Niterra GroupCSR and Sustainability
Procurement Guidelines

Niterra Co.,Ltd.
July 2023

Contents
Introduction······································································································1
Procurement Policy····························································································2Notes··············································································································3
CSR and Sustainability Procurement Guidelines······················································4
Ι Environment ·································································································4(I-1) Respond to climate change(I-2) Make sustainable and efficient use of resources (water and raw materials)(I-3) Promote environmental protection activities(I-4) Control hazardous chemicals(I-5) Obtain environmental permits and submit reports(I-6) Effectively implement an environmental management system(I-7) Conserve biodiversity and ecosystems
II Human Rights and Labor ···············································································6(II-1) Establish a system for respect for human rights(II-2) Prohibit forced labor(II-3) Prohibit inhumane treatment and infringements of human rights(II-4) Prohibit child labor(II-5) Prohibit discrimination(II-6) Ensure fair working conditions and equal opportunities(II-7) Ensure freedom of association and collective bargaining(II-8) Promote responsible procurement of resources and raw materials(II-9) Respect privacy(II-10) Promote engagement with local communities(II-11) Respect the rights of indigenous peoples(II-12) Others
III Business Continuity Plan (BCP)·······································································9(III-1) Formulate a BCP
IV Business Ethics····························································································9(IV-1) Conduct fair, transparent, free and proper business(IV-2) Prohibit abuse of power, and offering and acceptance of bribes(IV-3) Protect and respect intellectual property(IV-4) Use appropriate export procedures(IV-5) Disclose company information appropriately(IV-6) Prevent and promptly rectify inappropriate behavior(IV-7) Confront antisocial forces

V Information Security·····················································································11(V-1) Secure computer networks against threats(V-2) Prevent the leakage of confidential information of customers, personnel andthird parties(V-3) Prevent accidental leakage and take appropriate countermeasures ifleakage occurs
VI Occupational Health and Safety ·····································································12(VI-1) Take safety measures with equipment and instruments(VI-2) Promote safe activities in the workplace(VI-3) Promote hygiene in the workplace(VI-4) Take appropriate measures against occupational injuries and illnesses(VI-5) Properly manage disasters and accidents(VI-6) Manage physically demanding work
(VI-7) Promote safety and hygiene at all company facilities(VI-8) Promote health maintenance programs for employees
VII Product Quality and Safety ···········································································13(VII-1) Supply stable quality products and services

Introduction
In recent years, disasters caused by climate change have occurred more frequently
around the world, affecting the economic activities of companies. Under such circumstances,climate change has been regarded as an important issue. In addition, “business and humanrights” has emerged as another important issue to be addressed. Companies are required
to demonstrate and confirm that their activities respect the human rights of people involvedin their business and to prevent and mitigate negative impacts. Furthermore, “biodiversity”
is also attracting attention.
We, the Niterra Group, aim to solve these social issues through our business. We believethat doing so contributes to the realization of a sustainable society, and we thereby aspire
to contribute to making the earth on which we live sustainable. We will work to realize theseaspirations in cooperation with our suppliers, who are good partners for the Niterra Groupand with whom we enhance mutual trust and strive to realize mutual development.
We have revised our "CSR and Sustainable Procurement Guidelines." In addition to newly
adding items that society now requires us to address, we have clearly and specificallyindicated whether each item is required or recommended.
Please read these Guidelines and agree to abide by them. And let’s put them into practice
together. We also ask our suppliers to disseminate these Guidelines to their suppliers andencourage their implementation to ensure that our commitment to CSR and sustainability
permeates and is practiced throughout the supply chain.

Global Strategy Division Sustainability Strategy Dept.
Global Procurement Company
Niterra Co., Ltd.

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Procurement Policy
The Group's procurement policy is part of the Nittoku Way philosophy system, and is one of the
12 CSR Basic Policies established based on the Corporate Philosophy, the CSR and
Sustainability Charter, and the Corporate Code of Conduct. This guideline is based on the
procurement policy and is created in accordance with the CSR Basic policy.

Procurement Policy
We aim to realize globally optimal procurement based on our quality products principle.
To this end, we focus on strengthening cooperation with suppliers and promoting our
CSR and sustainability efforts throughout our supply chain system, while at the sametime striving to carry out proper purchasing transactions when procuring materials andparts, based on the following guidelines[Action Guidelines]●We conduct rational transactions based on fair, transparent, and open competition.
●We comply with procurement-related laws and regulations and foster responsible
procurement. We select suppliers based on comprehensive assessment of productquality, technology, prices, deliveries, CSR and sustainability initiatives, and efforts tocontinuously make improvements.
●Aiming to procure more eco-friendly products, we strive to promote our green suppliersystem.
●We enhance mutual trust with our suppliers, who are good partners for us, and strive
to realize mutual development.

* Please see our website regarding our Nittoku Way and CSR Basic Policy of Niterra Group.
Nittoku Way
https://www.ngkntk.co.jp/english/corporate/philosophy/nittokuway.html
CSR Basic Policy
https://ngkntk.disclosure.site/sustainability/pdf/CSR_Basic_Policy_en.pdf2Notes<Premises>(1) Compliance with laws and regulations
We are required to comply with laws and regulations and respect social conventions. We
ask that you thoroughly comply with the items described in these Guidelines.
(2) Thorough dissemination of the Guidelines to the supply chain
We ask our suppliers to disseminate these Guidelines to their suppliers, contractors andother supply chain partners and encourage them to act in accordance with them.
(3) Checking of compliance status
We may conduct a survey using a check sheet to identify the compliance status of these
Guidelines. The purpose of this survey is not only to identify potential risk areas but also toenhance the sustainability of the entire supply chain through continuous dialogue andcollaboration.

<Meanings of Required and Recommended>
Each item is marked [Required] or [Recommended].
[Required] are items that are essential for the Niterra Group and its supply chain to becomesustainable. We would like to encourage suppliers who have not yet worked on them toprepare to start activities. If there is anything we can do to assist you in this process, wewill be happy to support you.
[Recommended] is not a [Required] item at this time, but may be changed to [Required]in the future. Please be aware that Recommended are items on which society may expect
or demand us to take action in the future.

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CSR and Sustainability Procurement Guidelines

I Environment~ The Niterra Group continues to carry out business activities that are friendly to the global
environment by proactively working to address climate change and conserve biodiversity. ~(I-1) Respond to climate change
Suppliers should aim to achieve carbon neutrality (zero CO2 emissions) by 2050. And, theyshould set targets and take measures to reduce emissions of greenhouse gases, such as carbon
dioxide, methane, and fluorocarbons.
[Required]・Aim to achieve carbon neutrality by 2050.
・Set CO2 emission reduction targets (at least 2.5%/year compared to FY2021).
・Take measures to achieve the set CO2 emission reduction targets.
[Recommended]・Set emission reduction targets for greenhouse gases, such as methane and fluorocarbons.
・Take measures to achieve the set emission reduction targets for methane, fluorocarbons,etc.

(I-2) Make sustainable and efficient use of resources (water and raw materials)
Suppliers are required to set targets for resource use reduction and make continuous efforts to
reduce resource consumption and promote reuse and recycling of resources.
[Required]・Set targets for water use reduction to conserve water resources.
・Take measures to achieve water use reduction targets.
[Recommended]
・Take measures to reduce consumption of resources such as raw materials.

(I-3) Promote environmental protection activities
In addition to making continuous efforts to reduce waste, suppliers must comply with regulatory
standards for wastewater, exhaust gas, noise, and vibration emissions to the external
environment.
[Required]・Set targets to continuously reduce waste.
・Take measures to reduce waste.

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(I-4) Control hazardous chemicals
Suppliers are required to identify and manage chemical substances contained in products
handled by them, as specified in applicable laws and regulations. They must also identify
chemical substances used in production, inspection and maintenance processes and work to
reduce their release into the external environment.
[Required]・Identify chemical substances used in production, inspection and maintenance processes.
・Take measures to reduce emissions of the above-mentioned chemical substances into theexternal environment.

(I-5) Obtain environmental permits and submit reports
Suppliers are required to appoint managers as needed and obtain permits and approval fromand report to the government, in accordance with the applicable environmental laws andregulations.
[Required]・When government permits are required depending on the business content and location of
the plant, seek prior consultation, etc. to ensure timely obtainment of permits.

(I-6) Effectively implement an environmental management system
Suppliers must build an environmental management system that enables them to effectively
implement and manage environmental protection activities.
[Required]・Establish an environmental management system (ISO or equivalent; e.g. Eco Action 21)
and obtain third-party certification.

(I-7) Conserve biodiversity and ecosystems
Suppliers must implement environmental activities to reduce environmental impact in all theirbusiness activities, based on the understanding that biodiversity and ecosystem conservation
are crucial for a sustainable society and that the use of energy and resources, emissions ofenvironmentally hazardous substances, etc. have an impact on biodiversity.
[Recommended]
・Understand that the conservation of biodiversity and ecosystems is essential for asustainable society. (Examples: attending video training sessions provided by our company,
holding in-house study sessions, obtaining certification)
・Energy and resource use, emissions of environmentally hazardous substances, etc. havean impact on biodiversity. (Examples: attending video training sessions provided by ourcompany, holding in-house study sessions, obtaining certification)
・Examine the impact of the business on the ecosystem and conduct biodiversity
conservation activities.

5II Human Rights and Labor~ The Niterra Group respects human rights of all people who are affected by its businessactivities. ~(II-1) Establish a system for respect for human rights
Suppliers are required to establish a system for conducting activities related to business andhuman rights.
[Required]・Establish a human rights policy, etc., and clearly indicate and share the policy and approach
regarding respect for human rights with workers and all other parties concerned.
・Provide training and educational opportunities for workers to better understand humanrights issues and international trends related to respect for human rights.
・Regularly check whether there are any problems that violate human rights.

(II-2) Prohibit forced labor
Suppliers must not use forced labor or engage in human trafficking and must employ all workersof their own free will.
[Required]・Guarantee the right of workers to freely terminate their employment.
・Do not require workers to hand over government-issued identification, passports or work
permits.
・Do not force workers to work hours that have not been agreed upon in advance.
・Comply with all applicable local laws and regulations and relevant ILO conventions, and do
not require workers to pay recruitment fees, or other related fees or costs.
・Conclude an employment contract in the worker’s native or best-understood language sothat the worker can understand the contract in detail.

(II-3) Prohibit inhumane treatment and infringements of human rights
Suppliers must not engage in any inhumane treatment, such as abuse, corporal punishment,
sexual harassment, and power harassment, and must respect the human rights of workers.
[Required]・When an inhumane act is committed, aid the victims and deal with the case appropriately.
・Identify risks toward the elimination of inhumane treatment.

(II-4) Prohibit child labor
Suppliers must respect the rights of children and must not employ children under the minimum
employment age stipulated by the laws and regulations of the relevant country or region.
Suppliers also must not allow young workers under the age of 18 to perform dangerous workthat can harm their development.

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[Required]・Confirm age at the time of hiring.
・Establish rules regarding workers under the age of 18.

(II-5) Prohibit discrimination
Suppliers must not engage in any form of discrimination on the basis of race, color, age, gender,
sexual orientation, gender identity, ethnicity, nationality, disability, pregnancy, religion, union
membership, protected genetic information, or marital status.
[Required]・Do not engage in any form of discrimination on the basis of gender or any other ground withregard to all aspects of employment, including hiring, promotion and compensation.
・Create a system and an environment that facilitates the taking of childcare leave regardlessof gender.

(II-6) Ensure fair working conditions and equal opportunities
Suppliers must, in compliance with all applicable local laws and regulations, provide workers
with working conditions for a better quality of life, must pay fair wages that meet or exceed legal
minimum requirements, and must not unreasonably reduce wages. Suppliers must also promoteequal opportunity and equality in recruitment, promotion, and compensation.
[Required]・Properly inform workers about salary (overtime wages, bonuses, deductions, etc.), paid
leave, legal benefits, etc. by means of pay stubs or similar documentation.

(II-7) Ensure freedom of association and collective bargaining
Suppliers must respect freedom of association and the right to collective bargaining inaccordance with the laws and regulations of the relevant country and region.
[Required]・Create an environment and mechanism to ensure that collective bargaining between laborand management is carried out voluntarily and in good faith.

(II-8) Promote responsible procurement of resources and raw materials
Suppliers are requested to conduct their procurement activities in consideration of the impact
on local communities caused by the use of resources or materials (e.g., conflict minerals fromthe Congo, etc.) if that use creates social issues because of human trafficking, slavery, forcedlabor, child labor, torture, war crimes or other inhumane acts, and must take appropriate steps
to discontinue procurement of these materials if the possibility thereof exists.
[Required]・Check whether miners and refiners of tantalum, tin, tungsten, gold, cobalt and micacontained in the manufactured products cause or are involved in serious human rights
violations, environmental destruction, corruption, conflict, etc.in conflict regions and highrisk areas.

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[Recommended]
・Check whether miners and refiners of tantalum, tin, tungsten, gold, cobalt and mica used in
the manufacturing process (equipment and manufacturing methods) cause or are involved
in serious human rights violations, environmental destruction, corruption, conflict, etc. in
conflict regions and high-risk areas.

(II-9) Respect privacy
Suppliers must respect and not infringe upon the privacy of individuals.
[Required]・Appropriately manage personal information of customers, third parties, and workers.

(II-10) Promote engagement with local communities
To prevent negative impacts on the safety and health of local communities, suppliers must
prevent environmental destruction and pollution and conduct their business activities inconsideration of the rights of local residents.
[Required]・Ensure to be able to engage in communication with local communities (e.g.: having contact
information of community representatives)(II-11) Respect the rights of indigenous peoples
In business activities in areas where indigenous people reside, suppliers must recognize thatindigenous peoples have their own unique culture and history and must respect the rights ofindigenous people as stipulated in international agreements.
[Required]・Check whether or not indigenous people live in the area where the business is to be
conducted.

(II-12) Others[Required]・Provide training and education on occupational health and safety for foreign workers inJapan, including foreign technical interns and specified skilled workers, in languages thatthey can fully understand (such as their native language).

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III Business Continuity Plan (BCP)~ The Niterra Group has made preparations and formulated countermeasures in advance toensure stable supply of products and services in the event of a disastrous incident. ~(III-1) Formulate a BCP
Suppliers are expected to formulate a BCP in preparation for a situation in which a stable supplyof products or services may be inhibited by a natural disaster (e.g., an earthquake, windstorm,
flood), the spread of an infectious disease, or other serious incidents, and to keep it available
for smooth utilization.
[Required]・Formulate a BCP in preparation for crisis events, such as natural disasters, infectious
diseases and accidents.
・Conduct periodic drills based on the formulated BCP, and also update the contents of the
BCP.

IV Business Ethics~ The Niterra Group observes laws and regulations, and acts in a socially acceptable way to
conduct business appropriately. ~(IV-1) Conduct fair, transparent, free and proper businessSuppliers must engage in fair, transparent, and free competition and appropriate transactions.
They must also maintain sound and proper relationships with government and politicalorganizations and must not engage in acts of bribery that may lead to corruption.
[Required]・Provide appropriate education and training to workers.

(IV-2) Prohibit abuse of power, and offering and acceptance of bribes
Suppliers must not conduct any acts that cause disadvantage to their business partners by using
their superior position. Suppliers must also not offer or accept inappropriate benefits.
[Required]・Do not take advantage of a superior position to make unreasonable demands of business
partners, such as demanding unfair discounts, unreasonably short delivery times, andbusiness entertainment.
・Do not respond to unreasonable demands from customers who are in a superior position.
・Do not offer or accept inappropriate benefits, such as expensive mid-year or year-end gifts,
and excessive business entertainment.

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(IV-3) Protect and respect intellectual property
Suppliers must protect the intellectual property rights possessed or owned by themselves, andmust not illegally obtain or use, or infringe upon the intellectual property of third parties.
[Recommended]
・When developing, producing, selling, or providing products or services, conduct a priorinvestigation of the third parties’ intellectual property rights.

(IV-4) Use appropriate export procedures
Suppliers must use proper procedures to export and manage products and technologies. And
they must observe the related local laws and regulations.
[Required]・To ensure proper export control, conduct designated export control procedures, includingclassification.

(IV-5) Disclose company information appropriately
Suppliers are expected to appropriately disclose company information to stakeholders, and to
make efforts to promote mutual understanding therewith and maintain their trust.
[Recommended]・Engage in active and fair disclosure of corporate information (business activities, financial
situation, business performance, ESG [environmental, social, and governance] information),risk and incident information, etc. to stakeholders (such as customers, shareholders,investors, workers, business partners, local communities, governmental organizations, andthe mass media) in order to promote dialogue with stakeholders and enhance corporatetransparency.

(IV-6) Prevent and promptly rectify inappropriate behavior
Suppliers must conduct education and awareness-raising activities for workers to prevent
misconduct and human rights violations. They must also establish a system (whistleblowing
system) to detect and respond to misconduct early and must guarantee the confidentiality,
anonymity and protection of whistleblowers.
[Required]・Establish internal and external reporting system to enable early detection of misconduct andhuman rights violations. Or inform workers to use the Corporate Ethics Helpline establishedby our company.
・Strive to maintain the confidentiality of whistleblowers and protect them appropriately.
・Respond promptly to any misconduct or human rights violations, and provide feedback towhistleblowers on the findings of investigations.

10(IV-7) Confront antisocial forces
Suppliers must take a resolute stance against antisocial forces and organizations that pose athreat to civil order and security.
[Required]・Do not have any relationships with anti-social forces.

V Information Security~ The Niterra Group appropriately protects and manages all information resources. ~(V-1) Secure computer networks against threats
Suppliers are expected to take measures to ensure computer security, including but not limited
to virus checks, and to prevent information leaks from mobile devices, etc., and to impartappropriate education on information security to employees.
[Required]・Back up critical data, and maintain multiple servers and data centers.
・Always keep anti-virus software up to date.

(V-2) Prevent the leakage of confidential information of customers, personnel andthird parties
Suppliers must appropriately protect and manage confidential information belonging tocustomers, personnel and third parties that is known via business activities.
[Required]・Define the types and management levels of confidential information, and establish a system
to appropriately manage confidential information according to the defined levels.

(V-3) Prevent accidental leakage and take appropriate countermeasures if leakage
occursSuppliers must promote prevention of information leakage. If an accidental leakage
occurs, suppliers must take measures to minimize damage and prevent recurrence.
[Required]・Establish a system to prevent information leakage, promptly respond to an incident if it
occurs, and implement corrective actions after an incident.

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VI Occupational Health and Safety~ The Niterra Group is committed to maintaining workplace safety and hygiene so that theenvironments are agreeable to employees. ~(VI-1) Take safety measures with equipment and instruments
Suppliers must evaluate risks associated with equipment and instruments, and to takeappropriate safety measures and conduct inspections and maintenance therewith.
[Required]・Regularly inspect machinery and equipment and maintain them properly. Also, install safety
equipment in hazardous areas and make workers wear protective gear when working inhazardous areas.
・Ensure safety with appropriate design, engineering, and management measures in
response to changes in equipment and other conditions.

(VI-2) Promote safe activities in the workplace
Suppliers must evaluate the potential risks of accidents and health hazards in the workplace,and to ensure safety by means of appropriate designs, technologies and management.
[Required]・Identify, improve, and manage occupational safety and health risks in business in order toprevent disasters and accidents.

(VI-3) Promote hygiene in the workplace
Suppliers must grasp workplace conditions in terms of biological and chemical hazards, noise,and odors, which are harmful to health, and take appropriate measures against such events.
[Required]・Take measures against harmful chemicals, noise, and odors handled in the workplace.

(VI-4) Take appropriate measures against occupational injuries and illnesses
Suppliers must grasp the situation of occupational injuries and illnesses in the workplace, andprovide appropriate measures.
[Required]・Keep records of corrective actions in cases of accidents and injuries in the workplace.

(VI-5) Properly manage disasters and accidents
Suppliers must prepare emergency response measures for possible disasters and accidents inorder to protect human lives, and inform all people through the workplace.
[Required]・Conduct disaster evacuation drills on a regular basis.
・ Provide risk prediction training on a regular basis.

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(VI-6) Manage physically demanding work
Suppliers must identify, designate and appropriately manage physically demanding work so thatit does not lead to accidents or illness.
[Required]・Give special consideration to those who are engaged in physically demanding work
(handling heavy loads, working long hours in high or low temperatures, and dusty work).

(VI-7) Promote safety and hygiene at all company facilities
Suppliers must appropriately maintain the safety and hygiene of facilities provided as a part of
employee living (dormitories, cafeterias, toilets, etc.).
[Required]・Provide a sufficient number of clean toilets and access to drinking water, food, and rest
rooms for all workers.
・Maintain a sanitary environment with proper ventilation and air conditioning.
・Appropriately maintain the safety and hygiene of facilities that workers use outside of work
(dormitories, etc.) to ensure their health and hygiene.

(VI-8) Promote health maintenance programs for employees
Suppliers must appropriately manage the health of all employees via health checkups, etc., andmust also pay sufficient attention to their mental health.
[Recommended]
・Conduct annual stress checks at offices with less than 50 workers.

VII Product Quality and Safety~ The Niterra Group maintains the trust by making and supplying safe, high quality products
and services. ~(VII-1) Supply stable quality products and services
Suppliers are expected to build and manage a quality management system so as to conductbusiness reliably by continuously supplying safe, high quality products and services, andproviding accurate information.
[Required]・Carry out activities that meet the requirements of SQR (Supplier Quality Requirements).

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* These Guidelines are based on categories and wording in the Code of Conduct of the
Responsible Business Alliance (RBA), the Supply-Chain CSR Deployment Guidebook of theJapan Electronic and Information Technology Industries Association(JEITA), and the UN Global
Compact Supply Chain Subcommittee "Guidelines on Respecting Human Rights in
Responsible Supply Chains.”
The End14

Published by Niterra Co., Ltd.
Published in July 2023
For more information Global Procurement Company Niterra Co., Ltd.
Tel +81-568-76-1363