CSR Basic Policy of Niterra Group

April 2024

The CSR Basic Policy has been approved by the Board of Directors and covers allprocesses of the Niterra Group's businesses, including research and development of
product and service, design, production operation, materials procurement, logistics,
selection of suppliers, joint ventures and acquisitions.

Risk Management Policy
We adapt from a global viewpoint to changes in the management environment
surrounding our group and to the diversification of risks and will foster risk
management to reduce or avoid the loss of managerial resources, thereby improving
our corporate value.
Action Guidelines●We identify the risks that might hamper the achievement of our managementtargets from a global and long-term viewpoint and strive to prevent the actualizationof these risks in a planned and organization-based manner.
●In the event that such a risk materializes, we strive to minimize the impact on our
stakeholders, maintain their trust and prevent the recurrence of similar incidents.

Compliance Policy
With recognition that our company is a member of society, we enhance corporate
ethics and understand the spirit and meaning of laws, company regulations,international rules, and social norms in order to appropriately meet social demandand become a company trusted by the international community.
Action Guidelines●We not only comply with laws and regulations, but also act in good faith with
common sense and responsibility as a member of society.
●We comply with applicable laws and regulations regarding the prevention of corrupt
practices, and not engage in any corrupt practices (bribery, conflict of interest, insider
trading, anti-competitive practices, money laundering,

improper relationship with

politics and government, etc.), either directly or indirectly, and conduct our business1

activities with integrity.

●We regularly educate and raise the awareness of all our employees to impart a highlevel of ethics and correct knowledge, with which they can act voluntarily to preventa violation.
●Should a violation occur, we will promptly investigate the causes and take remedialactions. We will strive to take appropriate countermeasures to prevent recurrence
and fulfill our accountability.

Human Rights Policy
We are working to resolve various social issues to realize sustainable societies. We
recognize that as a prerequisite for this, it is important to respect human rights ofpeople who are affected by our business activities, and that it is essential tocontinuously fulfill such responsibilities in truly contributing to the realization ofsustainable societies. To this end, we respect human rights set out in the Universal
Declaration of Human Rights and the ILO Declaration on Fundamental Principles andRights at Work, and make our best efforts to protect the dignity of these people basedon the UN Global Compact, the UN Guiding Principles on Business and Human Rights,
and the OECD Guidelines for Multinational Enterprises.
Action Guidelines●We comply with the laws and regulations of all countries and regions in which we
conduct our business activities. If where national laws and international humanrights differ, we seek ways to respect internationally recognized human rights
wherever possible.
●We identify negative impacts that we could have on human rights through ourbusiness activities, and strive to prevent, mitigate, or eliminate the causes of suchimpacts.
●We establish a scheme for our employees and suppliers to access or report, andaccept consultations and notifications concerning human rights. Upon receiving
consultations or notifications, we investigate the facts, and if any problem is
identified, we remedy it through appropriate response.
● We disclose efforts and progress promptly on human rights actions and keep
updating ones through discussions and dialogues with various internal and external
stakeholders.
●This policy applies to all Corporate Officers and employees of the Group. We provide
appropriate education and trainings to ensure that all Corporate Officers andemployees understand and act with this policy.
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●We keep encouraging all of our business partners, including suppliers, to understandthe Policy and join our efforts to respect human rights.
<Appendix>
The Policy is top-ranked guideline on human rights actions and had been confirmed
by our CSR and Sustainability Committee and approved by Board of Directors'
meeting. The Policy shows the Group's approach on human rights and complements
our Corporate Philosophy, CSR and Sustainability Charter, and Corporate Code of
Conduct.
The Policy will be periodically updated in response to changing social and businessenvironment and human right issues, through discussions and dialogues withstakeholders. We keep adequate management system and reflect updates on relevantbusiness policies and procedures to integrate in entire business activities.
The human rights that the Group respects in its corporate activities include thefollowing:[Prohibition of forced labor]
We do not tolerate forced labor and human trafficking, and we employ employeeson their own volition.
[Prohibition of inhumane treatment]
We do not engage in inhumane treatment such as abuse, corporal punishment,
sexual harassment, or power abuse, and we respect the human rights of ouremployees.
[Prohibition of child labor]
We respect rights of children and do not employ them under the minimum age for
employment in the country or region. Workers under the age of 18 shall not perform
work that is likely jeopardize the healthy development.
[Prohibition of discrimination]
We prohibit discrimination of any kind, irrespective of race, color, age, gender, sexual
orientation, gender identity, ethnicity, nationality, disability, pregnancy, religion,
union membership, protected genetic information, or marital status.
[Working conditions and equal opportunities]
We comply with the laws and regulations of each country and region, such as minimum
wages, overtime wages, equal pay for equal work, working hours, etc., offer working
conditions for a better life for our employees, and do not unreasonably reduce wages.
We also ensure equal opportunities and equity in hiring, promotion, and compensation.

[Freedom of association and collective bargaining]
We respect freedom of association and the right to collective bargaining inaccordance with the laws and regulations of each country and region.
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[Responsible procurement of resources and materials]
We promote responsible procurement of resources and materials, taking into
consideration human rights issues, including those relating to conflict minerals. If
any use of such minerals is found, we will take appropriate measures.
[Respect for privacy]
We respect and do not infringe on the privacy of individuals.
[Comfortable workplace environment]
We comply with the laws and regulations concerning safety, hygiene and health in eachcountry and region, strive to reduce long working hours and create a safe, healthy andcomfortable workplace environment.

[Engagement with local communities]
To prevent negative impacts on the safety and health of local communities, weprevent environmental destruction and contamination, and conduct our businessactivities in consideration of the rights of local residents.
[Respect for the rights of indigenous peoples]
In business activities in areas where indigenous peoples reside, we recognize thatindigenous peoples have their own unique cultures and histories, and we respect
the rights of indigenous peoples as stipulated in international agreements.

Quality Policy
We continue to cocreate value with customers and contribute to society in accordancewith basic traits of "Quality Product" & "Involvement by all".
Action Guidelines●We constantly consider what we should do to please our customers with our
products and services, with a view to increasing our organizational capability.
● We are engaged in quality improvement activities across the company andencourage our employees to achieve higher goals by making the best use of theirindividual abilities and creativity and uniting their wisdom to address problems andchallenging issues.

4Information Security Policy
We regard all of our own information assets as one of our management resources.
Through the proper protection and effective use of our information assets, we pursue
healthy maintenance and development of our business.
Action Guidelines● We establish rules that clearly define the system and responsibilities for theprotection and management of all the information assets including the information
we keep for our customers, the know-how and intellectual properties owned by ourgroup, and personal information.
●We comply with laws, ordinances, and regulations regarding information security.
●We educate all executives and employees who handle information assets about theimportance of information security, and about specific items to be observed.
●We continuously update the information infrastructure for the maintenance andimprovement of the confidentiality, integrity, and availability of all the information
assets.
● We promote measures to prevent accidents in order to address the risks of
information leakage associated with the continuous advancement and sophisticationof information technology. Should an accident occur, we will strive to minimize thedamage and take preventive measures against recurrence.

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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 andpromoting our CSR and sustainability efforts throughout our supply chain system,
while at the same time striving to carry out proper purchasing transactions when
procuring materials and parts, based on the following guidelines:
Action Guidelines● We conduct transactions at appropriate prices based on fair, transparent, open
competition and rationality.

●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
to continuously make improvements.
●Aiming to procure more eco-friendly products, we strive to promote our green
supplier system.
●We enhance mutual trust with our suppliers, who are good partners for us, andstrive to realize mutual development.

Information Disclosure Policy
Aiming to become an enterprise capable of receiving great support and popularity
from people around the world, we strive to conduct transparent business operations
and fair information disclosure.
Action Guidelines●We disclose any corporate information required to be disclosed by the Financial
Instruments and Exchange Act and other laws and regulations, in an accurate andtimely manner.
●We actively disclose our corporate information, which is not subject to laws andregulations however deemed to be important for stakeholders, through our daily
actions, such as issuance of press releases and updates of our website.
●We focus on enhancing communication with our shareholders, investors, and otherstakeholders to further promote mutual understanding with them.

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Environmental Policy
As a globally developing core manufacturing corporation, we aim to promote
environmental conservation activities linked with corporate management maintaining
a good balance with corporate growth, based on the participation of all of ouremployees, in order to contribute to the construction of a sustainable society.
Action Guidelines● Through all of our business activities, we make particular efforts to reduce CO₂
emissions and improve energy efficiency, toward the realization of a decarbonizedsociety, conserve water resources, manage waste, and develop, offer and expand
environmentally friendly products.
●We prevent environmental pollution through the control of chemical substances thatplace a burden on the environment.
●We promote resource circulation by working to ensure sustainable use of resources andreduce environmental impact during and after product use.
●We recognize the benefits derived from ecosystem services and strive to conserve
biodiversity.
●We strive to raise environmental awareness among our employees to ensure that they
all positively participate in activities.
● We observe the laws, ordinances, and agreements concerning environmental
conservation.
● We aim to substantiate information disclosure to stakeholders and communication
activities, and also conduct activities for coexistence with the regional community.
●In order to achieve these targets, we will continuously improve our environmental
management system and strive to reduce our environmental impact.
●We keep encouraging all of our business partners, including suppliers, to understandthe Policy and join our efforts to promote environmental conservation.

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Human Resource Policy
We acknowledge that our employees are our most important management resource.
In light of this, we respect the diversity and individuality of our employees and strive
to develop the group as a whole by ensuring that these self-leading and innovative
human resources can fully demonstrate their capabilities.
Action Guidelines●We foster aspiring human resources who can act to bring about changes and alsochange themselves (self-leading and innovative human resources) and establish anenvironment where they can perform to the best of their abilities.
●We strive to nurture a corporate culture where human resources with different
qualities can fully realize their own capabilities and ensure that the right humanresources are assigned to the right posts.

Occupational Health and Safety Policy
With high respect to humanity, we act on occupational health and safety as thecompany’s starting point.
Action Guidelines●To prevent health damage, injuries at work, and illnesses of employees, we will
provide healthy and safety working environment and act to improve physical andmental health.
●We will comply with laws and voluntary regulations regarding Occupational Healthand Safety.
●We will continuously improve occupational health and safety management systemand health and safety performance.
●We will eradicate injury at work by eliminating hazards for occupational health andsafety and by reducing risks.
●We will promote ability and awareness at occupational health and safety througheducation and enlightenment.
●We will inform all employees about this policy and engage in health and safety activities
with the participation of all employees, based on the action plan agreed with theemployee representatives.
*This policy applies to all persons involved in our business activities, including employees, temporary employees,
contractors, suppliers, construction workers and visitors.

8Social Contribution Policy
As a good corporate citizen, we aim to contribute to society through the effective useof management resources.
Action Guidelines●We focus on the following activities:-Activities closely related to our business fields-Activities that respect the cultures of individual countries and local communities,
as well as activities that contribute to society such as traffic safety education
programs-Activities that contribute to the future of society, focusing on environmental
conservation, science, and education (in particular the development of nextgeneration human resources), as well as cultures to be bequeathed to the next
generation, etc.
●We strive to create a corporate culture that encourages executives and employees
to participate together in social contribution activities as social citizens. We also
respect and support their active involvement in society.

Tax Policy
By understanding the spirit and purpose of taxation laws and regulations, we respond
appropriately to the demands of society and aim to become a company trusted by theinternational community.
Action Guidelines●We fulfill our social responsibilities by observing laws on corporate taxation andother tax laws in every country, as well as international taxation standards including
the OECD Transfer Pricing Guidelines, the Action Plan on Base Erosion and Profit
Shifting, and the arm’s length principle of transfer pricing.
●In order to ensure compliance with taxation laws and regulations, we work toward
improving our knowledge and gaining a proper understanding of taxation and adopt
an attitude of sincerity toward tax authorities to enhance our reliability andtransparency.
●We properly manage taxation risks by working toward appropriate declaration andpayment of taxes in each country, thereby enhancing shareholder value.
●We never engage in profit shifting to tax havens and other low-tax countries orimplement other measures for the purpose of tax avoidance.

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