Anti- Slavery and Human Trafficking Statement for FY2023
This document is a statement by Noritsu Koki Co., Ltd. disclosing its commitment
to preventing forced labor and human trafficking in the Group’s operations andsupply chain in accordance with Section 54 of the UK Modern Slavery Act 2015.
1. About the Noritsu Koki Group■Structure and Business Overview
The Noritsu Koki Group (the “Group”) has 13 consolidated companies (including
three core companies) and 1,246 employees (as of December 31, 2023), mainly inthe parts/materials business and the audio equipment/peripherals, which bothutilize globally advanced technologies. This statement is issued by Noritsu Koki Co.,
Ltd. (the “Company”) on behalf of its consolidated company AlphaTheta EMEA
Limited (European subsidiary of AlphaTheta Corporation, one of the core companiesof the Group) which is a reporting entity under the UK Modern Slavery Act 2015
(the Act).
For more information about the business of our Group, please visit our website.
https://www.noritsu.co.jp/business_en/■Supply Chain
This statement describes the supply chain of products supplied by the Group.
Products supplied by the Group are manufactured at plants operated byconsolidated subsidiaries and at plants operated by contract manufacturers (EMSproviders, ODMs). AlphaTheta EMEA Limited imports and sells DJ, music production
and audio equipment to individual and corporate customers in Europe, including theUK. This equipment is made in contract manufacturing plants located primarily in
China and Southeast Asia. The Group has established long-term collaborative
relationships with these contract manufacturing plants, which are required tocomply with the Noritsu Koki Group Procurement Policy.
■Corporate Philosophy
In its corporate philosophy, the Company’s mission is “Prosperity for society andpeople” and its vision is to be “A corporate group that continues producing ‘No.
1/Only 1’ businesses.” The Company aims to realize this mission and vision byimplementing its values – “Understand the needs of the age and think one stepahead,” “Pursue products and services that enrich lives,” and “Respect the potential

for growth and innovation and support a spirit of challenge.”
Corporate Philosophy:
https://www.noritsu.co.jp/about_en/
2. Policies Related to Preventing Slavery and Human Trafficking■Noritsu Koki Group Human Rights Policy
In July 2022, the Group disclosed the Noritsu Koki Group Human Rights Policy, which
was approved by the Board of Directors. The policy is based on international humanrights standards, including the International Bill of Human Rights, the ILO
Declaration on Fundamental Principles and Rights at Work and its follow-up, theGuiding Principles on Business and Human Rights, and the Children’s Rights andBusiness Principles. This Policy states that the Group will not tolerate any form ofslavery and human trafficking and expects all of the Group board members,
employees as well as its suppliers and other business partners to comply with thePolicy. To fulfill its responsibility to respect human rights, the Group is committed
to developing and continuously implementing a framework of human rights due
diligence to avoid causing or fomenting negative human rights impacts in its value
chain.
Noritsu Koki Group Human Rights Policy:
https://www.noritsu.co.jp/sustainability_en/other_policies_en/#section3■Noritsu Koki Group Code of Conduct
The Group has established the Noritsu Koki Group Code of Conduct to clarify its
basic management approach and expected standards of conduct for corporate
executives and employees. The Code of Conduct is based on the basic policy ofcompliance with all applicable laws and regulations in each country and region
where the Group operates, and consists of the following six items: (1) LegalCompliance, (2) Social Contribution, (3) Working Environment, (4) Information
Management, (5) Ethical Behavior, and (6) Delivering Safe and High-Quality
Products and Services.
Noritsu Koki Group Code of Conduct:
https://www.noritsu.co.jp/company_en/conduct_en/■Noritsu Koki Group Procurement Policy
The Group has established the Noritsu Koki Group Procurement Policy, which clearlystatesitscommitment

topromotingsustainableprocurement

includingconsideration for human rights and the environment, as well as legal compliance.

AlphaTheta EMEA Limited, a reporting entity under the Act has established an AntiSlavery and Human Trafficking Policy which states that AlphaTheta EMEA Limited
will not tolerate any form of slavery and human trafficking and expects all of its
business partners who works for, or on behalf of, AlphaTheta EMEA Limited
anywhere in the world to adhere to the same standards and report any concerns toAlphaTheta EMEA Limited.
Noritsu Koki Group Procurement Policy:
https://www.noritsu.co.jp/sustainability_en/other_policies_en/#section2
AlphaTheta EMEA Limited Anti-Slavery and Human Trafficking Policy:
https://alphatheta.com/en/company/anti-slavery-and-human-traffickingstatement-for-business-partners/
3. Efforts to Prevent Slavery and Human Trafficking■Human Rights Due Diligence
Since 2023, with the support of an external consulting firm, the Company has
conducted human rights due diligence at the Groupwide level to ensure efforts torespect human rights are effective, in line with the Noritsu Koki Group Human Rights
Policy. As the first phase in this process, in 2023 the Company assessed exposure
to human rights risks in Group businesses and created a human rights risk map.
The human rights risk map shows the severity and relevance of risks to the Groupin a matrix, visualizing which human rights issues should be prioritized.
■Risk Assessment and Monitoring
To respect human rights and eliminate slavery and human trafficking from theGroup’s entire supply chain, the Group believes suppliers must also share its values
and policies on respect for human rights. In 2023, the Group informed all its key
suppliers about the newly formulated Group Procurement Policy. The Group also
conducted supply chain audits of contract manufacturers through its quality audit
mechanism, which overlaps with some areas of the Group Procurement Policy. On
human rights issues, the Group implemented risk assessment at suppliers throughits human rights due diligence mechanism.
■Effectiveness of Actions
As noted above, the Group conducts risk assessments, raises awareness of policies
and carries out quality audits of contract manufacturers and suppliers annually. By
monitoring the number and results of audits, the Company verifies the effectivenessof measures to prevent human rights violations.

The Group’s efforts to address sustainability issues, including human rights issues
such as slavery and human trafficking, are reported annually to the Sustainability
Promotion Committee and the Board of Directors.
■Education and Training
In 2022, the Group formulated and published the Noritsu Koki Group Human Rights
Policy and conducted human rights training for all the Group’s executives andemployees to raise awareness of the policy and embed it across the organization.
In 2023, the Group carried out human rights training based on “Business andHuman Rights Guidebook” (published by HURIGHTS OSAKA) for all corporate
executives and employees. Human rights training will be conducted annually for all
corporate executives and employees.
AlphaTheta EMEA Limited has also invested in educating staff to recognize the risks
of modern slavery and human trafficking through mandatory training and staff areencouraged to identify and report any potential breaches of the AlphaTheta EMEA
Limited Anti-Slavery Policy.
■Remediation
The Group operates an internal reporting system covering the entire Group to
rapidly detect and prevent risks and issues in corporate activities. Each Groupcompany also operates its own whistleblowing hotline that accepts reports onactions that violate, or could potentially violate, the Noritsu Koki Group Code ofConduct, including legal violations, human rights issues and corruption. While theCompany and its Group companies accept reports through their websites fromGroup stakeholders, including workers in the supply chain, the Group recognizes
that it needs to establish more effective mechanisms for remedying human rights
issues.
4. Looking Forward“Creating inclusive workplaces where diversity is respected and all employees canthrive and contribute with a future-oriented mindset” is one of the Group’smateriality issues. As a specific measure focused on respect for human rights, theGroup is “respecting diversity and promoting more flexible ways of working.”
In 2024, based on the results of human rights risk assessments conducted in 2023,
the Group will continue to explore risks that need to be prioritized while also
formulating risk mitigation and response measures.
The Group will also continue efforts to raise human rights awareness across theorganization and implement human rights training to cultivate an open corporate
culture that respects diverse values and prevents human rights violations, including
slavery and human trafficking.
Noritsu Koki Group Materiality:
https://www.noritsu.co.jp/sustainability_en/materiality_en/#projectThis statement was approved by a director delegated by the Company Board ofDirectors.

July 2024
Representative Director and CEORyukichi Iwakiri