1. CSR Section in Corporate Planning Department UN Global Compact - In-house training material - October 2009 Confidential

2. Nikon Corporation CSR Section in Corporate Planning Department October 2009 2 Course Objectives To help employees of Nikon group companies to deepen understanding of the international CSR guidelines: UN Global Compact and its Ten Principles, so that they will be able to conduct daily business operations in compliance with the UN Global Compact.

3. Nikon Corporation CSR Section in Corporate Planning Department October 2009 3 Nikon Group and UN Global Compact  Nikon participated in the UN Global Compact in July 2007, supporting the 10 principles regarding human rights, labor standards, environment, and anti-corruption. In Japan, Nikon is a 53th participating member.  UN Global Compact is in line with Nikon’s business policies that emphasize corporate social responsibility (CSR). Nikon’s participation was decided believing that awareness toward CSR and CSR-related activities by our group employees can be enhanced and promoted by complying with such international guidelines as UN Global Compact 10 Principles. We also expect that being an advocate of such international framework can win sympathy from our stakeholders in and outside Japan.  When CEO of parent company expresses commitment to UN Global Compact, all subsidiaries under the parent company are regarded to have endorsed the Global Compact. Based on this principle, whole Nikon group companies engage in the activities so that the principles of Global Compact and Nikon CSR Charter penetrate into all Nikon employees. Please also refer to Nikon CSR Charter. * Essilor International SA, our joint-venture partner in France, also joined UN Global Compact in 2003. Confidential

4. Nikon Corporation CSR Section in Corporate Planning Department October 2009 4 UN Global Compact  UN Global Compact was proposed by United Nations Secretary General Kofi Anan at the World Economic Forum in Davos, Switzerland, in January 1999, and officially installed in July 2000 at UN Headquarters in New York.  UN Global Compact seeks participants to endorse ten principles in the areas of human rights, labour, environment, and anti-corruption, and align their business operations and strategies with these 10 universally accepted principles.  Chief executive officers can lead companies to exercise responsible business practices to help ensure that markets, commerce, technology and finance advance in ways that benefit economies and societies everywhere and contribute to a more sustainable and inclusive global economy.  The UN Global Compact is not a regulatory instrument or homologation agency, but rather a voluntary initiative that relies on public accountability, transparency and disclosure to complement regulation and to provide a space for innovation. There is not a single way to advocate, but businesses are expected to make the UN Global Compact an integral part of their strategy, day-to-day operation, and organizational culture.  Number of participants worldwide as of October 5, 2009: 7019 participants in 131 countries Breakdown: 5137 businesses (including 2657 small-to-medium businesses) with 1882 organizations To acquire update information on international participants, visit the following site. http://www.unglobalcompact.org/ParticipantsAndStakeholders/index.html http://www.unglobalcompact.org/ParticipantsAndStakeholders/index.html  UN Global Compact aims to advance two objectives: mainstream the ten principles in business activities around the world; catalyze actions in support of broader UN goals, including the Millennium Development Goals (MDGs). Millennium Development Goals http://www.un.org/millenniumgoals/bkgd.shtmlhttp://www.un.org/millenniumgoals/bkgd.shtml

5. Nikon Corporation CSR Section in Corporate Planning Department October 2009 5 UN Global Compact Participants Source: UN Information Center homepage (Japan) as of July 6, 2009 NOTE: Countries are listed in the order of descending prevalence.

6. Nikon Corporation CSR Section in Corporate Planning Department October 2009 6  Address of former United Nations Secretary General Kofi Anan I propose that you, the business leaders, and we, the United Nations, initiate a global compact of shared values and principles, which will give a human face to the global market. We have to choose between a global market driven only by calculations of short-term profit, and one which has a human face. ( at World Economic Forum in January 1999) Full text http://www.un.org/News/Press/docs/1999/19990201.sgsm6881.html http://www.un.org/News/Press/docs/1999/19990201.sgsm6881.html  Address of United Nations Secretary General Ban Ki-moon The United Nations and business need each other. We need your innovation, your initiative, your technological prowess. But business also needs the United Nations. In a very real sense, the work of the United Nations can be viewed as seeking to create the ideal enabling environment within which business can thrive. (at NY business community gathering in January 2007) Full text http://www.unglobalcompact.org/NewsAndEvents/speeches_and_statements /10sgsmunausa.pdf http://www.unglobalcompact.org/NewsAndEvents/speeches_and_statements /10sgsmunausa.pdf

7. Nikon Corporation CSR Section in Corporate Planning Department October 2009 7 Benefits by participating in UN Global Compact Participation in the UN Global Compact offers following benefits:  Adopting social aspects in corporate visions to promote individual’s responsible conducts for sustainability solutions.  Adopting an established and globally recognized policy framework for the implementation and disclosure of CSR activities.  Sharing best and emerging practices to advance practical solutions and strategies to common challenges.  Accessing the United Nations’ extensive knowledge of and experience with sustainability and development issues.

8. Nikon Corporation CSR Section in Corporate Planning Department October 2009 8 Corporate Commitment to UN Global Compact  Make the UN Global Compact and its principles an integral part of business strategy, day-to-day operations, and organizational culture.  Integrate in its annual report or CSR report a description of the ways in which it implements the principles and supports broader development objectives. These communication reports are called communication on progress (COP) that is mandatory to all UN Global Compact participants. An organization who does not submit the COP is delisted. Nikon’s first COP “Nikon CSR Report 2008” was recognized as Notable COP. Notable COPs are selected by the UN Global Compact Office based on the set criteria, and only <5% of COPs have satisfied the criteria so far. In 2008, 27 COPs were selected (as of October 5, 2009), and in Japan Notable COPs have been given 10 times to nine Japanese companies (one company was awarded twice).  Publicize participation of the UN Global Compact through various communication tools including publicity matters and seminars, and promote significance of UN Global Compact and the 10 Principles while implementing responsible business practices through advocacy and active outreach to the public at large.

9. Nikon Corporation CSR Section in Corporate Planning Department October 2009 9 UN Global Compact principles in the areas of human rights, labour, environment, anti-corruption are derived from universally established four initiatives:  Human Rights The universal declaration of human rights http://www.un.org/en/documents/udhr/index.shtml Official site for universal declaration of human rights (OHCHR) stores full texts in 300 languages. http://www.ohchr.org/EN/UDHR/Pages/SearchByLang.aspx  Labor Standards The international labor organization’s (ILO) declaration on fundamental principles and rights at work http://www.ilo.org/declaration/lang--en/index.htm  Environment The Rio declaration on environment and development http://www.un.org/esa/dsd/agenda21/  Anti-Corruption The United Nations convention against corruption http://www.unodc.org/unodc/en/treaties/CAC/index.html

10. Nikon Corporation CSR Section in Corporate Planning Department October 2009 10 [Human Rights] Businesses should: Principle 1. support and respect the protection of internationally proclaimed human rights; and Principle 2. make sure that they are not complicit in human rights abuses. [Labour Standards] Businesses should uphold: Principle 3. freedom of association and the effective recognition of the right to collective bargaining; Principle 4. the elimination of all forms of forced and compulsory labour; Principle 5. the effective abolition of child labour; and Principle 6. the elimination of discrimination in respect of employment and occupation. Human Rights The universal declaration of human rights http://www.un.org/en/documents/udhr/index.shtml Official site for universal declaration of human rights (OHCHR) stores full texts in 300 languages. http://www.ohchr.org/EN/UDHR/Pages/SearchByLang.aspx Labor Standards The international labor organization’s (ILO) declaration on fundamental principles and rights at work http://www.ilo.org/declaration/lang--en/index.htm

11. Nikon Corporation CSR Section in Corporate Planning Department October 2009 11 Human Rights, Labour Standards (1)  Governments have the primary responsibility for human rights. However, individuals and organizations also have important roles to play in supporting and respecting human rights. As part of its commitment to the Global Compact, the business community has a responsibility to uphold human rights both in the workplace and more broadly within its sphere of influence.  In general, businesses whose operations are consistent with the legal principles applicable in the country of operation do not use forced labour or child labour. Businesses operating outside their country of origin may have an opportunity to promote and raise standards through their supply chains in countries where support and enforcement of human rights issues is insufficient.  Access to global information means that consumers are increasingly aware of where their goods come from and the conditions under which they are made. Nikon also receives the increasing number of inquiries regarding our products from customers, consumer groups, investment rating agencies.  If business gets involved in an improper human rights or labour issue even indirectly through its supply chain, it may suffer negative campaign advertisements from consumer groups with its profit, stock price, and brand image significantly affected. Global sourcing and manufacturing means that companies need to be fully aware of potential human rights and labour issues both upstream and downstream in a bid to reduce potential risks.

12. Nikon Corporation CSR Section in Corporate Planning Department October 2009 12 Human Rights, Labour Standards (2) – Actions by business  Bring human rights into company policy and culture, prepare guidelines, establish management system, and provide educational classes to employees.  Make a human rights assessment of the situation in countries where it does, or intends to do, business so as to identify the risk of involvement of human rights abuses.  Have explicit human rights policies both in Nikon group and our supply chains, and establish a monitoring system to ensure that their human rights policies are being implemented. Nikon group is requesting our suppliers to develop CSR activities to eliminate human rights abuses in our supply chains. See Nikon Procurement Partners’ CSR Guidelines. http://www.nikon.co.jp/main/jpn/profile/procurement/pdf/csr-guideline_e.pdf  Actively engage in open dialogue with human-rights organizations to receive their opinions and proposals.

13. Nikon Corporation CSR Section in Corporate Planning Department October 2009 13 Human Rights, Labour Standards (3) – Glossary * Excerpts from UN Global Compact homepage http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html  Complicit in human rights abuses There are three types of complicity: direct complicity, beneficial complicity, and silent complicity. Direct complicity occurs when a company actively assists in human rights violations committed by others. Beneficial complicity suggests that a company benefits directly from human rights abuses committed by others. Silent complicity describes a situation where a company may not be assisting or encouraging human rights violations, nor benefiting from the actions of those that commit abuses, but is viewed as staying silent in the face of human rights abuses.  Freedom of association and collective bargaining Freedom of association implies a respect for the right of all employers and all workers to freely and voluntarily establish and join groups for the promotion and defense of their occupational interests. Collective bargaining implies a process whereas workers can bargain freely with employers to define their work conditions and organizations. Workers have the right to set up, join, and run their own organizations without threats or retaliations from employers. Collective bargaining can only function well when it is conducted in good faith and constructively by both parties, so that aggregated energies are directed to benefit businesses, stakeholders, and eventually whole societies.  Forced labour Forced labour includes all works or services exacted from a person under threat or penalty where the person has not offered him/herself voluntarily. Provision of wages and other benefits to workers does not indicate that the labour is not forced. Workers should reserve rights to select or leave jobs at their own will based on established rules.

14. Nikon Corporation CSR Section in Corporate Planning Department October 2009 14  Child labour Child labour is still a serious problem in many developing nations. According to the ILO estimates issued in 2006, 218 million children aged 5 to 17 are victims of child labour, with 60% of them are in the Asia/Pacific region. In most cases, children are forced to work for a long time, with low wage or no wage, in environments that are often harmful to them mentally and physically. Many of them are separated from families and given no education, losing opportunities to acquire skills that may be required by future jobs due to illiteracy. Child labour that is caused by poverty and lack of development, as a result, generates unskilled and unqualified workers.  Discrimination in employment and occupation Discrimination includes “any distinction, exclusion or preference which has the effect of nullifying or impairing equality of opportunity or treatment in employment or occupation” “made on the basis of race, colour, sex, religion, political opinion, national extraction, or social origin, age, disablement, HIV/AIDS status, participation in labor unions, sexual orientations.” Non-discrimination means that workers are hired based only on their capabilities without any distinction, exclusion, or preference by other factors. All individuals must be given equal opportunities to develop job-related knowledge, skills, competitiveness. In general, discrimination is often engaged in indirect forms whereas rules or business practices that may seem neutral may cause exclusion. Indirect discrimination often creep in the business practices and attitudes, and if no measures are taken against it, it may deeply take root in the organization. Human Rights, Labour Standards (4) – Glossary * Excerpts from UN Global Compact homepage http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html

15. Nikon Corporation CSR Section in Corporate Planning Department October 2009 15 [Environment] Business should: Principle 7. support a precautionary approach to environmental challenges; Principle 8. undertake initiatives to promote greater environmental responsibility; and Principle 9. encourage the development and diffusion of environmentally friendly technologies.  [Environment] The Rio declaration on environment and development http://www.un.org/esa/dsd/agenda21/  The key element of a precautionary approach, from a business perspective, is the idea of prevention rather than cure. In other words, it is more cost-effective to take early action to ensure that irreversible environmental damage does not occur.  Society expects business to be good neighbours. Business gains its legitimacy through meeting the needs of society, and increasingly society is expressing a clear need for more environmentally sustainable practices such as clean and environmentally efficient productions. To this end, business is expected to set numerical targets and goals, and measure/track/report the progress data in corporation with its suppliers.  Environmentally sound technologies should protect the environment, are less polluting, use all resources in a more sustainable manner, recycle more of their wastes and products and handle residual wastes in a more acceptable manner than the technologies for which they were substitutes. They can be considered total systems including know-how, procedures, goods and services and equipment as well as organizational and managerial procedures.  Nikon group prepares the Environmental Action Plan (three-year plan on environmental measures), based on the Basic Environmental Management Policy, and advocates environmental management. Basic Environmental Mgt Policy http://nikon.com/about/csr/environment/plan/policy/index.htmhttp://nikon.com/about/csr/environment/plan/policy/index.htm Environmental Action Plan http://nikon.com/about/csr/environment/plan/action_plan/index.htmhttp://nikon.com/about/csr/environment/plan/action_plan/index.htm

16. Nikon Corporation CSR Section in Corporate Planning Department October 2009 16 [Anti-Corruption] Principle 10. Businesses should work against corruption in all its forms, including extortion and bribery.  [Anti-corruption] The United Nations convention against corruption http://www.unodc.org/unodc/en/treaties/CAC/index.html  On 24 June 2004, during the UN Global Compact Leaders Summit it was announced that the UN Global Compact henceforth includes a tenth principle against corruption.  Corruption can take many forms that vary in degree from the minor use of influence to institutionalized bribery. Transparency International's definition of corruption is "the abuse of entrusted power for private gain". This can mean not only financial gain but also non-financial advantages.  The OECD Guidelines for Multinational Enterprises define extortion in the following way: "The solicitation of bribes is the act of asking or enticing another to commit bribery. It becomes extortion when this demand is accompanied by threats that endanger the personal integrity or the life of the private actors involved."  Transparency International's Business Principles for Countering Bribery define "bribery" in the following way: "Bribery: An offer or receipt of any gift, loan, fee, reward or other advantage to or from any person as an inducement to do something which is dishonest, illegal or a breach of trust, in the conduct of the enterprise's business."  Participating businesses are asked to 1) introduce anti-corruption policies and programs; 2) report on the work against corruption in the annual Communication on Progress; and 3) join forces with industry peers and with other stakeholders.  Each Nikon group company prepares the code of conduct to identify proper behaviors and to raise the awareness against corruption.

17. Nikon Corporation CSR Section in Corporate Planning Department October 2009 17 The Ten Principles of UN Global Compact Human Rights Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and Principle 2: make sure that they are not complicit in human rights abuses. Labour Standards Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: the elimination of all forms of forced and compulsory labour; Principle 5: the effective abolition of child labour; and Principle 6: the elimination of discrimination in respect of employment and occupation. Environment Principle 7: Businesses should support a precautionary approach to environmental challenges; Principle 8: undertake initiatives to promote greater environmental responsibility; and Principle 9: encourage the development and diffusion of environmentally friendly technologies. Anti-Corruption Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

18. Nikon Corporation CSR Section in Corporate Planning Department October 2009 18 1. Sound corporate activities The Nikon Group endeavors to comply with international regulations, related laws, and internal rules, exercise sound and fair corporate practices, and earn the trust of stakeholders such as customers, shareholders, employees, business partners, and society. The Group will maintain constructive relationships with administrative bodies, remaining politically neutral and complying with laws, and will not engage in relationships with individuals or groups that threaten social order or safety. 2. Provision of valuable goods and services for society The Nikon Group will provide valuable products and services to society, endeavoring to increase the satisfaction and trust of our customers and contributing to the healthy development of society. 3. Respect for human beings The Nikon Group will respect diversity and individual human rights and provide a healthy and safe working environment in which all persons receive fair treatment without discrimination. It will also oppose enforced labor and child labor and respect fundamental human rights as well as workers' rights. 4. Protection of the natural environment The Nikon Group will proactively engage in environmental efforts and work to protect the natural environment, as these are common issues for all of mankind. 5. Responsibility to society as a corporate citizen The Nikon Group will carry out corporate activities that take into account the cultures and practices of each country and region and proactively engage in activities that contribute to society as a good corporate citizen. 6. Transparent operating activities The Nikon Group will communicate extensively with customers, shareholders, employees, business partners, and society and disclose business information in a timely and fair manner. It will also conduct reliable financial reporting through accurate accounting processes. 7. Responsibility of top management Top management and employees in managerial positions within each department must understand that they play an essential role in fulfilling the spirit of this Charter and thus, in addition to leading by example, they must ensure that this information is disseminated to everyone in the Group and all related parties. Management must always strive to understand the opinions of those both inside and outside of Nikon to develop a sound internal framework that ensures that the spirit of this Charter is upheld. If any incident occurs that violates this Charter, top management will demonstrate, internally and externally, their determination to solve the problem and strive to identify the cause and prevent its recurrence. Furthermore, they will uphold information disclosure and accountability obligations. They will clarify the authority and responsibility of each manager and employee and deal rigorously and objectively with all people involved in the matter, including top management. Nikon CSR Charter (enacted April 27, 2007)

19. Nikon Corporation CSR Section in Corporate Planning Department October 2009 19 Bibliography UN Global Compact homepage Overview http://www.unglobalcompact.org/AboutTheGC/ The Ten Principles http://www.unglobalcompact.org/AboutTheGC/TheTenPrinciples/index.html Brochure http://www.unglobalcompact.org/docs/news_events/8.1/GC_brochure_FINAL.pdf