Nippon Kayaku Group
Sustainable Procurement Guidebook
Ver. 4.0

February 2024
Nippon Kayaku Group1. Nippon Kayaku Group Policy ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・2
A. Nippon Kayaku Group's corporate policy・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・2
A-1. Nippon Kayaku Group Corporate Vision (KAYAKU spirit)・・・・・・・・・・・・・・・・・2
A-2. Nippon Kayaku Group Charter of Conduct and Code of Conduct ・・・・・・・・2
A-3. Nippon Kayaku Group Human Rights Policy・・・・・・・・・・・・・・・・・・・・・・・・・・・・・6
A-4. Nippon Kayaku Group Basic Policy on Anti-Bribery・・・・・・・・・・・・・・・・・・・・・10
A-5. The Declaration on Environment, Health and Safety, and Quality・・・・・・・13
B. Nippon Kayaku Group Procurement Policy・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・14
B-1. Basic Procurement Principles・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・14
B-2. Basic Procurement Policies・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・14
B-3. Policy on Responsible Mineral Procurement・・・・・・・・・・・・・・・・・・・・・・・・・・・15
2. Sustainable Procurement Guidelines ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・16
Section 1: Code of Conduct ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・16
1. Legal and Ethical Compliance・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・16
2. Human Rights and Labor・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・17
3. Health and Safety ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・19
4. Concern for the Environment・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・19
5. Product Quality and Safety・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・21
6. Information Security・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・21
7. BCP (Business Continuity Plan)・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22
8. Disclosure of Information・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22
9. Social Contribution・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22
Section 2: Establishing a Management System・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22
1. Establishing a Management System・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22
2. Supplier Management・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22
3. Establishing a Grievance Mechanism・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22
4. Disclosing the Activities ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・22<Reference> ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・23

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1. Nippon Kayaku Group Policy
A. Nippon Kayaku Group's corporate policy
A-1. Nippon Kayaku Group Corporate Vision (KAYAKU spirit)
Continuously providing society with the best products through ceaseless progress
and the combined forces of our consciences.

A-2. Nippon Kayaku Group Charter of Conduct and Code of Conduct
Nippon Kayaku Group Charter of Conduct
Business activities
1. The Nippon Kayaku Group will provide products and services that satisfy
customers through Communication with customers and the provision of appropriate
information, giving due consideration to the safety and reliability of its products andservices.
2. In all its business activities, the Nippon Kayaku Group will comply with all relevantlaws and regulations, including competition law, the spirit of these laws, and internal
regulations, and will engage in fair, transparent, and free competition. We will also
maintain sound relationships with the governing authorities in all regions.
3. The Nippon Kayaku Group respects human rights in all its business activities, andwill not discriminate or tolerate any inappropriately behavior for reasons based on
gender, age, nationality, race, religion, or disability.
4. The Nippon Kayaku Group will appropriately manage and utilize the companyʼsassets to improve the efficiency of its business activities and strive for continuous
development.
5. The Nippon Kayaku Group implements systematic crisis management in
preparation for the actions of anti-social forces that threaten the lives of citizens
and corporate activities, as well as for terrorism, cyber attacks, natural disasters,
and other events.
Relationship with society
6. The Nippon Kayaku Group respects the cultures, religions and traditions of eachcountry and region, works in harmony with society, and contributes to thedevelopment of society as a good corporate citizen.
7. The Nippon Kayaku Group will disclose information on its business activities tostakeholders in a timely and appropriate manner based on objective facts. We will2

also strive to increase corporate value through constructive dialogue withstakeholders.
8. In order to contribute to a sustainable society and the environment, the Nippon
Kayaku Group strives to conduct its business activities in harmony with the naturalenvironment by constantly taking into account the impact on the global environment,
not only complying with relevant laws and regulations, but also establishing its own
voluntary standards.
Information handling
9. The Nippon Kayaku Group will appropriately protect the information it possesses
through its business activities and take all possible measures for information
management. In addition, we recognize the value of information assets and respect
the intellectual property rights of others.
Relationships between the company and individuals
10. The Nippon Kayaku Group complies with labor-related laws and regulations,ensures a safe and comfortable working environment, and respects the basic humanrights, diversity, character, and individuality of individuals.
Roles of top management and thorough adherence to this charter
11. Those involved in the management of the Nippon Kayaku Group recognize thatrealizing the spirit of this charter is their own role and responsibility, and willthoroughly disseminate it to all employees. In addition, we will listen to the opinionsof people inside and outside the group, establish effective systems within the group,and ensure thorough implementation of corporate ethics. In the event of a situationthat contravenes the spirit of this charter, we will clarify both inside and outside thecompany our stance of solving the problem, investigate the cause, and work toprevent any recurrence.
Nippon Kayaku Group Code of Conduct
Chapter 1: Code of Conduct for business activities
1. Safety and quality of products
We are all responsible for producing quality products and striving for continuous
improvement to satisfy our customersʼ needs and scientific data.
2. Provision of product information
We will provide accurate and proactive information to ensure that our customers
3and business partners are able to use and handle our products properly.
3. Fair, impartial transactions
We will conduct fair and impartial transactions with all our customers and business
partners in accordance with the Competition Law and other relevant laws andregulations.
4. Prohibition of exchanging excessive gifts or entertainment
We will comply with all laws and regulations when exchanging gifts or entertainment
in connection with transactions, and will be prudent in light of sound businesspractices and social conventions. Build sound relationships with the government andprevent corrupt practices such as bribery.
5. Respect for human rights
We respect internationally recognized human rights and recognize and respect
diversity, including gender, age, nationality, race, religion, disability, ethnicity, skincoloring, culture, philosophy, beliefs, political views, and gender orientation.
6. Prohibition of conflicts of interest
We will not pursue personal interests and will not engage in activities that conflictwith the interests of the Company by utilizing our position in the job or informationacquired in the course of our business.
7. Appropriate protection and effective utilization of corporate assets
We will strive to enhance our corporate value by appropriately protecting andeffectively utilizing our corporate assets, including intellectual property.
8. Proactive efforts to improve operations
We are strongly responsible for our operations, constantly strive for selfimprovement and self-charge, and business to improve our operations.
9. Exclusion of anti-social forces
In the event that an anti-social force requests the provision of profits, we will takea firm stance in cooperation with relevant organizations and will not respond to
unfair demands.
10. Thorough crisis response
We are committed to safe operations. In the event of an accident, disaster, or
terrorist attack, or a cyber attack, we will promptly provide and report information
to relevant parties in accordance with established rules and take necessary
measures in accordance with the functioning of the response organization.
Chapter 2: Code of Conduct for relationship with society
11. Respect for cultures, religions, traditions, etc. in each country and region4

We will comply with the relevant laws and regulations of each country and regionin our business activities, and respect international norms, culture, religions,traditions, etc.
12. Good corporate citizenshipWe participate in and support volunteer and social welfare activities and make social
contributions through our business activities.
13. Interaction with local communities
As a member of local communities, we will actively participate in local organizations
and events and deepen exchanges with local people.
14. Timely and appropriate information disclosure
We actively disclose corporate information, such as management policies, financial
and non-financial data, to the stakeholders* in accordance with internal procedures.
15. Coexistence with the environment
In order to maintain a prosperous and healthy society in harmony with the naturalenvironment, we will assess the impact on the environment, actively implement
measures against climate change, including resource and energy conservation, andstrive for technological development.
16. Environmental protection initiatives
We will comply with all relevant laws, regulations, agreements, and internal
regulations at all stages of our business operations in order to protect theenvironment.
Chapter 3: Code of Conduct for information handling
17. Protection of corporate information
We will appropriately manage our tangible and intangible assets and protect thembased on Charter of Conduct. We will not disclose or use information beyond thescope required for business operations.
18. Protecting personal information
Recognizing the importance of personal information, we will acquire, use, andmanage personal information handled by the Company in an appropriate manner,complying with laws and regulations related to personal information as well as inhouse regulations.
19. Appropriate use of information systems
We will properly and effectively use corporate information equipment such as
personal computers, information systems, and network systems, and will not use
them for improper purposes.
520. Prohibition of insider trading
We will not use undisclosed information from the Nippon Kayaku Group or othercompanies to trade securities such as stocks.
21. Respect for the rights of others
We will respect the intellectual property rights of others. In addition, information
obtained through improper means will not be used.
Chapter 4: Code of Conduct for relationships between the company and individuals
22. Maintenance of working environment
We will comply with labor-related laws and regulations, labor safety and health laws,
labor agreements, and internal regulations, and ensure a safe, clean, bright, andenergetic working environment. We will also promote a work-life balance by creating
an environment where employees can perform their duties creatively and efficiently.
23. Prohibition of harassment
We will not engage in activities that hinder the realization of a healthy working
environment, such as sexual harassment and power harassment.

A-3. Nippon Kayaku Group Human Rights Policy
The Nippon Kayaku Group recognizes its responsibility to protect the human rights
of all people affected by its business activities.
To that end, the Nippon Kayaku Group hereby establishes the Nippon Kayaku Group
Human Rights Policy (the "Policy") based on the United Nations Guiding Principles
on Business and Human Rights, with the purpose of promoting initiatives to ensure
respect for human rights throughout the Group.
The Nippon Kayaku Group aims to meet the expectations of its stakeholders andcontribute to society through its business operations as part of its corporate vision,
the KAYAKU spirit. As a standard of conduct to realize the KAYAKU spirit, theNippon Kayaku Group has established the Nippon Kayaku Group Charter of Conduct
and Code of Conduct. In all of its corporate activities, the Group respects
fundamental human rights, complies with laws and regulations, engages in fairbusiness activities, and seeks to repay the trust placed in by its stakeholders byproviding happiness and delight.
1. Basic policy on human rights
This Policy is a promise that the Nippon Kayaku Group will respect human rights, in6order to earn the trust of all stakeholders based on its corporate vision:, the
KAYAKU spirit. The Nippon Kayaku Group supports and respects international
norms relating to human rights, including the United Nationsʼ International Bill of
Human Rights (made up of the Universal Declaration of Human Rights [UDHR], theInternational Covenant on Civil and Political Rights [ICCPR], and the International
Covenant on Economic, Social and Cultural Rights [ICESCR]), the United Nations
Declaration on the Rights of Indigenous Peoples, the OECD Guidelines forMultinational Enterprises, and the ILO Declaration on Fundamental Principles andRights at Work, as well as the Childrenʼs Rights and Business Principles developedby the United Nations Childrenʼs Fund (UNICEF), the United Nations Global Compact,
and Save the Children. As a signatory to the UN Global Compact, the Nippon Kayaku
Group also supports and respects the Ten Principles of the Compact.
2. Respect for human rights through business activities
2.1 Prohibition of discrimination and harassment
The Nippon Kayaku Group does not tolerate discrimination or harassment based on
gender, age, nationality, race, religion, disability, place of origin, ancestry, creed,political views, sexual orientation, marital status, employment status, or othercharacteristics.
2.2 Appropriate working hours
The Nippon Kayaku Group manages its employeesʼ working hours, days off, andleave entitlements appropriately and in accordance with applicable laws andregulations.
2.3 Fair and equitable remuneration
The Nippon Kayaku Group provides its employees with fair and equitableremuneration. It complies with applicable laws and regulations on minimum wages,
out-of-hours work, and statutory welfare and well-being programs and pays its
employees an amount higher than the minimum wage so that they are able tomaintain or exceed a certain standard of living.
2.4 Freedom of association and collective bargaining rights
Pursuant to laws, regulations, and labor practices of countries and regions where it
operates, the Nippon Kayaku Group respects its employeesʼ freedom of associationand the right to collective bargaining in their labor-management relations.
2.5 Prohibition of forced labor
The Nippon Kayaku Group does not tolerate forced labor. It also has no tolerance
for modern slavery in any form, including debt bondage or human trafficking.
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2.6 Prohibition of child labor
The Nippon Kayaku Group does not tolerate child labor and observes the statutory
minimum working age. It does not engage any person under the age of 18 years indangerous operations that may harm that personʼs health or safety, such as nightwork or out-of-hours work.
2.7 Occupational health and safety
In accordance with applicable laws and regulations, the Nippon Kayaku Groupestablishes a work environment where each and every employee can continue towork in good health and safety and without undue stress.
2.8 Impact on community residents
In order to avoid adverse effects on the safety or health of local community
residents, the Nippon Kayaku Group conducts human rights impact assessments(such as those relating to contamination and water stress) and takes necessary
measures in accordance with international norms to avoid risks and mitigate
impacts.
3. Scope of application
This Policy applies to all officers and employees of the Nippon Kayaku Group. The
Nippon Kayaku Group requires all business partners involved with its businessactivities, products and services to comply with this Policy.
4. Responsibility to respect human rights
The Nippon Kayaku Group recognizes that it cannot completely eliminate thepossibility of adverse impacts on human rights in its business activities. The Nippon
Kayaku Group will fulfill its responsibility to respect human rights and build a
responsible supply chain by not infringing on the human rights of those affected byits business activities and by taking appropriate measures to correct any adverse
impact on human rights in its business activities.
5. Human rights due diligence
The Nippon Kayaku Group will establish a system to ensure human rights due
diligence, identify adverse impacts of the Group on human rights in society, andstrive to prevent and mitigate such impacts.
6. Dialogue and consultation
The Nippon Kayaku Group recognizes that in order to appropriately address any
8impacts of its business activities on human rights, it is important to adopt theperspective of stakeholders whose human rights are, or are likely to be, affected byits business activities.
7. Education and training
The Nippon Kayaku Group will provide appropriate education and training to ensurethat this policy is incorporated and effectively implemented in all of its businessactivities.
8. Access to remedy
If it is found that the Nippon Kayaku Group's business activities have caused anadverse impact on human rights, or if involvement through business partners is
discovered or suspected, the Company will conduct an appropriate investigation and,if necessary, work to remedy the situation through dialogue based on international
standards and appropriate procedures.
9. Person responsible
The Nippon Kayaku Group shall clearly specify an officer in charge of theimplementation of this policy and supervise the state of its implementation.
10. Information disclosure
The Nippon Kayaku Group will disclose the progress and results of its efforts torespect human rights on its website, and by other means.
11. Applicable laws and regulations
The Nippon Kayaku Group will comply with the laws and regulations of each country
or region in which it conducts its business activities. In the event of any conflict
between the laws and regulations of individual countries and internationallyrecognized human rights, the Group will pursue ways to respect international
human rights policies to the fullest possible extent.
This policy is adopted by the Company's Board of Directors and signed by its
President and Representative Director.

9A-4. Nippon Kayaku Group Basic Policy on Anti-Bribery
Ⅰ．Preamble
Nippon Kayaku established the Nippon Kayaku Group Basic Policy on Anti-Bribery(hereinafter referred to as the Basic Policy) to clarify the basic concept, scope, andrules to be followed regarding the prevention of bribery, for declaration to both
inside and outside the company. This basic policy applies to all officers andemployees of the Nippon Kayaku Group (employees, junior employees, contract
employees, advisors, contract workers, part-time workers, etc.).
Ⅱ．Overview
The Nippon Kayaku Group established the Nippon Kayaku Group Charter of Conduct
and Code of Conduct to implement sustainable management that is integrated withmanagement strategy while maintaining a high level of ethical standards. This is
aimed at realizing the corporate vision KAYAKU spirit of "continuing to provide
society with the best products through constant progress and the combination of
conscience."
The Charter of Conduct and Code of Conduct stipulates that; we will "comply withcompetition laws and other relevant laws and regulations, as well as their spirit andinternal regulations, and engage in fair, transparent and free competition in all ourbusiness activities; that we will maintain sound relations with politics and thegovernment;" and that we will "comply with relevant laws and regulations in eachcountry and region, and respect international norms, cultures, religions andtraditions."
Furthermore, the Nippon Kayaku Group considers the establishment andstrengthening of anti-bribery systems both domestically and overseas to be an
important issue to be addressed by the Group as a whole as we continue to expand
our business globally year by year.
Ⅲ．Declaration
The Nippon Kayaku Group will comply with laws and regulations that prevent bribery
in each country and region in which the Nippon Kayaku Group operates, including
the Japan Anti-Unfair Competition Act, the U.S. International Anti-Corruption Act(Foreign Corrupt Practices Act:FCPA),the Bribery Act (Bribery Act:UKBA), and theChinese Commercial Bribery Regulation. In addition, we will not act in a way that
violates the Ethical Code for Public Employees of Japan, the Code of Ethics for
National Public Employees, the ethical rules stipulated by special public corporations,10local governments, etc., and the laws and regulations concerning the public
employees*1 , etc. of each country.
Ⅳ．Compliance items
1. Prohibition of Bribery of Public Officials, etc.
The Nippon Kayaku Group will not provide, offer or promise any illegal
entertainment, gifts, benefits or other economic benefits*2, whether directly or
indirectly, to domestic and overseas public employees or persons in similar positions("public employees, etc.") with the aim of influencing their conduct of duties..
In the event public officials, etc. request the provision of illegal entertainment, gifts,
benefits, or other economic benefits domestically or overseas, the Company shallrefuse such request and notify the relevant organizations as appropriate.
2. Payment to intermediaries
Payment shall not be made if the Nippon Kayaku Group becomes aware thatpayments

tocontractors,

agents,consultants,

wholesalers,

and

other

intermediaries to wholesalers to whom the businesses are outsourced, and a portion
thereof, are diverted to improper approaches to public officials, etc., or that there
is a possibility thereof.
3. Entertainment and gifts to business partners other than public officials, etc.
In compliance with national laws, industry codes and internal regulations, we will
not provide entertainment, gifts, or other economic benefits that exceed areasonable range of social conventions to our domestic and overseas business
partners, including their officers and employees.
4. Entertainment and gift-giving
We do not receive excessive entertainment from business partners or gifts of moneythat exceed the scope of social convensions.
5. Donation activity
Donations, such as grants and political contributions, will not be made for the
purpose of fraudulently obtaining or securing business benefits.
6. Control of Records
We will prepare and maintain accounting records of all transactions and dispositionsof assets, as appropriate and accurately as possible, to demonstrate that bribery
has not occurred.
Requests to Business Partners
This basic policy summarizes the Nippon Kayaku Group's approach to anti-bribery,
11and we believe that the understanding and cooperation of our business partners isessential to the implementation of this basic policy. The Nippon Kayaku Group
requests to conclude a contract that includes provisions to understand this Basic
Policy and to comply with relevant laws and regulations, including the prevention ofbribery, at the time of new use or renewal of the contract with intermediate
manufacturers such as contractors, agents, consultants and wholesalers who may
come into contact with public officials. If you encounter or suspect any violations tothis basic policy or related laws or regulations, please notify your contact person at
the Nippon Kayaku Group.
We also request that you cooperate in investigations by Nippon Kayaku Group
companies or relevant authorities regarding alleged violations or violations.
＊ 1 "Public officers, etc." refers to those who are in charge of legislative,administrative, judicial, and other public affairs in each country or region,
candidates for such services, officials of government agencies, employees ofcompanies and other organizations owned and operated by the government,
officers and employees of political parties, and officers and employees of public
international organizations composed of countries, regions, and their governments.
＊ 2 "Gifts, benefits, and other economic benefits" include all items that areequivalent to cash, such as gifts, services, employment, loans, travel expenses, foodand beverage, invitations (sports tours, theatrical tours), donations, daily grants,
and rewards, all of which are in profit, whether in their nominal terms. Provided,
however, that this shall not apply to acts where the scope of the Anti-Corruption
and Anti-Bribery Laws and Regulations applicable to each country or region ismoderate in light of lawful and sound business practices and socially accepted norms.

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A-5. The Declaration on Environment, Health and Safety, and Quality
The Nippon Kayaku Group, under its corporate motto of “KAYAKU spirit”, whichcalls for continuously providing society with the best products through ceaselessprogress and the combined forces of our consciences, we will contribute to therealization of a sustainable society that safeguards the life and health of consumers,
and supports a comfortable life.
Fundamental Policies
1. We will strive to maintain and improve the environment, peopleʼs health andsafety across the entire product lifecycle, from R&D to production, distribution,
sales, recycling, and disposal.
2. We will strive to prevent pollution, protect biodiversity, and conserve theenvironment by promoting reduction and proper disposal of waste, reduction of
resource consumption (of energy, water, and raw materials), and Climate change
measures (toward reduction of greenhouse gas emissions).
3. We will actively provide business partners with information needed for the safe
usage and handling of our products and for conserving the environment.
4. We will enhance the quality of not only products, but operating processes as well,and also work to enhance customer satisfaction.
5. We will heighten employee knowledge and skills through education and training
and achieve our goal of zero pollution, zero injuries, zero accidents and enhanced
quality.
6. We will disclose information so that stakeholders correctly understand ourbusiness activities and also strive to engage in dialogue with local communities andgovernment authorities.

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B. Nippon Kayaku Group Procurement Policy
B-1. Basic Procurement Principles
In order to realize the KAYAKU spirit, Nippon Kayaku Group will pursue mutual andsustainable growth with suppliers based on the understanding they are importantbusiness partners who help us produce products of the best quality. We will strive
to conduct procurement transactions that are fair, honest, impartial, and inaccordance with relevant laws, social norms, and our Basic Procurement Policies.

B-2. Basic Procurement Policies
At Nippon Kayaku Group, all procurement operations will be carried out inaccordance with the Basic Procurement Policies as set out below.
Compliance with Relevant Laws, Social Norms, and the Nippon Kayaku Group
Charter of Conduct
1. We will comply with all relevant laws and regulations when conducting
procurement operations.
2. We will judge the propriety of procurement activities based on Nippon Kayaku
Group Charter of Conduct and the Nippon Kayaku Group Code of Conduct.
Open-door Policy, Fairness, Impartiality, and Transparency in Business Transactions
3. We will conduct procurement-related business transactions in a fair, impartial,
and transparent manner, and follow an open-door policy with respect to businesses
at home and abroad.
4. In order to ensure transparency in all our procurement activities, we will
undertake due procedures based on written documentation or electronic purchasingsystems in accordance with the procurement operations standards.
Partnerships with our business partners
5. We will build partnerships with suppliers based on mutual understanding andtrust, and pursue mutual sustainable growth.
Protection of Information
6. We will protect supplier-related information obtained in the course of ouroperations, and strive to prevent any information leakage.

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Concern for the Environment
7. We will promote the procurement of eco-friendly goods and materials.
Basic Criteria for Selecting Suppliers
8. When selecting goods and materials, we will give due consideration to economic
factors such as quality, price, and date of delivery. We will also consider other factors
such as the supplierʼs operating foundations, technological competitiveness, andstability of supply.
9. When selecting suppliers, we will give due consideration to their commitment torealization of a sustainable society, including their observance of relevant laws andregulations, respect for human rights, concern for the working environment,
disaster preparedness and safety measures, efforts toward environmental
conservation, and other efforts designed to fulfill their Sustainable.
10. In addition to the above, we will give due consideration to whether or not thepotential supplier has a risk management system such as BCP (Business ContinuityPlan).

B-3. Policy on Responsible Mineral Procurement
There is a concern that profits from the mining and trade of gold, tin, tantalum,
tungsten, and cobalt, natural mica (hereinafter, the “minerals”) in CAHRAs*(hereinafter, the “target areas”) provide a major source of funding fororganizations involved in armed conflict, human rights violations includingchild labor and forced labor, environmental destruction, corruption, etc.
In light of this concern, we take measures to avoid the use of minerals from thetarget areas (hereinafter, “conflict minerals”) and any raw materials that containconflict minerals so as to avoid providing support for armed conflicts and/or
inhumane activities. In the event that any use by us of conflict minerals is identified,we will take corrective measures without delay. We ask our suppliers to abide by
our policy and cooperate with us by avoiding the use of conflict minerals in raw
materials used for our products.
* CAHRAs (Conflict-Affected and High-Risk Areas) stipulated by the EU Conflict
Minerals Regulation
See the list: https://www.cahraslist.net/cahras

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2. Sustainable Procurement Guidelines
This guideline is defined as a matter that the Nippon Kayaku Group and its suppliers
should work on in order to fulfill their social responsibilities as members of society
and to practice responsible corporate behavior. We hope that our suppliers will
understand this guideline, promote Sustainable activities throughout the supply
chain, including expanding to your suppliers, and aim to realize a sustainable society.
We kindly ask you to proceed with the efforts in line with this guideline.
Section 1: Code of Conduct
1. Legal and Ethical Compliance
1.1 Prohibition of Restrictive Trade Practices and Unfair Competition
Companies are requested to refrain from practices that restrict fair, transparent,
and free competition.
1.2 Prohibition of Abuse of Superior Bargaining Position
Companies are requested to refrain from practices that create disadvantage for theirown suppliers (sub-suppliers, from Nippon Kayaku's perspective) by abusing theirsuperior bargaining position.
1.3 Preventing Corruption
Companies must not be involved in bribery, corruption, blackmail, or embezzlement
in any form.
1.4 Prohibition of the Giving or Receiving of Improper Advantage
Companies are requested to refrain from giving to or receiving from theirstakeholders any improper advantage.
1.5 Respect for Intellectual Property
Companies are requested to refrain from infringing upon intellectual property rights.
1.6 Prevention and Early Detection of Improper Practices
Companies are requested to conduct activities designed to prevent improper
practices and to establish an early detection system.
1.7 Prevention of Leakage of Personal Information
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Companies must comply with relevant laws and regulations and appropriately
manage and protect all personal information of suppliers, customers, consumers,
and employees.
1.8 Proper Import/Export Control
Companies must maintain a clear management system and conduct appropriate
procedures for the import and export of technologies and goods regulated by law.
1.9 Prevention of Leakage of Information about Clients and Third Parties
Companies are requested to appropriately manage and protect confidential
information regarding clients and third parties.
1.10 Responsible Minerals Procurement
Companies must not use minerals in their products that can cause social problems
such as human rights and the environment.
1.11 Animal Welfare
Companies are requested to consider animal welfare and to treat experimental
animals appropriately so as to minimize their pain and stress. Companies are also
expected to abide by the 3Rs (replacement, reduction, and refinement) to ensurethat animal experiments are conducted properly and in consideration of animal
protection.
2. Human Rights and Labor
2.1 Prohibition of Inhumane Treatment
Companies are requested to respect the human rights of employees and to prohibit
abuse, harassment, and any other cruel and inhumane treatment. Companies mustalso provide workers with individually secured accommodations for storing theirpersonal and valuable items, and a reasonable personal space along with reasonableentry and exit privilege.
2.2 Prohibition of Discrimination
Companies must not engage in discrimination or harassment. Companies must also
consider requests from workers regarding religious practices where appropriate.

172.3 Working Hours
Companies are requested to manage employee working hours, days off, and leaveappropriately and to prohibit excessive overtime work. Companies are also expected
to strive to reduce long working hours.
2.4 Respecting Employeesʼ Right to Organize
Companies are requested to respect employeesʼ right to freedom of association andcollective bargaining so as to enable negotiations between labor and management
over the working environment, wage standards, etc.
2.5 Prohibition of Forced Labor
Companies are requested to employ all employees of their own free will with noemployee being subject to forced labor.
2.6 Prohibition of Child Labor
Companies must not allow children who are under the minimum age for
employment.
Furthermore, companies must not allow persons under the age of 18 to performhazardous work that is likely to jeopardize their health or safety, including night
shift and overtime work.
2.7 Occupational Accidents and Disease resulting from Employment
Companies are requested to understand the situation concerning occupational
accidents and disease resulting from employment, and to establish appropriate
measures.
2.8 Giving Due Consideration to Physically Demanding Work
Companies are requested to specify physically demanding work and to appropriately
manage workload to prevent accidents or disease.
2.9 Appropriate Wages
Companies are requested to provide employeeswith fair and equitablecompensation that exceeds the minimum wage and to abide by all applicable wagerelated legislation, including laws on minimum wages, overtime, and legally
mandated welfare measures.

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3. Health and Safety
3.1 Emergency Measures
In order to protect the welfare of employees, suppliers are requested to prepare
emergency measures as a precaution against possible disasters or accidents, andto ensure that they are fully understood throughout the workplace.
3.2 Health and Safety in Facilities
Companies are requested to appropriately safeguard health and safety in facilities
provided to employees (company housing, cafeterias, and restrooms, etc.).
3.3 Safety Measures for Machinery and Equipment
Companies are requested to establish appropriate safety measures with respect tomachinery and equipment used by employees.
3.4 Safety in the Workplace
Companies are requested to assess safety risks in the workplace and to use
appropriate designs, techniques, and control measures to secure safety. Taking
reasonable steps must also be taken to protect pregnant women and nursing
mothers.
3.5 Hygiene in the Workplace
Companies are requested to identify situations in which employees are exposed toharmful substances, noises, or odors, and to establish appropriate measures.
3.6 Employee Health Management
Companies are requested to carry out appropriate health management with respect
to all employees.
3.7 Health and Safety Communication
Companies must provide training on appropriate health and safety information
regarding various workplace hazards that workers are exposed to in the workplacein languages and methods that the workers can understand. A system that enables
workers to provide feedback on safety is also required.
4. Concern for the Environment
4.1 Environmental Management System
19Companies are requested to establish and run an Environmental Management
System.
4.2 Chemical Substance Management
Companies must comply with laws and regulations to identify, label, and manage
chemical and other substances posing hazard to humans or the environment, andconduct management to ensure safe handling, transport, storage, use, recycling,reuse, or disposal of such substances.
4.3 Environmental/Government Permits
Companies are requested to obtain permits from governmental bodies in cases
where they are required by local laws, and to submit the necessary reports to suchbodies.
4.4 Minimization of Impact on Environment (drainage, sludge, emissions)Companies are requested to comply with laws and regulations on drainage, sludge,
and emissions in the country concerned, and to make further improvements tovoluntary standards as necessary.
4.5 Sustainable and Efficient Utilization of Water, Raw Materials, etc. and Waste
Management
Companies must comply with relevant laws and regulations and ensure appropriate
management of resources and materials, including reduction and reuse of water,
raw materials, etc. used during manufacturing and promotion of utilization ofrecycled resources and recycled parts in order to promote the 3Rs (reduce, reuse,
and recycle), ensure sustainable and efficient utilization of water, raw materials, etc.,
and minimize waste.
4.6 Biodiversity Conservation
Companies are requested to conserve biodiversity.
Possible approaches to biodiversity conservation activities include: (1) grasping therelationships between business activities and biodiversity to promote biodiversity
conservation activities, (2) promoting conservation of habitats of living organisms,(3) working together with stakeholders, and (4) preventing climate change andusing resources effectively.
Companies are also requested to incorporate biodiversity initiatives into their20

environmental management systems, such as ISO 14001, for ongoing improvement(PDCA cycles).
4.7 Disclosing Environmental Activities
Companies are requested to disclose the outcomes of environmental activities asnecessary.
4.8 Reducing Energy Consumption and Greenhouse Gas Emissions
Companies must address energy efficiency and make continuous efforts for
reducing greenhouse gas emissions and energy consumption.
5. Product Quality and Safety
5.1 Securing Product Safety
When responsible for product design, suppliers are requested to ensure that the
products satisfy safety standards in the countries concerned.
5.2 Quality Management System
Companies are requested to establish and run a quality management system. And
must comply with their own quality standards and customer requirements inaddition to all laws and regulations applicable to the quality of products and services.
5.3 Control of Chemical Substances Contained in Products
With respect to all of their products, suppliers are requested to control chemical
substances specified in the laws of countries where the products concerned are
manufactured, imported to, or used in.
5.4 Provision of Accurate Information on Products and Services
Companies are requested to provide consumers and clients with accurate
information about their products and services.
6. Information Security
6.1 Protection from Threats to Computer Networks
Companies are requested to establish protective measures against threats tocomputer networks to prevent any harm arising in their company or othercompanies.

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7. BCP (Business Continuity Plan)
7.1 Disaster-Preparedness Measures
Companies are requested to prepare a BCP manual.
8. Disclosure of Information
8.1 Disclosure of Information to Stakeholders
Companies are requested to proactively disclose information to stakeholders
irrespective of whether or not such disclosure is mandated by law.
9. Social Contribution
9.1 Contribution to the Community
Companies are requested to voluntarily carry out activities designed to contributeto the development of the local and global community.

Section 2: Establishing a Management System
1. Establishing a Management System
Companies must establish a management system in order to comply with the codeof conduct.
2. Supplier Management
Companies must establish a process for communicating the requirements of thecode of conduct to suppliers and monitoring supplier compliance.
3. Establishing a Grievance Mechanism
Companies must establish a grievance mechanism that can be used by stakeholders
including workers and suppliers in order to prevent illicit behavior in their inside as
well as throughout the supply chain.
4. Disclosing the Activities
Companies must disclose information regarding their actions according to theseguidelines and relevant laws and regulations.

22＜reference＞
・Responsible Business Conduct Guidelines Ver1.0 (March 2020)(Japan Electronics and Information Technology Industries Association)・Responsible Business Alliance Code of Conduct Ver.7.0(2021)

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