Sustainability | SocietyRespect for Human Rights

Understanding of global trends on human rights issues

Since the UN Human Rights Council adopted the “protect, respect, and remedy” framework, known as the Ruggie Framework, with regard to business and human rights in 2008, a series of international Corporate Social Responsibility (“CSR”) guidelines and UN and EU policies have been introduced in accordance with the framework, and countries throughout the world have enacted laws addressing human rights in the context of international business. Specifically, these include the conflict minerals clause in the US Dodd-Frank Wall Street Reform and Consumer Protection Act enacted in 2010, the Transparency in Supply Chains Act enacted in the US State of California in 2010, the UN Guiding Principles on Business and Human Rights in 2011, the Modern Slavery Act in the United Kingdom in 2015, the EU regulation on conflict minerals in 2017, the Child Labor Due Diligence Act in the Netherlands in 2019, the Due Diligence in the Supply Chain Act in Germany in 2021, the Transparency Act in Norway in 2021, the EU Batteries Regulation in 2023, and the EU Corporate Sustainability Due Diligence Directive in 2024. This trend represents a strong appeal to companies to specifically identify human rights issues in their business activities and take appropriate action.

Our policies for respecting human rights

The TDK Code of Conduct states that “The TDK Group will continue to respect human rights, comply with relevant laws and regulations and international rules, and discharge its social responsibility with a strong sense of ethical values for the purpose of creating a sustainable society.”
For this purpose, we prohibit any form of child labor, forced labor including human trafficking, and unreasonable movement restrictions that lead to bonded labor in our supply chain. We also respect internationally recognized human rights, such as freedom of association and the right to collective bargaining. Furthermore, the TDK Code of Conduct also requires compliance with all relevant human rights laws and regulations including those prohibiting child and forced labor in the supply chain, such as Section 307 of the US Tariff Act of 1930, as amended, and the other laws identified above.
The TDK Group Policy on Human Rights was formulated in 2016. We respect and support international norms on human rights including the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, and the Children’s Rights and Business Principles. Based on the framework of the UN Guiding Principles on Business and Human Rights (UNGP), TDK promotes the correct understanding of potential human rights issues and takes steps to address them, not only within the business operations of the TDK itself but also throughout the value chain.
The "TDK Group Human Rights Policy" is published on our website and communicated to internal and external stakeholders. We expect all stakeholders, including our business partners and suppliers, to understand and support this policy, and we request that their responses be in compliance with the TDK Group Business Partner Code of Conduct, including the prohibition of unreasonable restrictions on movement leading to child labor, forced labor, or compulsory labor, and the respect for freedom of association and the right of collective bargaining.

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At TDK, the Sustainability Promotion HQ—with the Chief People and Sustainability Officer (CPSO) in place as the responsible party—promotes day-to-day human rights responses while coordinating with related functions. The Sustainability Promotion HQ issues reports at Board of Directors meetings at least twice a year regarding the status of sustainability initiatives for the entire Group including those with respect to human rights. The Board of Directors reviews and decides on these reports as necessary.
In addition, on April 1, 2025 we established a Sustainability Committee chaired by an executive officer appointed by the President and CEO, which is overseen directly by the Executive Committee, and which provides a venue for discussion of matters relating to the promotion of sustainability at TDK as an important issue of company-wide significance.

Due Diligence Process

The TDK undertakes human rights due diligence processes and promotes its due diligence activities in line with the procedures set out in the UNGP and the OECD Due Diligence Guidance for Responsible Business Conduct. We also continue to dialogue with internal/external parties including human rights specialists and stakeholders to make our activities more effective.

Human Rights Due Diligence Process of TDK Group

• TDK Code of Conduct
• TDK Group Policy on Human Rights
• TDK Group Business Partner Code of Conduct

• Identify potential human rights issues in the value chain
• Evaluate risks by probability, human rights impact, and scale of our company’s leverage
• Prioritize key themes based on risk evaluation result
• Assess detailed risks for each key theme
• Assess potential human rights risks in potential new business relationships created through M&A and similar transactions

• Implement measures for each key theme and periodic review
• Training

• Sustainability Website
• Human Rights Statement

Next, we did scoring and assigned prioritizations from the perspectives of severity of impact and probability of occurrence, and confirmed that they matched with "priority issues on which to focus." Furthermore, based on the results of reports from international human rights groups; the risk assessments for labor and business ethics, CSR self-checks, and audits at manufacturing sites; and reviews by external experts, we redefined our "priority issues on which to focus." As a result, we recognized three priority issues: "responsible mineral sourcing," "consideration of employee human rights at our manufacturing sites," and "consideration of employee human rights at suppliers (including contract manufacturers and staffing agencies)." We identified specific human rights issues (key human rights issues) to address within these three priority issues and are working on preventive and mitigation measures and monitoring progress. We will continue to conduct regular reevaluations.

Approach to Key Human Rights Issues

Goals and Achievements in FY March 2025

Initiatives

Initiatives for Prevention and Reduction of Human Rights Risks

With regard to issues that need to be prioritized as being of key importance, TDK undertakes activities aimed at preventing and mitigating risk, referencing the UNGP and the RBA Code of Conduct, assessment items and audit framework. In 2020, TDK joined the RBA, an organization which is dedicated to improving social, environmental and ethical conditions in the global supply chains. TDK utilizes the RBA Code of Conduct as the standard to promote our CSR activities at manufacturing sites. The details are as follows.

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Responsible Sourcing of Minerals

TDK started its response to the problem of conflict minerals following the enactment of the US Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010. The TDK Group Policy on Conflict Minerals was formulated in April 2013, to promote initiatives in full compliance with the Due Diligence Guidance of the Organization for Economic Cooperation and Development (OECD).
Considering that the scope of discussions on responsible sourcing of minerals has recently expanded to conflict-affected and high-risk areas for serious human rights violations or environmental pollution, to avoid being complicit in these problematic activities we revised our policy, which is now entitled the “TDK Group Policy on Responsible Sourcing Minerals” in January 2019. Under this revised policy, TDK continues to promote responsible sourcing of minerals throughout the supply chain, including minerals such as tantalum, tin, tungsten, gold, cobalt and mica, which pose an increased risk of being sourced from conflict areas and regions with high risks of misconduct, including human rights abuses and environmental destruction.

For more details, please see the following:

Respecting human rights of employees at our manufacturing sites

TDK recognizes that, in our role as a supplier, striving to give due consideration to social and environmental concerns at TDK Group manufacturing sites, and fulfilling our responsibilities to society, is very important for the long-term continuation of our business. Using a three-stage framework that covers self-assessment, auditing, training and dialogue, we strive to identify problems and realize continuing improvement.
Every year, we implement CSR self-checks and labor/corporate ethics risk assessment at all our manufacturing locations, based on the RBA framework. These activities are overseen by the Safety & Environment Group at the head office. Besides this, we are aiming to ensure that all manufacturing sites undergo either an RBA certification audit, a CSR audit conducted by a customer, or a simplified CSR assessment based on the RBA auditing criteria. If problems are discovered at a manufacturing site while implementing these activities, we will consider appropriate response measures and implement corrective action.

For more details, please see the following:

Respecting human rights of employees at business partners (including manufacturing sub-contractors and labor agencies)

Training

TDK raises awareness of human rights issues through e-learning or in person training that is given to all of our employees in key roles, including those in the UK. In addition, we have also been able to identify issues through training of internal CSR auditors based on RBA requirements and by CSR training that takes regional characteristics into consideration. In the supply chain, TDK provides educational tools as necessary to promote awareness at the time of implementing CSR self-checks.
In FY March 2025, TDK implemented CSR internal auditor training on a global scale. A total of 115 employees took part in the training, and the number of internal CSR auditors increased by 75.
In Japan, 23 employees from related functions took part in lectures given by external experts relating to human rights issues (including grievance mechanisms).

Grievance mechanisms and communications on human rights issues

TDK has established a global whistle-blowing system that allows TDK employees to speak-up or report any corporate ethics issues, including potential human rights concerns. These may be made directly or through internal or external help lines that are independent from employees’ own reporting lines. For outside stakeholders, we communicate and respond through the inquiry contacts on the TDK website. In response to inquiries on human rights issues made by some external organizations in FY March 2025, we explained TDK's policies on human rights and activities taken to ensure that TDK conducts business operations in accordance with these policies. In response to all inquiries and reports, relevant departments of TDK Group companies, independently or together, work to investigate, take necessary remedial actions and prevent recurrence of such issues.

Dialogue

TDK has engaged in dialogues with several third-party experts in order to better understand human rights issues that could impact our activities.
The following activity was held in FY March 2025:

• Discussion and clarification of where TDK aims to be in light of recent developments in business and human rights
  Regular dialogue has been held between TDK’s senior management and human rights experts, with external experts on human rights issues being invited to participate in dialogue with the leadership team of TDK’s Sustainability Promotion Headquarters.