Respect for human rights , Promoing diversity & inclusion and Health management

Respect for Human Rights

Basic policy

In compliance with the Universal Declaration of Human Rights and other international norms on human rights, the Nippon Steel Group is in the business of creating and delivering valuable and attractive products and ideas, by respecting our employees’ diverse views and individualities and utilizing them for the good of all. Based on the United Nations Guiding Principles on Business and Human Rights, the Nippon Steel Group Conduct Code has been set. By adhering to its nine principles, Nippon Steel conducts business ethically, while paying full heed to human rights issues arising with the increasing globalization of the economy. Nippon Steel gives due attention to the rights of workers, and staunchly opposes the use of forced or child labor. These are prerequisites of our corporate activities. We have also prohibited as unjust the discriminatory treatment of workers based on nationality, race, belief, creed, gender, age, sexual orientation, and disability. In addition, we give careful consideration to the traditions and culture, business practice, and labor practice of each country or region as we accelerate overseas business development.

Based on these basic ideas concerning respect for human rights, we strive to create a workplace environment where employees can share diverse values and maximize their abilities. We thereby seek to improve productivity, work conditions, benefits, and the working environment, with the aim to enrich the life of employees and achieve the corporate development.

Addressing human rights risks

From the viewpoint of promoting human rights (HR) awareness activities by assigning human rights awareness advocates at each steelworks and each office, and of implementing corporate-wide human rights awareness activities, we hold a “corporate-wide forum of human rights awareness advocates” in March each year to exchange views on human rights awareness education and new human rights risks, and to consider the related action policy for the next fiscal year. Based on this, we hold a “corporate-wide forum of human rights anti-discrimination promotion” at the beginning of the fiscal year, chaired by the Executive Officer in charge of Human Resources, with the HR managers of each steelworks and each office as members. At this forum, the fiscal year’s policy for promoting human rights development is determined.

In addition to implementing human rights awareness activities in accordance with the policies decided at the forum, each steelworks and each office are actively engaged in employee awareness-raising activities, including holding workshops on a specific issue of the steelworks or office. We also participate in enlightenment organizations and activities hosted by public entities and others in each community. We do this as concerted efforts for human rights enlightenment with the communities.

Along with the group-wide expansion of our efforts to Group companies in Japan and overseas, monitoring surveys on the status of compliance with labor-related laws and regulations, the establishment of consultation contacts, and other issues are regularly conducted via a checklist on internal controls.

Through these efforts, we are continuously and systematically promoting activities to prevent human rights abuses. This includes the understanding of human rights risks that change with the times and the development of a system and a strategy to reduce the risks.

Prevention of forced or child labor

Adhering to international norms concerning forced or child labor, Nippon Steel has the policy of prevention and eradication of both types of labor. We conduct regular monitoring surveys of our Group companies to prevent such violations in our business activities.

Compliance concerning salaries

In compliance with laws and regulation concerning salary and wages payment, Nippon Steel has set up pay at a higher level than minimum wage stipulated by the country, region, and type of work where we do business. With regard to bonuses, we regularly survey related matters, including the status of each country, region, and type of work, and hold meetings with labor representatives, to appropriately reward employees with due consideration given to business conditions and financial performance.

Human rights awareness education

Based on the policy decided at the “corporate-wide forum of human rights anti-discrimination promotion,” information on human rights awareness is incorporated in training courses for all ranks, from new employees to experienced ones. We also provide education on a variety of subjects, including the issues of harassment and anti-discrimination, understanding of LGBTQ, and human rights issues in the conduct of our business.

The number of recipients of
training courses by rank on
human rights in fiscal 2020

Two-way communication with employees based on good labor-management relations is important in order to prevent human rights abuses. We therefore incorporate education toward building sound labor-management relationships in training of executives of the Company and the Group companies.

In addition to general education that contributes to the prevention of human rights abuses in workplaces, we also address specific human rights abuse risks in formulating and oversight of specific work assignments. Examples include education on fair recruitment selection by employees assigned to the tasks of hiring in order to prevent job discrimination, and education on cross-cultural understanding and communication for those assigned to overseas business in the context of preventing human rights abuses (i.e., consideration for each country’s unique traditions, culture, business practices, and labor-management practices).

Mechanism of corrective actions

We have clarified whom to contact for consultation on various compliance issues including human rights. This is a part of efforts to establish a groupwide claim handling mechanism that makes it easy for employees and related personnel to ask for consultation, and that enables the Company to understand and identify incidents of discrimination.

Specifically, a Compliance Consultation Room has been established to accept inquiries and reports and give counseling regarding human rights abuses such as harassment, from employees of the Company and Group companies and their families, as well as from employees of business partners. Reports and consultations from various stakeholders are accepted through the Inquiry Form accessible on the website. Regarding the response to these individual incidents, such as internal reports and consultations, we investigate the facts and, if necessary, seek advice from outside parties, including lawyers and outside professional organizations, to protect the privacy of the persons and to ensure that they do not receive unfavorable treatment. We then provide guidance and education to those involved, and strive to appropriately resolve the incidents.

Furthermore, since labor-management relations play an important role in preventing human rights abuses and resolving related incidents, in the event of disputes concerning the interpretation of collective agreements, labor-management agreements or other rules directly related to them, a grievance committee is established to resolve the dispute, based on the agreement concerning complaint-handling procedures that has been concluded with the labor union. The committee comprises members from both the management and the labor side.

Communicating with stakeholders

Adhering to laws and the group-company labor agreements, and respecting the rights to organize and to bargain, Nippon Steel strives to maintain sound labor-management relationships. With a focus on mutual understanding through two-way dialogue, we have a place for discussion with labor unions for the entire Company as well as for each steelworks and each office. We discuss the operating and financial performance, safety, health, and production management issues, working conditions such as salaries and bonus payments, balancing of work and personal life, and other issues. Close labor-management communication is also maintained, particularly concerning the actual work cases for which the labor unions received reports from their members. The minutes of these discussions are recorded and shared through the Intranet and other means broadly, from senior management to work union members.

In-house magazines for the entire Company as well as each steelworks and each office are regularly published as a means to send various messages to employees. PR magazines are also published to convey our business and other information outside. Our steelworks and offices also regularly set up a place for dialogue with the nearby residents’ associations to ask for their understanding of our business operations and listen to opinions and requests from them; this is part of what we do to realize better communication with the local community.

Labor-management discussions
in fiscal 2020
114 times for the entire Company
950 times at steelworks and offices
Number of union members and unionized rate
(March 31, 2021)
(100% unionized)

Diversity & Inclusion
Basic policy

From the perspective of creating a company where diverse employees are productive, perform at their best, be empowered, and feel proud and fulfilled, we are reinforcing our diversity & inclusion efforts while focusing on the following five areas.

  • Promote female employee’s participation and career advancement
  • Realize work life balance so as to enable employees with various backgrounds and circumstances to perform at their best
  • Develop health management in order for employees to perform at their best until the retirement age of 65
  • Prevent harassment
  • Promote empowerment of the elderly and the disabled

The “Diversity & Inclusion Dept.” has been established as a dedicated unit to promote diversity and inclusion efforts.

Status of employees (non-consolidated basis)

Men Women Total
Number of employees (March 31, 2021) 26,578 3,001 29,579
Number of new hires (FY2021) 375 51 426
Average years of service (March 31, 2021) 16.0 11.0 15.5
Rate of voluntary termination (FY2020) 2.8% 3.4% 2.9%

Promotion of women’s participation and career advancement

What we have done so far

We have introduced the following programs: 1) a childcare leave which is more generous than legally required; 2) a program for employees who rejoin the company after having left it because of childcare or nursing care and other reasons; 3) a leave to assist overseas relocation of a spouse; and 4) a temporary exemption program for employees who have difficulty in relocation because of childcare or nursing care and other reasons. We have also been opening 24-hour childcare centers in steelworks and have introduced maternity work clothes for use by steelwork employees who are in the childbirth/childcare period, in order to help them continue their shift work without feeling concerned. We are thus enhancing programs to support employees’ work-life balance. In addition, we are investing in improving work infrastructure such as showers, toilets, and dressing rooms at manufacturing sites, and improving work practices, so as to establish a comfortable working environment for female employees.

In-house childcare center

In-house childcare center (Nagoya Works)

Number of in-house childcare centers
(April, 2021)
Number of users of in-house childcare centers
(April, 2021)

Toward further promoting women’s participation in the workplace

Based on the various programs and work environments that we have established, we have developed the following action plan to support female employees to continue to demonstrate their abilities through career development, and to promote their empowerment in all workplaces and levels, including enhancement of promotion to managerial positions.

Promotion of women’s participation and career advancement

Plan of action as a general employer, based on the Act on the Promotion of Female Participation and Career Advancement in the Workplace in Japan

In order to develop an employment environment where female employees can perform at their best, an action plan is formulated as follows:

  • Plan period: 5 years (April 1, 2021–March 31, 2026)
  • Goals, details of efforts, and implementation schedule


Aim to at least double and possibly triple the number of female employees in management positions in 2025 from 36 in 2020, and to increase by at least four times and possibly seven times by 2030.

From FY2021

  • Hire more women.
  • Confirm the individual circumstances and intentions of female employees, and consider placement and development measures based on their circumstances in order to enable them to continue to work and actively perform.
  • Invest in the working environment so as to expand the placement of women, mainly at steelworks (improvement in work infrastructure, work content, etc.)
  • Consider and implement work support measures for employees in the childcare status period, such as measures for childcare centers that offer night-time service.
  • In light of the enhancement of the programs related to childbirth and childcare, prepare a brochure to introduce the relevant programs, distribute it to employees, and revise related programs as needed.
  • Provide career education that will contribute to the further promotion of female employees’ performance.
  • Provide education on diversity to executives who supervise female employees.


Aim at 75% or higher utilization rate of paid leave days.

From FY2021

  • Prepare a pamphlet on the vacation and leave program, distribute it to employees, and develop educational activities.
  • Encourage taking paid leave days by setting with the labor union some specific days recommended for paid leaves and by conducting a campaign to do so in the summer.
  • Managers to take the initiative in taking off on paid leave days.
  • Managers to support each employee to take paid leaves as scheduled.

Improved hiring and retention

The ratio of women in overall hiring is 17%, and we will continue to expand their hiring. We also seek to improve the retention rate of female employees by taking the following measures: 1) promotion of teleworking; 2) elimination of long work hours (for those with constraint on workplace or work time due to childcare or other conditions to continue to work); 3) career assessments for female employees; and 4) flexible placement and development based on the understanding of individual circumstances.

Our other continual efforts include investment in the work environment with the aim of expanding women’s placement mainly at steelworks, and child-care support measures such as the establishment of childcare centers that offer night-time service. In fiscal 2021 we plan to open in-house childcare centers at the East Nippon Works’ Kashima area and the North Nippon Works Muroran area.

The ratio of women in overall hiring
(Average ratio for FY2019–FY2021)
Office staff and engineers 31%
Operators and maintenance personnel 12%
Overall hiring 17%

Support for employees’ career development and work-life balance

In addition to establishing career education programs to contribute to the further promotion of female employees’ performance, we also encourage them to develop their capability by providing opportunities for growth through proactive efforts in anticipation of various life events, and by actively promoting advancement to managerial positions.

We will create a workplace culture where work and home life are comfortably balanced by making various programs well known to employees, through improvement and introduction of brochures which explain the programs. We also provide to managers education concerning unconscious bias and diversity management.

With the aim of encouraging male employees with young children to actively participate in childcare, we encourage them to take child-care and related leave.

Utilization of childcare support program (FY2020)

Number of childcare leave users
and acquisition rate
100 men(8.5%)
137 women(100%)
Return ratio of female employees
after childcare leave
Number of users of the short-work hour program for childcare 119

Realizing the work life balance as a means to enable people with diverse situations perform well in the workplace

Restraint on long-work hour

As a precondition for an environment in which diverse human resources can perform at their best, we are committed to reducing long work hours based on appropriate work time management. Prior to the revision of the Labor Standards Act, starting in fiscal 2018, we set up work time capping rules for all employees, including managers, to promote improved work management and work practices that lead to more efficient, higher-value-added output.

We will continue to pursue workstyles that achieve maximum results within a limited amount of time, while incorporating the effects of business reform and DX measures.

Enabling flexible ways of working

All human resources with their diverse attributes and circumstances, such as age, gender, and restrictions on work time and workplace due to childcare and nursing care, ideally should make the most of their finite time available and perform at their best. From this viewpoint, we are expanding our work system to move away from traditionally-set ways of working and pursue more flexible and diverse ways of working in accordance with the nature of work at any given time and fluctuation in workload flow of operation needed at that time, and the circumstances of each individual.

In fiscal 2019, we revised the work-at-home system, which was previously limited to childcare cases, and introduced the teleworking system. Among employees under the flexible time system and those eligible to the short-work hour program for childcare and nursing care, those approved by the Company on the basis of their work assignment can do teleworking. The workplace in this case is not limited to home but any location.

Along with the introduction of the teleworking system, we have also adopted various IT tools to develop the environment that allows employees to work at any place as in the office. This has led to an efficient way of work, using spare time on business trip or out of office, and maximizing the ability of employees with childcare, nursing care, and other circumstances. In response to the COVID-19 pandemic, and since the Japanese Government made initial requests to refrain from going out and declared of the state of emergency, we have used the accumulated knowledge and experience, and have actively utilized the teleworking system.

A flexible time system has also been introduced. Since fiscal 2019, a more flexible management structure has been in place by our expanding the workplaces that could use the “coreless flexible system,” which eliminated the core time — an essential time period to be in the office, so that we can achieve a more harmonious way of working, balanced with personal life.

Based on these systems, we aim to achieve improved productivity and employees’ work-life balance, while pursuing ways in which individuals can perform at their best.

Enabling flexible ways of working

Realization of a flexible way to take time off from work

We have been establishing the employee environment so that it facilitates a flexible way to take time off from work, tailored to the circumstances of individual employees and their life stage.

With regard to annual paid leave, we encourage employees to use it to get refreshed physically and mentally. Each business site has set recommended dates to acquire annual paid leave. The head office, for example, sets every Friday in August as an “Eco-paid leave day,” and recommends that employees not set meetings and other events on those days in order to make it easier to take off those days. The annual leave utilization rate in and before fiscal 2019 exceeded 70%, but declined to about 60% in fiscal 2020 partly due to the effects of the temporary leave that was implemented in response to a large-scale production cuts. Looking ahead toward the target of 75% or higher in terms of the utilization rate, we will continue to work together with labor union to promote taking planned annual paid leaves in accordance with individual needs.

Concerning childcare leave, our program is applicable to a period that exceeds the statutory requirements and allows employees to accrue expired leave days for use. Currently, we are encouraging male employees who are entitled to childcare leave to do so and get actively involved in childcare. Through education and other means, we also focus on fostering a workplace culture that makes it easier for employees to take childcare leave.

Matched to the ongoing aging of Japanese society, programs for nursing care leave and time off for nursing care have been established to support employees continue working while attending to nursing care. The expired leave days that have been accrued can be used for nursing care purposes, as part of our efforts to provide an environment in which employees can work with peace of mind while providing care.

To promote the use of these programs, we distributed a brochure that summarizes each type of work and vacation program applicable for each life stage. We try to make the programs better known through various training programs.

 Realization of a flexible way to take time off from work

Benefit programs

In order to support the various life stages of employees and enable them to achieve a good work-life balance, we are also focusing on welfare measures. We support employees’ personal life with various programs: provision of housing, including dormitories and company housing, and a cafeteria plan (work-life support program).

Promote health management for employees to with a goal of maximizing workability until retirement at age 65.

Basic policy

We aim all employee work at their best from the time of joining the company to retirement, which has been extended to the age of 65. In order to accomplish this, we support them to maintain and enhance both mental and physical health. We conduct health promotion measures focusing on disease prevention as well as early detection and treatment. We are committed to providing an advanced health checkup including cancer or mental disorder screening and encouraging employees to take regular checkups and provide a consultation or a counseling about lifestyle or stress coping by health care professionals, as needed. Employees are expected to also be committed to implementing measures for their own health maintenance, such as to get various checkups and improve their daily lifestyle.

Nippon Steel Corporation Group Code of Conduct

5 Create a healthy, safe and comfortable work environment, and respect the character and diversity of our employees.

Nippon Steel’s Basic Policy on Safety and Health

Basic Philosophy

  • Ensuring and maintaining the safety and health of employees of the Nippon Steel Group is the Group’s most important, top-priority values and the basis that supports business development.
  • Under the Management Principles of “developing and bringing out the best in our people,” the Nippon Steel Group makes continuous efforts to abide by this philosophy and continues to contribute to society through their safety and health.

Specific Guidelines

  •  We observe applicable laws and regulations, and give top priority in all business decisions to ensuring safety and health.
  •  We maintain awareness and understanding of actual workplace conditions, provide the guidance needed to ensure safety and health, and remove factors that might lead to accidents.
  • We follow plans to implement measures to realize safer, healthier work procedures and work environments.
  • We ensure the observance of rules and engage in hazard prediction, and proactively implement workplace activities to enhance the level of safety and health.
  • We provide the education and training needed to ensure the safety and health of people working in the Nippon Steel Group.
  • We continuously develop and improve safety and health efforts through the safety and health management system.

April 1, 2019
Eiji Hashimoto
President of Nippon Steel Corporation

Commitment to the health of both the Company and its employees

Commitment to the health of both the Company and its employees

Organization for health promotion

Organization for health promotion

Promoting physical wellness

Cancer disease control

Various cancer screening (including non-statutory exams) based on age and gender are incorporated in our health checkups.

In particular, regarding exams for gastric and colon cancer, which are high risk diseases, we set the priority targets age and screening frequency for the examination, based on evidence. We also set our target rate of exam-taking and encourage employees to take exams for early detection and treatment of cancer.

Type of examinationPriority target
(target age and test frequency)
Gastric cancer examination (gastric fluoroscopy)Once every two years, 50-years old or older
Colorectal cancer test (fecal occult blood)Once a year, 40-years old or older
Prostate cancer test (PSA)Once every 3 years, 50-years old or older
Breast cancer screening (mammography)Once every 2 years, 40-years old or older
Cervical carcinoma of the uterus (uterine cytology)Once every 2 years, 20-years old or older
Gastric cancer risk test (pylori)When joined the company and at 40
Liver cancer risk test (hepatitis virus)When joined the company and at 40

Actual rates of taking cancer examination (2020)

Actual rates of taking cancer examination (2020)

Cerebral cardiovascular disease control

We have established a unique company-wide system that enables us to assess and manage the risk of diseases based on the results of health checkups. We provide health guidance according to risk factors or control the frequency of health checkups.

It is important that worker with high risk of cardiovascular disease improve their lifestyle. , We will improve the implementation rate of specified health guidance, which aimed at improving the dietary and exercise habits of workers, by setting a target rate and promoting medical visits. We cooperate with the Health Insurance Union for achieving the goal.

Specified Health Guidance (2019)

Specified Health Guidance (2019)

Promoting mental wellness

Aiming for each employee in the Nippon Steel Group to enjoy a robust life on and off the job, we provide a consulting service for prevention and early detection in the area of mental health, and have incorporated the issue of mental health in in-house seminars for each rank of employee. We also offer education on how to be aware of one’s own stress and to deal with it, how managers should care for their subordinates and manage their teams, and how to coordinate with the corporate health care professionals (physician, nurses, and other staff). We provide the stress check which is workplace stress survey every fall. Occupational health care professionals give guidance for improvement by teams and individuals based on the result of the stress check. In contributing to a vigorous work environment, managers implement necessary measures according to the issues of a team or an individual, coordinating with the personnel department and the health department. Because early detection and early response are important in the treatment of mental illness, we identify those who are at risk at the Health Consulting Contact by various measures in association with the Company’s “mental health e-learning and questionnaire event conducted every June.” Occupational health care professionals swiftly respond to the findings of the events to foster mental wellbeing.

Our mental health initiatives

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Classification Details
Proactive action (Self-care)
  • Stress check for awareness of their stress Mental health education programs by rank (target: new hires and young employees)
(Care by management supervisors)
  • Stress check for awareness of their stress
  • Support from supervisors or colleagues
  • Mental health education programs by rank(target: managers)
(Care by occupational health care professionals)
  • Providing mental health education program by occupational health care professionals
Early detection
  • Screening of those in poor conditions in the interview during a regular health checkup
  • Screening of highly-stressed people via stress checkups
  • e-learning to extract those who wish to be consulted
  • Establishment of a health counseling contact
Support for employees’ return to jobs and prevention of recurrence
  • Support for employees’ return to jobs based on the return-to-work program
  • Re-designing of work assignments for a smooth return to the workplace
  • Regular interviews after return by occupational health care professionals

Support to employees who work overseas

To enable employees who have been assigned to work overseas to be free of undue worries, a seminar for the employees and their family is held before the overseas assignment, and information on mandatory vaccination, the local medical system, and other matters are provided. Under the policy of providing continuous health management support during overseas assignments, interviews with occupational health care professionals are regularly conducted counseling via online and at the time of a temporary return to Japan, in addition to aftercare checkups of the regular medical exams. Moreover, one of the Company’s physicians periodically visits overseas offices, researches local medical institutions and the daily-life environment, and meets with the employees who work overseas to offer advice. We have contracted with a medical service company to provide the medical care locally, in preparation for the employees possibly becoming ill overseas.

Concerning the COVID-19 infections, necessary infection prevention measures, including evacuation measures, have been implemented in consideration of the local infection situation and the state of medical care, with the first priority on the safety and health of the employees who work overseas and their families.

Health-wellbeing activities

In addition to the above-stated health measures, we collaborate with the Health Insurance Union and labor unions in a variety of health-wellbeing activities, such as the “Health Challenge Campaign” living habits, “Health e-learning” for improving employee health awareness, and passive smoking preventive measures.

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Health Challenge Campaign
  • A company-wide effort in which employees challenge for two months to improve their own life habits
  • Provide courses that are effective in improving health checkup results and lifestyle.
    Ex. Take 8,000 steps a day/Have good breakfast
Health e-learning
  • Twice a year for all employees
  • The themes for 2020: “Healthy Life Basics: Sleep,” “Cancer Prevention and Cancer Screening”
Passive smoking preventive measures and non-smoking guidance
  • Since April 2020, smoking in Company buildings has been prohibited (excluding designated smoking rooms).
  • Visits to the on-site clinic or other clinics for smoking cessation or Web-based similar visits. For employees who wish to stop smoking, an occupational health care professional will provide individual guidance.

Preventing harassment

In order for all Nippon Steel employees to work with vigor, it is extremely important to respond appropriately to harassment issues, and we are strengthening our efforts to prevent them.

Specifically, we have clarified our internal policies to prevent harassment in terms of working regulations and internal regulations, and we have also prepared and distributed leaflets to promote awareness among all employees. In addition, we engage in education through e-learning for all officers and employees, and through sponsoring lectures on harassment at milestone training events, spanning activities from new employees to higher management. In addition to continuing these efforts, we will periodically review and improve the contents of our efforts, including the factoring in of awareness of unconscious biases as part of our training programs.

Several dedicated consultation and reporting points of contact have been established so that employees who face a harassment issue can consult with other people, in addition to someone close to themselves, such as their supervisor or colleague, . We are striving to create an environment wherein a harassment issue can be resolved without the employee concerned taking it on all alone.

Each of the contact points takes individual actions and makes sure not to disbenefit anyone for reporting or cooperating. After investigating and confirming the existence of a problem, we conduct fact checks and take strict measures in accordance with employment rules and other regulations.

Empowerment of the elderly and the disabled

Employment for the elderly

With regard to the promotion of the empowerment of the elderly, we extended the retirement age to 65 from 60 in fiscal 2021, after consultation with labor unions, and taking into account the declining working population, the response to the extended starting age of the pension system, and the maintenance and improvement of our workplaces.

Assuming that the same work will be carried out, even after the age of 60, the employment scheme as well as the salary and bonus scheme will remain the same up to the age of 65.

Under this new system, hopefully, all generations, up to 65 years of age, will continue to perform at their best at the front lines of our workplaces, while also invigorating the skill transfer process and communication within the workplace between generations, thereby creating a vibrant company.

Employment for the disabled

Recognizing employment of the disabled as an important social challenge, we are implementing an action plan for their employment and providing a friendly working environment.

Since 2007, we have established special-purpose companies to expand employment opportunities. As of June 2021, at four special subsidiaries of NS HEARTFUL SERVICE EAST NIPPON LTD., NS HEARTFUL SERVICE TOKAI LTD., NS HEARTFUL SERVICE KANSAI LTD., and NS HEARTFUL SERVICE KYUSHU LTD., over 100 people are actively engaged mainly in various outsourced work from Nippon Steel. The work includes data input and printing of written documents, cleaning of the steelworks premises, cleaning and management of the welfare facilities, and cleaning of work clothes.

Employment rate of the disabled
(as of June 2021)
Work scenery at one of the special-purpose subsidiaries

Work scenery at one of the special-purpose subsidiaries

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