NOK CORPORATIONESG DATA BOOK
2023

Content, Editorial Policy
This Data Book summarizes the NOK Group's performance data,
policies, and initiatives related to the environment, society, andgovernance (ESG). Referring to multiple reporting guidelines, wehave organized related numerical data for each ESG category.
We consider this Data Book to be a vital means of improving
communication with all of our stakeholders. We would appreciate
your candid opinions and feedback on the report.

Basic
Information

Environment​

Period Covered
Most of the activities described in this report took place in fiscal
2022 (April 1, 2022, to March 31, 2023)* Some activities are initiatives that began before the target period, as well very recent activities

Publication Date
July 2023 (published annually)Society

Scope of Coverage
NOK Corporation and 91 consolidated subsidiaries
Referenced Guidelines• ISO 26000: 2010 - Guidance on social responsibility• Global Reporting Initiative (GRI) Standards• United Nations Global Compact• Task Force on Climate-related Financial Disclosures (TCFD)
Governance​

Contact
Corporate Affairs Office, NOK CORPORATION
1-12-15 Shiba Daimon, Minato-ku, Tokyo 105-8585, Japan
TEL: +81-3-5405-6372 FAX: +81-3-5405-6379

Company Profile
Financial Data

01

Sustainability Overview

02

Environmental Management

03

Information Disclosure Based on TCFD Recommendations

06

Climate Change Countermeasure

09

Resource Conservation and Waste Recycling

11

Conservation of Water Resources

12Management of Substances of Environmental Concern

14

Environmentally Friendly Products

15

Conservation of Biodiversity

17

Human Rights

22

Human Resources

24

Labor Practices

25

Diversity27

Human Resource and Welfare System

28

Occupational Safety and Healthcare30

Supply Chain Management

33

Product Quality and Safety

35

Participation in Communities and Community Development

40

Corporate Governance

41

Compliance

44

Risk Management

47

GRI Standard Content Index

52

Disclaimer
This Data Book contains forward-looking statements regarding the Group’s plans, strategies, and performance. These are assumptions and judgments
based on information available at the time of issue, which entail risk and uncertainty. Please understand that future performance may differ from thesestatements due to changes in the environment and other factors.

Basic Information
Company Profile
Company Name NOK CORPORATIONHead Office

1-12-15 Shiba Daimon, Minato-ku, Tokyo 105-8585, Japan

Established

December 2, 1939

FoundedJuly 9, 1941

Capital23,335 million yen (as of March 31, 2023)

Number of
Employees

37,913 (consolidated, as of March 31, 2023)
3,419 (non-consolidated, as of March 31, 2023)

Consolidated
Subsidiaries

91 companies

Composition of employees by region (consolidated)

Europe and the United StatesJapan

1,410 (3.7%)

10,648 (28.1%)
FY 2022

37,913
Southeast Asia

15,196 (40.1%)

persons

China

10,659 (28.1%)

Basic Information

Environment​

Society

Governance​

Financial Data
Net sales (consolidated)

Operating income/Operating income margin (consolidated)(100 million yen)(100 million yen)

7,500

350
300
250
200
150
100
50
0

7,000

7,100
6,825

6,695
6,268

6,500

5,964

6,000
5,500
5,000

2018

2019

2020

2021

2022

(FY)

(%)

10

313

8

231
145

3.5 120

2.4

1.9
2018

2019

2020

Operating income

6

4.6 154

4

2.2 2
2021

2022

0
(FY)

Operating income margin

Net sales by geographic area (consolidated)

Net sales by business area (consolidated)

Other countries

506 (7%)

Other Business

Other Asian countries
and regions

284 (4%)

Electronic Products
Business

3,345 (47%)

1,299 (18%)

Seal Business

FY 20222,627 (37%)
FY 20223,471 (49%)

7,100

Japan

7,100

100 million yen

100 million yen
China

2,667 (38%)

R&D expenses by business (consolidated)

R&D expenditure by business (consolidated)

Other Business

8 (7%)

Other Business18 (4%)

Electronic Products
Business
13 (11%)

Seal Business

FY 2022

113

Seal Business

FY 202292 (82%)

Electronic Products
Business

100 million yen

187 (39%)478
100 million yen

272 (57%)

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022

100 million yen

34

-22

-14

258

133

Consolidated

%

0.4

-0.3

-0.2

3.1

1.5

ROE (Return on Equity)

Consolidated

%

0.8

-0.5

-0.3

5.4

2.6

Capital expenditure

Consolidated

100 million yen

701

477

257

410

478

R&D expenditure

Consolidated

100 million yen

105

113

101

104

113

Total assets

Consolidated

100 million yen

7,851

7,287

8,030

8,573

8,628

Net assets

Consolidated

100 million yen

4,855

4,472

5,021

5,544

5,773

Income tax

Consolidated

100 million yen

130

92

65

113

175

Item

Scope of coverage

Unit

Profit attributable to owners of the parent

Consolidated

ROA (Return on Assets)

01

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Sustainability Overview
NOK Group Sustainability Statement
At NOK Group, we aim to extend beyond generating economic
benefits for stakeholders: we aspire to evoke a profoundsense of pride within them. To that end, we have been
dedicated to fostering a sustainable society alongside ourbusiness endeavors since our founding.
Our Purpose statement, “Shaping Possibilities with
Unique Technology,” reflects our ambition to enhancepeople's lives with innovative products created using
proprietary technologies based on our R&D, and we strive tooffer people safer and more comfortable lifestyles byharnessing these capabilities and embracing diversity anduntapped possibilities.
We remain committed to proactively tackling worldwide
environmental and social challenges by leveraging the inherent
value within our company to realize a sustainable society.

Sustainability Framework, Governance
The NOK Group established an ESG Committee under the
direction of the Board of Directors to be a body that
formulates various management policies from a medium- tolong-term perspective. The ESG Committee, chaired by the
President and CEO, is made up of the various generalmanagers and directors who oversee ESG activities.
The committee promotes corporate management thatincorporates ESG values, such as by establishing policies
and targets for the NOK Group related to the environment,
society, and governance and monitoring progress toward
these targets.
The ESG Committee has also established two
subcommittees to support the implementation of ESG
measures from a specialist perspective. The Carbon Neutral
Subcommittee works on efforts across the Group to achievecarbon neutrality. The Climate Change Scenario Analysis
Subcommittee seeks to understand risks and opportunities
for our business activities based on the recommendations of
the Task Force on Climate-related Financial Disclosures(TCFD), and to reflect these risks and opportunities in ourbusiness activities.
Initiatives discussed by the ESG Committee arereviewed by the Board of Directors.

Board of Directors

ReportApprovals and Directions
Report

ESG Committee (Committee Chairperson: President)
ReportDirections

Climate Change
Scenario Analysis
Subcommittee

ReportCooperation

Directions

Carbon Neutral
Subcommittee

Promotion and Execution

Promotion and Execution

Cooperation

Promotion and Execution

Bases and Group companies

Participation in Initiatives
Initiatives in which NOK participates
CDP (formerly Carbon Disclosure Project)
United Nations Global Compact
Keidanren Japan Climate Initiative
Keidanren Initiative for Biodiversity Conservation
Ministry of the Environment Cool Choice
Keidanren Challenge Zero
Task Force on Climate-related Financial Disclosures (TCFD)

02

Central Environmental Conservation Committee(Chairperson: President)

NOK CORPORATION ESG Data Book 2023

Energy Conservation
Subcommittee

Environment​

Basic Information

Society

Governance​

Environment
Environmental Management
Basic Concept
NOK has established a system in accordance with ISO 14001
standards, promotes environmental management, andstrives to implement environmental management with thenext generation in mind, thereby reducing its environmental
burden. The current percentage of NOK Groupestablishments with ISO 14001 certification is 98.5%.

Basic Policies on Environmental Conservation

1

Based on our existing proprietary technologies, we strive to reduce environmental impact by promoting the improvement of technologies
and the development of products that take environmental conservation into consideration.

2

We comply with environmental laws and regulations, local government ordinances, and regional agreements, etc., and promote
activities for environmental conservation.

3
4
5

We promote energy conservation and reduction of greenhouse gas emissions to achieve a decarbonized society.
We strive to conserve resources and contribute to a circular society by reducing, reusing, and recycling waste.
To conserve water resources, we promote efficient water use and appropriate management of water quality.

6

We assess our impact on biodiversity and promote biodiversity conservation activities tailored to local characteristics in cooperation withbusiness partners and external organizations.

7

We strive to prevent environmental pollution and reduce environmentally hazardous substances by thoroughly managing all
chemical substances.

8

We disclose information on environmental conservation and social contribution activities and proactively communicate with local andbroader society.

9

We promote environmental education for all our employees to raise awareness of the global environment.

10

We strive to continuously improve our environmental management system by setting targets, promoting activities to reduce environmental
impact, and regularly assessing progress.
Enacted on September 17, 2001
Revised on June 28, 2023
Representative Director, Chief Executive Officer, NOK CORPORATION

Masao Tsuru

NOK’s Environmental Strategy: Twin Green Plan 2030
In response to the global trend toward carbon neutrality andthe results of TCFD scenario analysis, we revised the NOK
Twin Green Plan 2030, formulated in 2018, and declared that
we will aim to achieve carbon neutrality by 2050.
Under this long-term vision, the Group will work together

03

to realize a sustainable society through the provision of
eco-friendly products and business activities in response toelectrification of automobiles and carbon neutrality.
* For details, please refer to NOK’s website:
https://www.nok.co.jp/en/csr/twingreen.html

NOK CORPORATION ESG Data Book 2023

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Material Balance
INPUT

FY 2022 NOKOUTPUT

Raw materials

DesignGas emissions

Total raw-material input

79,183

Rubber11,994tons

Additives & Adhesives

10,188tons

Plastics

1,039

tons

Metals55,962

tons

EnergyTotal energy input

1,347

TJ

1,209

TJ

Gasoline

5

TJ

Kerosene

3

TJ

Heavy Oil A

35

TJ

Light Oil

1

TJ

Liquefied Petroleum Gas (LPG)

71

TJ

City Gas

24

TJ

Electric Power

Total CO2 emissions (Scope 1 + Scope 2)*1

tons

Water

• Environmental Conservation
Assessment of Products, etc.
• Environmental Impact Assessment

Procurement• Environmental Impact Assessment• Green Procurement•E nvironmental Conservation
Inspection of Machinery andEquipment

Production

Scope 1 (Fuel)

8 1,000 tons-CO2

Scope 2 (Electricity/heat)164 1,000 tons-CO2

Scope 3 (Indirect emissions)

2,137 1,000 tons-CO2

NOX (Nitrogen Oxides) *2

12

tons

SOX (Sulfur Oxides) *

2

tons

VOCs (Volatile Organic Compounds)

2

1,000 tons

Total wastewater623

1,000 m3

Rivers504

1,000 m3

Sewage system

119

1,000 m3

4

tons

By-product generation

44

1,000 tons

Industrial waste

18

1,000 tons

2

Wastewater

BOD load *3• Life Cycle Assessment (LCA)• Pollution Prevention• Chemical Substances Control• Energy Conservation• Waste Reduction• Environmental Impact Assessment

172 1,000 tons-CO2

Industrial waste, etc.

Total water withdrawals

792

1,000 mAmount of waste recycled

18

1,000 tons

Drinkable water620

1,000 m3

Final disposal

0.05

1,000 tons

Industrial water34

1,000 mValuable waste

26

1,000 tons

Groundwater139

1,000 m3

3

3

Logistics• Efficient Transportation• Promotion of Modal ShiftEnvironmentally hazardous substances
Chemical substances subject to the
Pollutant Release and Transfer Register(PRTR) system*4

1,456

tons

Customers

Environmentally hazardous substances
Chemical substances subject to the
Pollutant Release and Transfer Register(PRTR) system (discharge volume)*4

68

tons

Chemical substances subject to the
Pollutant Release and Transfer Register(PRTR) system (amount of movement)*4

46

tons

*1 Total CO2 emissions: Calculated based on the “Greenhouse gas emissions accounting and reporting manual.” The emission factor is based on the national emission factor by country publishedby the International Energy Agency (IEA).
*2 NOX (nitrogen oxides) and SOX (sulfur oxides): Total amount of NOX and SOX generated from specified facilities under the Air Pollution Control Act.
*3 BOD load: Biochemical oxygen demand (BOD) is one of the indicators of water pollution, and represents the amount of oxygen used by microorganisms to decompose pollutant organic material
in water. The figure for BOD load was obtained by multiplying the BOD measurement by the amount of effluent entering rivers.
*4 Substances subject to the PRTR system are preliminary figures as of May 30, 2023.

Concrete Activities
Environmental awards
In FY2020, the NOK Group introduced an environmental awards
program for the purpose of breathing life into environmental
activities within the Company and raising the awareness of every
employee regarding environmental issues. The program
comprehensively evaluates actions taken at each site to address
climate change, resource efficiency and circulation, biodiversity,and other environmental issues.
The initiatives judged to be the most outstanding are recognizedwith an award. The program also provides incentives.
In FY2022, the gold prize went to Wuxi NOK-Freudenberg
Oil Seal Co., Ltd. (WNF) for its work on reducing its overall

04

impact on the environment, taking into account its capacity totreat exhaust and wastewater when expanding production.
The silver prize was awarded to the NOK Plastics &Polyurethane Division for achieving significant energy
savings by reducing compressor power consumption andsteam fuel. The bronze prize was presented to Thai NOK Co.,
Ltd. (TNC) for the various initiatives it undertook to curtailelectricity use, utilize resources effectively, and plant trees.
It is hoped that this program will continue to raise awarenessof environmental conservation throughout the entire NOKGroup and further improve environmental activities.

NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Society

Governance​

Compliance with environmental laws and regulations
The NOK Group faced no major fines, surcharges, or lawsuits
related to environmental accidents or complaints in FY2022.
Environmental education
The NOK Group conducts a variety of education programs tofoster a company-wide environmental spirit. The NOK Group
conducts education by rank for its employees, as well as
specialized education that covers ISO 14001 management,
energy, waste, and chemical substance management, anddrills based on emergency scenarios. The result is raising
the environmental awareness of every employee.
New employee

General employee

Management positions

New employee training

Level-specificeducation

The CDP is an international NGO in the environmental
field, particularly climate change. It sends out questionnaires
to the world’s companies asking them to disclose
information about their environmental activities. Based on
the responses, it ranks the environmental actions of eachcompany and globally discloses that information.
In FY2022, we scored a “B” in both the Climate Change
and Water Security categories.
Going forward, we will continue to undertake initiatives
geared towards improving environmental problems so that
we might contribute to a sustainable society.

General employee education

2022
Climate Change

B

Water Security

B

Education for
management positions

Specialized
education(for eligible
employees)

Emergency-related education

Japan Climate Initiative

Education for internal auditors

The Japan Climate Initiative is a network committed tostrengthening the communication of information andexchange of opinions among mainly companies, local
governments, and NGOs that are actively fighting climatechange. The NOK Group became a member organization of
the Japan Climate Initiative in FY2022. We endorsed thedeclaration of this initiative to join the frontline of the global
decarbonization movement from Japan and we will continue
to take steps to reduce our greenhouse gas emissions with aview to realizing a carbon-neutral society by 2050.

Waste-related education
Energy-related courses
Chemical substances-related education

Working with suppliers
NOK administers an environmental survey to suppliers,
seeking to work together across the supply chain to reduce
environmental impact. Through this survey, we have beenable to ascertain up to 76% of suppliers’ CO2 emissions from
NOK alone. In addition, we have confirmed our water risk
assessment initiatives, and 79% of the suppliers who
responded to our survey have conducted water risk
assessments. We will continue to pursue initiatives toimprove environmental awareness among suppliers, and will
expand the scope of our efforts to include consolidated
companies so that we can reduce environmental impact
across the supply chain.

External Recognition and Initiatives in theEnvironmental Field
The NOK Group has been recognized externally for its
environmental actions. We have also endorsed, and signed
up to, various initiatives.

Initiative for Biodiversity Conservation
The NOK Group has supported the Keidanren Initiative for
Biodiversity Conservation since 2019.
The Keidanren Initiative for Biodiversity Conservation iscomprised of companies addressing more than one of theseven items in its revised action policy or companies thatagree with its overall purpose.
We will continue to partner with external organizations
to implement measures to help prevent deforestation andalleviate the impacts on biodiversity with the aim ofcontributing to the creation of a cohesive society in harmony
with nature.
Cool Choice
NOK has supported the Cool
Choice campaign of Japan’s
Ministry of the Environment
since 2020.

CDP
Since 2016 we have continued
to respond to the CDP’squestionnaire.

05

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Cool Choice is a popular movement initiated by the
Ministry of the Environment to encourage all kinds of“smart choices” in the fight against global warming toachieve the Japanese government’s stated targets under
the Paris Agreement.
We will press ahead with energy-saving measures andother initiatives for reducing our CO2 emissions as we work
towards achieving carbon neutrality by 2050.
Challenge Zero
NOK has endorsed the Keidanren’s Challenge Zero declaration
since 2020.
Challenge Zero is a project that registers and promotes
the “innovation challenges” of companies as they work
towards achieving a carbon neutral society to realize, in thesecond half of this century, the Keidanren’s stated aims of acarbon-free society and net-zero emissions.
NOK has registered a challenge that aims to realize ahydrogen society through the development of components for
greater fuel cell adoption. We continue to work on developing

Society

Governance​technologies and products that can help bring about acarbon-free society.
TCFD
In light of recent worldwide trends to achieve carbon
neutrality, the NOK Group expressed its support for therecommendations of the Task Force on Climate-related
Financial Disclosures (TCFD), established by the Financial
Stability Board (FSB), in April 2022. The NOK Group had beenpromoting initiatives on climate change under the NOK Twin
Green Plan 2030, its environmental vision for 2030, and now,
based on its endorsement of TCFD, the Group intends tofurther strengthen its efforts. Based on the TCFD's
recommendations, we will identify the risks andopportunities that climate change poses to our businessactivities, reflect them in our business strategies, andactively disclose information to enhance our corporate value.

Information Disclosure Based on TCFD Recommendations
In line with the recommendations of the TCFD, we disclose the NOK Group’s business strategies related to climate change.

Governance
The NOK Group has established an ESG Committee under
the auspices of the Board of Directors to formulate policies
and targets related to environment, social, and governanceissues, and to also monitor progress made towards
achieving those targets. Initiatives discussed by the ESG
Committee are subject to review by the Board of Directors.
Also, with the framework we have in place, the Climate
Change Scenario Analysis Subcommittee and the Carbon
Neutral Subcommittee, under the direction of the ESG
Committee, take the lead in collaborating with related
internal organizations, business sites, and Group companies
to promote climate change initiatives, reporting regularly to
the ESG Committee.

Risk Management
NOK’s “Risk Management Regulations” stipulate the basic
policy and management system for risk management acrossthe entire Group. Based on these regulations, the Company
has established a management system in which the CEO is
responsible for risk management and promotes risk
management for the Group. The ESG Committee evaluates06

and manages climate change risks and opportunities.
The Climate Change Scenario Analysis Subcommittee
collaborates with related internal organizations to pick out
and identify climate change risks and opportunities based on
their degree and duration of impact on our businesses.
The results of that identification process are reported to the
ESG Committee, which then assesses and discusses them,
before examining countermeasures and reflecting them inbusiness strategies. The most important risks and opportunities
are periodically reported to the Board of Directors.

Strategy
We recognize that climate change is an importantmanagement issue that will affect our finances into the
future. As such, we have carried out scenario analyses inaccordance with TCFD recommendations to assess theimpact and reflect climate change countermeasure in ourmanagement strategy. Based on data from sources such as
the International Energy Agency (IEA), the impacts of climatechange on our businesses were defined under two scenarios,the 4°C and 2°C scenarios. We then evaluated the risks andopportunities those two scenarios pose to the NOK Group.

NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Based on the results of these scenario analyses, we will be
reviewing and promoting actions to address the identified
risks and opportunities as outlined on the right.
We will also continue to expand our scenario analyses andSocietyincorporate their results into our business strategies andmanagement plans. The goal is to improve the resilience ofour management strategy.

4°C scenario

Envisioned world

Governance​

2°C scenario

Temperature rise

By the end of the 21st century, the global temperature rises by
about 4°C compared to the pre-industrial era.

By the end of the 21st century, the global temperature rise is kept toless than 2°C higher than the pre-industrial era.

Policies/energy

Little or no progress in carbon neutrality policies, no carbon tax
introduced, limited deployment of renewable energy.

Carbon taxes are introduced, the share of renewable energy grows,
business costs rise accordingly.

The automotive industry gradually moves towards electrification,
but the bulk of vehicles still run on internal combustion engines.

The automotive industry undergoes rapid electrification, which
results in a decline in the number of internal combustion engine
vehicles.

Gradual advances in electrification are accompanied by a gradualrise in the price of related raw materials.

Markets related to renewable energy and the reduction ofenvironmental footprints expand, and the robotics and semiconductor
markets also expand with the acceleration of digitalization.
The expansion of these markets is accompanied by rises in prices ofrelated raw materials to levels even higher than in the 4°C scenario.

Rising temperatures increase damage from flooding and tropical
cyclones, which affects factory operations and supply chains.

While rising temperatures cause damage from flooding and tropical
cyclones, their impacts are smaller than under the 4°C scenario.

Markets/raw materials

Physical risks

Scenario definition Period covered: 2030 Scope of coverage: Consolidated
Referenced scenarios: IEA 2DS, IEA SDS, IEA STEPS, RCP2.6, RCP4.5, RCP6.0, RCP8.5, etc.

Risks and Opportunities
Physical risks and our measures
More than 90% of the NOK Group’s production sites arelocated in Japan and other parts of Asia. Among all 76 sites,
eight have been assessed to be of high risk by the
AQUEDUCT* flood risk assessment tool (rivers andcoastline). The scale and frequency of floods and typhoon
damage in the Asian region are expected to increase in the
future as the impact of climate change worsens. Accordingly,
all of NOK’s sites, not just those currently designated as highrisk, carry the risk of negatively impacting operations andupstream/downstream supply chains. To combat this risk,
we are assessing the risk of hazards from natural disasters
at each site and, together with the flood risk of every site, we
are implementing longer-term (at least five years) water
gating and other disaster-prevention measures. We are also
ensuring we have enough raw materials and productinventory to cope with such risks in an effort to minimize theimpacts on upstream and downstream supply chains.
* AQUEDUCT is a water risk assessment tool made available by the World
Resources Institute (WRI). It is presented in the form of a world map that showswater risks in terms of quantity, quality, and regulatory and reputational risks.

Transition risks and our measures
The NOK Group’s mainstay products stop oils, liquids, gases,
and other substances in various forms from leaking out withthe use of sealing technology. A typical NOK product is oil
seals, which have long been used widely in the internal
combustion engines of vehicles. Given that the transition to a
low-carbon society for the purpose of neutralizing the07

impacts of climate change is accelerating a shift towards EVs,
we anticipate the risk of a decline in oil seal sales for internal
combustion engine applications. In terms of response
measures, the NOK Group is promoting product development
and sales expansion in fields that offer potential growth in a
low-carbon society, including electrical units for electricvehicles, seal products for batteries, and FPCs.
Also, another aspect of the global decarbonization
movement is the possibility that carbon tax regulations ineach country could be enacted and tightened. Most of the
NOK Group’s CO2 emissions come from the use of electricity
and there are concerns that business costs will increase if
the amount of CO2 we emit directly is taxed, or if our power
costs are hit with a carbon tax. Therefore, with the aim offurthering our efforts to reduce CO2 emissions, we raised our2030 overall domestic CO2 emissions reduction target to 50%
and the overseas emissions intensity reduction target to30%, compared to FY2018. We will continue to look at solar
power generation and the capacity of other technologies andproducts that can be adopted immediately, but up ahead,
we will closely examine and trial new emerging technologies
and measures and make investment plans to ensure that wereach our reduction targets.

NOK CORPORATION ESG Data Book 2023

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Group-wide

Impacts

Risks

Opportunities

Actions emand for control/electrical units andDelectronic components grows withelectrification.
Carbon neutrality increases opportunities togrow sales of low-friction, long-life products.
Markets related to renewable energy,
semiconductors, and labor- and powersaving (robots, etc.) grow.

 xpand sales to the electric vehicle (EV/FCV)
E
market and growth industries (renewableenergy, semiconductors, etc.).
Create more opportunities to expand sales ofseal products for electrical units and batteries
for electric vehicles, as well as newly
developed products.
Develop and expand sales of products withsmaller environmental footprints (low friction,
long life, high durability, bio-based raw
materials, etc.)
Develop and expand sales of FPCs for electricvehicle batteries.
Expand sales in the renewable energy storage
battery market.
Cultivate the electric vehicle infrastructure
market (charging stations).

 ising procurement costs due to carbon
Rtaxes on raw materials.
Rising raw-material prices due to shifts insupply-demand balance.

 educe raw-material costs through recyclingRand other effective uses of resources.
Reduce costs by improving supply-chain
efficiency.

 onitor supply-and-demand forecasts for raw
Mmaterials, and optimize procurement costs
and prices. (Seal products: raw-rubbermaterials, steel materials, etc.; Electronic
components: copper, etc.)
Strategy for developing material-saving
fabrication methods (to improve yields).
Consider increasing the use of reusedmaterials and product recycling.

Rising operating costs due to carbon taxes.

 romote manufacturing efficiency andPenergy-saving initiatives. (Improve
motivation to save energy.)

 evise the targets in the NOK Twin Green Plan
R
2030.
Introduce in-house carbon pricing.
Develop new low-energy materials andfabrication methods.

 ising energy procurement costs due toRshifts in electricity demand and power source
makeup.

Intensifying competition among electric
power suppliers.
Promote the introduction of in-houserenewable energy power sources using
public subsidies, etc.

 ptimize our power procurement sources.
O
Introduce renewable energy sources such as
solar power generation.

 orporate valuation negatively impacted dueCto insufficient environmental initiatives.
Concerns that these will become a standard
for making investment and funding decisions.

 ttract ESG investment by improvingAexternal evaluation.

 roactively disclose corporate information inP
accordance with the ESG Framework.

Carbon price

EnergyExternal
evaluation

Disasters

Electronic Products

 eclining sales of conventional products forDinternal combustion engine applications dueto the increase of electric vehicles.
Declining market competitiveness due todelays in response to environmental issues(prices, customers’ purchasing policies).

Markets

Raw materials

Seals upply-chain disruptions due to disasters.
Suspension of operations at Company plants
and damage to inventory in storage.

—

 arry out hazard risk assessments andCtropical cyclone/disaster countermeasures(water protection) at all locations.
Secure inventory levels that are appropriate
for the risk exposure.

Indicators and Targets
As part of our climate change actions, the NOK Group
formulated the NOK Twin Green Plan 2030, and has beenpromoting the reduction of CO2 emissions and developmentof next-generation eco-technologies. To strengthen our
climate-change actions, we have recently raised the CO2
emission reduction targets set in the NOK Twin Green Plan

2030 based on results from our TCFD scenario analyses.
With the aim of achieving carbon neutrality by 2050, we willcontinue to promote efforts to address climate change andconsider revisions to our targets from time to time based on
the results of scenario analyses and social conditions.

Targets
2050

Aiming to achieve carbon neutrality

2030

NOK consolidated (in Japan)
50% reduction in CO2 emissions (compared to 2018)
NOK consolidated (overseas)
30% reduction in CO2 emissions per unit (compared to 2018)08

NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Society

Governance​

Climate Change Countermeasure
Basic Concept
Concerns have grown in recent years about how abnormal
weather events occurring throughout the world may
threaten the survival of the human race. In Japan andoverseas, the decarbonization movement is gaining traction,highlighted by the adoption of the Paris Agreement in 2016,
and the Japanese government’s 2050 carbon neutral
declaration. It has also become important for companies topursue carbon neutrality as a factor that influences
management. They are required to reflect this approach intheir long-term management strategy, and also disclose
measures and information about how they are actively
reducing greenhouse gas emissions.

Recognizing that climate change is an important global
issue that must be addressed to create a sustainable society,
the NOK Group is working to achieve carbon neutrality by
2050. In line with TCFD recommendations, we are analyzing
the impact of climate change on our Company and promoting
the incorporation of climate change countermeasure into ourmanagement strategies. We are also working to reduce CO2
emissions throughout the product life cycle, including
through energy-saving activities, the active introduction ofrenewable energy, and the reduction of fuel used in logistics.

Three-Year Targets and Results (FY 2020–FY 2022)
In terms of progress toward the current three-year (FY2020 to FY2022) targets, we have achieved a 13.6% reduction in CO2 emissions
from FY2018, achieving our target, and a 3.9% reduction in CO2 emissions intensity. The introduction of renewable energy sources and our
day-to-day efforts to save energy are leading to reductions in CO2 emissions.

Three-year targets andresults for FY 2022

Baseline figure/
Base year

Target figure/Target year

1,000 tons-CO2

759.36/2018

683.42/2022

655.94ton-CO2/
million yen

1.251/2021

1.238/2022

1.203 (-3.87%)

Scope of coverage

Unit

CO2 emissions reduction target

Consolidated

CO2 emissions intensity
reduction target

Domestic groupcompanies

FY 2022 results* CO2 emissions are the sum of fuel and electricity consumption multiplied by the conversion factor. Fuel CO2 conversion factors are calculated using emission factors based on the Law
Concerning the Promotion of Measures to Cope with Global Warming.
The CO2 conversion factor for electric power is “CO2 Emissions from Fuel Combustion” from the International Energy Agency (IEA) (based on a location-based method).
CO2 emissions intensity represents a five-year average; the target is to reduce the five-year average change year on year by 1%.

NOK Group Mediumto Long-Term Targets

Baseline figure/
Base year

Target figure/Target year

1,000 tons-CO2

759.36/2018

Carbon neutral/2050

655.941,000 tons-CO2

258.60/2018

129.3/2030

188.23

Overseas groupcompanies

ton-CO2/
million yen

1.31/2018

0.92/2030

1.09Electricity consumption

Domestic groupcompanies

GWh

455.45/2018

373.47/2030

377.58CO2-free electricity ratio

Consolidated％

0.06/201810/2030

4.20

Scope of coverage

Unit

CO2 emissions reduction target

Consolidated

CO2 emissions reduction target

Domestic groupcompanies

CO2 emissions intensity
reduction target

FY 2022 results* CO2 emissions are the sum of fuel and electricity consumption multiplied by the conversion factor. Fuel CO2 conversion factors are calculated using emission factors based on the Law
Concerning the Promotion of Measures to Cope with Global Warming.
The electric power CO2 conversion factors are: domestic—emission factors by electric utility; and overseas—“CO2 Emissions from Fuel Combustion” by the International Energy Agency (IEA)(using both market-based and location-based methods).
The CO2-free electricity ratio includes credits and certificates.

CO2 emissions of the NOK Group (global)

CO2 emissions of the NOK Group (domestic)(1,000 tons-CO2)(1,000 tons-CO2)

800
700
600
500
400
300
200
100
0

300

656

250
Target Figure
Achieving carbon
neutrality

188

200
150

FY 2022CO2 emissions
27.2% reduction

100
502018 2019 2020 2021 2022

2050 (FY)09

0

Target Figure

50% reduction

compared to FY 20182018 2019 2020 2021 2022

NOK CORPORATION ESG Data Book 2023

2030 (FY)Environment​

Basic Information

CO2 intensity of the NOK Group (overseas)(GWh)

Target Figure
30% reduction

1.088

378

400

200

compared to FY 20181002018 2019 2020 2021 2022

Unit

Target Figure 18% reduction

500

300

FY 2022
CO2 Intensity
16.9% decrease

Greenhouse gas Scope ofcoveragebreakdown

Governance​

Total electricity consumption of the NOK Group (domestic)(tons-CO2/million yen)

1.600
1.425
1.250
1.075
0.900
0.725
0.550
0.375
0.200

SocietyCO2emissions

02030 (FY)GWP reference

CO2 emissions not Domestic
ton-CO2
groupfrom energy
companies
sources

IPCC Fourth Assessment
76 Report (AR4 value for a
100-year time horizon)

CH4

Domestic
ton-CO2
group
companies

IPCC Fourth Assessment
565 Report (AR4 value for a
100-year time horizon)

N2O

Domestic
ton-CO2
group
companies

IPCC Fourth Assessment
312 Report (AR4 value for a
100-year time horizon)

HFCs

Domestic
ton-CO2
group
companies

IPCC Fourth Assessment
1,127 Report (AR4 value for a
100-year time horizon)

PFCs

Domestic
ton-CO2
group
companies

IPCC Fourth Assessment
1,182 Report (AR4 value for a
100-year time horizon)

SF6

Domestic
ton-CO2
group
companies

IPCC Fourth Assessment
62 Report (AR4 value for a
100-year time horizon)

NF3

Domestic
ton-CO2
group
companies

IPCC Fourth Assessment
0 Report (AR4 value for a
100-year time horizon)

2018 2019 2020 2021 2022

2030 (FY)

CO2-free electricity ratio of the NOK Group (global)

(%)

10
8
6

4.2

4
2
0

2018 2019 2020 2021 2022

2030

(FY)

Concrete Activities
Adoption of internal carbon pricing
The NOK Group is promoting the adoption of internal carbon
pricing (ICP) to further measures aimed at reducing CO2
emissions with a view to achieving carbon neutrality.
Internal carbon pricing is a mechanism that we use to attach
our own monetary value (carbon price) to CO2 emissions.
In doing so, it provides a frame of reference for investment,
thereby facilitating investment in equipment that contributes
to CO2 emission reductions. We have set a carbon price of
30,000 yen/ton-CO2 for capital investments (environmental
investments) that help lower CO2 emissions (Scope 1 and 2),such as in extremely energy-efficient equipment andrenewable energy equipment (solar power generation).
Using this mechanism, we intend to step up the pace ofefforts to reduce CO2 emissions and do everything we can toachieve carbon neutrality.
Purchase of renewable energy (Japan, China)

renewable energy.
In November 2022, the Tokai Plant switched to 100%
CO2-free energy for the electricity it consumes. As a result,as of the end of March 31, 2023, the plant had been able toreduce emissions equivalent to 772 tons. Mektec
Manufacturing Corporation (Zhuhai) Ltd. is reducing anequivalent of 7,079 tons-CO2 annually by adopting renewableenergy sources.
Reduction in energy consumed by recovering waste heat (China)
As a means of curbing its CO2 emissions, NOK (Wuxi) Vibration
Control China Co., Ltd. is reducing its energy consumption byrecovering waste heat generated at its plants.
Waste heat (from compressors and VOC treatment)
generated in each process is reused and supplied as a heatsource to a single plant with a heat pump. As a result, wewere able to lower energy consumption in the factory andreduce the equivalent of 593 tons of CO2.

To achieve carbon neutrality, we continue to purchase

10

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

FY 2022 Scope 3 breakdown

Society

Governance​

Scope of coverage

Unit

CO2 emissions

1

Purchased goods and services

Consolidated

1,000 tons-CO2

2,005

2

Capital goods

Consolidated

1,000 tons-CO2

1

3

Fuel- and energy-related activities (not included in Scopes 1 and 2)

Consolidated

1,000 tons-CO2

80

4

Upstream transportation and distribution

Non-consolidated

1,000 tons-CO2

10

5

Waste generated from operations

Consolidated

1,000 tons-CO2

20

6

Business travel

Consolidated

1,000 tons-CO2

5

7

Employee commuting

Consolidated

1,000 tons-CO2

15

8

Upstream leased assets

Non-consolidated

1,000 tons-CO2

0

9Downstream transportation and distribution

Consolidated

1,000 tons-CO2―

10 Processing of sold products

Consolidated

1,000 tons-CO2

0

11 Use of sold products

Consolidated

1,000 tons-CO2

N/A

12 End-of-life treatment of sold products

Consolidated

1,000 tons-CO2―

13 Downstream leased assets

Consolidated

1,000 tons-CO2

N/A

14 Franchises

Consolidated

1,000 tons-CO2

N/A

15 Investments

Consolidated

1,000 tons-CO2

N/A

Total

Consolidated

1,000 tons-CO2

2,137* Categories 9 and 12 are not included in the calculation because it is difficult to calculate their current status.

Resource Conservation and Waste Recycling
Basic Concept
We live a convenient and prosperous life surrounded bymany things in a social system of mass production, massconsumption and mass disposal. At the same time, various
environmental problems are occurring, such as the depletionof natural resources and destruction of the environment.
In recent years, many around the world are calling for a shift
to a recycling society and demanding that businesses further
promote the efficient use of resources, taking into accountentire product lifecycles, as well as the 3Rs (Reuse, Reduce
and Recycle).

The NOK Group has been promoting the 3R initiative torealize a recycling-oriented society. The Group strives tocontribute to a sustainable society and to enhance ourcorporate value through a range of measures throughout the
product life cycle, including the efficient use of raw materials,
water, and energy as well as waste reduction and recyclingof resources by improving each process.

Three-Year Targets and Results (FY 2020–FY 2022)
The amount of waste sent to domestic landfill in FY 2022 was 977 tons, a significant reduction from 1,986 tons in FY 2018, when thefoundry began operations. However, the recycling rate was 97.9%, slightly below the target level.

11

NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Society

Governance​

Resource use targets and results for FY 2022

Scope of coverage

Unit

Baseline figure/
Base year

Target figure/Target year

FY 2022 results

By-product recycling rate

Domestic groupcompanies%

96.8/2018

100/2030

97.9*1 By-product: General term for industrial waste and valuable resources.
*2 Recycling rate: “Recycling rate = 1 – amount of landfill disposal / amount of by-product generated × 100”

Waste-related targets, and results for FY 2022

Scope of coverage

Unit

Baseline figure/
Base year

Target figure/Target year

FY 2022 results

Industrial waste

Domestic groupcompanies

tons

23,486/2021

23,251/2022

20,038Amount of industrial waste generated
by the NOK Group (domestic)

NOK’s final amount disposed of in landfill
and waste recycling rate (domestic)(1,000 tons)

70
60
50
40
30
20
10
0

（%）

(tons)

3,000

46

Target figure (Recycling rate)

1

94.0

1,500

977

1,000

26
2018

■Valuable waste

2019

2020

■Amount recycled

2021

2022

98.0

97.9

2,000

19

100.0

98.0

2,500

92.0
90.0

500
(FY)

■Amount disposed of in landfill

0

2018

2019

2020

■Amount disposed of in landfill (left)

2021

2022

88.0
(FY)

Waste recycling rate (right)

Concrete Activities
Reduction in volume of stretch film used (Japan)

Food loss reduction measures (Japan)

NOK is working to reduce the amount of stretch film it uses
when products are being transported. After examining safety,
quality, and workability aspects, the department started
using thinner stretch film and environmentally friendly
strapping and belts as replacements for stretch film andpolypropylene strapping. It also switched to wrap-freeshipping and the use of energy-efficient materials. As aresult, we were able to reduce waste by some 35 tons
compared to 2019 and lower our CO2 emissions by anequivalent 110 tons-CO2.

At the Shonan R&D Center, we are cooperating with thecaterer we contract to operate the employee cafeteria topursue activities aimed at reducing food loss.
We asked employees to adjust the amount of food they
intend to eat, gave instructions on ways of reducing food loss,
and carried out an initial survey of lunchtime visitors. As aresult, we were able to reduce the amount of food waste in theemployee cafeteria by 38%.

Conservation of Water Resources
Basic Concept
Currently, the global shortage of water resources is seen asa problem, exacerbated by an increase in drought-stricken
regions and the mounting severity of flood damage as aresult of the worsening climate crisis. It has become
increasingly important for companies to make effective useof water resources to build a sustainable society.
The NOK Group works to protect water resources byidentifying and reducing the amount of water used in the

12

manufacturing process of our products, and by taking
thorough measures to clean wastewater. In addition,
the NOK Group assesses the water risks in each country andregion to respond to different water risks according to thecountry and region, and promotes conservation of water
resources activities tailored to the characteristics of eachcountry and region.

NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Society

Governance​

Response to Water Risk
Moreover, since wastewater after use in the
manufacturing process may contain harmful substances,
there is a concern that if wastewater exceeding the effluent
standard prescribed by law is discharged, it may cause
environmental pollution and harm to the local community.
For this reason, we regularly carry out thorough wastewater
treatment control, run emergency drills, and check
response procedures.

The NOK Group uses high-quality water in the manufacturing
processes of our products. Ensuring a stable supply ofhigh-quality water is important in conducting our businessactivities, so if a natural disaster or other event prevents astable supply of high-quality water, we expect this to impact
a variety of value chains and disrupt supply chains. Thismeans business activities and water are closely related.

Three-Year Targets and Results (FY 2020–FY 2022)
As a result of global efforts to grasp the volume of water withdrawals and wastewater at each plant and to reduce thevolume of water withdrawals, the volume of water withdrawals and wastewater was 8,666,000 m3 and 6,026,000 m3,
respectively, in FY2022. In the production process, efforts were made to reduce water withdrawals by optimizing water
circulation facilities in cooling towers that use water, and reusing wastewater. As a result of these activities, the amount ofwater intake in FY2022 was down compared to FY2021.

Water resource targets and FY 2021 performance Scope of coverage
Increase-controlled water withdrawals

Consolidated

Unit
1,000 m3

NOK Group’s total water withdrawals

Baseline figure/Base year Target figure/Target year
9,187/2021(1,000 m3)(1,000 m3)

8,000

8,666

8,666

7,250

8,000

6,500

7,000

6,026

5,750

6,000
5,000

9,187/2022

NOK Group’s wastewater

10,0009,000

FY 2022 results

2018

2019

2020

2021

2022

(FY)

5,000

2018

2019

2020

2021

2022

(FY)

Assessment of Water Risks with AQUEDUCT
There were no major incidents of non-compliance in the
NOK Group in FY2022 concerning water consumption andwater quality.
The NOK Group conducts water risk assessments acrossthe Group to efficiently promote response measures to water
risks. The results of the study on water stress at global
production locations obtained by using AQUEDUCT*, operated
by the World Resources Institute (WRI), are as follows:
4%

6%
16%

25%
All

76

■ Extremely High■ High■ Medium - High■ Low - Medium■ Low

The survey revealed that of the total 76 sites, six sites inThailand and China and two sites in Germany are production
sites with high water stress. The NOK Group is currently
working to grasp and control water withdrawals on aconsolidated global basis. In addition, we will conduct waterrisk assessments when new facilities are established, andwe will strive to produce and conserve water resources withconsideration for water withdrawals and wastewater.
* AQUEDUCT: A water risk assessment tool published by the World Resources Institute(WRI). It provides a world map with information on water risks such as quantity of water,water quality, regulations, and reputation.

locations49%

13

NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Society

Governance​

Concrete Activities
Reduction in water withdrawal (China)
Mektec Manufacturing Corporation (Zhuhai) Ltd. is taking
measures to reduce its volume of water withdrawal. With theuse of reclaimed water recycling systems, it is reusing 60% of its
wastewater by watering flower beds with rainwater and using
RO concentrate in scrubber machines, to flush toilets, to clean
floors, to spray building rooftops (as a cooling measure), and to
dilute drug solutions for disposal.
Recycling of wastewater from the washing of molds andother operations (China)
Wuxi NOK-Freudenberg Oilseal Co., Ltd. previously used totreat and discharge some 7,600 tons of effluent annually.
This effluent came from washing molds, exhaust treatment
shower towers, removing static electricity and oil, andpolishing. After adding a wastewater treatment process to
the recycling process, it was able to recycle approximately

6,800 tons of wastewater per year, thereby reducing its
annual volume of wastewater to just 800 tons.
Groundwater recharge (Japan)
In an effort to protect water resources, the Kumamoto Plant
supports a project to recharge groundwater in the Kumamotoarea promoted by the Kumamoto Groundwater Foundation.
This is an activity in which farmers with rice paddies ingroundwater recharge areas and companies andorganizations that have signed owner agreements grow rice
together, so that the water stored in the paddies penetrates
underground and promotes groundwater recharge. In FY2022,
rice transplanting and harvesting was carried out for the firsttime in three years. In addition, by donating 150 kilograms of
harvested rice to food banks, we not only conserve water
resources, but also actively contribute to society.

Management of Substances of Environmental Concern
Basic Concept
Owing to the fact that chemical substances are destroying
ecosystems and harming people’s health, regulations on
substances of concern worldwide are being tightened year afteryear. Companies are required to comply with these regulations
and manage and reduce their use of chemical substances,taking the entire life cycles of their products into consideration.

The NOK Group will reduce the substances of concern
used and emitted in its business activities, minimize and try
to eliminate the impacts of pollutants in society, identify andmanage chemical substances throughout the product life
cycle, and help reduce the environmental impacts in theentire supply chain.

Three-Year Targets and Results (FY 2020–FY 2022)
The NOK Group’s VOC emissions during FY2022 were 2,900 tons, keeping its VOC emissions below the Group’s target of 5,855 tons.

VOC emission targets and FY 2022 results

Scope of coverage

Unit

Baseline figure

Target figure

FY 2022 results

Consolidated

1,000 tonsー

5.86 or less

2.900

Target VOC emissions

Concrete Activities

Total VOC emissions of the NOK Group

Expansion of adhesive exhaust gas treatment facilities at
No. 3 Plant (China)(tons)

6,000
Target Figure

5,000
4,000

2,900

3,000
2,000
1,000
0

2010

2018 2019 2020 2021 2022

14

(FY)

Given the growing volume of organic gas emitted on theadhesive production line, to comply with regulations andprepare to expand processing capacity in line with projected
growth in production, we expanded our adhesive exhaustgas treatment facilities. The result was an improvement in
the exhaust-gas collection rate to 95%–98%. We were able toreduce VOC emissions to a far greater degree than the
average for actual VOC emissions measured on site, leading
to a better work environment.

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Environmentally Friendly Products
Basic Concept
To minimize the impacts of climate change, the depletion of
resources, waste treatment, the growing demand for water
resources, and other environmental risks, and to create asustainable society, we cannot ignore the environmental
burden of the products we use on a daily basis. Accordingly,
companies must develop products and technologies that
contribute to environmental protection in ways that consider
the entire life cycles of their products, from the procurementof raw materials to the products’ manufacture,transportation, use, and disposal.
The NOK Group is developing products that contributeto next-generation eco-technologies, taking into account theentire product lifecycle.

Standard of Environmental Impact Assessment
for Design
We assess the environmental impact of designs of new
products, new materials and new production machines inaccordance with NOK’s Standard of Environmental Impact
Assessment for Design. Based on this standard, we
undertake environmental assessments across the entire
product lifecycle, starting with the design stage, including
product and equipment processes, and promote thedevelopment of environmentally friendly products.

Assessment

DesignProduction

Use

Green procurement〇〇

Disuse of substances of concern (regulatory compliance, minimizing external discharge and dispersion)〇〇

Reduction of energy consumption (using energy-efficient materials and equipment, contributing to energy savings during use)

〇

〇

〇

Use of resources (recyclable materials, fewer resources used, improved yields, improved service life)

〇

〇

〇

Reduction of waste (ease of disassembly, reuse, low disposal ratio)〇〇

Disposal〇〇

Reduction of CO2 via Eco-Friendly Products
As part of the Green Product component of the Twin Green
Plan 2030, the NOK Group has continued to engage inbusiness activities with the stated aim of helping to reduce
CO2 emissions through its products. To efficiently andeffectively promote this initiative, we have calculated, basedon our own standards, the size of our contributions to CO2

reductions at the NOK product use stage. The result of ourcalculations for FY2021 came to a CO2 reduction of 807,000
tons. We will continue to contribute to the goal of carbon
neutrality by developing and expanding sales of productsthat help reduce CO2 emissions.

Approach to calculating size of contributions to CO2 reductions
CO2 reduction contribution [CO2] = contribution to CO2 reductions per product [CO2/items/hours] x duration of use [hours] x
annual sales volume [items]* Only automotive products were included in the scope of calculation

Environmental Accounting

Trends in environmental investments and costs

In targeting sustainable development and with the aim of
efficiently and effectively taking action to addressenvironmental conservation issues, every year we determine
how much we need to invest and spend on environmental
conservation in our business activities.

(Millions of yen)

2,000
1,500

1,100

1,000

556

500
0

544
2018

2019

2020

2021

2022

(FY)

■Environmental conservation investments ■Environmental conservation costs

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NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Society

Governance​

Scope of coverage

Unit

FY 2020

FY 2021

FY 2022

Environmental conservation investments

Non-consolidated

millions of yen

464

495

544

Environmental conservation costs

Non-consolidated

millions of yen

620

550

556

Total

Non-consolidated

millions of yen

1,084

1,045

1,100

Scope of coverage

Unit

FY 2022

Pollution and resource costs

Non-consolidated

millions of yen

168

Pollution and resource investments

Non-consolidated

millions of yen

2

Water risk costs

Non-consolidated

millions of yen

49

Water risk investments

Non-consolidated

millions of yen

33

Trends in environmental investments and costs

Environmental conservation costs

We expect pollution and resource costs of 192 million yen (waste treatment, analysis ofenvironmentally hazardous substances, etc.) and water risk costs of 39 million yen (analysis ofwastewater and groundwater, purchase of wastewater treatment equipment and chemicals, etc.).

Potential future costs (shadow costs)

Scope of coverage

Unit

FY 2020

FY 2021

FY 2022

Reduction of power consumption

Non-consolidated

GWh

5

9

11

Reduction of CO2 emissions

Non-consolidated

ton-CO2

2,033

4,258

5,006

Economic effects of environmental conservation measures

Scope of coverage

Unit

FY 2020

FY 2021

FY 2022

Energy-saving effectNon-consolidated

millions of yen

61

107

194

Gain on sales of recyclable materials

Non-consolidated

millions of yen

248

1,256

1,145

Unit

Investments

Costs

Environmental conservation costs to control environmental burdencaused by business activities within business areas

millions of yen

210

344

Pollution prevention costs

Investment, and maintenance and management costs related to pollution
prevention activities

millions of yen

34

102

Global environmental conservation costs

Investment, and maintenance and management costs related to global
warming countermeasures, including energy conservation

millions of yen

175

72

Resource circulation costs

Investment, and maintenance and management costs related to resource
recycling activities, including waste disposal and recycling

millions of yen

2

169

Upstream and downstream costs

Costs of controlling the environmental burden that occurs in upstream
and downstream processes, such as green procurement, etc.

millions of yen

00Management activity costs

Costs associated with management activities such as ISO 14001
maintenance and operation

millions of yen

059

Research and development costs

Costs of research and development that contributes to the environment,such as the development of environmentally friendly products

millions of yen

334

135

Social activity costs

Costs related to greening of business establishments and support for theactivities of environmental conservation groups

millions of yen

017

Costs involved in dealing withenvironmental damage

Costs associated with the removal of environmental burdens, such as
special equipment and facilities

millions of yen

00

Fines, penalties and/or legal costs associated with the settlement of environmental accidents and complaints

millions of yen

0

0

Total

millions of yen

544

556

Aggregate total

millions of yen

Effects of environmental conservation

FY 2022 NOK environmental accounting
Category
Business area costs

Main contents

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NOK CORPORATION ESG Data Book 2023

1,100

Environment​

Basic Information

Society

Governance​

Conservation of Biodiversity
Basic Concept

organizations to implement measures to help prevent
deforestation and alleviate the impacts on biodiversity.
We also ask that our suppliers take biodiversity into
account when doing business and we intend to strengthen
partnerships to ensure that net-positive impacts are felt acrossthe entire supply chain, not just by our primary suppliers.

In recent years, species have become extinct mainly as aresult of the destruction of the natural environment,
overexploitation, and climate change, and subsequently, theworld’s biodiversity is shrinking at an alarming rate. A new
set of 23 targets for biodiversity through to the year 2030,
known as the Kunming-Montreal Global Biodiversity
Framework, was adopted at COP15 following the expiry of
the Aichi Biodiversity Targets for 2020. Safeguarding
biodiversity is considered to be one of many global issues,
with all countries urged to take action. Companies, too, must
protect biodiversity and consider the natural environment
when doing business.
The NOK Group undertakes no business activities inregions designated as a World Heritage Site and has no plansto do so. As part of our efforts to protect biodiversity, we will
carry out risk assessments and partner with external

Biodiversity Risk Assessments
To assess the risks pertaining to how the NOK Group'sbusiness activities might affect biodiversity, we used the
IBAT* to study the relationships between our production
sites and key biodiversity areas. The results of the study
revealed that of the sites where a nature reserve is locatedwithin a five-kilometer radius, one of them is a wetlands
designated under the Ramsar Convention, while five others
are IUCN Category II protected areas (national parks).

No. of sites

World
Heritage

Ramsar

MAB

Domestic production sites

50

0

1

Overseas production sites

26

0

0

Total

76

0

1

IUCN
Ia

Ib

Ⅱ

Ⅲ

0

0

0

5

0

0

0

0

0

0

0

0

0

5

0

* IBAT is a biodiversity information database tool developed by an alliance comprising the IUCN, the UNEP-WCMC, Birdlife International (an international environmental NGO), and Conservation International.

We also used the WWF Biodiversity Risk Filter to assess
biodiversity risks at all NOK Group sites. As a result, none ofour 76 production sites were categorized as being “very highrisk” in terms of supply services, regulatory and basic
services, and impacts on biodiversity. We will continue toperform risk assessments of biodiversity and our businessactivities, leverage the results of these studies in our
measures for safeguarding biodiversity, and press ahead withinitiatives best suited to the characteristics of each region.
* The WWF Biodiversity Risk Filter is a risk assessment tool for biodiversity made available
by the World Wide Fund for Nature.

Supply 供給サービス
services

16 3

70

12
V e r y lo w

Regulatory andbasic services

86

調整および基盤サービス

14Low
M e d iu m
H ig hV e r y h ig h

Impact on
生 物多様性への負荷
biodiversity

0%

68

32

50%

10 0 %

Concrete Activities
Environmental conservation education at Ohba Reservoir(Japan)At the Shonan R&D Center, with the aid of NPO Fujisawa
Green Staff Association, we are working to preserve thewetlands of the Oba Reservoir, helping to improve thelandscape and conserve wetland plant and animal life.
In addition, with the aim of gaining a deeper understanding of
the connection between living things and nature, a guide fromthe Green Conservation Section of the Fujisawa City Office led
a walking tour to observe the habitats of plants and living
creatures around the Ohba Reservoir and Hikichigawa Water

17

Park. We also held a nature observation event, offering achance to come into contact with nature.
Reforestation activities (Thailand)
Thai NOK Co., Ltd. has conducted tree planting for three
years in a row as part of its carbon capture initiative. As of2022, to encourage the participation of all employees, thearea for planting has been expanded by 2,800 m2 to a total
area of 4,400 m2. In FY2022, more than 260 trees wereplanted. Planting trees is expected to contribute to carbon
neutrality by absorbing CO2 in the future.

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Environmental Performance Data
Scope of coverage

Unit

FY 2019

FY 2020

FY 2021

FY 2022

Non-consolidated andmanufacturing subsidiaries

tons

90,66180,64689,157

79,183

RubberNon-consolidated andmanufacturing subsidiaries

tons

13,048

11,742

13,154

11,994Compounding ingredients and adhesives

Non-consolidated andmanufacturing subsidiaries

tons

10,971

9,921

11,012

10,188

Plastics

Non-consolidated andmanufacturing subsidiaries

tons

1,083

965

1,149

1,039

MetalsNon-consolidated andmanufacturing subsidiaries

tons

65,55958,01863,842

55,962

Non-consolidated andmanufacturing subsidiaries

TJ

1,471

1,394

1,480

1,347

Input
Total consumption of raw materials

Total energy consumption

Electricity

Fuels

Energy emissions intensity

Consolidated

TJ

5,094

4,700

5,255

4,797

Non-consolidated andmanufacturing subsidiaries

TJ

1,324

1,261

1,337

1,209

Consolidated

TJ

4,385

4,071

4,581

4,160

Non-consolidated andmanufacturing subsidiaries

TJ

147

133

143

139

Consolidated

TJ

709

629

674

637

Non-consolidated andmanufacturing subsidiaries

TJ/millions of yen

0.011

0.011

0.011

0.010

Consolidated

TJ/millions of yen

0.009

0.010

0.010

0.008

CO2-free electricity ratio

Consolidated

%

0.2

0.3

0.5

4.2

3

Total water withdrawals

Non-consolidated andmanufacturing subsidiaries

1,000 m

821

809

832

792

Consolidated

3

1,000 m

9,363

8,347

9,187

8,666

Non-consolidated andmanufacturing subsidiaries

3

1,000 m

611

612

664

620

Consolidated

3

1,000 m

4,990

4,569

4,960

4,269

3

Industrial water

Non-consolidated andmanufacturing subsidiaries

1,000 m

37

27

31

34

Consolidated

1,000 m3

4,081

3,511

4,013

4,190

Ground water

Non-consolidated andmanufacturing subsidiaries

1,000 m3

173

171

137

139

Consolidated

1,000 m3

292

267

214

207

Non-consolidated andmanufacturing subsidiaries

m3/millions of yen

6.2

6.5

6.1

6.1

Consolidated

m3/millions of yen

17.0

17.0

16.6

14.1

Non-consolidated andmanufacturing subsidiaries

1,000 m3

240

224

164

169

Consolidated

1,000 m3

1,628

2,231

2,568

2,640

Consumption of substances subject to PRTR

Non-consolidated andmanufacturing subsidiaries

1,000 tons

1.6

1.5

1.6

1.5

OutputScope of coverage

Unit

FY 2019

FY 2020

FY 2021

FY 2022

Non-consolidated andmanufacturing subsidiaries

1,000 tons-CO2

214

186

198

172

City water

Inputs (water intake) emissions intensity

Water consumption

Total CO2 emissions (Scope 1 + Scope 2)

Consolidated

1,000 tons-CO2

722

636

741

661

Scope 1

Non-consolidated andmanufacturing subsidiaries

1,000 tons-CO2

9

8

9

8

Consolidated

1,000 tons-CO2

43

38

41

39

Scope 2

Non-consolidated andmanufacturing subsidiaries

1,000 tons-CO2

205

178

189

164

Consolidated

1,000 tons-CO2

679

598

700

622

Location-base*18

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

OutputScope of coverage

Unit

FY 2019

FY 2020

FY 2021

FY 2022

Total CO2 emissions (Scope 1 + Scope 2)

Non-consolidated andmanufacturing subsidiaries

1,000 tons-CO2

195

183

189

171

Market-base*
Scope 1

Scope 2CO2 emissions for Scope 3*
NOx

SOx

VOC emissions
Emissions of substances subject to PRTR
Total wastewaterRiver/lake

Sewage system

BOD load

Industrial waste

Amount of waste recycled

Landfill disposal amount

Valuable waste

Recycling rate

Consolidated

1,000 tons-CO2

693

628

727

656

Non-consolidated andmanufacturing subsidiaries

1,000 tons-CO2

9

8

9

8

Consolidated

1,000 tons-CO2

43

38

41

39

Non-consolidated andmanufacturing subsidiaries

1,000 tons-CO2

186

175

181

163

Consolidated

1,000 tons-CO2

650

590

685

617

Consolidated

1,000 tons-CO2

268

269

2,169

2,137

Non-consolidated andmanufacturing subsidiaries

Kg

8,975

8,591

8,047

11,502

Domestic group companies

Kg

23,49023,072

20,83821,697

Non-consolidated andmanufacturing subsidiaries

Kg

3,784

2,973

2,580

2,345

Domestic group companies

Kg

3,784

2,973

7,757

3,103

Non-consolidated andmanufacturing subsidiaries

1,000 tons

2.1

1.8

1.9

1.6

Consolidated

1,000 tons

3.4

3.1

3.2

2.9

Non-consolidated andmanufacturing subsidiaries

1,000 tons

0.132

0.102

0.123

0.068

Non-consolidated andmanufacturing subsidiaries

1,000 m3

582

586

669

623

Consolidated

1,000 m3

7,735

6,116

6,619

6,026

Non-consolidated andmanufacturing subsidiaries

1,000 m3

471

451

538

504

Consolidated

1,000 m3

3,845

2,758

3,014

2,641

Non-consolidated andmanufacturing subsidiaries

1,000 m3

111

135

130

119

Consolidated

1,000 m

3,890

3,358

3,605

3,385

Non-consolidated andmanufacturing subsidiaries

tons

3.97

3.53

5.34

4.04

Domestic group companies

tons

5.16

5.36

6.96

7.92

Non-consolidated andmanufacturing subsidiaries

1,000 tons

20

20

21

18

Consolidated

1,000 tons

58

52

60

52

Non-consolidated andmanufacturing subsidiaries

1,000 tons

20

20

21

18

Consolidated

1,000 tons

42

44

50

43

Non-consolidated andmanufacturing subsidiaries

1,000 tons

0.34

0.07

0.06

0.05

Consolidated

1,000 tons

13

6

7

6

Non-consolidated andmanufacturing subsidiaries

1,000 tons

29

26

29

26

3

Consolidated

1,000 tons

56

47

55

51

Non-consolidated andmanufacturing subsidiaries

%

99.3

99.8

99.9

99.9

Consolidated

%

89.0

94.1

93.7

94.2

* CO2 emissions are the sum of fuel and electricity consumption multiplied by a conversion factor. The CO2 conversion factor for fuel uses an emission factor based on Japan’s Act on Promotion of
Global Warming Countermeasures.
For electric power CO2 conversion factors, in Japan we use the emission factors of different general transmission and distribution utilities; overseas we use the CO2 Emissions from Fuel
Combustion factor of the International Energy Agency (IEA) (combining market- and location-based methods).

19

NOK CORPORATION ESG Data Book 2023

Environment​

Basic Information

Society

Governance​

List of ISO14001-certified companies
In the NOK Group, 98.5% of plants/offices have obtained ISO14001.

Country

ISO14001-certified companies

Scope of application

NOK CORPORATION
Tenei Seal Industry Corporation

Headquarters Factory
Fukushima Plant: Certified as NOKNOK METAL Co., Ltd.
Miyagi NOK Corporation
Miharu Industry Corporation
Tohoku Seal Industry Corporation
Nihonmatsu NOK Corporation

Certified as NOK

Isohara Polyurethane Industry Corporation

Certified as NOK

Isshin Industries Corporation
Kanasei Corporation
Kikugawa Seal Industry Co., Ltd.

Certified as NOK

MYK Corporation

Certified as NOK

TVC Co., Ltd.

Japan

Saga NOK Corporation
Kumamoto NOK Corporation
Kusu NOK Corporation
Nichinan NOK Corporation
Aso NOK Corporation
Nippon Mektron, Ltd.
MEKTEC-J Co., Ltd.

Certified as Nippon Mektron, Ltd.

Synztec co., ltd.
Kuki Roll Industry Co., Ltd.

Certified as Synztec co., ltd.

Tokiwa Industry Co., Ltd.
NOK KLUEBER CO., LTD.
UNIMATEC CO., LTD.
NOK Elastomers Processing Co., Ltd.

Tohoku Plant: Certified as NOK
Kyusyu Plant

NOK Fugaku Engineering Co., Ltd.
Kusu Seimitsu Co., Ltd.

Certified as NOK Fugaku Engineering Co., Ltd.

Thai NOK Co., Ltd.

Thailand

Mektec Manufacturing Corporation (Thailand) Ltd.
Mektec Precision Component (Thailand) Ltd.

Malaysia

Synztec (Malaysia) Sdn. Bhd.
Vietnam NOK Co., Ltd.

Vietnam

Mektec Manufacturing Corporation (Vietnam) Ltd.
Synztec Vietnam Co., Ltd.
PT. NOK Indonesia

Indonesia

PT. NOK Freudenberg Sealing Technologies
PT. NOK Precision Component Batam
Wuxi NOK-Freudenberg Oil Seal Co., Ltd.
Changchun NOK-Freudenberg Oil seal Co., Ltd.
Taicang NOK-Freudenberg Sealing Products Co., Ltd.

China

NOK (Wuxi) Vibration Control China Co., Ltd.
Mektec Manufacturing Corporation (Zhuhai) Ltd.
Mektec Manufacturing Corporation (Suzhou) Ltd.
Synztec Precision Parts (Shenzhen) Co., Ltd.

TaiwanGermany

Mektec Corporation
MEKTEC EUROPE GmbH (MEK-E)
Mektec Manufacturing Corporation Europe DE GmbH

Certified as MEKTEC EUROPE GmbH

Czech Republic

Mektec Manufacturing Corporation Europe CZ s.r.o.

Certified as MEKTEC EUROPE GmbH

Hungary

Mektec Manufacturing Corporation Europe HU Kft.

Certified as MEKTEC EUROPE GmbH20NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Environmental Performance Results Aggregation Range
Page

Item

Aggregation range

Input

P.4

Material Balance
OutputThree-Year Targets andResults

P.9-11

P.11-12

P.12

Climate ChangeCountermeasure

Resource Conservationand Waste Recycling
Conservation of
Water Resources

NOK Group Medium- to
Long-Term Targets

Three-Year Targets andResults
Three-Year Targets andResults

Raw materials

Non-consolidated and manufacturing subsidiaries

EnergyNon-consolidated and manufacturing subsidiaries

Water

Non-consolidated and manufacturing subsidiaries

Environmentally hazardous substances

Non-consolidated and manufacturing subsidiaries

Gas emissions

Non-consolidated and manufacturing subsidiaries

Wastewater

Non-consolidated and manufacturing subsidiaries

Industrial waste, etc.

Non-consolidated and manufacturing subsidiaries

Environmentally hazardous substances

Non-consolidated and manufacturing subsidiaries

CO2 emissions

Consolidated

CO2 emission intensity

Domestic group companies

CO2 emissions (global)

Consolidated

CO2 emissions (domestic)

Domestic group companies

CO2 emission intensity (overseas)

Overseas group companies

Electricity consumption

Domestic group companies

CO2-free electricity ratio

Consolidated

Scope 3

Consolidated (Categories 4 and 8 are non-consolidated)

GHG

Domestic group companies

Landfill disposal amount

Domestic group companies

By-product recycling rate

Domestic group companies

Industrial waste

Domestic group companies

Total water withdrawals

Consolidated

Wastewater

Consolidated

Water risk assessment

Consolidated

P.14

Management of Substancesof Environmental Concern

Three-Year Targets andResults

VOC emissions into the atmosphere

Consolidated

P.15-16

Environmentally Friendly
Products

Environmental Accounting

Various costs

Non-consolidated

Raw materials

Non-consolidated and manufacturing subsidiaries

EnergyConsolidated

Input

P.18-19

Environmental
Performance Data
Output21

Water

Consolidated

PRTR results

Non-consolidated and manufacturing subsidiaries

CO2 emissions

Consolidated

NOx

Domestic group companies

SOx

Domestic group companies

VOC emissions into the atmosphere

Consolidated

Wastewater

Consolidated (BOD indicates domestic group companies)

Industrial waste, etc.

Consolidated

PRTR results

Non-consolidated and manufacturing subsidiaries

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Society
Human Rights
In its principles of corporate conduct, NOK upholds anapproach to management that respects human rights.
To address respect for human rights more concretely,
we formulated a Human Rights Policy with the desire to makeour basic stance on human rights known across theCompany and among outside stakeholders, and to gain
understanding and cooperation in promoting respect forhuman rights. The Board of Directors approved the revised
policy on May 24, 2023.

NOK Group Human Rights Statement

Human Rights Statement

1

2

3

4
5

6

In line with our management philosophy of fostering a company driven by care and trust in our employees , the NOK Group places utmost
importance on the well-being and dignity of each individual within our organization.We are committed to upholding human rights asprotected in internationally recognized norms, including the International Bill of Human Rights, the ILO Declaration on Fundamental
Principles and Rights at Work, and the Ten Principles of the UN Global Compact.
The NOK Group aligns with and supports the United Nations Guiding Principles on Business and Human Rights, and our company
policy is founded upon these principles. Furthermore, through our Principles of Corporate Behavior , we recognize that compliance withlocal laws, adherence to international norms — including human rights, and consideration of cultural diversity, customs, and stakeholderinterests — are integral to our operations, and we pledge to respect human rights across all countries and regions where we
conduct business.

Scope of Application
This policy applies to all individuals within the NOK Group, including officers, employees, suppliers, and other relevant parties. We require
the utmost respect for human rights throughout our supply chain, ensuring that no entity associated with the NOK Group is complicit in any
human rights violations.

Human Rights Due Diligence
Based on this policy, the NOK Group will institute and execute essential mechanisms for human rights due diligence. In alignment with the
NOK Group Procurement Policy and CSR Procurement Guidelines, we require our suppliers to adhere to human rights standards.
Additionally, we request our other business partners to uphold human rights based on this policy.

Remediation & Correction
We have implemented a dedicated point of contact for reporting human rights compliance violations and seeking consultations.
Upon identifying a breach that has resulted in or contributed to an adverse impact on human rights, we take prompt action to address andrectify the situation.

Education & Training
To ensure a comprehensive understanding and consistent implementation of this policy among all officers and employees, we continually
foster awareness through educational initiatives, training programs, and ongoing efforts. These initiatives specifically focus on enhancing
knowledge and promoting a culture of respect for human rights and preventing harassment.

Priority Action Areas & Transparency
Following this policy, we concentrate on the designated priority action areas outlined separately to uphold our commitment to human rights.
To ensure transparency and accountability, we diligently execute these initiatives and provide regular updates on our progress andoutcomes through various channels, including our company website.

December 16, 2021
Revised: May 24, 2023
Representative Director, Chief Executive Officer, NOK CORPORATION

Masao Tsuru

22

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Basic Concept
・Ensuring freedom of association and collective bargaining rights

NOK Group strictly adheres to the laws and regulations of the countries where we operate, ensuring that our employees are free to join or establish labor
unions without any hindrance. Moreover, we actively recognize and support the exercise of collective bargaining rights.

・Eliminating forced labor

The NOK Group maintains a zero-tolerance policy towards forced labor and human trafficking, whereby individuals are coerced into work against their will
and under the threat of punishment.

・Eradicating child labor

The NOK Group firmly opposes and prohibits child labor below the minimum age defined by labor laws and regulations in the countries and regions where
we operate and international norms.

・Ensuring equal opportunities and non-discrimination in employment

The NOK Group is committed to providing equal and unbiased employment opportunities to all individuals, irrespective of their race, color, gender, religion,
political opinion, national origin, social origin, age, disability, HIV/AIDS infection or development, labor union membership, sexual orientation, or political or
personal beliefs. We strictly prohibit any form of discrimination based on these grounds.

・Ensuring harassment prevention

At the NOK Group, we hold the utmost respect for the human rights of every employee. We maintain a zero-tolerance policy towards all forms ofharassment, including power harassment and sexual harassment.

・Ensuring fair wages and responsible working hours

We are dedicated to upholding the payment of wages following legal requirements and endeavor to provide living wages or higher. Additionally, we strictly
prohibit excessive overtime work that surpasses the legal limits on working hours.

Confirming Human Rights Compliance

Human Rights Supervisory Framework

Regarding respect for human rights and compliance withlabor laws at overseas subsidiaries, we confirm annuallywhether there has been any discriminatory treatment of
employees or incidences of harassment, child labor, orforced labor.
Also, as a consultation service for human rights issues,
we have set up internal and external reporting hotlines inJapan, staffed by a lawyer. We have also established aninternal reporting hotline at each of our overseas
subsidiaries. We receive several consultations every year
and take corrective action in cases where we are able toconfirm compliance violations, and may take disciplinary
action for violations in accordance with internal guidelines.
There were no major human rights violations in FY2022.
We conduct human rights due diligence as stipulated in
our Human Rights Policy, including in the supply chain, andtake corrective action when we identify any rights violations.

The Corporate Administration Office is tasked with promoting
and confirming the thorough implementation of humanrights compliance at NOK and its subsidiaries.
Also, the Internal Control Audit Committee, an advisory
body to the Board of Directors, regularly supervises andaudits the human rights compliance framework of NOK and
its subsidiaries based on Internal Control Regulations, andreports the results to the Board of Directors and the Boardof Corporate Auditors.

Respect for Basic Human Rights in Relation to Employees
Our Principles of Corporate Behavior set forth the values ofrespect for human rights and provision of a comfortable andsecure working environment. Our Behavioral Guidelines on
Employee Compliance also stipulate respect for humanrights and the prohibition of discrimination and harassment.

23

Initiatives and Results for FY 2022
1. Human rights due diligence
We carried out surveys on human rights and labor atdomestic Group Companies and certain overseas
subsidiaries, confirming that there were no human rights
violations requiring corrective action.
We also conducted similar surveys for our major
suppliers and received responses from approximately 60% ofthem, confirming that there were no human rights violations
requiring corrective action. We will continue to carry out
regular surveys, conduct ongoing monitoring, and propose
improvements as necessary.
2. Human rights education
We offered education to all employees by producing a humanrights education video and distributing it to Group
Companies in Japan and overseas.

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Human Resources
Basic Concept
personnel who can contribute to the creation of such
workplaces through various programs.

It is in the respective workplaces where employees can feelthat the company is carrying out “management that respects
people based on care and trust” as stipulated in theManagement Principles. Under the Basic Principle of Human
Resources Development and the Vision of Human Resources
Development, NOK aims to create workplaces where
employees can find satisfaction in their jobs and feel thatthey are growing. To this end, we are working to develop

Basic Principle of Human Resources Development“A workplace nurtures its people, and people nurture
their workplace”

Vision of Human Resources Development“Development of human resources who take pride in their jobs
and respect each other”

NOK’s Human Resources Development Program
expectations of the Company, and to contribute to thecreation of workplaces where attendees themselves andtheir colleagues can find satisfaction in their jobs and feelthat they are growing.

The employee education program of NOK consists oflevel-specific education and development/specialized
education. The level-specific education is intended to enableattendees to correctly understand their own roles and the

System of NOK’s human resources development program

Department
Manager

Department manager training
Manager follow-up training

Sub-section
Chief, AssistantSection Manager

Worksite leader training

4th year 4th year follow-up training
3rd year
New employee

Interview

Special training

New manager training

Business skills training

Section Manager

Temporary assignment training

Executive officer training
Global human resources development

Operating Officer

New employee training
Junior training
programManagement
program

Top management
programSpecial skills training
programLevel-specific education

Rather than simply developing people who can speak
English, the goal of the Global Human Resource
Development program is to develop people who can work in
English. To improve overall English communication skills,
in addition to regular language training, we provide
opportunities to experience as many different cultures as
possible while still in Japan, and are nurturing humanresources who will be active globally.
Human resource
development programs

Human resources
development program

Development/specialized education

In 2022, we introduced an online video learning service
called Schoo and worked to expand learning opportunities
for interested employees as a part of our development/
specialized education program. Employees can watch videos
on demand, but we also work to cultivate awareness of theimportance of learning, including through group sessions
watching videos on business skills and other areas directly
related to work.

Scope of coverage

Unit

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022

Number of participants

Major domestic group companies

persons

829

1,103

1,027

1,524

8,383

Training time results

Major domestic group companies

hours

13,741

13,992

15,763

17,512

22,94024

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Engagement Survey
Going forward, we will pursue initiatives to enhance
engagement, using the scores of peer companies in the top
20th percentile as a benchmark.

We administered an engagement survey targeting regular
employees and reemployed personnel of major domestic
Group Companies. The response rate was 98%, representing
nearly all targeted employees. Our comprehensive score
surpassed that of peer companies of a similar corporate scale.

Labor Practices
Basic Concept

Establishment of Healthy Labor Management andLabor Relations Based on Dialogue

Practicing the management principle of respecting humandignity means respecting and protecting workers’ rights. In
putting into practice management that respects humandignity, we comply with Principles 1 to 6 of the UN Global
Compact. Moreover, putting into practice one of NOK’s
Management Principles, to be “a company with open
communication,” leads to the active promotion of dialogue
among employees and between the Company andemployees. Under these Management Principles, NOK is
striving to create a workplace where employees can workwith vitality and peace of mind.

Dialogue between management and employees is essential
to realizing “management that respects people based oncare and trust” and promoting healthy development.
Through respecting the right to organize, the right to bargain
collectively, and other rights of workers, the NOK Group has
built a healthy labor-management relationship.
100% of employees of NOK Corporation and majordomestic Group Companies are members of labor unions(apart from non-eligible employees). Regular labormanagement meetings are held with the participation of the
top management. Not only do we carry out negotiations on
working conditions, but also explain business conditions andpresent management issues. Also, discussions on the
Company’s important policies and measures take place sothat both the labor side and the management side cancooperate in realizing business development and employee
wellbeing. Measures that have a significant impact on
employees are explained and discussed in advance.
The Company explains the business environment andmanagement plan for the next fiscal year to the labor unionand holds consultations about them. With that in mind,
the union submits a demand for consensus-based compensation
and working conditions for its members. In the spring of2023’s negotiations, the request was fully discussed
and concluded.

Compliance with Labor-related Laws
Our domestic Group Companies are instructed to ensurecompliance with the Labor Standards Act, the Labor Union
Act, and any and all other labor-related laws. Our overseas
Group Companies are also instructed to ensure compliancewith labor-related laws of each relevant country
corresponding to these labor-related laws. There were noserious legal violations in FY2022.
Business sites in Japan that accept foreign technicalinterns have been checked for compliance with the
Immigration Control Act as well as for the working and living
environment and working conditions for interns to ensurethat there were no problems overall.

(As of March 31, 2023)

Item

Composition of
employees(by type of
employment)

Unit

Regular employees

Non-consolidated

persons

3,419

3,529

3,676

3,489

Non-regular employees

Non-consolidated

persons

410

389

389

398

401

Total

Non-consolidated

persons

3,829

3,918

4,065

3,887

3,820

Regular employees

Consolidated

persons

42,25140,49237,99937,61337,913

Non-regular employees

Consolidated

persons

3,015

2,726

2,388

2,300

2,285

Total

Consolidated

persons

45,266

43,21840,38739,91340,19825

FY 2018

NOK CORPORATION ESG Data Book 2023

FY 2019

FY 2020

FY 2021

FY 2022

Scope of coverage

3,419

Basic Information

Environment​

Composition of
employees(by region)

Scope of coverage

Unit

Consolidated

persons

10,78911,001

11,017

10,73010,648China

Consolidated

persons

11,681

10,913

9,383

9,690

10,659Southeast Asia

Consolidated

persons

18,651

17,395

16,194

15,623

15,196

Europe and the UnitedStatesConsolidated

persons

1,130

1,183

1,405

1,570

1,410

Consolidated

persons

42,25140,49237,99937,61337,913

persons

2,677

2,747

2,857

2,704

2,643(3,446)

persons

742

782

819

785

776(877)

persons

3,419

3,529

3,676

3,489

3,419(4,323)

years

16.9

17.1

17.3

17.8

17.9(17.5)

years

18.9

19.3

19.5

20.0

20.7(19.3)

years

17.4

17.6

17.8

18.3

18.5(17.9)

age

40

40.1

40.3

40.9

41.1(41.3)

age

39.8

40.1

40.4

41.2

42(41.4)

age

39.9

40.1

40.3

41.0

41.3(41.3)

%

―

22.1

20.7

19.6

18.8(17.8)

%

―

27.5

27.3

27.2

26.5(25.7)

%

―

29.6

29.1

27.1

25.7(26.8)

%

―

20.5

22.4

25.5

28.5(29)

%

―

0.3

0.4

0.5

0.5(0.6)

FemaleTotal
Male

Average length ofcontinuous
service

FemaleOverallMale

Average age

FemaleOverall
Age 20s and underAge 30s

Employee ratio by
Age 40sage
Age 50s
Age 60s and over
Ratio of female inmanagerial
positions

Consolidated

%

0.5

0.8

0.5

0.3

1.7

Consolidated

%

29.2

28.1

30.0

35.7

32.1

On a consolidated basis

FemaleTotal

Number of newhires(total of new
graduates andmid-career hires)

Hiring ratio
Male
FemaleTotal
Age 20s and underAge 30s
Number of newhires by age group(total of newAge 40s
graduates andmid-career hires) Age 50s
Age 60s and over
Employeeturnover(leaving on own
volition)

FY 2021

Overseas

Male

Rate of hiring of
new female
graduates for the
managerial track

FY 2020

Domestic

Ratio of mid-career Ratio of mid-careerand foreignemployees
national employees
Ratio of foreign-national
in managerial
employees
positions

Hiring of new
graduates

Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)

FY 2019

FY 2022

Item

Male

FY 2018

Governance​

Japan

Total
Composition of
employees(on the basis ofgender)Society

Male
FemaleTotal

Consolidated

%

―

―

―

―

26.9

Non-consolidated(Major domestic group companies)

%

―

―

9.8

9.8

11.3(12.3)

Non-consolidated(Major domestic group companies)

%

―

―

0.3

0.3

0.3(0.3)

persons

115

117

92

30

68(80)

persons

32

34

25

11

12(16)

persons

147

151

117

41

80(96)

%

6.1

5.2

6.3

13.3

16.1(14.9)

persons

―

134

98

47

88(113)

persons

―

42

26

22

22(30)

persons

0

176

124

69

110(143)

persons

―

―

―

55

85(111)

persons

―

―

―

12

19(21)

persons

―

―

―

2

6(11)

persons

―

―

―

0

0(0)

persons

―

―

―

0

0(0)

persons

―

34

48

44

63(81)

persons

―

12

18

16

16(16)

persons

0

46

66

60

79(97)

Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)
Non-consolidated(Major domestic group companies)

26

NOK CORPORATION ESG Data Book 2023

Basic Information

Item
Ratio of standard
entry-level salary
to regional
minimum wage

Scope of coverage

Fukushima
IbarakiKumamoto

Ratio of senior management hired fromregional communities
Employee genderwage gap(percentage forfemale if
men=100)
Employeeretention status
Number of labormanagement
conferences held

Society

Environment​

Major production sites of NOK and
Nippon Mektron, Ltd.
Major production sites of NOK and
Nippon Mektron, Ltd.
Major production sites of NOK and
Nippon Mektron, Ltd.
Non-consolidated(Major domestic group companies)

Unit

FY 2018

Governance​

FY 2019

FY 2020

FY 2022

FY 2021

%

―

132.9

132.6

128.1

123.6

%

―

―

―

―

116.4

%

―

134.2

133.7

129.2

124.3

%

―

―

―

6.5

7.8(8.3)

Non-consolidated

%

―

―

―

―

71.8

Non-consolidated

%

―

―

―

―

75.3

Non-consolidated

%

―

―

―

―

55.4

Rate of turnoverNon-consolidated(Major domestic group companies)

%

1.3

1.0

1.8

1.7

2.3(2.2)

Number of Central Labor
Management Councils
held

Major domestic group companies

sessions

16

16

17

16

17

Major domestic group companies

persons

―

―

―

―

692

All workers
Of which regular
employees
Of which part-timeand fixed-term
employees

Development staff

Diversity
Basic Concept
The NOK Group takes the stance of recruiting and appointing
various diverse human resources regardless of their gender,race or nationality. Approximately 38,000 employees ofdiverse nationalities, races, genders, and employment types
are currently working in the NOK Group. We ensure that
executives at both domestic and overseas bases understandmanagement based on respect for human dignity, which isthe basic principle of the NOK Group, and promote thepractice of such management in accordance with thecircumstances in each region.
We are working to ensure that the percentage offemale, foreign nationals, and mid-career hires whoare promoted to management positions is at thesame level as that of regular hires, and there is nodiscrimination regarding promotion.
With the stance of localizing business execution by
overseas bases, the NOK Group promotes the development

and appointment of human resources who acknowledge andunderstand local conditions, regardless of their race or gender.
Interaction among executives and the technology,
manufacturing, sales, operations, and other departments ofboth domestic and overseas bases is facilitated so that they
can utilize the outcomes to develop personnel and improve
operational quality and efficiency in each department.
Furthermore, non-Japanese employees are appointed tothe executive positions of overseas subsidiaries. In addition,
we proactively advance the appointment, development, andparticipation of employees of foreign nationalities by
providing training for engineering staffs and manufacturing
operators of overseas subsidiaries in the technology andmanufacturing departments, and hiring non-Japanese
students in Japan.

Composition of employees by region (consolidated)

Ratio of female in management positions (consolidated)

Europe and the United StatesJapan

1,410 (3.7%)

10,648 (28.1%)
FY 20222,016 (73.1%)

37,913
Southeast Asia

15,196 (40.1%)

persons

Male

2,757
persons

China

10,659 (28.1%)

27

FY 2022NOK CORPORATION ESG Data Book 2023

Female741 (26.9%)

Basic Information

Society

Environment​

Governance​

Concrete Activities
Female’s Empowerment
NOK is taking various measures to increase the number offemale career-track hires. We are also working to enhance
training and guidance functions so that female employees
currently in non-career-track positions can actively advanceto career-track positions, and beyond that to management
positions, in line with their willingness and abilities.
The medium-term plan in effect through FY2025 callsfor NOK Corporation and major domestic Group Companies
to double the number of female managers compared to theend of FY2022, and to raise the ratio of career-minded femalein leadership and specialist positions to 30%.

We achieved our targets for FY2022, which were to raise
the percentage of female hired for career-track positions up
tp 10% and to triple the number of female employees inmanagement positions.
Enhancing the Employment and Support System for People
with Disabilities
NOK furthers the employment of people with disabilities sothat they can take jobs according to their abilities andcompetencies, and live independent lives in their communities.
Divisions around Japan promote the allocation of people withdisabilities to fulfilling jobs and the creation of workplaces thatenable them to work comfortably to establish an environment
where people with disabilities can work with vitality.

Human Resource and Welfare System
Basic ConceptWork-life Balance

As part of management based on respect for human dignity,
NOK is making efforts to create working environments
where employees can balance their job satisfaction with a
comfortable lifestyle. In addition to past measures taken to
help employees achieve both professional and personalgoals, we now consider and undertake various othermeasures from the viewpoint of work-style reform.
To realize flexible and diverse work styles, we are also
working on implementing and improving a flextime system,
childcare leave, nursing care leave, and other employee
benefit systems, lowering the upper limit on overtime toshorten working hours, and improving the rate of paid leave
taken by employees.

To ensure that each and every employee can work in a waythat suits them, we have in place support systems that go
beyond the legally required minimum, such as the system ofshorter working hours for employees with children up to thefourth grade and the family care leave system, which allows
employees to take up to one year of leave. To make it easierfor employees to use these resources, we are working toensure the system works properly by disseminating
information and providing advice about it.
In addition, to create a more pleasant workplace, we haveadopted flexible working hours with no core time and eased
restrictions on working from home and taking half-day paid
leave. In FY2022, to further promote support for balancing
work and family life, we introduced a special leave system thatenables employees to take special paid leave for treatment
and recuperation related to personal injury, pregnancy andchildbirth, and nursing and care for family members.

Number of days of annual paid leave taken

Length of childcare leave taken by men

Less than 5 days

0.0%

5 days toless than 10 days

20 days or more

3.7%

15.2%

FY 2022

15 days toless than 20 days

10 days toless than 15 days

23.4%

57.7%

Over 1 year

0.0%

6 months toless than 1 year

4.2%

3 months toless than 6 months

1 week toless than 2 weeks

4.2%
1 month toless than 3 months

29.2%

28

Less than 1 week

12.5%

NOK CORPORATION ESG Data Book 2023

FY 202220.8%
2 weeks toless than 1 month

29.2%

Basic Information

Item

Scope of Coverage

Male

Number of employees
who took childcare leave Female
Rate of return-to-workafter childcare leave

Society

Environment​

Governance​

Unit

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022

Non-consolidated(Leave-taking rate for men) persons

0

1

2

5

24(21.8)

Non-consolidated

persons

53

60

47

30

32

Male

Non-consolidated

%

―

―

―

100

100

FemaleNon-consolidated

%

―

―

―

100

100

Number of employees
who took nursing care
leave

Male

Non-consolidated

persons

0

0

1

1

2

FemaleNon-consolidated

persons

0

0

0

0

0

Number of persons
reemployedMale

Non-consolidated

persons

223

209

212

221

183

FemaleNon-consolidated

persons

6

6

10

12

12

Rate of employment

Non-consolidated(Consolidated)

%

2.06

2.06

2.03

Actual total hours worked per employee

Non-consolidated

hours

2,096.2

2,041.7

1,953.0

2,006.8

1,997.3

Overtime worked per employee (on an annual basis)Non-consolidated

hours

253

205.8

117

183.2

180.7

Average number of days of annual paid leave taken

Non-consolidated

days

13.6

14.5

14.5

16

16.9

Employment of disabled
persons
Hours worked per
employee/
Average number of days ofannual paid leave taken

2.15 2.56(0.71)

Concrete Activities
Drawing on Career Aspiration Surveys and Interviews

Reinforcing Efforts to Shorten Working Hours andEncourage Paid Leave-Taking
NOK has endeavored to shorten the total actual working
hours to help employees pursue comfortable andprosperous lifestyles. The labor-management committee
annually develops a plan for new initiatives and reviews theperformance of previous initiatives. Specifically, we checkthe record of overtime work hours and paid leave actuallytaken on both a departmental and individual basis by using
the relevant data, and thereby identify problems and develop
a response plan. Our target at present is to keep total actual
working hours to within 2,000 hours and for employees totake 17 or more days of paid leave.
To achieve these goals, we have adopted a policy of
promoting digitization to improve operational efficiency, andare making active efforts to this end. The use of Web-based
conferencing and the paperless system have taken root, andwe will continue to promote digitization of business operations.
Participation in Initiatives and Collaboration by Industry
and Theme
We take part in regular meetings and working group
activities related to the personnel policies put in place by theindustry associations of auto parts companies. This allows
us to gain information on industry trends related to diverse
work styles and revisions to labor-related laws andregulations, which is useful in considering improvements tothe personnel systems.

29

Every year, NOK offers employees an opportunity to reporton their current workplace situations and their job
aspirations. At that time, supervisors hold an interview with
employees regarding the content of the reports, including
their career aspirations, which is used in personnel
development and utilization, as well as to place the rightpeople in the right positions.
Other forms of communication
1. Workplace communication
The NOK Group strives to always be an open andcomfortable workplace. Managers take the initiative inachieving and maintaining a level of communication between
superiors and subordinates, colleagues, and workplaces.
For example, in addition to holding monthly departmental
meetings, supervisors and subordinates are required tomeet at least once every six months. An IT environment isalso in place that enables employees to easily communicate
with superiors, colleagues, and subordinates even whenworking from home.
2. Support for retiree associations
To help employees enrich their lives after retirement, NOK
established retiree associations around Japan (eightregional blocks), and supports each association throughholding regional gatherings and other events for retirees
to interact.

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Occupational Safety and Healthcare
Basic Concept

In addition, in FY2022, the President released a
Health Declaration to indicate the commitment of top
management to initiate health promotion based on a healthmanagement approach.
As a company, we view mental and physical health as amanagement issue and are working to support employee
health. We also encourage employees to engage in healthy
activities on their own.

Respect for human dignity is one of the NOK Group’s
Management Principles, and we believe safety is a vital
precondition for human dignity.
We have always operated our business according to theidea that health and safety are a top priority in everything we
do. To communicate the safety commitment of top
management more explicitly to employees, we formulated
the NOK Group Safety Principles in FY2017 and are pursuinghealth and safety activities across the Group with the aim ofeliminating industrial accidents.

Safety Principles of NOK Group“Safety is the foundation for implementing management spiritthat respects human dignity, my desires, and my mission”

Occupational Health and Safety Promotion Framework

Occupational Health and Safety Promotion Framework

Although the NOK Group does not have a certified safety
management system, we have established a labor healthand safety management framework led by the President, andare pursuing a PDCA cycle in accordance with ISO 45001
standards for occupational health and safety management
systems to promote health and safety activities for Group
Companies and for all operations both on the premises ofvarious business sites and beyond. Also, based on
emergency response standards, each business site has
established its own emergency response protocols.
In addition, at each business site we have formed healthand safety committees made up of representatives fromlabor and management. The committees meet monthly toconfirm the status of activities and discuss and decide on
health and safety measures.
The Safety and Health Promotion Department, which
oversees the entire Company, collaborates with the healthand safety secretariats of each business site, branch, andGroup Company to maintain and improve the health andsafety management level of the NOK Group.

Representative Director, Chief Executive Officer

Central Safety and Health Committee (Chair: Safety Officer)
NOK Safety and HealthControl Division

NOK
Domestic plants

Head office/branches

Safety and HealthCommittee(Chairperson: Head ofBusiness Unit)

Safety and HealthCommittee(Chair: Safety and
Health Officer [headoffice], BranchManager [branches])

Group Companies

Safety and HealthCommittee(Chairperson: Person
responsible for safety)

Medium-term Health and Safety Plan
1. Improving the level of safety management to eliminate
lost-time injuries and reduce the total number ofoccupational accidents to half
2. Equipment safety measures through risk assessment
3. Zero explosions and fires and thorough implementation of
measures to prevent recurrence

Development of Medium-term Occupational Healthand Safety Plan
We formulated a medium-term health and safety plan
spanning FY2019 to FY2022 and have continued to takemeasures in the following three key areas.
Lost-time injury frequency rate*1

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022

Manufacturing industry*2 (calendar year)

1.20

1.20

1.21

1.31

1.25

Domestic group companies

0.46

0.27

0.21

0.28

0.35

*1 Rate of lost-time injuries per 1 million hours*2 Ministry of Health, Labour and Welfare 2021 Occupational Accident Trend Survey

Lost-time injury severity rate*1

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022

Manufacturing industry* (calendar year)

0.100

0.100

0.070

0.060

0.080

Domestic group companies

0.071

0.038

0.011

0.004

0.005

2

*1 Severity of injuries represented by the number of workdays lost per 1,000 hours*2 Ministry of Health, Labour and Welfare 2021 Occupational Accident Trend Survey

30

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Lost-time injury frequency rate

Lost-time injury severity rate

1.50

0.120

1.00

0.080

0.50

0.040

0.00

2018

2019

2020

Manufacturing industry (calendar year)

Item
Deaths due to occupational accidents

Governance​

2021

0.000

2022

Domestic Group Companies (FY)

2018

2019

2020

Manufacturing industry (calendar year)

2021

2022

Domestic Group Companies (FY)

Scope of coverage

Unit

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022

Domestic group companies

persons

0

0

0

0

0

Formulating Action Plans
We create annual action plans based on the status ofindustrial accidents. The Central Safety and Health Committee,
chaired by the executive in charge of health and safety andmade up of representatives from labor and management,deliberates and decides on the plan, which it disseminates toall business sites along with priority action items.
Business sites that have experienced industrial accidents
and require particular improvement draw up improvement
plans as designated “specified management business units.”
The Safety and Health Promotion Department follows up withthese sites on an individual basis.

Distributing a Message from Top Management
Based on the NOK Group Safety Principles, we formulated
the NOK Occupational Health and Safety Policy in FY2022.
The policy indicates the specific direction of health andsafety activities in line with the thinking of the Company’s
top management.

Safety Day Activities
We established a monthly Safety Day to carry out health andsafety activities at each workplace. On these days, allemployees at each workplace engage in health and safety
activities, including identifying local risks and implementing
response measures, as well as actions to raise
mutual awareness.

Measures to Improve Safety

we identify processes, equipment, and tasks which have thepotential to cause serious industrial accidents as “designatedhazards,” and prioritize response measures andmanagement to address these hazards.

Health and Safety Education
Health and safety education begins when employees firstenter the Company. We follow up with regular educational
programs to help employees gain the knowledge and skills
needed to work safely, as well as hazard simulations using
hands-on hazard simulation equipment we designed in-house.
We also carry out training for line managers, seeking toinstill unified thinking about health and safety managementin their own workplaces and a shared awareness of healthand safety as managers.
With the aim of instilling safety knowledge andmaintaining and raising the safety awareness of employees,
we also offer training at each workplace using our Safety
and Health Guidelines. Created in 1972, we still use theseguidelines as a tool for health and safety education andactivities in the workplace, revising them as needed.

Fire Prevention
With a priority on preventing fire disasters and small fires,we have formed a fire prevention Task Force to consider issues
and response measures and deploy them across the Group.
We have also established a database that we use toshare Group-wide information on near-miss incidents andsmall fires and deploy response measures horizontally.

Based on risk assessment results and past data such as
near-miss incidents and findings of safety patrols,

31

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Health Maintenance and Promotion(1) Health management
We have a 100% regular health checkup rate. In addition,
we actively encourage medical examinations and provide healthguidance with the aim of ensuring that 100% of employees
undergo follow-up examinations for the early detection andtreatment of illnesses.
For mental health issues, we make online interviews
with an industrial physician or counselor available. We havealso set up a 24-hour, year-round free telephone consultation
service through an external specialist organization, putting
in place a framework to respond early on to any issues andsupport a smooth return to work.

(2) Health promotion
To boost employee awareness of health, we introduced ahealth management app that for employee smartphones,
and use it to disseminate health information.
We also provide aerobic workouts under the guidance of
our athlete employees to help staff develop the habit ofexercising. In particular, workouts held online aim to address
the lack of exercise among employees working remotely.

Scope of coverage

Unit

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022persons

143

129

161

150

141

Facility safety training (simulations, safety standards training)

Major domestic
group companies
Non-consolidated

persons

330

59

146

102

274

No. of units undergoing facility safety improvements

Non-consolidated

units

622

1,131

994

646

194

Investment in facilities and equipment for safety measures

Non-consolidated

millions of yen

330

320

68

170

270

Total number of employees commended
for safe driving (commended for 30 years or longer)

Major domestic
group companies

persons856(78)910(124)908(139)963(158)925(146)

Scope of coverage

Unit

FY 2020

FY 2021

FY 2022

Major domestic
group companies

cases

850

715

552

Major safety activities
Safety, hygiene and health training for line managers

Major mental and physical health initiatives
Number of health consultation calls

Concrete Activities
Traffic Safety Initiatives
The NOK Group is committed to creating a culture of traffic
safety as a company engaging in transportation in society
through our products.
To eliminate traffic accidents and violations among
employees, we formulate annual action plans to promote
safe-driving management throughout the Group. We areworking to build a heightened awareness of safe driving
practices, including driving for private purposes commuting.
For example, since the 1970s, before the Road Traffic Act
mandated the wearing of seatbelts, we have worked to ensurethat all occupants of our vehicles, not just drivers, wear aseatbelt. In addition, we provide education and guidance at each
workplace to prevent speeding and driving under the influence,
which can cause serious accidents.
In an effort to maintain and improve the road safety
awareness of employees, we have also established a system
to commend excellent drivers who continue to drive safely,
awarding them according to their number of years without
an accident or violation.
In addition, as part of safe-driving activities at each
workplace, we use driving simulators to confirm driving
tendencies and participate in community-sponsored zeroaccident, zero-violation challenges. We also regularly hold32

traffic safety seminars with the help of the Japan Automobile
Federation (JAF) andlocal police stations.
Our actions havedrawn acclaim. In FY2022,
five business sites werecommended by externalorganizations as excellent
business sites.
Initiatives to Improve the Workplace Environment
The NOK Group first launched activities to improve our work
environment in 1993. Since then, we have systematically
implemented environment controls (noise, heat, and cold),safe work practices (working posture and the handling ofheavy objects), and support systems (such as providing
break-time facilities).
Starting in FY2019, we began reinforcing our efforts,
with a focus on Group Companies.
In FY2022, we introduced work vests equipped with fansto protect against overheating during outdoor work, andinstalled humidifiers and air purifiers to protect against
infectious diseases.

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Supply Chain Management
Basic Concept
We believe that to fulfill our corporate social responsibility,
it is essential to share a common awareness across the
procurement supply chain while building relationships basedon mutual trust.
Today’s society is also facing many problems such asenvironmental and human rights issues, and companies are
expected to help address these to build a sustainable society.
To this end, we established the NOK Group Procurement
Policy for conducting procurement activities with suppliers.

At the same time, we ask suppliers to respect ourCharter of Corporate Behavior, the NOK Group Human Rights
Policy, the CSR Procurement Guidelines, and the NOK Group
Green Procurement Guidelines as we work across the entire
supply chain to achieve equitable, fair, and socially andenvironmentally friendly procurement and bring about asustainable society.

NOK Group Procurement Policy
1. We comply with laws, regulations and social norms.
2. Based on the idea of free competition, we select suppliers in a stringent manner by providing fair and equal opportunities.
3. We share mutual interests and benefits with suppliers based on the idea of mutual prosperity.
4. We engage in open communication and build relationships of trust with suppliers.
5. We conduct improvement activities proactively in collaboration with suppliers.

Breakdown of suppliers by region

Item

Scope ofcoverage

Unit

FY 2020

FY 2021

In Japan

%

93.3

91.5

In China

%

84.3

84.7

Within ASEAN

%

72.2

77.3

Other

2.1%
Breakdown of local
procurement
by region(by value)

ASEAN

29.4%
Number of suppliers
worldwide

China

Japan

46.7%

About 3,000

21.8%

33

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

CSR Procurement Guidelines

To fulfill our corporate social responsibility, we request that not only our Group but also our suppliers refer to these guidelines andactively promote CSR activities, including within their supply chains.

1

Compliance with laws and regulations
We will comply with laws and social norms in each country, including competition laws, trade-related laws, and environment-related laws.

Respect for human rights
・We do not deal with business entities that use forced or child labor, that engage in unlawful employment of foreign nationals or any otherillegal employment, and that do not satisfy occupational safety and health regulations.

2・We do not discriminate on the grounds of race, ethnicity, creed, gender, age, marital status, physical characteristics, disability, etc., in any
employment or treatment (application, recruitment, promotion, remuneration, right to receive education, work grants, wages, welfare,punishment, dismissal, retirement, etc.).
・We comply with the laws and regulations of each country and region where employees are entitled to minimum wages, overtime, wage
deductions, piece-work payment, other benefits, working hours (including overtime), holidays, and annual paid holidays. In particular, werecommend that wages exceed national and local laws and regulations, and we do not work excessive overtime hours.
・We respect the freedom of association and the right to participate in collective bargaining, and engage in good faith dialogue andconsultation directly with employees or their representatives. We also recognize employees’ right to freely associate or not in accordancewith the laws and regulations of each country and region.
・We do not accept any form of harassment, including abuses of power and sexual harassment.

3
4
5
6
7
8
9
10

SafetyWe prioritize the safety of customers and consumers, and purchase products that satisfy safety regulations.

Green procurement
We carry out procurement activities based on the NOK Group Green Procurement Guidelines with consideration for conserving the global
environment.

Confidentiality
We deal with suppliers that can appropriately manage and control the confidentiality of information on customers, individuals andtechnologies, etc., obtained through business transactions.

Elimination of anti-social forces
We do not deal with any organized crime groups, any of their members and related individuals, any other antisocial forces, or any business
entities associated with them.

Activities regarding conflict minerals
We strive to avoid purchasing minerals and their processed products sourced from countries where inhumane armed forces are active andmining minerals for their financial resources.

Contribution to local community and society
We contribute to the development of the local community and society by proactively doing business with local suppliers.

Information disclosure
We disclose business information related to management and finance, product handling and safety, quality, environment information, etc., toall stakeholders in a timely and appropriate manner, and develop and maintain mutual understanding and trust through open and faircommunication.

Deployment of CSR to suppliers’ own supply chain
To advance initiatives throughout the supply chain, we ask suppliers to implement initiatives throughout their own supply chain equivalent
to those described in the NOK Charter of Corporate Behavior and CSR Procurement Guidelines.

34

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Product Quality and Safety
Basic Concept
The NOK Group has long engaged in manufacturing under
the concept that “quality is built in through the
manufacturing process.” Since our founding, our technology
and quality have earned the trust of numerous customers,
who use our products in a variety of fields.
To build in quality through the manufacturing process,our efforts have concentrated on cultivating the people
involved in manufacturing under our Management Principles
of respecting human dignity. This is the source of our quality.
We have developed a variety of educational programs forthis purpose. Recently, we have focused in particular on
strengthening the training of managers and supervisors,
driven by the desire to pass on the basics of manufacturing
to future generations as veteran employees retire frommanufacturing sites.
In recent years, we have also been proactively
incorporating digital technologies to further enhancecustomer satisfaction.

Basic policy“Putting quality first, we provide services and products that
customers can trust at all stages of research and development, design, production, sales, service, etc.”

Behavioral guidelines
1. All employees work together to make constant efforts toimprove quality
2. Improve our unique technology
3. Continuously improve administration technology
4. Thoroughly comply with laws and regulations
5. Continuously manage the policy

NOK Group Three-Year Quality Assurance Policy (2020–2022)
Return to the Basics of Quality
Priority Action Items
Under the Chairman’s initiative of “Return to the Basics of Quality,” we are working over a period of three years to get back to basics toensure NOK Group quality that customers can rely on, guided by the following four points.
1．Thorough adherence to basics
In earning customer trust, our top priority is to stick to the basics. Specifically, we aim to educate our employees in quality assurance based on correct
standards and ensure compliance, thereby continuously improving their skills in quality assurance. We will ensure that the products we deliver tocustomers do not cause any inconveniences due to inadequate work standards or non-compliance in some area of operations.

2．Prevention of serious quality problems
Growing demand for product safety and quality increases and increasingly sophisticated demands from customers for compliance and responses to
product defects identified in the market require a new approach to process development. Therefore, we will enhance our manufacturing capabilities in allareas, ranging from development to production sites, to prevent defects from occurring.

3．Non-conformance reduction activities
From the perspectives of environmental conservation and contribution to the bottom line of the organization, we need to reduce non-conformity loss
occurring at production sites. We are putting top priority on items with a high number of non-conformities, and each department is supporting andpromoting these activities. Non-conforming products can also be the cause of complaints that inconvenience customers. Therefore, we have deployed an
AI-based failure resolution method to identify the causes of non-conformities and ensure that measures are taken to prevent them.

4．IT-based quality control improvement
By promoting the digitalization of operations, we are striving to streamline tasks and avoid over-reliance on individual skills, techniques, and experience.
In addition, we will improve the speed and accuracy of traceability by further enhancing the digitalization of quality records.

35

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Quality Management Framework
To continue supplying products that meet customer needs, NOK has established a quality management framework based on ISO
9001 and other international standards, which we are operating in pursuit of ongoing improvement.
See page 39 for our acquisition of quality management system certification.

Quality Assurance Framework
Quality Officers also supervise the planning, coordination,and promotion of quality assurance. We develop Quality
Assurance (QA) Action Plans in line with the NOK Quality
Assurance Policy and conduct regular on-site Quality
Assurance (QA) Reviews.
In addition, our mother factory in Japan takes the leadin supporting the launch of overseas production transfers,
implementing priority action items, and resolving quality
issues. The Quality Control Office is also involved in key
matters associated with these operations, seeking theirseamless implementation.

Quality Assurance Activity Plan
We have deployed the quality assurance policy and quality
targets to each business division, and they have formulated
the action plans. We pursue activities by setting out priority
action items and metrics for achieving quality goals.

Quality Assurance Review (QA Review)
Quality Officers conduct on-site QA Reviews. They assess
whether implementation plans have been formulated with anunderstanding of the intent of the Quality Assurance Policy
and whether quality improvement activities are being carriedout effectively. In recent years, one focus has been on
addressing weaknesses by having production sites take thelead in conducting reviews.

Quality Control Department Managers’ Meeting
This is a regular venue for quality control department
managers to gather and exchange information on thedevelopment of priority action items for the fiscal year andthe progress of activities. This occasion gives participating
managers an opportunity not only to share best practicecases presented by various sites, but also to sharelessons learned.
In this way, Group Companies in Japan and abroad canreadily exchange information on quality management
systems in place to ensure that NOK’s products have auniform level of quality worldwide, thereby enhancing
customer satisfaction.

Quality Assurance System Overview
Policy, Decision Making

President

Domestic Group Companies

Quality Control Office

Overseas Bases

Quality Officer

Control over the functions
involved in quality assurance,such as planning, coordination,and promotion

Quality Officer
QA review

Quality Control Representative
Formulation of QA Activity Plans
and application of plans to eachdepartment and each production
subsidiary under his/her control.

Divisions

Factory

Quality Control Representative

Quality Control Representative

As a mother factory

Production
Subsidiaries

36

・Product transfers and launches of overseas production
・Support for quality assurance activities
・Promotion of priority issues

NOK CORPORATION ESG Data Book 2023

Quality Control
Department Managers'
Meeting・Deployment of bestpractices・Sharing of lessons
learnedBasic Information

Environment​

Society

Governance​

Quality Improvement Activities
We are taking steps to improve quality in all of our processes, from order receipt to delivery.

Overview of quality improvement activities
Management process

Policy deployment

Quality Assurance Activity Plan

Audit, review

Quality Assurance Review

Communication

Quality Control Department Managers' Meeting

Product realization process

Customers

Order receipt

DesignTrial production

Mass production
Trial production

Mass production
InitialMass production

Delivery

Customers

Field quality

Judgment at quality gates

Mass-production process improvement

Customer satisfaction

Field quality monitoring activities

Special quality evaluation meeting

Activities to reduce non-conformity

Customer commendation

Education, training

SuT Program

Human resource development

Cultivation of administrators and supervisors

Motivation

In-house Quality Award System

Revitalization of the workplace

QC circle activities

Support process

Field Quality Monitoring Activities

Overview of field quality monitoring activities

NOK draws on field quality data to regularly monitor foranything that could lead to significant complaints from themarket. Using results obtained from past activity
performance assessments, surveys, and analyses, among
other data, we collaborate on initiatives related to themesthat have been able to be established, including proposing
improvements to customers.
There were no violations of various regulations or
voluntary codes in FY2022.

Field

Customers
Proposal of improvement measures

Sales Department

・Grasp of customer
information
・In-house information
development

Database

Technology Department(business division)

・Actual product survey
・Examination andimplementation of
improvement measures
・Accumulation of our unique
technology

37

Collection of actual products for survey

NOK CORPORATION ESG Data Book 2023

Quality Assurance
Department

・Early detection ofabnormalities through data
monitoring and analysis
・Selection of survey target
products

Basic Information

Environment​

Special Quality Evaluation Meeting
NOK engages in preventative activities to ensure the deliveryof products of consistent quality to customers. This involves
dividing new product development into three stages fromdesign to production: prototype design; trial mass
production; and management of initial mass production.
We have criteria in place to determine whether to move on tosubsequent stages and address any issues at an early stage.
In particular, we hold special quality evaluation
meetings for products that involve new development, basedon which a Quality Officer makes a judgment about moving
on to the next stage.

Societyan advanced curriculum to train participants in methods
through hands-on exercises.
Many employees who have gone through the SuTProgram are applying the methods they learned to various
improvement activities.
* SuT stands for Speed-up Tools of Problem Solution.

Overview of the SuT Program

Reducing Non-Conforming Products Linked withClarifying of Mechanisms
NOK is taking action to reduce product non-conformity toenhance quality and cut back on waste. Avoiding causing
difficulties for customers means not generating nonconformity in the various production processes.
To accomplish this, we start by implementing a response
measure for a single instance of non-conformity until it isresolved, and then repeat this process for each instance of
non-conformity in turn, until we have a series of measures inplace to eliminate overall non-conformity. We pursue such
Zero Non-Conformity Initiatives every year at each site on anarray of themes.
The starting point for such activities is the carefulobservation of production sites, actual products, and actual
situations as well as repeated verification based on a given
mechanism. This approach has helped employees on sitehone their problem-solving skills. In addition, representing
the results of verification of the mechanism using Fault Tree
Analysis (FTA*) enables the data to be managed for use in
future proprietary technologies.

Governance​

Advanced course(specialized course)

Response surface method
Weibull analysis
DRBFM, etc.

Intermediate course

Multivariate analysis
Design of experiments
KT method, etc.

Introductory course

Seven QC tools
QC story
Root-cause analysis, etc.

QC Circle Activities
NOK employees take initiative in conducting quality control (QC)
circles to pursue quality improvement activities in small groups.
QC circles seek to resolve matters employees deal with intheir day-to-day workplaces, and also provide a venue for thegrowth and character formation of members through sharedactivities, which also leads to more vibrant workplaces.
In FY2022, 740 QC circles in Japan and overseas took
part in a quality control competition. The top activity
presentations of circles selected by each company wereentered into the NOK Group QC Circle Convention, and theoutcomes of the winning circles’ activities were showcased.
Since the first NOK Group QC Circle Convention washeld in 1963, this competition has been held 70 times overthe span of 59 years.

Road to Qualifying for the Group Convention
NOK Group QC Circle Convention* A method of failure and accident analysis.

Improvement Activities through Quality Control
Education and Practice Based on QC-Oriented Thinking
NOK offers quality control education at each level of theorganization. We put a particular emphasis on problem
solving, where we advocate fact- and data-based logicalanalysis and improvement under the motto of “Let’s argue
from the data,” which is a hallmark of QC-oriented thinking.
The business today demands a swift response at the
point of problem solving. To achieve this, NOK offers a SuT*
Program which aims to support the more widespread use oftools that help speed up problem-solving.
Having started out with a course on the “Seven QC
tools,” we now offer more than 20 courses ranging frommultivariate analysis to design of experiments. We also have

38

NOK
Domesticblock
3 circles

Overseas
China block
1 circle

OverseasSoutheast Asiablock
2 circlesGroup
Companyblock
1 circle each

Total of 740 circles

Customer Commendations
We have received high marks from customers for our quality
achievements and improvement activities.
In FY2022, we received 14 commendations for quality.

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

List of quality management system certified companies

Country

Certified companies(business divisions/business establishments)

Operating site

ISO 9001

7-Mar-14

Tenei Seal Industry Corporation

ISO 9001

18-Dec-20

Miharu Industry Corporation

ISO 9001

12-Apr-21

Tohoku Seal Industry Corporation

ISO 9001

2-Apr-21

Miyagi NOK Corporation

ISO 9001

15-Mar-21

Nihonmatsu NOK Corporation

ISO 9001

3-Mar-21

NOK CORPORATION, Plastics & Polyurethane Division

NOK CORPORATION, Gaskets & Boots DivisionJapan

ISO 9001

14-Apr-21

Kitaibaraki Plant

ISO 9001

3-Sep-07

Isohara Polyurethane Industry
Corporation

ISO 9001

15-Dec-14

Shizuoka Plant

ISO 9001

9-Oct-13

Nihonmatsu Plant

ISO 9001

9-Oct-13

Tsukuba Plant

ISO 9001

9-Oct-13

MYK Corporation

ISO 9001

9-Oct-13

Kikugawa Seal Industry Co., Ltd.

ISO 9001

9-Oct-13

ISO 9001

17-Oct-07

Tottori Plant

ISO 9001

3-Jun-09

TVC Co., Ltd.

ISO 9001

3-Jun-09

Kumamoto Plant

NOK CORPORATION Tokai Plant
NOK CORPORATION, Vibration Control Rubber Division

ISO 9001

30-Sep-98

Isshin Industries Corporation

ISO 9001

28-Nov-11

Kanasei Corporation

ISO 9001

13-Apr-11

Saga NOK Corporation (Ureshino Plant)

ISO 9001

7-Feb-01

Saga NOK Corporation (Tosu Plant)

ISO 9001

7-Nov-08

Kusu NOK Corporation

ISO 9001

27-Mar-04

Kumamoto NOK Corporation

ISO 9001

24-Mar-04

Nichinan NOK Corporation

ISO 9001

24-Mar-05

NOK CORPORATION, Precision Moldings & O‐rings Division

ISO 9001

25-Jun-08

Oil Seal Production

IATF 16949

28-Jan-18

Vibration Control Production

IATF 16949

24-Jan-18

Rubber Seal Production

IATF 16949

2-Feb-18

Aso NOK Corporation

VietnamThai NOK Co., Ltd.

Vietnam NOK Co., Ltd.
P.T. NOK Indonesia

Indonesia

PT. NOK Freudenberg Sealing Technologies

Wuxi NOK-Freudenberg Oil Seal Co., Ltd.
Changchun NOK-Freudenberg Oil seal Co., Ltd.

China

Date of acquisition

NOK CORPORATION, Oil Seal Division

NOK METAL Co., Ltd.

ThailandType of standards

ISO 9001

1-Sep-09

IATF 16949

12-Dec-11

IATF 16949

26-Jul-17

ISO 9001

10-Jul-18

IATF 16949

13-Jun-18

ISO 9001

21-May-99

IATF 16949

17-Apr-18

IATF 16949

12-Jun-18

ISO 9001

20-Feb-07

IATF 16949

20-Jan-16

NOK (Wuxi) Vibration Control China Co., Ltd.

IATF 16949

15-Mar-19

NOK (Wuxi) Water Treatment Technology Co., Ltd.

ISO 9001

29-Oct-20

Taicang NOK-Freudenberg Sealing Products Co., Ltd.

* This list covers establishments engaged in seal production among overseas group companies.

39

NOK CORPORATION ESG Data Book 2023

Basic Information

Society

Environment​

Governance​

Participation in Communities and Community Development
Expenditures on Social Contribution Activities
and Percentage by Field
Social welfare 3.15%

Other 0.7%

Environment 7.54%
Local community activities,
conservation of traditional
culture10.14%(millions of yen)

Health, medicine,sports36.4%
FY 2022 Total

119 million yen

Academic, research,education

Crime prevention, disasterprevention

24.77%

17.28%

DonationsNOK Group’s Social Contribution Activities

140
120
100
80
60
40
20
0

116

119
82

81

2020

2021

60

2018

2019

2022

ExamplesHealth, medicine, sports

Participating in blood donation events, Ecocap bottlecap recycling activities, medical assistance, sponsoring sports
events, supporting and donating to school sports events

Academic, research, education

Accepting interns, granting scholarships, supporting events for next-generation development and school events

Crime prevention, disaster prevention

Participating in and donating to crime prevention and traffic safety activities, participating in disaster prevention
activities, visiting victims after disasters

Local community activities,
conservation of traditional culture

Sponsoring local festivals, making donations to shrines, donating goods to local communities, inviting local
residents to festive events at the plants

Environment

Participating in local cleanup activities, tree planting activities, activities for water purification by utilizing paddy
fields, recycling

Social welfare

Donations to the Red Cross and other social welfare organizations

Contributions to Local Communities
The NOK Group’s plants in Japan and overseas Group
Companies regularly conduct cleanup activities in theirsurrounding areas. We also engage in activities that areclosely tied to local communities, such as co-sponsoring
local festivals, inviting local residents to festivals held atbusiness sites, and participating in volunteer activities.
Through support organizations, our business sites inJapan have donated canned food for use in disasterstockpiling at children’s cafeterias, which provide free or
reduce-priced meals to children.
Changchun NOK-Freudenberg Oil Seal Co., Ltd., a Group
Company in China, donates picture books and teachingmaterials, holds storytelling sessions by employees, andsupports children with disabilities.

Every year at the Kumamoto Plant, employees volunteer
to help with open burning to preserve and restore thegrasslands of Aso.

Contributing to Society through Sports
NOK supports athletes, driven by a strong desire tocontribute to society through the dreams and inspiration thatsports can offer to people. Since April 2019, we have
employed four athletes under the Athlete Navigation System(Athnavi), a program run by the Japanese Olympic
Committee (JOC) that offers job-search support for top
athletes. While actively participating in competitions, theathletes also engage in activities to improve the health of
our employees, including organizing and running remoteworkouts and employee training sessions.

40

Also, in collaboration with professional sports teams
that have a vision for existing and prospering alongside theirlocal communities, we hold sports workshops for local juniorhigh-school students, and plan and hold events.
In addition, we support the activities of local elementary,junior high, and high schools and sports clubs by opening
the gymnasiums and grounds of the NOK Group’s domestic
business sites and of overseas Group Companies.

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Governance​

Society

GovernanceCorporate Governance
Basic Concept

serve as executive officers cooperate with each other in theexecution of their duties, while directors of the board,
including external directors, mutually monitor each other.
The corporate auditors, including external auditors, audit
management. The Board of Directors and the Board of
Corporate Auditors, which include personnel from outside thecompany, are the key to strengthening the checking function.
To improve objectivity and transparency regarding
nominations and remuneration, the Board of Directors has
established the Management Oversight Council with key
members from outside the company as an advisory body to
the Board of Directors, which regularly confirms importantmatters such as nominations and remuneration and provides
appropriate advice to the Board of Directors.
In addition, significant management risks are checked andassessed at the Management Oversight Council periodically.
In terms of the internal audit function, the Internal
Control Audit Committee, an advisory body to the Board of
Directors, regularly audits the systems to ensure the proper
operation of NOK and its subsidiaries in accordance with theInternal Control Regulations, and reports the results to theBoard of Directors and the Board of Corporate Auditors.

The NOK Group aims not only to contribute to the developmentof economic society by creating added value through faircompetition, but also to become a company that benefitssociety at large by promoting management that can make all
stakeholders proud of the company and continue pursuingtheir dreams together. We are also promoting a management
plan to secure economic growth with stability and strong
increases in revenue over the medium to long term.
For this reason, the NOK Group considers continuously
strengthening the corporate governance framework as oneof our business management priorities, and we arecommitted to this goal.

Corporate Governance Framework
NOK has adopted the format of a company with a board ofcorporate auditors. To develop and provide products andservices from the customer’s perspective in a businessenvironment where technological innovation and the needs of
end users are rapidly changing, we believe it is important that
directors who are well-versed in operating a business be
involved in making key management decisions. From thispoint of view, the directors of the board who concurrently

Corporate Governance Framework
Shareholders’ Meeting
Appoint/Remove

Consult

Appoint/Remove

Appoint/Remove

Audit/Report
Nine directors
Five auditors(including three external directors)(including three external auditors)

Management Oversight Council
Supervise

Report・Directions for executing
management policies
and plans・Appoint/supervise
・Request report・Submit important businessexecution plans

ReportInternal Control Audit Committee/
Internal Audit Department

Report・Draft business execution plans
・Promote business execution

Hold

ReportGroup Strategy Council
and Management Council

Central Labor
Management Council, etc.

Explain or discuss business plans,
important organizational changes,
management policies, etc.

ReportReportReportDirectAccounting Auditor
Information
Exchange

Consult and direct

・Discuss important mattersand report on businessexecution (consolidated,segments and companies)

NOK Representative Director, Chief Executive Officer

ReportConsult
Share

・Share management
policies and plans
・Consult on andmonitor businessexecution

Head Office Divisions
DirectDirect

ESG, risk management,compliance, quality andenvironment management, etc.

Operating Divisions/Group Companies
Plan and promote execution plans for the business in charge

41

NOK CORPORATION ESG Data Book 2023

Audit

Audit

Basic Information

Environment​

Governance​

Society

Steps to enhance corporate governanceYear and month
2004
2006

PolicyPurposeApr.

Established the Crisis Management Office

Prevent and minimize negative impacts on business continuity

Jul.

Established the Accounting and Audit Division

Established as the Internal Audit Unit

May Established the Basic Policy for the Internal Control System
Enacted the NOK Charter of Corporate Behavior

Enacted and declared Management Principles, Management Policies, andPrinciples of Corporate Behavior

Aug. Enacted the Behavioral Guidelines on Employee Compliance
Compliance Rules established2008

Enacted and disseminated guidelines on matters for employees to comply with
Provisions on the handling of compliance with laws and regulations andcompany rules and regulations

2007 Mar. Established the Risk Management Rules
Oct.

Formulate basic policies for the internal control system

Provisions on responses to the occurrence of business risks and emergencies

Established the internal control subsidiary management rules

Prescribes instructions to subsidiaries and compliance by subsidiaries

Established the internal control rules for financial reporting

Prescribes methods for developing and evaluating internal controls overfinancial reporting

Jan. Established the Internal Control Audit Committee

Audit and maintain the state of the internal control system

2009 Jun. Introduced the Operating Officer System

Separate management oversight and executive functions, and establish an agile
management framework

Changed the term of office of directors to one year

Separate management oversight and executive functions, and establish an agile
management framework

Revised the executive compensation system

Introduce a long-term performance-based and performance-linked
compensation system

Established internal control rules

Consolidate Internal Control Subsidiary Management Rules and other internal
control-related rules

2015 Jun. Established the Risk Management Committee

Minimize risk probability and losses through cross-organizational verificationand evaluation

2013

Jul.

One external director took office
2016

2017

2019

Apr.

Strengthen the management oversight function

Installed a whistle-blowing system (that covers domestic Group Companies) Created a whistle-blowing framework by establishing the Whistle-Blowing
Hotline (in and outside the company)

May Started assessing the effectiveness of the Board of Directors

Improve the effectiveness of the Board of Directors

Jun. Increased the number of external directors to two

Strengthen the management oversight function

Oct.

Established the CSR Committee

Raise the awareness of CSR throughout the company and promote effective
CSR activities

Established the Central BCM Committee

Increase the effectiveness of the business continuity plan and help to improve
corporate value

Jan. Seal Segment BCM Committee established

Build and maintain the BCM within the segment as a sub-organization of theCentral BCM CommitteeMar. Electronic segment BCM committee established

Build and maintain the BCM within the segment as a sub-organization of theCentral BCM CommitteeJan. Established the Business Continuity Management Rules

Provides a business continuity management systemJul.

Established the Management Oversight Council (composed of the
Check, assess, and advise on key management issues and serious risks
President and Representative Director, external directors and auditors).

2020

Oct.

Expanded the internal reporting system (China Group companies
excluding Taiwan and Hong Kong)

2021

May Established the ESG Committee

Promote the company’s continued sustainable growth and the implementationof responsible initiatives

2022 Mar. Expanded and introduced a whistle-blowing system (Asian Group
Companies outside mainland China)
Jun. Established the Internal Audit Department

Strengthen the reporting framework by expanding the establishment of somewhistle-blowing desks at overseas bases
Established a specialized department for internal control audits

Formulated whistle-blowing regulations
2023

Strengthen the reporting framework by expanding the establishment of somewhistle-blowing desks at overseas bases

Formulated regulations in compliance with the revised Whistleblower
Protection Act

Apr. Formulated NOK Group Anti-Bribery and Anti-Corruption Policy

Took actions and reinforced framework for bribery and corruption prevention

Formulated basic rules for bribery and corruption prevention

Remuneration of Directors and Auditors
With respect to the remuneration of directors and auditors,
the company has established the following policy for
determining the details of remuneration for directors andauditors. Based on this policy, the amount of remuneration42

for directors is decided by discussions at Board of Directors
meetings and the amount for auditors by discussions ofauditors respectively, within the limits of the total amountdetermined at the general meeting of shareholders.

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Governance​

Society

Basic Policy
To this end, we have introduced a new stock-based
compensation plan for the management of the NOK Group’s
core companies, in which a certain percentage varies
according to the level of achievement of KPIs related to thepriority implementation measures in the NOK Group’s
medium-term management plan. The goal is to increase
corporate value over the medium to long term and to enhance
stakeholder satisfaction through monetary and stock-based
compensation, which varies according to the degree to which
performance targets are achieved in a single fiscal year.

The NOK Group aims to become a strong company
generating high profitability by producing and selling unique,technology-backed products that are useful to society
around the world. We believe that pursuing this policy as aGroup with a medium- to long-term perspective will help toenhance the NOK Group’s medium- to long-term corporate
value and raise stakeholder satisfaction.
In carrying out this policy, we believe it is necessary to
encourage management, including the directors of the corecompanies of the NOK Group, to achieve their goals and toenhance stakeholder satisfaction by means of compensation.

(As of June 30, 2023)

Composition of the Directors

Unit

Gender

Total

Internal/External

Male

FemaleInternal

External

Directors

persons

8

8

0

5

3

Operating Officer*

persons

16

15

1

16

0

* Figures for operating officers do not include those concurrently serving as directors.

Item

FY 2022Unit

FY 2018

FY 2019

FY 2020

FY 2021

Chief Executive Officer

persons

—

2

2

2

2

Directors

Composition of Management Oversight Council(advisory body for nominations, remunerations, etc.) Outside Directors

persons

—

0

0

0

0

persons

—

2

2

2

3

Outside Auditors

persons

—

1

1

1

—

Number of board of statutory
auditors’ meetings held

sessions

—

2

2

2

2

Management Oversight Council(advisory body for nominations, remuneration, etc.)

Composition of Board of Directors

%

—

100

100

100

100

Directors

persons

9

8

9

9

9

Of which, the number ofoutside directors

persons

2

2

2

2

3

Of which, the number offemale directors

persons

0

0

0

0

0

Average attendance rate

Auditors

persons

5

5

5

5

5

Of which, the number ofoutside auditors

persons

3

3

3

3

3

Of which, the number offemale auditors

persons

0

0

0

0

0

Number of board of directors’
meetings held (held on paper)sessions

14 (0)

13 (2)

14 (2)

12 (0)

13 (1)

%

97.7

98.2

100

99.1

100

sessions

11

9

12

11

11

%

92.7

97.8

98.3

100

98.2

Directors

millions of yen

296

289

317

406

393

Remuneration of Directors and Auditors*1

Of which, the number ofoutside directors

millions of yen

12

12

11

14

25

Auditors

millions of yen

60

59

60

67

75

Auditor Remuneration*2

Of which, the number ofoutside auditors

millions of yen

18

18

17

17

27

Composition of auditors

Board of Directors

Average attendance rate
Board of Statutory Auditors

Number of board of statutory
auditors’ meetings held
Average attendance rate

*1 The directors’ remuneration for FY 2018 includes remuneration for one auditor who retired from the position of board director at the conclusion of the 112th Ordinary General Meeting of
Shareholders held on June 17, 2018.
The directors’ remuneration for FY 2019 includes remuneration granted to a board director who stepped down as a director as of October 31, 2019.
The directors’ remuneration for FY 2021 includes remuneration for one auditor who retired from the position of board director at the conclusion of the 115th Ordinary General Meeting of
Shareholders held on June 25, 2021.
The directors’ remuneration for FY 2022 includes remuneration for one auditor who retired from the position of board director at the conclusion of the 116th Ordinary General Meeting of
Shareholders held on June 24, 2022.
*2 The directors’ remuneration for FY 2020 includes remuneration for two auditors who retired from the position of board director at the conclusion of the 114th Ordinary General Meeting of
Shareholders held on June 25, 2020.

43

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Governance​

Society

Board of Directors and Skills Matrix
Skills possessed
Officers

Directors

Years in
Genderposition

Name

Corporate
management

Financial,Business andGlobaltechnology Sales strategy accounting, andmanagement
capital policies
strategy

Masato Tsuru

Male

44

〇

〇

Masao Tsuru

Male

3

〇

〇

Yasuhiko Kuroki

Male

10

Akira Watanabe

Male

10

Junichi Orita

Male

2

〇

ESG
(Environmental,
Social, Governance)

〇

〇

〇
〇

Kensaku Hogen

External

Male

8

〇

Makoto Fujioka

External

Male

7

〇

Naoki Shimada

External

Male

1

〇

Nozomu Maehara

Male

3

Hideki Watanabe

Male

3

〇

External

Male

11

〇

Hideki Ogawa

External

Male

7

〇

Atsushi Kajitani

External

Male

7

〇

Auditors Osamu Kobayashi

Newbusiness

〇

〇
〇
〇
〇

〇
〇
〇

〇
〇

Compliance
Basic Concept
The NOK Group established the Compliance Rules in 2006,
based on the NOK Charter of Corporate Behavior, which
stipulates compliance with laws and regulations as well as
the company’s various rules and regulations.
The company established the Behavioral Guidelines on Employee
Compliance as a guide for specific details of the regulations.

This document specifies the items that employees mustcomply with in their business activities, and we ensure that all
Group employees familiarize themselves with the Guidelines.

Behavioral Guidelines on Employee Compliance (Plan)
1.	Respect for Human Rights, Prohibition against
Discrimination and Harassment
2. Fair and Appropriate Trade
3. Regulations against Insider Trading
4.	Export/Import Procedures (Security Trade Control)
5. Laws Related to Intellectual Property Rights
6. Severance of all Relations with Antisocial Forces

44

7. Environmental Conservation
8. Health and Safety
9. Provision of Useful and Safe Products
10. Appropriate Management of Information
11.	Prohibition Against Acts that May Damage theCompany’s Interests
12. Reporting Violations of Ordinances, etc.

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Governance​

Society

NOK Charter of Corporate Behavior

We, NOK Corporation, are committed to being an entity that fulfills the role of driving efforts toward the realization of a sustainable society
according to the Management Principles under the NOK spirit. We will pursue this through developing the Management Policies in such a
way that all our stakeholders are proud of us and chase their dream with us; and, while upholding the principle of fair and free competition,
through creating added value that is socially useful, generating employment, and acting autonomously and responsibly. In order to achieve
this realization, we will behave according to the eleven principles set forth below in the Principles of Corporate Behavior in both domestic
and overseas operations, so as so respecting human rights, complying with related laws, regulations, and international rules as well as thespirit behind those, and discharge our social responsibility with a strong sense of ethical values.

Enacted on May 1, 2006
Revised on July 1, 2019

Management Principles

Management Policies

1. T
 he Management has to run the Company based on feelings ofcare and trust in its employees.

1. We are committed to be a strong and unique parts supplier while
focusing its managerial resources on core business areas.

2. T he Management has to run the Company while uniting to ensure
full ventilation without forming any cliques.

2. We are committed to be a profitable and robust company while
fulfilling company-wide cost reduction programs ranging fromfront-line sales to manufacturing floor.

3. T he Management has to run the Company while making
absolutely incredible efforts against all odds and risks.
4. T he Management has to run the Company while pursuing dreams
with management plan.

3. We are committed to continuously improving our quality while
producing and selling our products that are proven to betechnologically unique and socially useful, on a global scale.

Principles of Corporate Behavior
1. Provision of Socially
Useful Products

We will develop and provide socially useful and safe products through the creation of new value, and provide pertinent
information regarding products and have sincere dialogues with end users and customers while also working toachieve sustainable economic growth and solve social issues, thereby gaining their satisfaction and deeper trust.

2. Fair and Appropriate Trade

We will ensure that we engage in fair, transparent, and free competition, that transactions are appropriate, andthat responsible procurement is carried out, when selling products and purchasing materials. Also, we will
maintain a sound and proper relationship with political bodies and government agencies.

3. Proper Disclosure andManagement of Information

We will disclose accurate information about the Company timely and appropriately, and have constructive dialogues
with the various stakeholders who surround our business in order to increase the corporate value. Also, protect andproperly manage personal and customer data and other types of information as well as intellectual property rights.

4. Thorough Risk Management and We will resolutely provide systematic risk management to prepare against activities of antisocial forces, terrorists,
Severance of all relations with cyberattacks, natural disasters, and other elements that threaten the lives of the public and business activities.
Especially we will resolutely confront any antisocial forces or groups and sever all relations with such groups.
Antisocial Forces and Groups
5. Commitment toEnvironmental Conservation

We will proactively initiate environmental conservation activities while taking into account the fact that commitment
to solving environmental issues is a prerequisite for a company to engage in business activities as a going concern.

6. Promotion of Social
Contribution Activities

As a good corporate citizen, we will actively participate in communities and contribute to their development.

7. Cooperation with theInternational Community

As a global corporation, we will comply with laws and regulations of the countries and regions where our business
operations are based , and respect human rights and other international norms of behavior (ex. prohibition of childlabour and forced labour). Also, conduct business by taking into consideration the local culture and customs aswell as the interests of stakeholders, and contribute toward the development of the local economy and society.

8. Respect for Human Rights

We will carry out management that respects the human rights of all people.

9. Provision of a Safe andComfortable Working
Environment

We will realize a work style that enhances the abilities of employees while respecting their diversity, character andpersonality, and by drawing a line between public and private matters, and maintaining order in the workplace,
we will realize a comfortable working environment that takes cleanliness, health, and safety into consideration.

10. Responsibilities of
Our Officers

Our officers, while carrying out management with the recognition that it is their role to realize the spirit of thisCharter, will establish effective internal control systems, and will take the lead in an exemplary manner toimplement the Charter within the entire NOK Group, while encouraging our business counterparts to act in amanner consistent with this Charter. In addition, our officers will constantly listen to opinions from both within andoutside the Company to ensure compliance with business ethics.

11. Response to Problems

In the event that a matter in noncompliance with this Charter arises, which causes society to lose trust in us,
our officers will take steps such as taking the lead in solving the problem, identifying the cause, and taking measures
to prevent the recurrence of similar problems, thus fulfilling their responsibilities. Moreover, they will publicly
disclose relevant information promptly and appropriately, fulfill their accountability requirements, indicate those
who are in authority and those who are responsible, and severely punish those involved, including them.

45

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Prevention of Bribery and Corruption
The NOK Group declares in NOK Charter of Corporate
Behavior that it will maintain "fair, transparent, and freecompetition, appropriate business transactions, and soundand normal relations with political and administrative
authorities,” and that corruption and bribery are prohibited.
As a signatory to the United Nations Global Compact, theNOK Group respects the Ten Principles of the United Nations
Global Compact and has established the NOK Group Policyon Prevention of Corruption and Bribery to further promotemeasures to prevent corruption and bribery. In the event of aviolation of the Group’s anti-corruption policy, the Risk
Management Committee is primarily tasked with taking
response measures.
Our Whistle-Blowing Hotline also accepts information on
violations of anti-corruption rules.
Meanwhile, the Internal Control Audit Committee
conducts an annual anti-corruption audit of all domestic andinternational divisions and Group subsidiaries, and reports
the results to the Board of Directors.

NOK Group Policy on Prevention of Corruption and Bribery

12Compliance with Laws and Regulations
We will observe laws and regulations prohibiting bribery (hereinafter referred to as "bribery related laws and regulations") in theperformance of group duties in the countries and regions concerned.

Prohibition of Provision or Receipt of Illicit Profit
We will not engage in any acts (including facilitation payments) that are prohibited by bribery related laws and regulations for the purpose ofobtaining illicit or unfair profits, regardless of whether domestic or foreign, directly or indirectly, public officials, private citizens, or private companies.

3

Prohibition of Bribery Through Third Parties

4

Proper Accounting and Record Management

5

Education and Training

6

Effective Operation of the Whistle-Blowing System

7

Risk Assessment and Review

8

Monitoring and Continuous Improvement

We will prevent bribery through third parties and will not tolerate such acts by appropriately managing business relationships with third
parties, such as agents and consultants.

We will keep accurate and factual accounting books and other records for all transactions related to this policy, perform appropriate
accounting procedures, and properly maintain these records.

We shall provide education and training on the prevention of corruption and bribery for officers and employees to thoroughly inform them of
the purpose and content of this policy.

We will establish a contact point for consultation and reporting for when we recognize an act that violates or may violate this policy, and wewill use this contact point to prevent, detect early, and correct the act in question.

We will periodically assess risks of corruption and bribery, handle high-risk business activities in a focused manner, and review this policy
and responses based on this policy as necessary.

We will monitor the status of compliance with this policy and internal rules concerning the prevention of corruption and bribery, and makecontinuous improvements based on the results.
Formulated: April 1, 2023

46

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Governance​

SocietyCompliance education

Implementation period

TargetTraining for new employees

When joining Company(April)New employees

Training for newly appointed
managers

When appointed(twice a year)

Newly appointed managers

Acquisition of compliance knowledge necessary for labor
management

Management training forseconded employees

When seconded(once a year)

Newly seconded officers

Acquisition of internal control and compliance knowledge

Group legal training

Once a year

Group company officials

Acquisition of compliance knowledge required for work

Compliance Promotion Month

Every October

All group officers and employees

Education via compliance primers and educational databases
Compliance awareness surveys, comprehension tests, etc.

Four times a year

All group officers and employees

Acquisition of knowledge on laws and regulations by theme
and improvement of compliance awarenessDistribution of compliancearticlesMeasure, purpose
Acquisition of basic compliance knowledge

Scope of coverage

Unit

FY 2018

FY 2019

FY 2020

FY 2021

FY 2022

Serious legal violations

Consolidated

cases

0

0

0

0

0

Amount of fines for legal
violations

Consolidated

millions of yen

—

—

—

—

—

Violations of the Code of
Conduct other than above

Consolidated

cases

3

6

8

4

4

Anti-corruption violations

Consolidated

cases

0

0

0

0

0

Amount of fines for anticorruption violations

Consolidated

millions of yen

—

—

—

—

—

Track record of politicalcontributions

Consolidated

millions of yen

0

0

0

0

0

Item

Risk Management
Basic Concept
NOK’s Risk Management Regulations stipulate the basic
policy and management framework for risk management
across the entire Group. Based on these regulations,the Company has established a management framework inwhich the President is responsible for and promotes risk
management for the Group. We believe there are two typesof business risks that may affect the management of theCompany: business strategy risk, in which we seek tomaximize returns while balancing risks to enhance corporate
value; and the risk of loss, in which we seek to prevent or
minimize the probability of losses occurring to maintaincorporate value.
Business strategy risk is assessed at meetings for
examining the Group's management strategy, where risks

47

associated with the promotion of business and new projects
at Group companies are identified and discussed to maximize
returns in a timely and appropriate manner. As for risk ofloss, the Risk Management Committee is established toassist the chief risk management officer, who periodically
identifies and analyzes risks, as well as quantifies themthrough risk-level assessments that take into account thefrequency (timing) of occurrence and the scale of loss
(amount of damage). Thus, the Risk Management Committee
examines issues and response measures by prioritizing theirimportance and urgency.

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Governance​

Society

Risk Management Framework
Management and Supervisory Bodies
Board of Directors
ReportGuide and Supervise

Business Execution Bodies
President (Risk Management Officer)
DirectCheck and Evaluate

Business Strategy Risk Management

Risk of Loss
Management

ReportReportGroup Strategy Review Meeting

Risk Management Committee

Refer for Discussion

Subsidiaries

ReportHead Office Divisions(Business Administration Department)

Business Execution Division
Thorough Awareness

ReportCrisis and Risk Categories That May Significantly Impact Company Management
Risks of loss are categorized as follows based on the type of crisis that may significantly impact company management and its cause.
Type of crisis

Cause

Risk category

Fire, explosion
Natural disasters (earthquakes, floods, etc.)
Shutdown of operations

Illness (COVID-19, H1N1 influenza, SARS, etc.)
Suspension of materials supplies

・Disaster risk・Country risk

Unlawful obstruction of business
Disruption of critical infrastructure
Judicial risk (crime, profit sharing, etc.)
Taxation (violation of tax laws, etc.)
Legal violations, etc.

Companies Act, Financial Instruments and Exchange Act (shareholder derivative lawsuits, etc.)
Environment (pollution, etc.)

・Legal risk
・Credit risk

Labor laws (violation of Labor Standards Act, sexual harassment, etc.)
Industrial accidents
Employee death, serious injury,or the possibility thereof

Traffic accidents
Natural disasters (earthquakes, floods, volcanic eruptions, etc.)
Fire, explosion

・Disaster risk・Country risk

Overseas armed conflict, riots, terrorism, kidnapping, etc.
・Legal risk

Lawsuits
Other matters that significantly impact
company management

Loss, leakage of key confidential information

・Credit risk

Serious quality issues

・Credit risk

Other

・Various risks

48

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

Business Risks
1. Business strategy risk

Strategic risk

(1) Dependence on customer performance
The bulk of the Group’s business is the manufacture and sale of seal products and electronic products. In these fields, our major clients are leading
domestic and foreign manufacturers of automobiles, construction machinery, and electronic devices. Sales to such client companies may be affectedby factors beyond the Group’s control, such as the companies’ business performance and unforeseen changes in contracts. A decline in sales to suchcustomers may affect the Group’s operating results and financial position. The Group aims for a balanced customer portfolio and strives to minimize
the risk of sales declines to client companies.
(2) Alliances with other companies
The Group engages in various alliances with other companies in developing its business. However, the Group’s operating results and financial
position may be affected by factors beyond its control, such as the dissolution of such alliances due to the peculiar circumstances of alliance partners.
In particular, since 1960, the Company has been in a capital and technical alliance with Freudenberg in Germany. Freudenberg (including its
group companies) has played an important role as a partner company in the business development of our Group.
Freudenberg is currently our largest shareholder, holding 25.1% of outstanding shares of the Company through its investment arm,
Freudenberg S.E. The Group recognizes that its alliance with Freudenberg will remain stable going forward. However, should there be a change
in the relationship with Freudenberg or Freudenberg’s business strategy or some other change, this may affect the business of the Group.

Investment risk

(1) Impact of changes in demand trends
Oil seals and other mainstay products of the Group are primarily used in internal combustion engines. Fuel cell and electric vehicles have also
entered the automotive market in recent years. Anticipating the future spread of such vehicles, the Group is also promoting R&D into new
products that can be installed in the vehicles. At present, however, it is difficult to foresee the impact that the spread of fuel cell and electricvehicles will have on the Group’s operating results and financial position.
Moreover, as the trend toward the commoditization of automobiles, construction equipment, electronic device products, and office equipment
grows, the number of local manufacturers in emerging countries has increased. Going forward, mounting competition may cause prices to decline,
which may affect the Group’s operating results and financial position.
(1) Impact of exchange rate fluctuations
With overseas sales accounting for roughly 70% of Group consolidated net sales in the fiscal year under review, exchange rate movements invarious regions may affect the Group’s operating results and financial position. For this reason, we hedge risks by means of foreign exchange
forward contracts. However, as such contracts do not necessarily avoid exchange rate risks entirely, exchange-rate fluctuations may have an
impact on the Group’s operating results and financial position.

Market risk

(2) Impact of interest rate fluctuations
The Group raises funds in consideration of the need for funds, the means of funding, and financial conditions. Fluctuations in interest rates onfunding stemming from changes in financial conditions may affect the Group’s operating results and financial position.
(3) Impact of stock market trends
Domestic and overseas stock market trends affect the valuation of investment securities held by the Company and the investment status of theGroup’s pension assets. A downturn in the stock market could subject investment securities to valuation losses, cause a decrease in pension
assets, and increase the Company’s burden.
(4) Fluctuations in raw materials costs
The costs of steel sheets, synthetic rubber, copper foil, resin films, gold, and other products that are the main raw materials for Group products
fluctuate in line with supply and demand. As these fluctuations in raw materials costs are not always immediately reflected in product prices,
they may affect the Group’s operating results and financial position. Given such fluctuations in raw materials costs, the Group is seeking a broad
range of business partners in Japan and worldwide to ensure a stable, continuous supply of raw materials.

2. Risk of loss

Legal risk

(1) Impact of legal regulations
The Group is subject to various laws and regulations in the various countries where it operates. We are working to develop internal regulations andmanuals that conform to such laws and regulations, foster and thoroughly instill awareness of compliance through various types of education, andbuild a framework for collaboration with outside experts. However, if such laws and regulations are revised or made more stringent going forward,
the additional costs incurred in complying with new regulations may affect the Group’s operating results and financial position.
(2) Risks related to lawsuits and other legal proceedings
When doing business in various countries, the Group establishes frameworks for Group internal control and collaboration with outside experts andhedges risks by taking out various types of insurance. However, we may become a party to lawsuits, regulatory action, or other legal proceedings.
If fines or restrictions on business execution are exacted on the Group as a result of such proceedings, this may affect the Group’s operating
results and financial position.

49

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Society

Governance​

2. Risk of loss

Legal risk

(3) Impact of intellectual property infringement
The Group guards its proprietary technology by obtaining patent rights and other intellectual property rights, and is also attentive to preventing
infringement on the intellectual property rights of third parties. However, if the inability to adequately guard the Group’s intellectual property
rights due to factors such as disparities in country circumstances results in lower sales or in litigation costs, or if Group products unintentionallyinfringe on the intellectual property rights of other companies, resulting in the need to suspend sales or pay compensation, this may affect theGroup’s operating results and financial position.
(4) Impact of environmental regulations
The Group complies with environmental laws and regulations at its various sites and takes necessary measures to address the environmental
demands of customers. In the future, however, laws and regulations or customer demands may become more stringent, the Group may bear
additional environmental responsibilities, and business activities may be restricted. If responding to such developments incurs a sizable cost,this may affect the Group’s operating results and financial position.

Country risk

(1) Political and economic conditions
The Group operates in Japan, North America, Europe, China, and other Asian countries. Therefore, shifts in political and economic conditions in the
countries and regions where the Group manufactures and sells products may affect the Group’s operating results and financial position.

Disaster risk

(1) Natural disasters, etc.
The Group’s production and distribution activities may be hindered by earthquakes, typhoons, floods, volcanic eruptions, and other natural
disasters, fires and other accidents, and the outbreak of infectious diseases. To prepare against such eventualities, we are striving to minimize
business continuity risks by decentralizing production sites and putting safety measures in place. We also hedge risks by means of various typesof insurance. However, it may not be possible to entirely prevent or mitigate the occurrence of such events, which may affect the Group’s operating
results and financial position.
(2) Infectious diseases, etc.
To prepare against situations in which an outbreak of infectious disease or other pandemic hinders production and transportation activities,
the Group is striving to minimize business continuity risks by decentralizing production sites and putting safety measures in place.
In particular, we have taken various measures to minimize the impact of COVID-19 since its global outbreak in 2020. Measures include
drafting a response manual, allowing employees to work remotely and follow staggered working hours, and using remote working tools to create
an environment where work can continue. There are signs that the pandemic is subsiding, as countries reassess their handling of the disease.
However, if there is a resurgence in new infections or the pandemic is prolonged, the economic or business environment of the Group may
deteriorate, which may affect the Group’s operating results and financial position.
(1) Impact of information leaks
In the conduct of business, the Group comes into possession of technical information, personal information, and other confidential information.
We have established an internal framework and procedures to prevent leaks of such information. However, in the event that information is leaked due
to unforeseen circumstances, this may affect the Group’s operating results and financial position.

Credit risk

(2) Impact of cyberattacks, etc.
The Group makes use of outside organizations and other resources to investigate and implement preventive measures against operational shutdowns,
loss of key data, and information leaks due to malicious cyberattacks. However, cyberattacks using unknown methods may affect operations.
(3) Impact of product quality issues
The Group manufactures products in accordance with globally recognized quality control standards at its various production sites. However, entirely
eliminating product quality defects due to unpredictable causes is difficult. In the event of a product defect that leads to a large-scale recall or productliability, the significant cost of the response and the loss of social credibility may affect the Group’s operating results and financial position.

Responding to Disaster Risk
1. Business Continuity Management (BCM) System
Regarding business risks and emergencies, NOK defines
natural disasters, fires, explosions, serious accidents andepidemics of infectious disease as “events that interfere withbusiness continuity.” The company established the BusinessContinuity Management System to ensure business
continuity and to promote business continuity activities
consistently and effectively should such an event occur.
Specifically, the NOK Group BCM Committee wasestablished as a standing committee to promote business

50

continuity management activities. The management
framework consists of the BCM Committee, which is
responsible for formulating, maintaining, and updating thebusiness continuity plan (BCP), securing the budget andresources to implement it, implementing preventative
measures, conducting education and training, conducting
inspections, and engaging in ongoing activities.
In the event of an emergency, the Company must
immediately set up an emergency response headquarters at
the head office and on-site response headquarters at local

NOK CORPORATION ESG Data Book 2023

Basic Information

Environment​

Information Security Measures, Cyber Security Strategy

business establishments. Depending on the situation,
relevant departments and divisions will work together todeal with the situation promptly and appropriately.

The NOK Group regards damage arising from the leak ofcustomer or personal information and increasingly
sophisticated cyberattacks as significant risks, and conducts
assessments of such risks in the Risk Management
Committee. Security risks identified by the committee arereported to the President and reviewed. In addition, having
established an NOK Group Information Security Policy, theCentral Information Security Committee and the information
security committees established within each division andGroup company systematically implement response
measures for their organizations.
In FY2022, our activities centered on strengthening
cyber security measures, such as shoring up vulnerability
countermeasures and deploying tools to detect suspicious
communications. Going forward, we will continue to
implement a PDCA cycle, striving to maintain and enhance
information security measures.
In addition, we will actively participate in joint measures
to strengthen information security measures for the entire
supply chain outside the Group as well, including those ofindustry groups.

Response to Disaster Risk
Central BCM Committee
Segment BCM Committee

Seal
Business

Electronic Products
Business

Governance​

Society

Other
Business

Sub-committee in Segment
Sub-committee by organization (by business division and location)
Sub-committee by function (cross-functional)* A sub-committee is established in each segment’s BCM Committee.

2. Planning and promoting business continuity plans (BCP)NOK will proceed with business continuity measures basedon the following basic policy:
1. Give top priority to ensuring safety, protecting people, andsaving people's lives.
2. As a member of the local community, actively cooperatewith the recovery of the whole region.
3. Minimize the impact on customers and stakeholders, andfulfill responsibilities as a business operator.

Protection of Intellectual Property
The NOK Group has summarized key points regarding
intellectual property-related laws in the Behavioral
Guidelines on Employee Compliance, and works to ensurethat all employees are aware of these points. In this way,
the Group seeks to apply for and obtain intellectual property
rights for our own inventions, as well as respects theintellectual property rights of other companies and strives toprevent infringements of others’ rights by researching andidentifying the patents belonging to other companies.
We have also set up an Anti-Counterfeit Committee toprotect NOK brands and are working to confront
counterfeiting overseas. In China, we are locating plants that
manufacture counterfeit products and removing pages
selling counterfeit products from online sales sites.

Each business site, including domestic and overseas
Group Companies, has a plan that outlines policies, systems,
and procedures to ensure that important business
operations are not interrupted or are restored as quickly as
possible if an unforeseen event should occur. At the sametime, the Company verifies the plan’s effectiveness throughtraining and responding to identified issues. It also continues
to implement measures to minimize damage, improve
emergency communication methods and reporting systems,
and reinforce the earthquake resistance of our IT
infrastructure. We are also working with suppliers tostrengthen the business continuity of our supply chain BCM.

Unit

Exposing counterfeit product manufacturing sites

cases

8

4

3

9

8

Deleting online sales sites

cases

629

830

664

5,093

5,284

Domestic

cases

1,316

1,355

1,267

1,265

1,202

Overseas

cases

1,195

1,250

1,433

1,729

1,728

Total

cases

2,511

2,605

2,700

2,994

2,930

Domestic

cases

1,868

1,882

1,768

1,770

1,666

Overseas

cases

2,001

1,901

2,112

2,674

2,683

Total

cases

3,869

3,783

3,880

4,444

4,349

Patents held (non-consolidated)

Patents held (NOK Group)51

FY 2018

FY 2019

NOK CORPORATION ESG Data Book 2023

FY 2020

FY 2021

FY 2022Item

Basic Information

Environment​

Society

Governance​GRI Standard Content Index
GRI Standard

Disclosure No.

Relevant sections

102
GRI 102:
1
102-1
102-2
102-3
102-4
102-5
102-6
102-7
102-8
102-9
102-10102-11

General Disclosures
General Disclosures 2016
Organizational profile
Name of the organization
Activities, brands, products, and services
Location of headquarters
Location of operations
Ownership and legal form
Markets served
Scale of the organization
Information on employees and other workers
Supply chain
Significant changes to the organization and its supply chain
Precautionary principle or approach102-12External initiatives

102-13

Membership of associations2
102-14102-15
3
102-16102-17

StrategyStatement from senior decision maker
Key impacts, risks, and opportunities
Ethics and integrity
Values, principles, standards, and norms of behavior
Mechanisms for advice and concerns about ethics

4
102-18Governance
Governance structure102-19102-20102-21

Delegating authority
Executive-level responsibility for economic, environmental, and social topics
Consulting stakeholders on economic, environmental, and social topics

102-22102-23102-24102-25102-26Composition of the highest governance body and its committees
Chair of the highest governance body
Nominating and selecting the highest governance body
Conflicts of interest
Role of highest governance body in setting purpose, values, and strategy

102-27102-28

Collective knowledge of highest governance body
Evaluating the highest governance body's performance102-29102-30102-31
102-32102-33102-34102-35102-36102-37102-38102-395
102-40102-41

Identifying and managing economic, environmental, and social impacts
Effectiveness of risk management processes
Review of economic, environmental, and social topics
Highest governance body's role in sustainability reporting
Communicating critical concerns
Nature and total number of critical concerns
Remuneration policies
Process for determining remuneration
Stakeholders' involvement in remuneration
Annual total compensation ratio
Percentage increase in annual total compensation ratio
Stakeholder engagement
List of stakeholder groups
Collective bargaining agreements

102-42102-43

Identifying and selecting stakeholders
Approach to stakeholder engagement102-44

Key topics and concerns raised

6
102-45102-46102-47102-48102-49102-50102-51
102-52102-53

Reporting practice
Entities included in the consolidated financial statements
Defining report content and topic boundaries
List of material topics
Restatements of information
Changes in reporting
Reporting period
Date of most recent report
Reporting cycle
Contact point for questions regarding the report52

Company Profile—
Company Profile—
Company Profile—
Company Profile
Labor Practices
Supply Chain Management—
Corporate GovernanceCompliance
Risk Management
Environmental Management
CDP (formerly Carbon Disclosure Project)
United Nations Global Compact
Keidanren Japan Climate Initiative
Keidanren Initiative for Biodiversity Conservation
Ministry of the Environment Cool Choice
Keidanren Challenge Zero
Task Force on Climate-related Financial Disclosures (TCFD)
Japan Auto Parts Industries Association
Japan Business Federation
—
—

Page

Basic Information—
Basic Information—
Basic Information—
Basic Information, P1
P25−P27
P33−P34—
P41−P44
P44−P47
P47−P51
P3−P6

P2, P5−P6———

NOK Charter of Corporate Behavior
Corporate GovernancePrevention of Bribery and Corruption
NOK Group Human Rights Policy, Review of Human Rights Compliance

P45
P41−P44
P46−P47
P22−P23

Sustainability Promotion Framework, GovernanceCorporate Governance
Sustainability Promotion Framework, Governance
Sustainability Promotion Framework, Governance
Establishment of Healthy Labor Management and Labor Relations
Based on Dialogue
Board of Directors and Skills Matrix—
Corporate Governance Framework
Prevention of Bribery and Corruption
Corporate Governance Framework, Sustainability Promotion
Framework, Governance
Board of Directors and Skills Matrix
Steps to enhance corporate governanceCorporate Governance Framework
Corporate Governance Framework
Risk Management
Sustainability Promotion Framework, Governance
Sustainability Promotion Framework, Governance
Review of Human Rights Compliance
Review of Human Rights Compliance
Remuneration of Directors and Auditors
Remuneration of Directors and Auditors
Remuneration of Directors and Auditors——

P2
P41−P44
P2
P2—
Establishment of Healthy Labor Management and Labor Relations
Based on Dialogue—
Establishment of Healthy Labor Management and Labor Relations
Based on Dialogue
Workplace communication
Establishment of Healthy Labor Management and Labor Relations
Based on Dialogue—
Content, Editorial Policy———
Content, Editorial Policy
Content, Editorial Policy
Content, Editorial Policy
Content, Editorial Policy

NOK CORPORATION ESG Data Book 2023

P25
P44
—
P41
P46
P41, P2
P44
P42
P2
P41
P47−P51
P2
P2
P23
P23
P42−P43
P42−P43
P43
—
—
—
P25
—
P25
P29
P25
—
Content, Editorial Policy———
Content, Editorial Policy
Content, Editorial Policy
Content, Editorial Policy
Content, Editorial Policy

Basic Information

GRI Standard
102-54102-55102-56
103
GRI 103:
103-1
103-2
103-3
200
GRI 201:
201-1
201-2
201-3
201-4
GRI 202:
202-1
202-2
GRI 203:
203-1
203-2
GRI 204:
204-1
GRI 205:
205-1
205-2
205-3
GRI 206:
206-1
GRI 207:
207-1
207-2
207-3
207-4
300
GRI 301:
301-1
301-2
301-3
GRI 302:
302-1
302-2
302-3
302-4
302-5
GRI 303:
303-1

Environment​

Disclosure No.

Relevant sections

Claims of reporting in accordance with the GRI Standards
Content, Editorial Policy
GRI content index—
External assurance—Management approach
Management Approach 2016
Explanation of material topics and scope—Management approach and its components—
Evaluation of the management approach—
EconomyEconomic Performance 2016
Direct economic value generated and distributed—
Financial implications and other risks and opportunities due to climate change Risks and Opportunities
Defined benefit plan obligations and other retirement plans—
Financial assistance received from government—
Market Presence 2016—
Ratios of standard entry level wage by gender compared to local minimum wage Labor Practices
Proportion of senior management hired from the local community
Labor Practices
Indirect Economic Impacts 2016
Infrastructure investments and services supported
Participation in Communities and Community Development
Significant indirect economic impacts
Participation in Communities and Community Development
Procurement Practices 2016
Proportion of spending on local suppliers
Breakdown of suppliers by region
Anti-Corruption 2016
Operations assessed for risks related to corruption
Prevention of Bribery and Corruption
Communication and training about anti-corruption policies and procedures
Prevention of Bribery and Corruption
Confirmed incidents of corruption and actions taken
Prevention of Bribery and Corruption
Anti-Competitive Behavior 2016
Legal actions for anti-competitive behavior, anti-trust, and monopoly practices CSR Procurement Guidelines
Tax 2019
Approach to tax—
Tax governance, control, and risk management—
Stakeholder engagement and management of concerns related to tax—
Country-by-country reporting—
Environment
Materials 2016
Materials used by weight or volume
Material Balance
Recycled input materials used
Resource Conservation and Waste Recycling
Reclaimed products and their packaging materials—
Energy 2016
Energy consumption within the organization
Material Balance
Energy consumption outside of the organization
Material Balance
Energy intensity
Environmental Performance Data
Reduction of energy consumption
TCFD Indicators and Targets, Climate Change Measures
Reductions in energy requirements of products and services
Climate Change Countermeasure
Water and Effluents 2018
Interactions with water as a shared resource
Working with Suppliers

303-2
303-3

Management of water discharge related impacts
Water withdrawal

303-4

Water discharge

303-5
GRI 304:
304-1

GRI 305:
305-1

Water consumption
Biodiversity 2016
Operational sites owned, leased, managed in, or adjacent to, protected areas andareas of high biodiversity value outside protected areas
Significant impacts of activities, products and services on biodiversity
Habitats protected or restored
IUCN Red List species and national conservation list species with habitats inareas affected by operations
Emissions 2016
Direct (Scope 1) GHG emissions

305-2
305-3

Energy indirect (Scope 2) GHG emissions
Other indirect (Scope 3) GHG emissions

305-4
305-5

GHG emissions intensity
Reduction of GHG emissions

305-6
305-7

Emissions of ozone-depleting substances (ODS)
Nitrogen oxides (NOx), sulfur oxides (SOx), and other significant air emissions

GRI 306:
306-1
306-2

Waste 2020
Waste generation and significant waste-related impacts
Management of significant waste-related impacts

306-3
306-4
306-5
GRI 307:
307-1
GRI 308:308-1

Waste generated
Waste diverted from disposal
Waste directed to disposal
Environmental Compliance 2016
Non-compliance with environmental laws and regulations
Supplier Environmental Assessment 2016
New suppliers that were screened using environmental criteria

304-2
304-3
304-4

Society

53

Conservation of Water Resources
Response to Water Risk
Response to Water Risk
Material Balance
Response to Water Risk
Material Balance
Environmental Performance Data
Conservation of Biodiversity
Biodiversity risk assessments
Concrete Actions for Conservation of Biodiversity—

Governance​

Page
Content, Editorial Policy
Main Content Index
—
—
—
—
—
P7−P8
—
—
—
P26
P26
P40
P40
P33
P46−P47
P46−P47
P46−P47
P34
—
—
—
—
P4
P11−P12—P4P4P18−P19
P8−P11
P9−P11P5
P12−P14
P13−P14
P13−P14P4
P13−P14
P4
P18
P17
P17
P17
—

Material Balance
Climate Change Countermeasure
Material BalanceMaterial Balance
Breakdown of Scope 3 Emissions in FY 2022
CO2 intensity of the NOK Group (overseas)
Climate Change Countermeasure——
Material BalanceManagement of Substances of Environmental Concern
Environmental Performance Data

P4
P9
P4
P4
P11
P10
P9
—
—
P4
P14
P19−P20

Material BalanceMaterial Balance
Resource Conservation and Waste Recycling
Standard of Environmental Impact Assessment for Design
Material Balance, NOK’s final amount disposed of in landfill andwaste recycling rate (domestic)

P4
P4
P11−P12P15
P4, P12Compliance with Environmental Laws and Regulations

P5

—

—

NOK CORPORATION ESG Data Book 2023

Basic Information

GRI Standard

Environment​

Disclosure No.
Negative environmental impacts in the supply chain and actions taken

400
GRI 401:
401-1
401-2

SocialEmployment 2016
New employee hires and employee turnover
Benefits provided to full-time employees that are not provided to temporary or
part-time employees
Parental leave
Labor-Management Relations 2016
Minimum notice periods regarding operational changes
Occupational Health and Safety 2018
Occupational health and safety management system
Hazard identification, risk assessment, and incident investigation

403-3
403-4
403-5
403-6
403-7
403-8
403-9
403-10
GRI 404:
404-1
404-2
404-3
GRI 405:
405-1
405-2
GRI 406:
406-1
GRI 407:407-1
GRI 408:
408-1
GRI 409:409-1
GRI 410:410-1
GRI 411:411-1
GRI 412:
412-1
412-2
412-3
GRI 413:
413-1
413-2
GRI 414:
414-1
414-2
GRI 415:415-1
GRI 416:
416-1
416-2
GRI 417:
417-1
417-2
417-3
GRI 418:
418-1
GRI 419:
419-1

Governance​

Relevant sections

308-2

401-3
GRI 402:402-1
GRI 403:
403-1
403-2

SocietyP5
P33

Labor Practices—

P26

Human Resource and Welfare System—
Occupational Health and Safety Promotion Framework
Occupational Health and Safety Promotion Framework
Health Maintenance and Promotion
Occupational Health and Safety Promotion Framework
Occupational Health and Safety Promotion Framework

Occupational health services
Worker participation, consultation, and communication on occupational healthand safety
Worker training on occupational health and safety
Occupational Health and Safety Promotion Framework
Promotion of worker health
Health Maintenance and Promotion
Prevention and mitigation of occupational health and safety impacts directly linked by—business relationships
Workers covered by an occupational health and safety management system
Occupational Health and Safety Promotion Framework
Work-related injuries
Lost-time injury frequency rate, Lost-time injury severity rateWork-related ill health—Training and Education 2016
Average hours of training per year per employee
Employee Education Program of NOK
Programs for upgrading employee skills and transition assistance programs
Employee Education Program of NOK
Percentage of employees receiving regular performance and career development reviews —Diversity and Equal Opportunity 2016
Diversity of governance bodies and employees
Labor Practices (Employee Data)
Diversity
Ratio of basic salary and remuneration of women to men
Labor Practices (Employee Data)
Non-Discrimination 2016
Incidents of discrimination and corrective actions taken—
Freedom of Association and Collective Bargaining 2016
Operations and suppliers in which the right to freedom of association and—collective bargaining may be at riskChild Labor 2016
Operations and suppliers at significant risk for incidents of child labor
Confirming Human Rights Compliance
Forced or Compulsory Labor 2016
Operations and suppliers at significant risk for incidents of forced orConfirming Human Rights Compliancecompulsory labor
Security Practices 2016
Security personnel trained in human rights policies or procedures—
Rights of Indigenous Peoples 2016
Incidents of violations involving rights of indigenous peoples—
Human Rights Assessment 2016
Operations that have been subject to human rights reviews or impact—
assessments
Employee training on human rights policies or procedures
Human Rights
Significant investment agreements and contracts that include human rights clauses or—that underwent human rights screening
Local Communities 2016
Operations with local community engagement, impact assessments, andContributions to Local Communities
development programs
Operations with significant actual and potential negative impacts on local communities—
Supplier Social Assessment 2016
New suppliers that were screened using social criteria—
Negative social impacts in the supply chain and actions taken
CSR Procurement Guidelines
Supply Chain Management
Public Policy 2016
Political contributions
NOK Charter of Corporate Behavior
Customer Health and Safety 2016
Assessment of the health and safety impacts of product and service categories Quality Assurance Framework
Quality Improvement Activities
List of quality management system certified companies
Incidents of non-compliance concerning the health and safety impacts ofField Quality Monitoring Activities
products and services
Marketing and Labeling 2016
Requirements for product and service information and labeling—
Incidents of non-compliance concerning product and service information—and labeling
Incidents of non-compliance concerning marketing communications—
Customer Privacy 2016
Substantiated complaints concerning breaches of customer privacy and losses Information Security Measures, Cyber Security Strategy
of customer data
Socioeconomic Compliance 2016
Non-compliance with laws and regulations in the social and economic area
Number of serious violations, amount of legal violation fines, otherviolations of the Charter of Conduct, number of anti-corruption
violations, amount of anti-corruption fines

54

Page

Working with Suppliers
Supply Chain Management

NOK CORPORATION ESG Data Book 2023—
P28−P29—P30
P30−P31
P32
P30−P31
P30−P31P31
P32—
P30−P31
P31
—
P24
P24
—
P25−P27
P27−P28
P27
—
—
P23
P23
—
—
—
P22
—
P40
—
—
P34
P33
P45
P36
P37−P38
P39
P37
—
—
—
P51

P47