To our stakeholders:

I am pleased to confirm that NEC Europe Ltd reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations.

We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Chris Jackson
President and CEO

NEC Europe Ltd. provides “Solutions for Society” that promote the safety, security, efficiency and equality of society. Further information on our activities can be found on our website: https://uk.nec.com/.

We are the regional headquarters of the NEC Group in the EMEA region, and a wholly owned subsidiary of NEC Corporation. Our approach to human rights sits within NEC Corporation’s wider Human Rights agenda for the NEC Group.

NEC upholds the United Nations’ (UN) International Bill of Human Rights, the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work, and the Ten Principles of the UN Global Compact. NEC also seeks to improve its in-house initiatives on respect for human rights by taking into account trends in international standards and laws, such as the UN’s Guiding Principles on Business and Human Rights and Sustainable Development Goals.

We aim to contribute to the progression of respect for human rights in society, to promote compliance with global requirements and to pursue sustainable and ethical procurement activities with the cooperation from our supply-chain partners.

NEC has a variety of policies and procedures that support human rights, including the NEC Way, the NEC Group Human Rights Policy, The NEC Group Procurement Policy and the Guidelines for Responsible Business Conduct in Supply Chain.

We have implemented other key policies that pertain to sustainability, health and safety, whistleblowing and dealing with emergency response.

We require that all our employees comply with the NEC Way, the NEC Group Code of Conduct, the NEC Group Human Rights Policy and the NEC Group Procurement Policy.

The process for speaking up, the investigation of whistleblowing reports and the implementation of remedial actions is described in our whistleblowing policy, which protects employees from retribution in case they raise a concern about human rights issues.

We use Safecall as our third party confidential reporting line, supported by our own internal whistleblowing committee led by senior managers from Human Resources, Finance, Sustainability, Legal and Compliance.

We communicate the Guidelines for Responsible Business Conduct in Supply Chains to our business partners, including suppliers, in order to promote sustainability activities and human rights. We only accept candidate suppliers after having performed due diligence and we engage with them to obtain visibility of their supply chains beyond first tier where relevant. We expect our selected suppliers to meet our conditions of supply throughout the duration of their relationship with us and we ask for their support in reporting serious incidents to us in a timely manner. Suppliers’ concerns can be reported either via an internal responsible business contact line, the Legal division of NEC Europe, or Safecall.

Our due diligence approach within our own organization and in the supply chain has not revealed occurrences of breaches of human rights. We have confirmed this information by engaging with our staff and suppliers, including through audits and by reviewing the suppliers’ monthly reports.

We have promoted work life balance and provided training and wellbeing opportunities to our staff.

We have monitored the data pertaining to our online Code of Conduct training and we have included the review of social and governance matters, including human rights, in the core agenda of the Board of Directors meetings. These matters are also discussed during other meetings which involve a balanced representation of staff and management.

Our human resources processes protect key labor and human rights issues such as freedom of workers to terminate employment, of movement, of association, prohibition of any threat of violence, harassment, and intimidation, of the use of worker-paid recruitment fees, of compulsory overtime, of child labor, of discrimination, and the provision of access to remedy.

We promote a culture of responsible behavior through a variety of internal initiatives (such as themed talks, meetings, training) and the use of internal communication tools (intranet, display screens, emails and newsletters). We have made our external confidential reporting line, Safecall, available to our suppliers in the context of their relationship with us.

We publish an annual statement on Modern Slavery and Human Trafficking referring to Section 54 of the Modern Slavery Act 2015.
https://uk.nec.com/en_GB/emea/about/policy/modern_slavery_and_human_trafficking_statement.html

We use International Labor Organization (ILO) indicators of forced labor in our vendor assessments.

90% of our key suppliers in terms of annual spend have confirmed that they either comply with the NEC Group Responsible Business Guidelines or that they have similar guidelines in place.

We have not received any claims on forced or compulsory labor either through the normal reporting process or through Safecall.

We seek to reduce the environmental impacts of our business activities as part of our corporate responsibility activities.

We also seek to reduce the environmental impacts of society as a whole through our products and services.

We have stablished a regional environmental policy which supports the environmental policy of the NEC. This policy expresses our approach and intended outcomes, and is reviewed annually.

We rigorously ensure that all actions of our employees and corporate officers comply with this policy. Furthermore, we require all business partners, contractors, and other stakeholders engaged in our supply chains to behave in a manner consistent with relevant guidelines and agreements.

We have conducted periodic reviews of certain aspects of our environmental management system to drive improvement.

We have established clear environmental responsibilities in all our subsidiaries.

We have implemented a variety of procedures for environmental compliance including waste management.

We have encouraged our staff think about saving natural resources, conserve energy, and reduce in-house environmental footprint through initiatives such as internal competitions.

We have achieved more than 90% of completion rate for our annual environmental training.

We have prioritized the procurement of hardware, software and services and solutions that have a low environmental footprint, with regards to CO2 emissions, waste production, and carry a green innovation potential.

We have supported and contributed to NEC's Corporation environmental commitments and targets. Further information can be found here: https://www.nec.com/en/global/csr/eco/target.html?

The NEC Way defines our Purpose and Principles as a company while advocating a Code of Conduct and a Code of Values for everyone at NEC, from executives through to employees.

The Code of Conduct prohibits any act of corruption with other parties including facilitation payments, public officials and government officials, supranational or international organizations, in any country or region where we do business.

Furthermore, we have established an Anti-Corruption Policy, with the intention of instituting a system to prevent corruption and stipulating rules for compliance by corporate officers and employees.

We recognize that checking on routine operations is an important part of preventing corruption, and therefore, as part of the wider NEC, we promote internal guidelines for hospitality, gifts, and donations, such as political donations.

We raise awareness through web-based training programs to increase the awareness and compliance of our staff.

We have promoted compliance as the fundamental basis of our activities through internal audits, compliance day and other communications.

Our Whistleblowing Committee is appointed to review, oversee, and monitor our anti-fraud program.

We have continued the promotion of our training on bribery and corruption, requesting all staff to confirm compliance.

We have only accepted candidate suppliers after having performed due diligence and engaged with them to obtain visibility of their supply chains beyond first tier where relevant.