“Business Conduct Guidelines”
In carrying out corporate activities, we endeavor to respect human rights, toobserve relevant laws, ordinances, and regulations as well as social
standards, and to uplift the spirit of business ethics both in Japan and in
the world. We also strive to maintain and improve an appropriate
relationship with society as widely as possible, by taking part in theactivities of external organizations in cooperation with them, and by making
contributions to society, including global environmental protection activities.
We aspire to coexist with society with an adequate awareness of corporatesocial responsibility as business people.
Establishment of “Business Conduct Guidelines”
The Business Conduct Guidelines originate from the “Company Policy”.
The “Company Policy” which manages NKK’s business activities is deeply
rooted in the basic corporate philosophy, as follows: Based on the concept ofits raison d’etre (significance of existence) as a manufacturing company,
NKK will always provide the world with the most excellent products whichcustomers worldwide purchase to pay for a feeling of security and trust
incorporated in them, thereby contributing to society.
NKK carries out its business activities based on the “Company Policy”.
Meanwhile, we have newly established the “Business Conduct Guidelines”,
which serve as guidance for business conduct applicable to all members ofour company (code of conduct). We hereby clarify our ideal figures and oursocial responsibilities, and all of us are determined to make continued
efforts for achieving them.
With a full awareness of our mission as business people, we will address thecreation of a system to comply with the Business Conduct Guidelines, andwill constantly practice the code of conduct.
Scope of Application
The Business Conduct Guidelines apply to all directors, executive officers,
and employees of Nippon Kodoshi Corporation.
Business Conduct Guidelines
Chapter 1: Efforts for Performance of Business Activities
We will follow the path of a technology development-oriented company,

which satisfies needs of the present age by the application of traditional
technologies. We will make the utmost efforts to perform our daily
operations, based on a strong belief that the following is the task assigned
to ourselves involved in manufacturing, and is the social contribution which
can be made only by ourselves: We will seek new products and high added
values, and will provide customers with the world’s most excellent productsby the discovery of the things that meet the world’s future technologicalneeds, and by constant self-reinvention and enhancement of capacity
building.
When pursuing business activities, we will adhere to the fundamental
position of a manufacturer that we will steadily perform all of what weshould do as a matter of course to meet customers’ expectations.
1) Efforts for technical development
We will make continued efforts to win consumers’ satisfaction and trust,by way of developing and offering products which are beneficial to society.
We will also make strategic efforts for the creation of NKK’s intellectual
properties, acquisition and protection of their rights, and the applicationof them in order to maximize NKK’s corporate values.
2) Efforts for ensuring safety and for maintaining and improving quality
When developing and offering products, we will share a common
understanding that ensuring safety and maintaining and improving
quality are essential to the attainment of customers’ continued
satisfaction and trust. Based on this belief, every one of us will address
production activities.
3) Efforts for maintaining and upgrading stable supply
Our manufacturing products have a high market share both in Japanand in the world, and so against all possible risks we will take every
measure to maintain and upgrade the current stable supply system fromthe global point of view, including the stable procurement of raw
materials, dispersion of plants and offices into suitable locations,reorganization of internal control systems, and other efforts.
Chapter 2: Relationship between society and ourselvesToday’s global environmental problems are shared by the entire human race,and have significant impacts on continued corporate existence and activities,

and so we will make aggressive efforts to promote such activities as
intended for leaving and passing a better global environment onto the next
generation, in view of collaboration with administrative agencies, NPOs,and local communities. We also make efforts to pursue fair and transparent
corporate activities, to maintain and improve an appropriate relationshipwith society as widely as possible.
1) Coexistence and co-prosperity with customers
In pursuit of achieving NKK’s sustainable growth and development, wewill do our best, in all sincerity and in good faith, to maintain andimprove a fair and stable relationship with customers.
We will respect the intellectual property rights of other companies. We
will also make efforts to abide by relevant laws, ordinances, andregulations, and to understand and apply them whenever necessary.
2) Social contribution activities
We are well aware that it is our obligation as a good corporate citizen to
actively engage in creating a better society. With this awareness and as
part of our corporate activities, we will make efforts for global
environmental protection based on relevant environmental polices,control manuals, and other criteria. We will also endeavor to establish
communication with society, including local communities, as widely as
possible, and to find out social needs and problems. Accordingly, we will
make voluntary efforts to take many measures for the satisfaction ofsocial needs, and for the substantial resolution of social problems.
In addition, we will strive to address environmental protection as far as
we can do so in our individual daily lives as a private citizen.
3) Information disclosure
Since we assume a social responsibility to shareholders and investors, aswell as to customers and local communities, we are aware that it is ourresponsibility to establish communication with them widely as an open
corporation. Based on this awareness, we will make efforts to release
information to them in as many ways as possible.
To increase the transparency of our corporation, we will disclose in atimely manner not only statutory information (legally required
information), but also such information as we consider necessary forusers at our discretion.

Chapter 3: Relationship between NKK and its employees
Based on the understanding that a company and its employees areimportant partners in the promotion of corporate activities and in thecreation of new corporate values, we have a high regard for dialogues
between NKK and its employees.
In the present day, with growing diversity in individual values, it isimportant that NKK will do its best to respect the characters andpersonalities of its employees, and to manage a personnel system in which
employees enjoy the amenities of life. Meanwhile, it is vital for employees tomake proactive efforts for their repeated reinventions in response to socialchanges. We believe that continued efforts by both parties will only make itpossible to achieve NKK’s sustainable growth and development.
Above all, as a manufacturer, we will make efforts to ensure a safe andemployee-friendly working environment in cooperation between NKK and
its employees.
1) Respect for human rights
We respect fundamental human rights, diverse values, personalities,characters, and the privacy of individuals, and give employees by nomeans any discriminatory treatment due to their nationality, gender,beliefs, or social standing. We will immediately take appropriate
measures against any such offensive actions and words as deemed toviolate the code of conduct.
2) Efforts for occupational safety and health measures
We will strive to ensure an employee-friendly and comfortable working
environment conducive to employees’ health and safety, by way ofconstant and positive activities carried out by the organization for themanagement of occupation safety and health. We will also make efforts toimplement measures for mental healthcare at workplaces, in pursuit ofmaintaining and improving employees’ overall health, both physicallyand mentally.
Supplementary rules
We will revise the “Business Conduct Guidelines” whenever necessary, toappropriately respond to enactments or amendments of applicable laws,ordinances, and other regulations, and to changes in social conditions. Forany acts outside the provisions of the Business Conduct Guidelines, we will
behave in compliance with public order and morals.
If any incident or misconduct arises, we will address such problem asfollows:
1) We will immediately clarify and reveal facts.
2) We will investigate and find out the main cause, and take measures toprevent a recurrence.
3) We will cope with the matter in good faith, regardless of where theresponsibility lies.
If employees behave in violation of the “Business Conduct Guidelines”,
either intentionally or by gross negligence, and if the Employment
Regulation is applicable to such behavior, then disciplinary measures will betaken against such behavior pursuant to the employment regulation. Ifdirectors or executive officers perform such acts as offensive to the“Business Conduct Guidelines”, then disciplinary measures will be taken
against such acts in light of the company law and other applicable laws,
ordinances, and regulations.

NIPPON KODOSHI CORPORATION(Revised June 18, 2015)