Sustainability | SocialRespect 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. These laws require companies to specifically identify human rights issues in their business activities and take appropriate action.

Our Policies for Respecting Human Rights

The TDK Group Code of Conduct states that “The TDK Group shall respect and uphold international norms regarding human rights. In addition, based on the recognition that it is important to understand the potential impact of all corporate activities on human rights and to conduct activities to prevent and mitigate adverse impacts, the TDK Group shall continuously administer human rights due diligence within the value chain to fulfill its responsibilities.” To that end, TDK Group Code of Conduct provides that “The TDK Group shall not tolerate any form of inhumane labor including child labor and all types of forced labor or human trafficking,” and that “The TDK Group shall comply with applicable laws and regulations regarding minimum wages, working hours, and other protections for workers.” TDK respects such internationally recognized human rights, as respect for freedom of association and right to collective bargaining. The TDK Group Code of Conduct also states that “The TDK Group shall take measures to remedy, correct, improve, and prevent recurrence if the TDK Group recognizes that its corporate activities have caused or contributed to adverse human rights impacts. In addition, the TDK Group shall enhance effective mechanisms to enable quick actions concerning any comments related to human rights, and to remediate the issue if any.”
The TDK Group Policy on Human Rights was formulated in 2016. TDK respects and supports 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 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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TDK promotes human rights initiatives under the responsibility of the Sustainability Committee Chair (Corporate Officer). The Sustainability Management Group within the Corporate Strategy Headquarters works in close collaboration with relevant functions to advance these ongoing initiatives and day-to-day operations. Group-wide sustainability policies, including human rights initiatives, are discussed and deliberated by the Sustainability Committee under the direct control of the Executive Committee, and are subsequently submitted to both the Executive Management Meeting and the Board of Directors Meeting. The Board of Directors reviews these submissions and, when necessary, undertakes further deliberations and makes resolutions.
In FY March 2026, two topics relating to human rights were deliberated on and examined by the Sustainability Committee.

Due Diligence Process

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 the TDK Group

• TDK Group 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 “human rights key themes.” 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 conducted an analysis of vulnerable stakeholders and redefined our “priority issues on which to focus.” As a result, we recognized three priority issues: “responsible sourcing of minerals,” “respecting human rights of employees at our manufacturing sites,” and “respecting human rights of employees at suppliers (including manufacturing sub-contractors and labor agencies).” We identified specific human rights key elements 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 Specific Human Rights Key Elements

Goals and Achievements in FY March 2026

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. In April 2013, we formulated the TDK Group Policy on Conflict Minerals, established a survey and response system at each Group company, and have carried out initiatives in line with the Due Diligence Guidance of the Organisation for Economic Co-operation 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, mica, copper, graphite, lithium and nickel 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. In addition, we aim to ensure that every manufacturing site undergoes of the following at least once every three years: 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 2026, TDK implemented the following activities:

• We conducted CSR internal auditor training on a global scale, with a total of 185 employees taking part
• We implemented a business ethics e-learning program for all TDK Group employees
• Members of the Sustainability Management Group took part in training provided by the UNDP’s B+HR Academy
• A member of the Sustainability Management Group attended the 14th United Nations Forum on Business and Human Rights, which was held in Geneva in November 2025

Dialogue

TDK engages in regular dialogue with external experts regarding the promotion of human rights.
Through this dialogue, TDK receives assessments and recommendations on its existing initiatives, deepens its understanding of human rights issues, and leverages these insights to further enhance its future initiatives.
In FY March 2026, TDK held the following dialogue:

• Mr. Yusuke Yukawa, an attorney-at-law at Nishimura & Asahi (Gaikokuho Kyodo Jigyo), took part in a dialogue with the Corporate Officer who chairs TDK’s Sustainability Committee, on the topic of “The human rights promotion measures that global enterprises need to take, and the role of senior management”

For more details, see the PDF noted below.

Dialogue Held in the Past

2024

Responding to recent trends relating to business and human rights, a dialogue was held between TDK senior managers and external experts on human rights regarding the strategy that TDK should adopt. Through this dialogue, besides confirming the appropriateness of TDK’s initiatives in light of international expectations and trends, we also obtained insights regarding the company’s future strategic direction.

2021

Study session on human rights issues in the supply chain
Invited an outside expert on human rights issues in the supply chain and held a study session attended by senior managers of the global procurement function.

2017

Targeting Human Rights Responses at the Supply Chain
Invited two outside experts on human rights to attend a study session on the role required of TDK in response to human rights in the supply chain.

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2015

CSR Promotion in the Supply Chain
Invited an outside expert on human rights for an exchange of opinions concerning what is expected of TDK to promote CSR in the supply chain.

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2014

Identification of Human Rights Issues through Dialogue with Stakeholders
Engaged in a dialogue with experts on human rights to identify human rights issues relevant to TDK.

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2013

Human Rights Due Diligence Workshop (Caux Round Table Japan)
Participated in the Human Rights Due Diligence Workshop, organized by the Caux Round Table Japan. We worked to grasp human rights risks through an exchange of opinions with NGOs and experts (10 associations), while identifying human rights issues in manufacturing through discussions with members from nine participating companies.

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