Nittoku Human Rights Policy
NITTOKU supports the "United Nations Guiding Principles on Business and Human Rights",
international human rights principles, and international norms on human rights, and promotes
efforts to respect human rights based on these principles.
We have established the following human rights policies and will comply with them to ensure thathuman rights are respected.

1. Scope of application
This policy applies to all directors, officers, employees, and temporary employees of ourcompany. We also encourage our suppliers, business partners, and others who support us torespect human rights in accordance with international human rights norms and to make every
effort not to violate them.

2. Respect for human rights
We, NITTOKU Corporation (hereinafter referred to as "we" or "us"), shall take utmost care not
to infringe upon the human rights of others in all aspects of our business activities, and shallstrive to prevent and mitigate negative impacts on human rights, thereby fulfilling ourresponsibility to respect human rights.
We will conduct human rights due diligence to assess the impact of our business activities onhuman rights, and will continuously monitor and report the impact to the appropriate parties. If
any negative human rights impacts should arise through our business activities, we will
respond appropriately with fair and equitable remedial measures to mitigate or eliminate suchimpacts.

3. Diversity and inclusion (acceptance of diversity)
We are committed to maintaining a work environment that is free from disparate opportunity,
discrimination, disadvantageous treatment, or harassment based on race, ethnicity, gender,
physical characteristics, nationality, social origin, religion, age, disability, sexual orientation,gender identity or expression, or political opinion.
Recruitment activities, hiring, staffing, training, compensation and promotion are conductedwith respect to competence, performance, skills and experience.
We do not tolerate any form of harassment or conduct that is offensive to personal dignity,including, but not limited to, lack of respect, inappropriate behavior, unfair treatment, orretaliation. These will not be tolerated outside the workplace as well as in the workplace.
We will continue our efforts to prevent human rights violations through regular education andother measures.

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4. Freedom of association and the right to collective bargaining
We respect the right of employees to form labor unions without fear of reprisal or harassment,
and to choose whether or not to participate in such unions in accordance with applicable laws
and regulations. If a labor union is formed, the Company will endeavor to have a constructive
dialogue with the labor union and will negotiate in good faith.

5. Prohibition of forced labor
We prohibit all forms of forced and compulsory labor.

6. Prohibition of child labor
We will comply with minimum age limits for employment in accordance with applicable laws
and regulations.

7. Maintaining the safety and health of employees
We will comply with all safety and health laws and regulations, and strive to create andimprove a healthy, safe and sanitary work environment.

8. Internal reporting system
An internal reporting system has been worked to accept consultations and reports.
If you become aware of any conduct that violates or may violate laws, regulations, corporate
ethics, internal rules and regulations including this policy, or other unethical practices, you
may report or consult with your division or department head. Anyone may also reportanonymously to the Compliance Hotline.
The consultation system shall maintain anonymity and confidentiality, and shall prohibit any
disadvantageous treatment or retaliatory measures against such persons by the concernedparties.
We will investigate and respond to reports, take appropriate action, and take appropriate
corrective or remedial measures in the event of violations.

9. Privacy
We will comply with laws and regulations regarding personal information and ensure that all
personal information is obtained and handled appropriately.
This policy has been approved by our Board of Directors and signed by our President and CEO.

October 31, 2023
President and CEO Junichi IDE

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