Nichirei Group Supplier Guidelines
These guidelines provide commentary and reference information forcomplying with the Nichirei Group Supplier Code of Conduct. We requestthat our suppliers refer to these guidelines in successfully implementing
initiatives to comply with the Supplier Code of Conduct.
“Suppliers” refers to companies from which the Nichirei Group procures
raw materials and products; companies to which we outsource
manufacturing: and partner companies to which we outsource logistics
services such as transportation and freight handling.
Legal Compliance and Ethical Behavior
Legal Compliance・Suppliers shall comply with the laws and regulations of applicablecountries and regions and respect international standards ofconduct.
(Commentary)
Countries around the world have recently introduced and enacted
various laws, regulations and policies relating to the environment,
human rights and bribery. Companies need to understand and comply
with these laws and regulations, some of which apply not only in the
country of domicile but are also extraterritorial. Efforts to understandand fully comply with relevant laws and ordinances are therefore
necessary.
International standards of conduct delineate the conduct expected ofsocially responsible organizations, and are derived from customaryinternational laws, generally accepted international legal principles, anduniversally or nearly universally recognized intergovernmental
agreements, including treaties and conventions. Examples include theUN Guiding Principles on Business and Human Rights, the Sustainable
Development Goals (SDGs), the OECD Guidelines for Multinational
Enterprises, and the Tripartite Declaration of Principles concerning
Multinational Enterprises and Social Policy. They deserve respect andaccommodation even when compliance with them is not obligatory.
Initiatives that conform to international standards of conduct are
particularly important in countries where governance is not robust andlegal compliance is insufficient.

Prohibition of Bribery and Corrupt Practices
・Suppliers shall not engage in any form of corruption, including
bribery, graft, blackmail and embezzlement.
(Commentary)
Corruption refers to making or receiving illegal or improper payments
for goods or services, or committing fraudulent acts such as bribery,
graft, extortion or embezzlement for personal gain. Examples include“facilitation payments” to government officials to obtain the required
government approval and kickbacks paid to customers to win orders.
Giving or receiving anything of value directly or indirectly, including
promises or solicitation, in order to win business or profit improperly is
prohibited.
Association required in the course of business to smoothly build
relationships is not prohibited, but moderation is key. Maintaining ahigh level of transparency through means including rigorous accounting
and record keeping is required to preclude personal benefit or theacceptance of impropriety as a normal condition.

Continuous compliance requires the formulation of a policy,
appropriate employee education and training, and ongoing, rigorous
enforcement of that policy.

Anti-competitive Practices
・Suppliers shall comply with applicable laws and shall not engage inbid-rigging or other anti-competitive practices.
(Commentary)
Suppliers are requested to comply with all applicableantimonopoly/antitrust laws and to conduct business in a fair andcompetitive manner. Violations may result in substantial fines.
Continuous compliance requires the formulation of a policy,
appropriate employee education and training, and ongoing, rigorous
enforcement of that policy.

Exclusion of Antisocial Forces
・Suppliers shall not conduct any transactions with antisocial forces.
(Commentary)
Antisocial forces include but are not limited to crime syndicates,
members of crime syndicates, criminals associated with crime
syndicates, companies affiliated with crime syndicates, racketeers who
extort money by disrupting companies’ shareholder meetings(“sokaiya”), and racketeers or designated violent organizations posing
as social movements.

Human Rights and Labor
Freedom of Occupational Choice・Suppliers shall respect the free will of employees, and shall not use
forced labor, slave labor, human trafficking, bonded labor or
involuntary prison labor.
(Commentary)
Freedom of occupational choice means that people work voluntarily
and without any threat of punishment. It is forbidden to use bonded
labor, to restrict freedom of movement, or to otherwise be involved in
the use of forced labor.
“Forced labor” refers to labor performed involuntarily against aperson’s free will, and includes the following situations:・ Employment contracts for foreign workers that are not in theirnative language or in a language they can understand;・ Employment and working conditions that have not been properly
explained in writing;・ Workplaces that inhibit communication with or access to theoutside world;・ Compulsory withholding of a portion of employee compensationas temporary safekeeping or savings;
・ Workers incurring debt to pay high fees for obtaining
employment;
・ Overtime work in excess of legally designated limits or labormanagement agreements;

・ Restrictions on employee movement without valid reasons
including health, safety or information security;

・ Possession by employer of original copies of employee
identification such as passports

Many reports in recent years have highlighted forced labor among
migrant workers, especially foreign workers. In Japan there have been
many reports of problems involving the employment of foreigntechnical interns. Employers hiring workers from overseas throughJapan’s foreign technical intern system must ensure appropriate work,
working conditions and living environments. These employers needto properly grasp the actual situation, including employment
brokerage services, and give the utmost consideration to respecting
the human rights of foreign technical intern trainees, who are in avulnerable position.

Child Labor and Young Workers
・Suppliers shall not involve children who are under the minimum
working age in labor. Employees under the age of 18 shall only bepermitted to engage in non-hazardous work.
(Commentary)
The minimum working age is defined by ILO Convention No. 138(1973) as no less than the age of completion of compulsory schoolingand, in any case, shall not be less than 15 years.

Also, the minimum working age varies depending on the type of work.
For hazardous work, all countries must have a minimum working ageof 18 years.
“Hazardous work” includes but is not limited to the following:
・ Underground work (in mines, quarries, pits, etc.), maritime work,
work at dangerous heights, or work in confined spaces;
・ Work that uses dangerous machinery, equipment or tools, or thatinvolves manual handling or transportation of heavy objects;
・ Work performed in environments that are unhealthy for reasons
including exposure to unsafe temperature or noise levels, or tovibration;
・ Long hours of work, night work, and work involving improper
detention on the employer’s premises.
Violation of the minimum working age is unlikely for Japanese citizens
because of the country’s system of compulsory education. However, toavoid violation of the minimum working age among foreign children in
Japan or children overseas, suppliers shall check documents that
confirm date of birth, such as a birth certificate, identification card,
driver’s license or graduation diploma, and retain a copy of the relevant
document.
Discrimination
・Suppliers shall not discriminate based on characteristics including
race, color, place of birth, age, gender, gender identity, sexual
orientation, disability, pregnancy, ethnicity, religion, political views,
union membership, home environment and marital status.

(Commentary)
Acts regarding wages, promotions, compensation, education,
recruitment or employment practices that could result in discriminationmust not occur. Discriminatory acts include impairment of equal
opportunity or fair treatment based on a health examination or
pregnancy test. All employees must receive equal pay for equal work,without discrimination.
Freedom of Association and Right to Collective Bargaining
・Suppliers shall respect the right of all employees to form or join alabor union and engage in collective bargaining.
(Commentary)
This means that suppliers shall permit their employees to form andparticipate in labor unions, trade associations and labor councils andcommittees. The purpose of this is to enable good dialogue between
labor and management.
“Collective bargaining” is the means by which an employer and labor
union representatives reach an agreement through employee involvement
in working conditions, overtime work, grievance procedures andworkplace issues.
Workers and their representatives must be able to form and participate inlabor unions and engage in collective bargaining without fear of
discrimination, retaliation, intimidation or harassment. In addition,
workers and their representatives must be able to engage in collective
bargaining in order to achieve mutual understanding with management
regarding their concerns and opinions about working conditions andmanagement practices.

Harassment and Punishment
・Suppliers shall not engage in inhumane treatment such as
harassment and abuse.
(Commentary)“Inhumane treatment” is physical and mental abuse and harassment,
including sexual and “power harassment” (workplace bullying in which
the perpetrator abuses their position of authority, negatively impacting
the workplace environment through acts that go beyond what isnecessary or appropriate for work operation). “Harassment” is any
improper and unwelcome conduct that might reasonably be expected or
be perceived to cause offense or humiliation to another person. Specificexamples include sexual harassment, sexual abuse, corporalpunishment, mental and physical repression, verbal abuse, power
harassment (workplace bullying) and discrimination based on
pregnancy or birth.
Treatment that humiliates people or violates their dignity is prohibitedin relationships with employees and also in relationships with business
partners and client companies.

Working Hours
・Working hours shall not exceed the maximum prescribed by law.
Employees shall be given a minimum of one day off per week.
(Commentary)
Excessive working hours harm the physical and mental health ofworkers, reduce work efficiency and cause careless accidents.
Appropriate management is therefore required. Suppliers shallappropriately schedule working hours, holidays and rest breaks inaccordance with relevant laws and regulations in each country.
Consideration shall also be given to international standards.
“Appropriate management” is as follows:
・ The number of working days per year shall not exceed the
maximum prescribed by law;
・ The number of working hours per week, including overtime (butexcluding unavoidable times of emergency such as disasters andother crises) shall not exceed the maximum prescribed by law;
・ The provision of legally mandated annual paid leave, prenatal andpostnatal leave and childcare leave;・ The provision of legally mandated rest breaks;

・ The performance of physical and mental health examinations toprotect the health of workers
Suppliers shall pay close attention to avoiding excessive working hours
for long-distance truck drivers through means including appropriate
operational management and health checks.

Wages
・Suppliers shall pay appropriate wages and allowances that meetstatutory requirements including minimum wage, overtime wages,
legal benefits and employee benefits. Also, suppliers shall not makeunreasonable wage reductions for disciplinary reasons.
(Commentary)
Wages must meet the basic living needs of employees, with some
disposable income remaining. Employers must make efforts to pay aliving wage if the statutory minimum wage or the industry standard of
the country or region where business is being conducted does not meet
the basic needs of employees.
In addition, employers must pay workers compensation for overtime
work at a higher rate than for normal working hours, in accordancewith relevant laws and regulations. Employers must also provide
workers with a wage slip that confirms correct payment.
Unjustified wage deductions such as uniform fees, fees for personal
protective equipment required for work and uniform cleaning fees are
regarded as unpaid wages. However, unpaid wages do not include
compensation deducted due to late arrival or absenteeism.
Wage reductions for disciplinary reasons not covered by labor laws,
work regulations, agreements between labor and management or theconsent of the recipient are not permitted.

Occupational Health and Safety
Employee Safety
・In workplaces and company-provided housing, suppliers shallidentify potential chemical, biological or physical hazards that
affect the safety of employees, and take safety measures.

(Commentary)
Suppliers need to identify workplace hazards, including their likelihoodof occurrence, and take safety measures for workers. Examples ofworkplace hazards include human contact with machinery, chemicals
and electricity and other energy sources, as well as fires, accidents
involving vehicles, and falls.
Examples of safety measures that suppliers must implement
systematically are as follows.
・ Identify and evaluate hazards, including the likelihood of theiroccurrence;・ Design workplaces with appropriate attention to risk eliminationand preventive maintenance;
・ Safety awareness activities, including handling of personal
protective equipment
Pregnant women and breastfeeding mothers require special
consideration.
Types of work requiring particularly rigorous safety measures include
work in low-temperature warehouses and high-temperature and highhumidity factories, vehicle operation for extended periods, andhandling of harmful chemical substances, microorganisms, viruses andradioactive ores. Regarding risks arising from chemical and biologicalprocesses, management processes must be put in place to prevent oraddress the catastrophic release of chemical or biological substances.
Emergency Response・Suppliers shall take emergency preparedness measures inworkplaces and company-provided housing, and shall conductperiodic emergency drills.

(Commentary)
All companies must be prepared for fires and other emergencies. They
must prepare for emergencies in order to protect worker lives andsafety and company assets.

”Emergency preparedness” includes emergency reporting systems;
worker notification systems; clear evacuation methods; installation ofevacuation facilities; clearly marked exits that are free of obstacles;
appropriate exit facilities; stockpile of emergency medical supplies;
installation of fire detection systems, fire extinguishers, fire doors andsprinklers; ensured means of external communication; and establishedrecovery plans. Both workplaces and company-provided housing
require advance preparation.
Employees must be thoroughly acquainted with emergency
preparedness measures. Methods include conducting emergency
preparedness education that includes evacuation drills, and storing anddisplaying emergency response procedure manuals in easily accessible
places in the workplace.
Safety of Equipment, Facilities and Vehicles
・Suppliers shall conduct regular inspections and take safetymeasures for production machinery, vehicles, and other facilities
and equipment.

(Commentary)Most workplaces use machinery, equipment and vehicles of some kind.
The appropriate design, maintenance and use of these devices isessential for the safety and health of employees. Whether for a simple
or complex machine or for a forklift or truck, every precaution must be
taken to protect equipment operators, drivers and other employees frominjury.
Safety measures involve management practices that prevent accidents
and health problems that occur during work. For mechanical devices,
examples include the adoption of safety mechanisms with nomenclature
ranging from fail-safe and foolproof to interlock and tagout, theinstallation of safety devices and protective walls, and regularinspections and maintenance of machinery and devices.

Physically Demanding Tasks
・Suppliers shall take safety measures for physically demanding
tasks, including those that require lifting of heavy objects or
prolonged standing, and highly repetitive tasks.
(Commentary)
In addition to heavy labor such as manually handling and transporting
raw materials and heavy items, physically demanding tasks include
repetitive work over extended periods such as physically demanding
assembly work and data entry, and work that involves unnatural
posture. Safety measures are important because these tasks can result ininjuries and disabilities due to physical stress. Examples of safetymeasures include an ergonomic work environment, regular rest breaks,
the provision of work aids and equipment, and sharing of tasks by andin cooperation with multiple workers.

Sanitation
・In workplaces and company-provided housing, suppliers shallprovide ready access to clean toilet facilities and potable water, andsanitary eating facilities.
(Commentary)Protecting the health of employees and keeping the working and living
environment sufficiently sanitary is crucial for sound corporate activities.
Ensuring hygiene requires keeping facilities clean and hygienic andattention to the following points:
・ Potable water: water quality inspection in compliance with laws andregulations, and access to safe drinking water by providing watercoolers and the like;・ Provision of hygienic meals: includes clothing and health inspections
for cooks, pest control, proper temperature control of food, andcertification of cafeteria operations;・ Toilets: includes clean toilet facilities sufficient for the number ofpeople, and provision of toilet paper;・ Dormitories: includes fire prevention measures, emergency evacuationroutes and exits, secure storage facilities for personal belongings suchas lockers with keys, sufficient room size of approx. 3.3 m2 or more perperson, ventilation, temperature control, and appropriate lighting.

Health Management

・Suppliers shall practice proper health management withconsideration for maintaining employees’ health.
(Commentary)Protecting the health of employees supports their health and welfare
and sound corporate activities. Suppliers shall ensure that employees
receive high-quality medical care in the workplace and in the local
community, and implement measures such as encouraging healthy
lifestyles through health promotion programs.
At its very least, “appropriate health management” involves conducting
legally mandated health examinations for prevention and early
detection of employee illness. Due consideration must also be given topreventing health problems due to overwork and to providing mental
health and other care.

Communication
・Suppliers shall share, convey and provide education on the necessary
health and safety information in employees’ native language or alanguage they can understand.
(Commentary)
Suppliers must provide appropriate workplace health and safety
information and education and training for any identified workplace
hazards to which workers will be exposed, including mechanical,
electrical, chemical, fire and physical hazards. Supervisors andmanagers are responsible for the health and safety of their employees,
so they need to know how to identify and address risk factors in theworkplace. At the very least, other employees need to understand thehealth and safety risks of their work and the precautions they must taketo work safely.
Suppliers shall clearly display health and safety information within
their facilities in locations that are identifiable and accessible toworkers. Information must also be provided in a language that theirworkers understand, regardless of their nationality.
Education and training shall be provided to all workers prior to the startof work and thereafter on a regular basis. Adequate safety information,
education and training is particularly important for workers handling
dangerous substances such as radioactive materials, pharmaceuticals,
pharmaceutical intermediates, reagents, microorganisms, viruses andtoxic substances.

Environment
Climate Change・Suppliers shall set targets for reduction of greenhouse gas
emissions, and make efforts to reduce greenhouse gas emissions bypromoting energy conservation and the use of renewable energy.
(Commentary)
Climate change countermeasures are one of the most important
challenges facing humankind today. “Greenhouse gases” refers to adiverse array of gases, but generally to carbon dioxide (CO2), methane,
nitrous oxide, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs),
and sulfur hexafluoride (SF6).
Suppliers need to set voluntary reduction targets, formulate plans inorder to ensure the reduction of greenhouse gas emissions.

The following are examples of measures for reducing greenhouse gas
emissions:・Efficient use of energy in operations
・Use of renewable energy such as wind power, hydropower and solar
power
・Use of fuel-efficient vehicles, electric vehicles, fuel cell vehicles, etc.
・Improving transportation efficiency by raising the truckload
utilization capacity ratio and by achieving a modal shift to rail andmarine transportation, etc.
・Upgrading to refrigerants that have low global warming potential
valuesWater・Suppliers shall make efforts to reduce the amount of water used inbusiness processes, and prevent the release of polluted water into
the environment.
(Commentary)
Water is indispensable for almost all types of businesses, whether forfactories, farmland, offices, or food processing facilities. Responsible
water use means limiting water use as much as possible, minimizing theenvironmental impact of water use, and managing wastewaterappropriately. The use of water requires particular attention, especiallyin areas with high water risk.
In addition, companies must continuously monitor pollutants in
wastewater to avoid adverse effects on the surrounding area and theenvironment. Emergency facilities are also required. Examples include
isolation valves and shut-off valves to stop leakage and outflow ofclean water and sewage due to industrial accidents and natural
disasters, and rainwater and sewage basins to handle leakage oroverflow.

Waste
・Promote efficient use of raw materials, reduce waste, and dispose ofwaste properly.
(Commentary)
Waste includes by-products, virgin material and garbage from company
operations. Waste must be treated in accordance with the law. The
problem of food loss in particular has attracted public attention inrecent years, and therefore requires appropriate measures.
Appropriate waste management programs to reuse, reduce and recycle
waste can also lessen environmental impact and reduce corporate costs.
In addition, medical waste requires rigorous measures such as proper
treatment of infectious waste.

Control of Emissions into the Atmosphere・Suppliers shall make efforts to reduce emissions of ozone-depleting
substances and atmospheric pollutants.
(Commentary)
Atmospheric emissions are gases, steam, and fine particles (dust)
released into the atmosphere from sources such as chimneys, vehicle
exhaust, electric power generators, and facility air outlets. Theseemissions can cause air pollution and affect the environment and thehealth of employees and residents of the local community.
Atmospheric emissions can also include ozone-depleting substancesand volatile organic compounds. Suppliers shall analyze and monitor
these substances prior to emission, and based on the results, conduct
required management and treatment before their release.
Countermeasures include regular inspections of the process forhandling emitted substances and the performance of processing
equipment.

Chemical Substance Management
・Appropriately manage chemical substances, reduce the amountused, replace with less harmful substances, and implement
programs to prevent leakage.
(Commentary)
Chemical substances can adversely affect the environment and thehuman body. Therefore, these substances must be managed and usedaccording to their characteristics. In Japan, for example, chemical
substances must be managed in accordance with the Act on the
Evaluation of Chemical Substances and Regulation of Their

Manufacture, etc. (commonly referred to as the "Chemical Substances
Control Law"), the Poisonous and Deleterious Substances Control Act,the Industrial Safety and Health Act, the Fire Service Act and the Act
on Confirmation, etc. of Release Amounts of Specific Chemical
Substances in the Environment and Promotion of Improvements to theManagement Thereof (commonly referred to as the “PRTR Law").
Appropriate management of chemical substances includes proper
management of safety data sheets (SDS), labeling of chemical
substances, use of protective equipment and having procedures in theevent of leakage.

Consideration for Local Communities
・Suppliers shall show consideration for neighboring residents by
reducing noise, vibration and odors caused by the supplier’s
business operations.
(Commentary)
Noise, vibration and odors from factory and vehicle operations canadversely affect the living environment of local residents. These issues
must be properly managed through the introduction of equipment andchanges to operations. Early morning and night-time factory andvehicle operations require particular attention.
Regular dialogue with local residents is also important for identifying
issues and deepening understanding.

Biodiversity

・Suppliers shall make effort to conserve biological diversity and thenatural environment.
(Commentary)“Biodiversity” refers to the diversity of ecosystems, species and genes
on Earth. It is also a measure of the health of ecosystems. Maintaining
and conserving biodiversity is important because many companies rely
directly or indirectly on natural resources for the continuity of theirbusinesses.
Specifically, area environmental assessments must be conducted before
expanding or operating new factories to avoid adversely affecting thenatural environment and biological diversity.

Animal Welfare・Suppliers shall give consideration to animal welfare.
(Commentary)“Animal welfare” means a commitment to the physical and mental
welfare of animals through activities such as minimizing the pain andstress that humans give to animals. The following “five freedoms” areprinciples recognized worldwide, and related legislation is moving
forward in Europe and the United States.
・Freedom from hunger or thirst through ready access to food andwater

・Freedom from discomfort through the provision of an appropriate
environment
・Freedom from pain, injury or disease through prevention, diagnosis
and treatment
・Freedom to express (most) normal behavior through the provisionof sufficient space, appropriate stimulation and company of theanimal's own kind・Freedom from fear and distress through the provision of
appropriate conditions and treatment
These principles require people to consider livestock breeding andslaughter methods. This mindset has also expanded over the past
several years to include decapods such as shrimp and cephalopods suchas squid in addition to livestock.
Regarding the use of animals in life science testing, the three Rs havebeen adopted: replacement, which means use of non-animal methods
over animal methods whenever it is possible to achieve the samescientific aims; reduction, which refers to methods that enable
researchers to obtain comparable levels of information from fewer
animals; and refinement, which refers to methods that alleviate orminimize potential pain, suffering or distress for the animals used.
Alternative methodologies that are scientifically valid and acceptable atthe regulatory level are desirable.

Raw Material Procurement

・Suppliers shall ensure the traceability of raw materials and conduct
procurement with consideration for protection of natural resources,
the environment and animal welfare.
(Commentary)
The collection and production of raw materials such as agricultural,marine and livestock products can cause problems such as
deforestation, environmental pollution and resource depletion.
Therefore, it is necessary to trace raw materials to ascertain their origin
and confirm they have no adverse effect on the environment.
Through the use of a certification system, this type of sustainable raw
material procurement can ensure a measurable level of sustainability.
The following are examples of well-known certifications.
・Marine Stewardship Council (MSC)
https://www.msc.org
・Aquaculture Stewardship Council (ASC)https://www.asc-aqua.org
・Roundtable on Sustainable Palm Oil (RSPO)
https://www.rspo.org
・ GLOBALG.A.P., ASIAGAP, and J-GAP (Good Agricultural
Practice)https://www.globalgap.org/
https://jgap.jp

Management
Establishment of Management System
・Suppliers shall establish an appropriate internal management
framework and operate a management system for complying with
the Nichirei Group Supplier Code of Conduct and these guidelines.
(Commentary)
Fulfilling each of the items in these guidelines requires an appropriate
management system.
Suppliers shall establish a management system based on a framework
for continuous improvement using a policy-based Plan-Do-CheckAction (PDCA) system of execution measures for corrective action andstakeholder engagement. This approach is not necessarily for the
purpose of obtaining certification. Furthermore, the management
system should include the following elements:
・ Corporate commitment (policy)
・ Manager accountability and responsibility・ Legal requirements and customer requirements
・ Risk identification and risk management
・ Goals for improvement
・ Education and training
・ Communication
・ Worker feedback, participation and grievances
・ Assessment and audit of identified risks
・ Corrective action process

・ Documentation and archiving
The following certifications are useful for establishing a management
system.
・ Occupational health and safety management system: ISO 45001 andothers・ Environmental management system: ISO 14001 and others
・ Quality management system: ISO 9000, ISO 13485 and others
・ Food safety management system: ISO 22000, FSSC 22000 andothers・ Information security: ISO/IEC 27001 and others
・ Business continuity plan: ISO 22301 and others

Operating Permits
・Suppliers shall appropriately obtain and maintain the permits,authorizations and notifications, etc. that are necessary in theiroperations.
(Commentary)Companies need to meet the requirements of permits, authorizations
and notifications mandated by laws and regulations in ways that areappropriate to their businesses.
Japan has laws and regulations that require companies to employ
managers with certain qualifications. For example, the Waste
Management and Public Cleansing Law requires administrators
qualified to manage the treatment of specially controlled industrial
waste, the Act on Temporary Measures to Promote Business Activitiesfor the Rational Use of Energy and the Utilization of Recycled
Resources (commonly known as the Energy-Saving Act) requires
energy managers in plants that use energy exceeding a designated level,
and the Air Pollution Control Act requires pollution control managers
at plants that emit chemical substances, dust, and soot.
In addition, the use of chemical substances in business operations
incurs various obligations. For example, companies that use poisonousand deleterious substances, designated chemical substances or
hazardous materials are required to employ administrators specificallyqualified to manage those substances. A company’s business or plant
location may also necessitate environmental impact assessments oradministrative permits for facilities that handle hazardous materials.
Permit, authorization and notification requirements vary by businessand industry, so suppliers need to ascertain relevant obligations andtake appropriate action.

Quality Control
・Suppliers shall ensure the quality and safety of their products andservices.
(Commentary)
The safety, quality, and accuracy of information regarding products andservices can have a tremendous impact on customers and on
stakeholders throughout the supply chain. Widely used management
systems include ISO 9001 and ISO 22000.
In the unlikely event of a product malfunction, prompt action tominimize damage is required, such as reporting to relevant parties,suspending production, recalling products and introducing corrective
measures.
Information Management
・Suppliers shall properly manage and protect the inside informationof other companies, including intellectual property, as well as the
personal information of related parties.
(Commentary)
Information management has become increasingly important with rapid
progress in the advanced information and communication society inrecent years. Inadequate information management such as leakage ofconfidential and personal information can have a tremendous impact,
not only on companies and their customers, but also on various
stakeholders, including those in the supply chain.
In addition to measures to prevent confidentiality breaches and protect
personal information, cyber security against ransomware attacks has
become extremely important in recent years.

Harmonious Coexistence with Local Communities
・Suppliers shall strive for harmonious coexistence with local
communities as a member of society.
(Commentary)
Harmonious coexistence with local communities is extremely importantfor stable business activities. Regular dialogue with local residents anda variety of community development initiatives are therefore important.

Social contributions in the local community, employee volunteerism,
collaboration with NPOs and governments to resolve social issues, anddonations and support in the event of a disaster are recommended.

Business Continuity
・To meet their supply obligations, suppliers shall formulate business
continuity plans to ensure preparedness for large-scale natural
disasters and other adverse events.
(Commentary)
Risks that impede business continuity include large-scale natural
disasters such as earthquakes, tsunami, floods, torrential rain, heavy
snowfall and tornadoes, along with associated power outages, water
outages, traffic obstacles, accidents such as fires and explosions;
epidemics due to infectious diseases and other illnesses; and terrorism
and riots.
Requisite proactive measures require a localized strategy to protect
against, mitigate and recover from assumed damage to individualcomponents of production facilities. Efforts should also include
ensuring alternative production methods under the assumption that
restoring damaged facilities may take an extended period of time.
Suppliers need to formulate a manual for rapidly restoring operations in
the event they are interrupted, and to provide ongoing education andtraining to employees so that they can respond to disasters.

Grievance Mechanisms

・Suppliers shall accept reports from stakeholders regarding actsthat violate the Nichirei Group Supplier Code of Conduct and theseguidelines, and implement mechanisms for rectification.
(Commentary)“Grievance mechanisms” are mechanisms for ameliorating negative
impacts from corporate activities involving human rights or other issues
should they occur. These mechanisms include hotlines, internal
whistleblowing systems and mentoring systems.
The Nichirei Group Supplier Code of Conduct and these guidelines
require the establishment of mechanisms that enable employees andother stakeholders to report violations following predefined procedures.
Grievance mechanisms can also be established for use by a single
supplier or collectively by several companies.
In addition, the grievance mechanisms must ensure the confidentialityof the report, including the names of employees and others involved in
making the report, and must protect those people from retaliatory
treatment.

Supplier Management
・Suppliers shall encourage upstream suppliers to comply withguidelines consistent with the Nichirei Group Supplier Code of
Conduct and these guidelines.
(Commentary)
The Nichirei Group Supplier Code of Conduct and these guidelines
must be followed throughout the supply chain. Therefore, in addition toimplementing them internally, suppliers need to expand this initiativeby encouraging upstream suppliers to comply with guidelines
consistent with the Nichirei Group Supplier Code of Conduct and theseguidelines, continuously monitor the supply chain, and take corrective
action as needed.
The Nichirei Group expects swift compliance with any requests for
supplier cooperation.