NRS Group Anti-Bribery and Corruption Policy
Policy (Declaration)
NRS Group, guided by the corporate philosophy of “Like a shining diamond, to sharehappiness with everyone,”adheres to the "NRS Group Ethical Business Standards,"
which promotes "business activities based on laws, social norms, and social
common sense" and "healthy and positive relationships with business partners andstakeholders in commercial transactions."
Our group, based on these fundamental principles, is committed to thorough antibribery and corruption efforts. We will comply with laws and regulations thatprevent bribery in various countries and regions where our group operates,including Japan's Unfair Competition Prevention Act, the United States Foreign
Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA), and China's commercial
bribery regulations. This policy applies to all officers and employees of our group,
including employees, contract employees, consultants, advisers, temporary workers,
and dispatched workers, who have employment contracts with various NRS Groupcompanies.
1.Prohibition of Bribery
NRS Group shall not engage in the following actions:
1.1.Bribery
Offering, promising, or approving, directly or indirectly, the provision of money orother benefits to public officials or others (※1) both domestically and internationally,in order to influence their official duties.
1.2.Extortion
Demanding, promising, or accepting money or other benefits as compensation forproviding actual benefits, whether for oneself or a third party, both domestically andinternationally.
(※1) "Public officials or others" refers to individuals falling under the following
categories:
1. Those engaged in public duties for governments (hereinafter referred to as"governments") in Japan or foreign countries.
2. Those engaged in administrative work for government-related agencies.
3. Officers or employees of legal entities that are treated similarly to public officials
under domestic and foreign laws.
4. Individuals engaged in public duties for international organizations.
5. Individuals performing tasks delegated by governments or internationalorganizations.
6. Staff members of political parties.
7. Candidates for public office.
8. Others who are similar to those mentioned in 1-7 above.

2.Entertainment and Gifts to Non-Public Officials
Entertainment, gifts, and similar gestures to individuals who do not qualify as public
officials in accordance with local laws will be conducted within socially acceptablenorms and in compliance with the laws of each respective country.
3.Establishment of Anti-Bribery and Corruption Measures
NRS Group designates the Internal Control, Legal, and Risk Management
Department as the responsible department for establishing anti-bribery andcorruption measures. We maintain and operate an organizational structure toprevent bribery and corruption through rigorous and fair operation of internalreporting channels and comprehensive commitment to these measures.
4.Understanding and Compliance with NRS Group Corporate Ethics CodeNRS Group outlines compliance standards, including anti-bribery and corruption, inthe "NRS Group Corporate Ethics Code." We publish this code on our website andensure that all officers and employees of NRS Group understand and comply withit.
5.Audit and System Review
NRS Group will periodically assess its anti-bribery and corruption measures throughaudits, with a continuous focus on improvement.
6.Recording and Preservation of Transaction Details
NRS Group will accurately and appropriately record and preserve all expenses inaccounting records and other relevant documents to demonstrate that bribery.
7.Measures Against Bribery and Corruption
If NRS Group becomes aware of concerns related to bribery and corruption, we willconduct appropriate and necessary investigations. When evidence of bribery andcorruption is found, we will take proper and strict actions in accordance with internal
regulations and employment rules.
Established on October 1, 2023
Hiroto Tanaka
President & COO