NIPPON SHOKUBAI Group
Code of Conduct

September 2022
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Message from the President
Nippon Shokubai Group Employees
In April 2022, we revised our Group Mission Framework
to fulfill our Mission, “TechnoAmenity: Providing
prosperity and comfort to people and society, with ourunique technology.” Our Values and Code of Conduct
embody the mindset and behaviors we hope each
employee of the Nippon Shokubai Group will hold in highregard. Previously, it was only our Group Mission weshared within the internal group. However, having unified
our group initiatives, we decided to implement thisrevision to share our Group Mission Frameworkcompanywide to respond to the stakeholder demands that
accompany the changing times.

Kazuhiro Noda, President

In today’s drastically changing external environment, support from our stakeholders is
indispensable to the ongoing business activity of the Nippon Shokubai Group. Therefore, in
addition to pursuing economic profits, earning the trust of our stakeholders by fulfilling
our corporate social responsibilities and meeting the demands of a global society while
complying with the applicable laws and regulations is fundamental to our business.
However, merely complying with societal demands results in a passive stance. For
Nippon Shokubai to demonstrate its purpose, everyone working for the Nippon ShokubaiGroup must share our Group Mission Framework and apply themselves to fulfilling our
Mission.

Thus, our Code of Conduct outlines the conduct that each employee should adopt andimplement for the Nippon Shokubai Group to satisfy its corporate social responsibilities
and move toward achieving its Mission.

I ask everyone at the Nippon Shokubai Group, including myself, to join forces in using
this Code of Conduct as a guideline for daily work to allow us to carry out our Group
Mission.

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ContentsGroup Mission FrameworkWhat Is the Code of Conduct?



Roles and Responsibilities of Executives and Managers

Steps to Take When Unsure of What to Do

If You Discover a Violation of the Code of Conduct

Code of Conduct (Full Version)････････････････････････････ 4･･････････････････････････････ 6･･･････････ 6･･･････････････････ 7･･･････････････ 8

1.

Realizing a sustainable society

2.

Safety first3.

Compliance

4.
5.
6.
7.

･･･････････････････････････ ９･････････････････････････････････････････ 10････････････････････････････････････････ 12
Respect for human rights･････････････････････････････ 14
Fair and honest business dealings･･････････････････････ 17
Providing value to our customers･･･････････････････････ 24
Preserving the environment････････････････････････････ 27

8.

Communicating with stakeholders

9.

Promoting active participation of diverse human resources･･････････････････････ 29

10. Contributing to local communities･･･ 31･･･････････････････････ 34

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Group Mission Framework

The Nippon Shokubai Group’s Mission Framework is shared by the entire Nippon
Shokubai Group. To realize the Mission, the Nippon Shokubai Group has established a setof Values that every employee of the Nippon Shokubai Group (all executives andemployees) should focus on as well as a Code of Conduct as a standard for daily businessbehavior and decision-making.

Mission

Providing Prosperity and Comfort to People and Society,with Our Unique Technology
Prosperity and comfort are not only economic and material but harmonious with theglobal environment as well as social and spiritual, such as diversity, fairness, and safety.
We will keep contributing to the realization of a sustainable society by practicing ourTechnoAmenity mission in the future.

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Group Mission Framework
ValuesRes p ec t Divers it y
We will create new value
by respecting the unique traits of each person.
Pio neer N ew Po s s ibil it ies
We will courageously provide solutions
for customer challenges and social issues.

Co nt ribu te to G l o ba l E nviro nmental Pres ervatio n
We will work to ensure that a better global environmentis passed down to the next generation.

Code of Conduct (Summary)Every person working at the Nippon Shokubai Group will carry out business activities with acommitment to the guiding principles below.
1.

We will contribute to the realization of a sustainable society by putting the2.

We will execute our business activities by always ensuring both internal and external safety.

4.

We will support international human rights standards and respect the human rights of all people touched

3.

5.
6.
7.
8.
9.

10.

Group Mission into practice.

We will enforce thorough-going compliance in every area.
by our business activities.

We will engage in fair and sincere business activities with all of our stakeholders.
We will provide the materials and solutions needed by customers.

We will help reduce our environmental impact and help tackle environmental issues through technology.
We will actively disseminate information and dialogue with stakeholders.

We will recognize and respect diversity so that every person and organization reaches their full potential.
We will contribute to the development of local communities as a member of those communities.

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What Is the Code of Conduct?
The Code of Conduct is a document that presents our guiding principles for the specificconduct that all executives and employees of the Nippon Shokubai Group should practiceearning the trust of all our stakeholders and promoting our business activities with an eye
toward fulfilling our Mission.
Each of us should act in a manner that represents Nippon Shokubai Group’s guiding
principles. In sharing these guiding principles, each employee will demonstrate theirindividuality and capability to enable us to fulfill our Mission.
Everyone working for the Nippon Shokubai Group is expected to adhere to the Code of
Conduct in their daily work.

Roles and Responsibilities of Executives and Managers

While the Code of Conduct indicates the behavior that everyone should practice during

regular work, the actual desired behavior varies depending on the type of job. Therefore,
practicing the Code of Conduct during daily work requires an understanding of the content
of the Code of Conduct and how it applies to each job.
Furthermore, daily management at each workplace is central for implementing the Codeof Conduct into everyday work.
Therefore, executives and managers in supervisory positions have the following majorroles and responsibilities in ensuring that everyone is following the Code of Conduct:

Act as a model

Lead by example to encourage associates to follow the Codeof Conduct.

Help instill the
Code of Conduct

Instill the Code of Conduct by applying it to each job
performed. Hold discussions to share how associates canimplement the Code of Conduct in their daily work.

Provide a safe
environment

To prevent behavior that violates the Code of Conduct,
provide an open atmosphere for associates to be able tospeak up when they do not know what to do or when aproblem has arisen.
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Steps to Take When Unsure of What to Do
Please go through the following steps when you are not sure what to do or when

you have questions about how to proceed.

Step 1

Step 2

Step 3Is this conduct in accordance with the applicablelaws and regulations, the Mission, Values, and Codeof Conduct of the Nippon Shokubai Group, andother corporate policies and internal rules?

Would this be described as proper conduct toother people around the world?

Would you engage in this same conduct if it
affected your family or close friends?

If you are unable to answer yes to anyof the above questions, the conduct inquestion is not what the Company
expects. Talk to your supervisor or

the relevant department to devise abetter alternative.

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If You Discover a Violation of the Code of Conduct
Everyone working at the Nippon Shokubai Group must comply with the applicable laws
and regulations, internal rules, and Code of Conduct. Violating them will cause us to lose
our stakeholders’ trust and keep us away from fulfilling our Group Mission. In addition,
violators will be subject to disciplinary action based on our employment rules.

The company’s profit or following the orders of a superior do not justify such violations.
If you discover questionable behavior or behavior that violates the laws and regulations,internal rules, or Code of Conduct, please inform your boss and discuss it with them. If thatcourse of action is not feasible, please contact the whistleblower desk at each Group
company for a consultation.

Furthermore, we will protect the privacy of reporters/whistleblowers.
Information given to any in-house whistleblower desk will be treated asconfidential unless otherwise required by law. In addition, the whistleblower will
not receive any disadvantageous treatment for having reported or discussed thematter providing that consultations and reports are not carried out withdishonest intent.

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Code of Conduct (Full Version)
1. Realizing a sustainable society
We will contribute to the realization of a sustainable society
by putting theGroup Mission
into practice.

(1) Contributing to the future for people and society
a. We will use our unique technology to provide economic, physical, as well
as social and spiritual prosperity and comfort to people and societies

throughout the world. By doing this and proactively tackling social issues
and customer challenges, we will help bring about a sustainable change.

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2. Safety first

We will execute our business activities by always ensuring
both internal and external safety.

(1) Comprehensive process safety and disaster prevention
a. Recognizing that safety is the foundation of our existence, we will observe
all laws, ordinances, and regulations concerning security and disasterprevention.

b. We will ensure the safety and well-being of workers, their families, andsociety through comprehensive implementation of programs to prevent
explosions, fires, leakage of hazardous materials, and accidents anddisasters that may harm the environment and people.

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2. Safety first(2) Workplace health and safety
a. We will strive to eliminate work-related disasters, and we will observe alllaws, ordinances, and regulations concerning workplace health and safety.

b. We will consider our health as well as the health of those working with us
and will strive to maintain and enhance a workplace environment inwhich everyone can be assured of safety and comfort.

(3) Business continuity

a. We will formulate a business continuity plan and take other appropriateorganizational initiatives and measures to ensure our workers’ safety andmaintain our business activities in the face of threats, such as

earthquakes, floods, and other natural disasters, pandemics and cyberattacks.

b. In the event of an actual threat, we will take the appropriate steps inaccordance with our predetermined guidelines and procedures forresponse.

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3. Compliance

We will enforce thorough-going compliance in every area.

(1) Observance of the applicable national and local laws,
ordinances, and regulations and business ethics
a. We will observe the applicable laws, ordinances, and regulations in the

countries and regions where we do business, and our codes of conduct

and in-house rules. We will behave with integrity, fairness, goodwill, in aself-directed fashion, and law-abiding spirit.

“Integrity” is doing your best for others without telling lies.
“Fairness” is taking actions that anyone would find just and convincing.
“Goodwill” is observing social etiquette.
“Self-directed” is seeing everything as relating to you.
“Law-abiding” is taking actions based on the purpose, intent, and context
of the rules.

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3. Compliance(2) Thorough-going compliancea. We will diligently collect information about the laws, ordinances, andregulations that govern our business activities.

b. We will implement thorough-going compliance, including formulating inhouse rules and manuals and offering opportunities, such as educational
and training sessions.

(3) Reporting and review of behavior that violates the Codeof Conduct
a. When we learn of behaviors that violate laws, ordinances, regulations,

our in-house rules or our Code of Conduct, we will promptly report anddiscuss it with the relevant supervisor. In cases where this is not feasible,
we will discuss the incident and report it to the company’s consultation
desk or internal whistleblower desk.

b. The internal whistleblower desk will protect whistleblowers’ identities
and promptly conduct an investigation of the relevant facts.

c. We will not condone reprisals against persons who reported incidents ingood faith or who cooperated in our investigations but will treat themfairly to avoid putting them in an unfavorable position.

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4. Respect for human rights

We will support international human rights standards
and respect the human rights of all people touchedby our business activities.

(1) Respect for human rights
a. We will respect everyone’s human rights and will not engage in any

conduct that unfairly discriminates or harms the dignity of an individual,
regardless of the reason.

b. We will prevent human rights violations by respecting international

human rights standards and the laws and ordinances of each country andregion. In the event of a violation, we will respond appropriately and with
fairness.

c. Recognizing that our business activities have an impact on human rights,
we will not provide products to firms or groups that commit or promote
human rights violations, and we will not take part in purchasing any
products or services from such firms or groups.

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4. Respect for human rights(2) Prohibition against forced labor and child labora. Under no circumstances will we ever engage in forced labor or child labor,
and we will not allow forced labor or child labor to take place in our
supply chain.

(3) Prohibition against discrimination
a. Under no circumstances will we ever engage in discrimination based on

gender, age, nationality, race, ethnicity, social status, place of origin, beliefs,
creed, religion, physical characteristics, sexual orientation, sexual identity,
or disease or disability.

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4. Respect for human rights(4) Prohibition against harassmenta. Under no circumstances will we ever engage in sexual

harassment, abuse of power, pregnancy discrimination, or otherdiscriminatory behaviors against another person or do anythingthat threatens them or makes them uncomfortable, regardless ofwhether such threat is physical or emotional.

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5. Fair and honest business dealings

We will engage in fair and sincere business activities
with all of our stakeholders.

(1) Fair and free dealings
a. We will observe the applicable laws, ordinances, and regulations concerning fair andfree competition and business activities in other countries and regions where we dobusiness. We will avoid any conduct which restricts free and fair market competition(abuse of market dominant position, cartel, and unfair trade practice) in every

business activity including sales, procurement, research and development, andmanufacturing, in order to ensure free and fair business activities.

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a. We will not commit any violation of anti-bribery laws of any country,
including making inappropriate payoff, offering or promising to pay

money/anything of value to public officials or will not make any illegal
facilitation payment (small payments for speeding up bureaucratic
procedures).

b. We will not aid, abet, or authorize any of such illegal conduct by any third
party.

c. We will not provide with or accept any entertainment and gifts, which go

beyond the bounds of socially accepted limits, to/ from clients, customers,
and other business partners.

(3) Respect for trade-related laws and ordinancesa. In trading raw materials and products, we will follow proper trade

procedures in accordance with the applicable laws and ordinances andwill not trade in contraband.

b. We will not export technology that will be used as information, materials,

or products in the production of weapons of mass destruction that wouldinterfere with the preservation of international peace and safety,
including nuclear, chemical, and biological weapons.

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5. Fair and honest business dealings(4) Responsible procurementa. Because our business activities are dependent on the cooperation of themany people and companies in our supply chain, we will promoteresponsible procurement practices and engage in transactions that arehonest and proper.

b. We work with our business partners so that they understand and relatewith our Code of Conduct as we engage with them.

(5) Proper management and use of corporate assets
a. We will not use the company’s tangible and intangible assets, including its
products, equipment, supplies, information, and intellectual property, forpersonal or inappropriate purposes; we will manage and use these assets
so as to prevent their loss, theft, or improper use and ensure theireffective use.

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5. Fair and honest business dealings(6) Respect for and use of intellectual property
a. We will strive to protect our intellectual property rights and use them in

effective way as we believe that patents, trademarks, designs, knowhow,

trade secrets, and publications are key corporate assets and the source ofour competitive strength.

b. In the manufacture and sale of our products, research and development,
provision of service, and other business activities, we will respect the
intellectual property rights of others and will not infringe on them.

c. We will proactively use our intellectual property in open innovation andother external partnerships, and we will develop and provide innovativeand effective products and services for solving the problems facing
society and our customers.

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5. Fair and honest business dealings(7) Information security
a. We will closely control access to our information assets and data systems
in order to prevent unauthorized access, loss, leaks, manipulation,
destruction, and hacking.

b. We will formulate measures to counter threats to our computer networkand endeavor to minimize any damage to ourselves and others.

c. On an ongoing basis, we will review our framework for responding toincidents should they occur.

(8) Management of confidential informationa. We will strictly manage the confidential information of others obtained in
the course of business.

b. We will not allow unauthorized disclosures or leaks, and we will not
permit such information to be used for purposes other than thoseintended, nor will we permit viewing by uninvolved parties.

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5. Fair and honest business dealings(9) Proper accounting practices and tax compliancea. In accordance with the laws and ordinances concerning accounting

standards in the countries and regions where our Group does business,
we will work to build effective systems of internal control and use
accurate and proper accounting practices.

b. We place great importance on tax compliance, and we will observe eachcountry’s and region’s laws and ordinances concerning corporate

taxation, etc., as well as tax treaties and international taxation rules.

(10) Protection of personal information and privacy
a. We respect individuals’ privacy and collect personal information to theextent necessary and appropriate. Also, we strictly manage the personal

information that we collect and will not disclose it to third parties or use
it for other than its intended purpose, except in cases required by law or
where we have received advance permission from the individual inquestion.

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5. Fair and honest business dealings(11) Prohibition against individual conflicts of interesta. We will not commit any act that uses information gained in the course ofbusiness to seek personal profit, or that is contrary to the company’s
interest.

b. We will not abuse our corporate position or authority, nor will we seek
personal profit or cause the company to lose money in violation of ourjob responsibilities.

c. We will not engage in any personal transactions that compete with theGroup, nor will we engage in any conduct that competes with the Group,
such as becoming a manager or key investor at a competitor.

(12) Dealing with antisocial forces

a. We will have absolutely nothing to do with antisocial forces that threaten
public order and safety or the stable business of the company, whether itis through business relations, money laundering, and other means ofproviding profits to those involved in such forces.

b. We will take a firm stance in rejecting improper demands from antisocial
forces.

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6. Providing value to our customers

We will provide the materials and solutions
needed by customers.

(1) Providing solutions to our customers’ problems
a. We will provide products and services that are responsive to ourcustomers’ needs and solve their problems.

b. We will innovate to drive forward with solutions to the needs of society
and our customers.

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6. Providing value to our customers(2) The “three actuals” principle
a. In all of our tasks, we will relentlessly observe the actual locations, actual
objects, and actual realities that underlie all of our work. The resulting
ideas allow us to take judgments and actions that are free ofpreconceptions.

(3) Providing safe and reliable products and services
a. We will meet our customers’ needs and specifications, ensuring safety

and quality so that our customers can confidently use our products andservices.

b. We will respond promptly and sincerely to our customers’ inquiries andfeedback and incorporate their feedback into enhancing and developing
our products and services.

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6. Providing value to our customers(4) Providing safe, high-quality informationa. When providing products and services, we will properly furnish thenecessary information regarding quality and safe usage in an easily
understandable way.

b. We will not falsify any of our business data or falsely represent that wehave acquired data that we have not.

(5) Dealing with product-related accidents
a. In the event of a problem with the safety or quality of a product that wehave provided to a customer, we will respond promptly and sincerely andwill take the appropriate steps to find the cause and prevent recurrences.

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7. Preserving the environment

We will help reduce our environmental impact and help tackle
environmental issues through technology.

(1) Harmony with the global environment
a. Based on the desire to leave a better global environment to the next

generation, we are controlling emissions of hazardous materials and aretaking initiatives to address environmental issues.

(2) Climate change initiatives

a. Besides reducing emissions of carbon dioxide and other greenhousegases in our business activities, we are helping to reduce emissions

throughout the supply chain by creating environmental contribution
products, thus contributing to bringing about carbon neutrality.

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7. Preserving the environment(3) Efficient use of resources
a. We are actively involved in resource conservation, waste

reduction, and recycling efforts so that our limited and precious
resources can be used more efficiently.

(4) Preserving biodiversity

a. Recognizing that our business activities do affect biodiversity,
we are promoting a deeper understanding and awareness ofpreserving biodiversity and biodiversity-friendly programs.

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8. Communicating with stakeholders

We will actively disseminate informationand dialogue with stakeholders.

(1) Fair disclosure of informationa. We disclose timely and accurate information about ourselves inaccordance with the applicable legislation, and we are transparent in our
explanations.

b. We take the initiative to actively disclose our financial information as wellas such non-financial information as our mission, policies, businessperformance, environmental programs, and stakeholder relations, thebetter to deepen understanding about our Group among shareholders,investors, and other stakeholders.

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8. Communicating with stakeholders(2) Communicating with stakeholdersa. We will actively engage in dialogs with our various stakeholders,

including customers, business partners, employees, local communities,

government bodies, shareholders, and investors, and strive to build andmaintain long-term relationships of trust with them and to gain theirsupport for the Group’s business initiatives. So that we will increase ourcorporate value.

b. We appreciate both positive and negative feedback from those outside theGroup, and we strive for two-way communication.

(3) Prohibition against insider trading

a. We will not buy or sell shares or other securities or recommend theirpurchase or sale to others based on material non-public information(information that would significantly affect the share price if disclosed)

about our Group or its business partners gained in the course of business.

b. If we possess material non-public information, we will not leak suchinformation prior to its disclosure.

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9. Promoting active participation of diverse humanresources

We will recognize and respect diversity
so that every person and organization reaches
their full potential.

(1) Respecting diversity
a. We will create a working environment and culture where

employees can work with diversity and mutual respect and cangrow together.

b. We, as professionals, will make every effort to show his or her
individuality and ability, which will lead to innovation.

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9. Promoting active participation of diverse humanresources(2) Fair hiring, labor, and compensationa. We will treat everyone fairly in accordance with their work skills and performance.
b. In assigning work locations, we will take into consideration our employees’ ability
and track record in performing their jobs well and getting their work done, theirchildcare and care-giving responsibilities, and their orientation.

c. We will maintain sound hiring and labor practices, and our treatment of employees

regarding wages, work hours, vacations, and the like will conform to the applicablelaws and ordinances of the respective countries and regions.

d. In accordance with the applicable laws and ordinances of each country and region, we
will respect the right to form or participate in labor unions, the right to engage incollective bargaining, and the right to assemble peacefully. We will also build healthy
management–labor relations through dialog.

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9. Promoting active participation of diverse humanresources(3) Promoting work–life balance and developing skills
a. We will enhance each person’s job satisfaction and skills by allowing them to have abalance between their job and their personal life, which may entail child-rearing,care-giving, and medical treatment, thus creating a work culture that engenders highperformance.

b. We will respect each individual’s orientation and will work in cooperation with them,taking into consideration their family situation, including childcare, care-giving, andother personal circumstances.

c. We strive to develop everyone's skills and build their careers through a variety of

training opportunities, including on-the-job training, in-house and off-site training
sessions, and self-study courses.

d. We will offer ample opportunities for our employees to develop their skills andadvance their careers and will support them so that they can take responsibility andpride in proactively tackling and solving the problems they face at work.

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10. Contributing to local communities

We will contribute to the development of local communities
as a member of those communities.

(1) Respecting local culturea. We will respect the natural surroundings, culture, traditions, and customsof the countries and regions where we do business, and we will work

together with local communities and contribute to their development.

b. We will work to participate in and contribute to local communities bymeans of local procurement and hiring.

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September 2022 Version 1