Nintendo publishes human rights policy and employee commitments covering DEI, supply-chain

Nintendo Co., Ltd. has published a corporate human rights policy that it says applies to “everyone employed by Nintendo” and that explicitly supports the International Bill of Human Rights, the Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. The company ties the policy to its mission to “Put Smiles on the Faces of Everyone Nintendo Touches,” and says the policy “articulates Nintendo’s commitment to respecting human rights in accordance with our corporate vision and codes of conduct.”

The company’s CSR Procurement Guidelines were created with external specialists and adopt the standards of the Responsible Business Alliance. Nintendo says the Guidelines are available in Japanese, English, and Chinese and provide “specific guidance based on relevant international laws, regulations, and standards” covering human rights, sustainability, ethical procurement, prohibition of forced labor, respect for workers’ rights and occupational health and safety. The Csassets Nintendo excerpt includes an administrative identifier, Docusign Envelope ID: 0B036002-B6C3-44D5-A256-C98670BCF251, linked to those procurement materials.

Nintendo lists concrete hiring practices aimed at reducing modern-slavery risk. The company states that “all employees are bound by written employment contracts,” that it “uses reputable employment agencies to source temporary workers,” and that it requires each recruitment agency to provide terms including minimum wages before accepting workers from those agencies. Nintendo further says it periodically reviews terms with employment agencies and that an anonymous procedure exists for reporting legal violations or suspected issues. The company’s public materials also reference a Modern Slavery Transparency Statement dated 09/2018.

Training and education are a central element of Nintendo’s rollout. The policy text states that “Nintendo educates everyone employed by Nintendo about this Policy to ensure effective integration and implementation into every aspect of our business activities.” At the subsidiary level, Nintendo of America Inc. provides annual training on the Code of Business Conduct and ongoing human-rights training for staff working with the supply chain. Nintendo of Europe SE requires Code of Conduct training for all new employees, including sections on the UK Modern Slavery Act, with periodic refresher trainings. Nintendo Australia Pty Limited regularly implements training on the Australian Modern Slavery Act for relevant employees, and Nintendo says the General Manager of the Human Resources Department ensures Japan employees receive training on laws, the Nintendo Standards of Behavior and human rights.

Nintendo frames human-rights due diligence as an active process that “involves opinions from external experts.” The company’s published HRDD paragraph stops mid-sentence on remediation, so the public text does not include a full remedial clause. External assessment from the World Benchmarking Alliance gives Nintendo an “ICT (Supply Chain only) 5.5 out of 26” and notes it “is not clear that there is a senior manager responsible for human rights issues and policy,” citing the CSR Report 2019 and the Modern Slavery Transparency Statement.

Nintendo’s employee standards include the Nintendo Standards of Behavior, the Nintendo Code of Conduct and the Nintendo DNA, and the company’s Code of Business Conduct explicitly says it “provides for the confidential treatment of complaints under the code and prohibits retaliation for any such complaints made in good faith.” Public materials now outline a set of procurement, training and recruitment controls and name international standards, but the WBA score and truncated remediation language leave open questions about how senior-level accountability and remedial procedures will operate in practice.