Nippon Kayaku Group Human Rights Policy
The Nippon Kayaku Group recognizes its responsibility to protect the human rights of all people
affected by its business activities.
To that end, the Nippon Kayaku Group hereby establishes the Nippon Kayaku Group Human Rights
Policy (the "Policy") based on the United Nations Guiding Principles on Business and Human Rights,
with the purpose of promoting initiatives to ensure respect for human rights throughout the Group.
The Nippon Kayaku Group aims to meet the expectations of its stakeholders and contribute to society
through its business operations as part of its corporate vision, the KAYAKU spirit. As a standard ofconduct to realize the KAYAKU spirit, the Nippon Kayaku Group has established the Nippon Kayaku
Group Charter of Conduct and Code of Conduct. In all of its corporate activities, the Group respects
fundamental human rights, complies with laws and regulations, engages in fair business activities, andseeks to repay the trust placed in by its stakeholders by providing happiness and delight.
1. Basic policy on human rights
This Policy is a promise that the Nippon Kayaku Group will respect human rights, in order to earn thetrust of all stakeholders based on its corporate vision:, the KAYAKU spirit. The Nippon Kayaku
Group supports and respects international norms relating to human rights, including the United
Nations’ International Bill of Human Rights (made up of the Universal Declaration of Human Rights[UDHR], the International Covenant on Civil and Political Rights [ICCPR], and the International
Covenant on Economic, Social and Cultural Rights [ICESCR]), the United Nations Declaration on theRights of Indigenous Peoples, the OECD Guidelines for Multinational Enterprises, and the ILO
Declaration on Fundamental Principles and Rights at Work, as well as the Children’s Rights andBusiness Principles developed by the United Nations Children’s Fund (UNICEF), the United Nations
Global Compact, and Save the Children. As a signatory to the UN Global Compact, the Nippon
Kayaku Group also supports and respects the Ten Principles of the Compact.
2. Respect for human rights through business activities
2.1 Prohibition of discrimination and harassment
The Nippon Kayaku Group does not tolerate discrimination or harassment based on gender, age,nationality, race, religion, disability, place of origin, ancestry, creed, political views, sexual orientation,
marital status, employment status, or other characteristics.
2.2 Appropriate working hours
The Nippon Kayaku Group manages its employees’ working hours, days off, and leave entitlements
appropriately and in accordance with applicable laws and regulations.

2.3 Fair and equitable remuneration
The Nippon Kayaku Group provides its employees with fair and equitable remuneration. It complies
with applicable laws and regulations on minimum wages, out-of-hours work, and statutory welfare
and well-being programs and pays its employees an amount higher than the minimum wage so thatthey are able to maintain or exceed a certain standard of living.
2.4 Freedom of association and collective bargaining rights
Pursuant to laws, regulations, and labor practices of countries and regions where it operates, theNippon Kayaku Group respects its employees’ freedom of association and the right to collective
bargaining in their labor-management relations.
2.5 Prohibition of forced labor
The Nippon Kayaku Group does not tolerate forced labor. It also has no tolerance for modern slavery
in any form, including debt bondage or human trafficking.
2.6 Prohibition of child labor
The Nippon Kayaku Group does not tolerate child labor and observes the statutory minimum working
age. It does not engage any person under the age of 18 years in dangerous operations that may harmthat person’s health or safety, such as night work or out-of-hours work.
2.7 Occupational health and safety
In accordance with applicable laws and regulations, the Nippon Kayaku Group establishes a work
environment where each and every employee can continue to work in good health and safety andwithout undue stress.
2.8 Impact on community residentsIn order to avoid adverse effects on the safety and health of local community residents, the Nippon
Kayaku Group conducts human rights impact assessments (such as those relating to contamination
and water stress) and takes necessary measures in accordance with international norms to avoid risks
and mitigate impacts.
3. Scope of application
This Policy applies to all officers and employees of the Nippon Kayaku Group. The Nippon Kayaku
Group requires all business partners involved with its business activities, products and services tocomply with this Policy.
4. Responsibility to respect human rights
The Nippon Kayaku Group recognizes that it cannot completely eliminate the possibility of adverse
impacts on human rights in its business activities. The Nippon Kayaku Group will fulfill its
responsibility to respect human rights and build a responsible supply chain by not infringing on thehuman rights of those affected by its business activities and by taking appropriate measures to correctany adverse impact on human rights in its business activities.
5. Human rights due diligence
The Nippon Kayaku Group will establish a system to ensure human rights due diligence, identify
adverse impacts of the Group on human rights in society, and strive to prevent and mitigate suchimpacts.
6. Dialogue and consultation
The Nippon Kayaku Group recognizes that in order to appropriately address any impacts of its
business activities on human rights, it is important to adopt the perspective of stakeholders whose
human rights are, or are likely to be, affected by its business activities.
7. Education and training
The Nippon Kayaku Group will provide appropriate education and training to ensure that this policy
is incorporated and effectively implemented in all of its business activities.
8. Access to remedy
If it is found that the Nippon Kayaku Group's business activities have caused an adverse impact onhuman rights, or if involvement through business partners is discovered or suspected, the Company
will conduct an appropriate investigation and, if necessary, work to remedy the situation throughdialogue based on international standards and appropriate procedures.
9. Person responsible
The Nippon Kayaku Group shall clearly specify an officer in charge of the implementation of thispolicy and supervise the state of its implementation.
10. Information disclosure
The Nippon Kayaku Group will disclose the progress and results of its efforts to respect human rights
on its website, and by other means.
11. Applicable laws and regulations
The Nippon Kayaku Group will comply with the laws and regulations of each country or region inwhich it conducts its business activities. In the event of any conflict between the laws and regulationsof individual countries and internationally recognized human rights, the Group will pursue ways torespect international human rights policies to the fullest possible extent.

This policy is adopted by the Company's Board of Directors and signed by its President andRepresentative Director.
Established April 1, 2022
Revised February 27, 2024
Nippon Kayaku Co., Ltd.
President and Representative Director
Atsuhiro Wakumoto