paid overtime wages based on the local law

4. Communication and reporting

Epson’s efforts to address issues requiring corrective action are reviewed annually and reported on Epson’s websites and in its Sustainability Report. The Epson Group’s global efforts are also reported through statements on modern slavery and human trafficking.



To build and maintain good labor-management relations, Epson actively provides information to its employees and engages them in sincere talks and discussions. Epson also communicates with customers as needed about its efforts to respect human rights.



Epson recognizes that areas such as labor and health and safety pose the highest risk of human rights abuses. In FY2023, we assessed risks in other areas too. The Ministry of Justice defined 25 human rights categories that companies should respect. Referring to those and considering the severity (degree of difficulty in recovering human rights) and the extent of the impact, as well as the relevance to our business operations, we selected AI, privacy, consumer safety (product safety and marking in particular), and the environment and climate change as our four main subjects.

Human rights categories that companies should respect



We discussed the four subjects with relevant departments and determined the current state in Epson. Examples of subjects discussed include generally assumed adverse human rights impacts; adverse impacts in which Epson could be involved; general mechanisms and frameworks for preventing, stopping, and mitigating adverse impacts; mechanisms and frameworks at Epson; reporting channels for stakeholders; and the actual state of reporting. As a result of the discussions, we found no serious adverse impact of AI since its use is currently limited in-house. Nevertheless, we will keep monitoring it because there is a possibility that AI will be deployed in our businesses and incorporated into our products, which could cause adverse human rights impacts. We have not found any serious adverse impacts in the other three subjects at this time, but we will continue to monitor them.

Grievance mechanism

Epson has set up numerous grievance mechanisms. In addition to the Epson Helpline, the company has specialized advisory services to handle human rights-related inquiries and reports from employees (including contract employees, part-time employees, temporary employees, agency workers, etc.). There are advisory services for harassment, long working hours, foreign employees, diversity issues, among others. The Epson Helpline and the diversity advisory service can also be used to report or discuss human rights related issues that are not covered by the specialized advisory services. The advisory services take into consideration the wishes of the person making an inquiry or reporting an incident as they ascertain the facts and act to remedy the situation and prevent recurrences. In FY2023, we exchanged information with these advisory services and launched an effort to understand the overall situation regarding reporting on human rights.

Epson has established supplier compliance hotlines that suppliers and their employees can use to seek remediation. Customers, investors, community residents, and other stakeholders can access advisory services on the corporate website. In addition, they can file grievances via an Engagement and Remedy Platform provided by the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER), which Epson joined as a member in April 2024. JaCER is an organization that aims to provide a cooperative "Engagement and Remedy Platform" involving multiple member companies for redress of grievances and to act in a professional capacity to support and promote redress of grievances by member companies based on the Guiding Principles on Business and Human Rights. Epson will use these advisory services and platforms to appropriately respond to reports and concerns regarding human rights from a wide range of stakeholders.
The information contained in reports is strictly protected at advisory services, reprisals against whistleblowers are prohibited, and anonymity is ensured.

Education

We have been educating our global workforce of people working in areas such as human resources, health and safety, environment, ethics, and supply chain management about the RBA Code of Conduct and its requirements. In 2021, we revised the Epson Group Human Rights Policy. We took this as an opportunity to hold further study sessions on the subject of business and human rights for directors and personnel in corporate and global HR departments. 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 who completed the course was 18,473 as of September 2023. In the 2023 fiscal year, the course on business and human rights was offered online to managers and above at seven of Epson’s main overseas manufacturing and sales affiliates. The course completion rate was 92.7% as of the end of June 2024. In FY2024, Epson plans to implement the course at all overseas affiliates.

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), Dutch Child Labour Due Diligence Law (Wet Zorgplicht Kinderarbeid), and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Initiatives to Prevent Power Harassment

Employee Advisory Service

Epson seeks to create a fair and pleasant working environment. Toward this end, we have set up an advisory service and are addressing grievances to prevent and stamp out power harassment. In FY2024, we added a new external reporting channel to accept anonymous claims. We also provide training to personnel who handle grievances to improve their skills and reduce their stress. We do so by sharing examples of how claims have been handled in the past and sharing information on legal changes.

Power Harassment Prevention Training

We provide Group-wide training on the prevention of power harassment that is tailored to the different echelons.
For executive management, the training provides an opportunity to think about how to create an organization that is free of power harassment. For middle managers, the training reminds them of the seriousness of the impact that power harassment can have. After sharing power harassment examples, participants engage in discussions and consider preventative actions. In addition, we require all employees to take an online course every year. We also provide executives and employees who will be assigned overseas with training tailored to their needs and local circumstances.
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.

Harassment Recurrence Prevention

Human rights abuses including harassment and labor-related grievances are regularly reported to executive management. This information and company responses are shared with managers and disclosed company-wide to prevent similar incidents in the future. We require Group companies to report all material harassment incidents. There have been no omissions in reporting in recent years.

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 800 times up to the end of FY2023. 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 13,000 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 Anger Management Business Leadership Award Grand Prize for it from the Japan Anger Management Association in June 2023.

Power Harassment Prevention Training/Anger Management Training (after 2015)

Current as of March 31, 2024

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 FY2023 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.