Compliance
Since our Group regards compliance with laws and social norms as a condition for the survival and development of thecompany, our course of action stipulates that we need to conduct “sensible business activities” and conduct ourselves as“good corporate citizens and decent members of society”. In response, we have recognized that compliance means complying with laws and social norms and established a compliance basic policy, in addition, we have been promoting compliance activities such as training sessions on corporate ethics for all employees.

Activities
a system that allows us to provide peace of mind by clearly defining in our rules the prohibition of interference with investigations, finding informants, and harassment.

Top Message Transmission
Every year, top message is transmitted to all employees in orderto clearly convey the Groupʼs stance for compliance.

Compliance Basic Policy

We hold training sessions on corporate ethics for officers andemployees, including new employee, working to ensure thateach and every one of us looks at compliance and actively promotes it.
In addition, regarding various laws and regulations, we regularly hold training on important business themes such as antitrust laws, insider trading regulations, and regulations on the“Combating Bribery of Foreign Public Officials”. We also conduct training with an emphasis on practicality, such as systematically holding in-house seminars themed on familiar legal matters, lectured by internal instructors.
Various trainings are provided to officers and employees ofour company as well as those of affiliated companies as efforts
to improve the knowledge of the entire Group.

Twice a year, the entire Group, including each division/department, plant/laboratory, and affiliate, checks the status of compliance, and in case of a risk of compliance violation or potential
compliance violation, the Risk Management & Compliance Officereceives reports including the response status. The content isreported to management and shared within the Group throughthe Risk Management & Compliance Committee to help prevent
recurrence.

1. W
 e consider compliance to be an important management issue and ensure thoroughcompliance in every aspect of its business activities, thereby establishing corporate ethics.
2. A ll officers and employees of Nissan Chemical Group shall be sufficiently aware of compliance and prevent the occurrence of a compliance violation.
3. In the event that a compliance violation has occurred or is likely to occur, we take aprompt and appropriate response.

Consultation Hotline

SystemIn our Group, the Risk Management & Compliance Committee,
which is held twice a year, has been established as an organization to enhance the effectiveness of risk management, and tomaintain and promote compliance. The committee is chaired by
the Chief Risk Management Officer (CRO), who is appointed at theBoard of Directors, and is composed of the Risk & ComplianceManagers of each division/department, plant/laboratory, and domestic consolidated subsidiary appointed by the CRO. The important matters and countermeasure plans, etc. related to compliance are approved at the Board of Directors after discussion at
the committee.
The Risk Management & Compliance Office under the Corporate Planning Department has been established as a specializedorganization to promote continuous improvement in all of ourgroupʼs compliance activities. In addition to providing educationand guidance on risk management and compliance, the Risk
Management & Compliance Office receives reports on the statusof compliance with laws and regulations and measures related
to compliance, etc. in each department on a regular basis from
Risk & Compliance Managers, and when necessary, supports
improvement, and shares information within our group.
Furthermore, we have established a system to prevent compliance violation or resolve the problem early on, including theConsultation Hotline as an internal reporting system based on
the Whistleblower Protection Act.

●Number of compliance violations
Indicator
Consultation Hotline Reports
Legal actions received for anti-monopoly/
anticompetitive practices (under investigation)

ScopeUnit2019

2020

20212022

Consolidated*

Cases

2218

Consolidated*

Cases

0 (0)

0 (0)

0 (0)

0 (0)

Fines charged and settlement fees foranti-monopoly/anticompetitive practices

Consolidated*

1,000 yen

0000

Confirmed corruption incident (underinvestigation)

Consolidated*

Cases

0 (0)

0 (0)

0 (0)

0 (0)

Fines charged and settlement fees for corruption

Consolidated*

1,000 yen

0000

Other incidents related to compliance(excluding environmental)

Consolidated*

Cases

0000

Fines charged and settlement fees for othercompliance related incidents(excluding environmental)

Consolidated*

1,000 yen0000* Includes domestic unconsolidated group companies

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We have set up a Consultation Hotline as an internal reporting
helpdesk to prevent compliance violations or resolve problems
early on. When an employee discovers a compliance violation or
potential compliance violation, the employee shall address theproblem in normal operation in principle, through measures that
include reporting the matter to their superior. However, if theemployee thinks it would be difficult to address the problem
promptly and effectively, they can use the Consultation Hotline.
The contact point for reporting shall be the Risk Management & Compliance Office, outside attorneys, or outside Audit &Supervisory Board members, and the means for reporting may
be selected from e-mail, mail, or telephone. Upon receipt of a report, the contents are reported to the Audit & Supervisory Boardmembers. The Board of Directors periodically receives reports
from the Risk Management & Compliance Office on the status of
the operation of the internal reporting system and supervises it.
While accepting anonymous consultations, we have established◎ Refer to the list on P79 for information on training in FY2022

Compliance Manual
The Compliance Manual sets forth rules so that executives andemployees, etc. (regular employees, contract employees, parttime workers, temporary workers and dispatched workers) of
the Nissan Chemical Group comply with laws and regulations,company rules, social norms, and ensure compliance. It is regularly reviewed depending on the situation, such as the enforcement and revision of laws and regulations. In addition, by including information about the Consultation Hotline system anddetails about its features in the Compliance Manual, we are raising awareness about our internal reporting system.

Compliance Manual Rules
As a corporate citizen

As a manufacturer

As a stakeholder of the Company

 omply with the laws/regulations of the industry●C nsure the safety of products●E rohibit conflict of interest●P● Restrict contributions and political donations

 rotect the environment●P● Terminate any relationships with antisocial forces● I mplement safety and disaster● Comply with antitrust laws
 onduct fair transactions with suppliers and●Ccomply with the “Act against Delay in Payment ofSubcontract Proceeds, Etc. to Subcontractors”● Prevent unfair competition
 omply with laws and regulations related to●Csecurity trade control
 omply with laws and regulations related to●Cimport/export● Prohibit excessive entertainment and gifts● Prohibit bribery of foreign officials, etc.
● Implement appropriate marketing and advertising● I mplement appropriate tax payment based on thetax systems in each country and international tax
standards

prevention measuresAs a public corporation
 isclose management information●D onduct appropriate accounting●Cprocessing

As a member of the workplace omply with work regulations●C espect human rights; prohibit●Rdiscrimination
 rohibit sexual harassment●P rotect privacy●P nsure the health and safety of the●Eworkplace rohibit political and religious●Pactivities

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 se corporate assets appropriately●U rohibit insider trading●PAs a person who handles
work-related information
 anage confidential corporate●Minformation appropriately

 se information systems●Uappropriately

 anage personal information●Mappropriately

 rotect intellectual property rights●PSustainability

Compliance Training

Compliance Status ReportingRisk ManagementCompliance
Anti-corruption Initiatives

Risk Management Basic Policy
1. W
 e place top priority on the safety of the lives of officers and employees of the Nissan
Chemical Group.
2. W
 e consider risk management as an important management issue, and engage in the activities from a company-wide perspective.
3. A
 ll officers and employees of the Group shall be sufficiently aware of risk management,
strive to improve their abilities, and endeavor to prevent the occurrence of loss risk.
4. We promptly share the information on risk throughout the Group.
5. W
 e make efforts to respond promptly and accurately to the occurrence of loss risk and tominimize losses.

Nissan Chemical Group Anti-Corruption Policy
1. Definitions“Corruption” means the abuse of entrusted official authority for personal or company gain, including bribery.
“Bribery” means that, when company conducts its businesses,- any of its officers or employees provides improper benefits to a third party for the purpose of inducing a third party to conduct fraudulent or illegal acts, or upon request from a third party, or- any of its officers or employees demands or receives improper benefits from a third party.
2. Commitment to Anti-Corruption
The Nissan Chemical Group has zero tolerance for corruption of any kind.
It shall not engage in any form of corruption relating to public officials, governmental agencies and any other clients (“BusinessPartners”).
It shall also continuously ask the Business Partners not to engage in any corruption.
3. Compliance with respect to Anti-Corruption
The Nissan Chemical Group shall comply with and require the Business Partners to comply with domestic and internationallaws and regulations concerning the prohibition of bribery and corruption, such as the Unfair Competition Prevention Act, theU.S. Foreign Corrupt Practices Act and the Anti-Unfair Competition Law of the Peopleʼs Republic of China (commercial briberyrules). It shall also keep and maintain accurate financial records relating to business transactions involving itself.
4. Remediation
In the event that the Nissan Chemical Group violates this Policy in the course of its business activities, it shall make efforts toremedy and correct the said violation through appropriate means and fully cooperate with investigations by the relevant authorities.
WebCompliancehttps://www.nissanchem.co.jp/eng/profile/compliance.html
Promotion of Fair-Tradinghttps://www.nissanchem.co.jp/eng/csr_info/communication/employee/acp.html●Measures for promoting compliance (FY2022)
General ComplianceDirector and management level compliance training, newly-appointed managers compliancetraining, new employee training

Anti-monopoly Act and Act
against Delay in Payment of
Subcontract Proceeds, Etc. toSubcontractors

Training related to the Anti-monopoly Act and Act against Delay in Payment of Subcontract
Proceeds, Etc. to Subcontractors; Internal audit related to the Act against Delay in Payment of
Subcontract Proceeds, Etc. to Subcontractors

Information Management

Information management training; Internal audit related to information management and My
Number Act related management

Insider Trading Regulation

SystemThe Risk Management & Compliance Office under the Corporate
Planning Department has been established as a specialized organization to promote continuous improvement in all of our risk
management activities.
In addition, the Risk Management & Compliance Committee,
which is held twice a year, has been established as an organization to enhance the effectiveness of risk management, and tomaintain and promote compliance. The committee is chaired by
the Chief Risk Management Officer (CRO), who is appointed at
the Board of Directors, and is composed of the Risk & Compliance Managers of each division/department, plant/laboratory,
and domestic consolidated subsidiary appointed by the CRO.
The Risk & Compliance Managers periodically conduct risk
identification and assessment, formulate countermeasure plans,conduct self-assessment for status of implementation of thecountermeasure plan and subject, formulate improvement plan,and regularly perform education and training at each division/

Security Export Control

Foreign Exchange Law related training

Consultation Hotline

Continuous dissemination of related information via the in-house newsletter and posters

Others

We clarified risks taking into account the business characteristics of each division and the surrounding businesses, including
global political, economic and social conditions. Subsequently,
risk assessment was conducted from the viewpoint of probability and impact on the business. By following the assessment, arisk map was created and Group Major Risks were identified.
The contents of major risks were deliberated at the Risk Management & Compliance committee and approved at the Board ofDirectors.

Risk Management &Compliance Committee
CRO

Training for insider trading prevention
Training for the prevention of corruption and Combating Bribery of Foreign Public Officials

Overall Risk Assessment Process

Board of Directors

Risk & Compliance Manager
Anti-bribery

department, plant/laboratory and domestic consolidated subsidiary.
The important matters related to risk management andcountermeasure plans, etc. are approved at the Board of Directors after discussion at the committee.

Risk Management & Compliance Office,Corporate Planning Department(Secretariat office)(Each division/department,plant/laboratory, anddomestic consolidated subsidiary)

ReportTraining for newly-appointed board members, training for board members, and contract-related
training

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Nissan Chemical Corporation

Sustainability Promotion Committee
Climate Change Committee
Environment & Safety Committee
Quality Assurance Committee

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Sustainability

ti-corruption advocated by the 10 principles of the United Nations
Global Compact (UNGC), in April 2018, we joined the UNGC, and in2019, we formulated anti-corruption policies covering our company, affiliated companies and their subsidiaries in April 2018. Furthermore, we have established a system to prevent complianceviolation or resolve the problem early on, including the Consultation Hotline as an internal reporting system based on the Whistleblower Protection Act.

Our Group strives to ensure the transparency of transactions. In
our compliance manuals, we have specified matters to be observed: Comply with antitrust laws, Conduct fair transactions
with suppliers and comply with the “Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors”, Prevent
unfair competition, Prohibit excessive entertainment and gifts,and Prohibit bribery of foreign officials, etc. With regard to an-We are promoting risk management under the supervision of the Chief Risk Management Officer (CRO) with the aim ofcontributing to the achievement of our management strategic goals through recognizing the various risks involved in theNissan Chemical Group, preventing the occurrence of loss risk and minimizing the impact of their occurrence.