Nittobo Code of Conduct
1. Code of conduct for responsibility as a provider of products and services
The Nittobo Group is committed to developing and providing safe, effective, quality products
and services that satisfy our customers and offer fair value. To achieve this goal, we arecommitted to identifying the true needs of our customers, pursuing safety from thedevelopment phase, and paying due attention to environmental issues during manufacture
and other phases, thereby fulfilling our corporate responsibilities as a provider of products
and services.
1-1. Developing and providing products and services that satisfy our customers

Recognizing our central mission—to contribute to society by providing better products
and generating new value—we are committed to creating new technologies that meetcustomer needs and to pursuing research and development for new products. We put
quality and safety before all else and strive to reduce costs through efficient and ecofriendly production, thereby realizing products that meet the needs of our customers.

1-2. Ensuring quality and safety

A fundamental duty of any company that provides products and services is to prevent
accidents attributable to defects in such products or services. In particular, under the
Product Liability Act (PL Act), companies bear liability without fault for damages
attributable to safety-related defects. Ensuring quality and safety requires unremitting
pursuit of safety and quality in accordance with the Nittobo Group Quality Management
Regulations. It is also important to communicate to our customers in a clear, appropriate,easy-to-understand manner important information, including precautions against use forpurposes and in ways that differ from those intended and hazardous actions that must be
avoided.

1-3. Providing appropriate information on products and services

Quality and price are important criteria by which our customers select products andservices. Representations that make the quality or trade conditions of a product orservice appear far better than the actual quality or trade conditions by alteration of data
or incorrect inspection methods are prohibited under the Act against Unjustifiable
Premiums and Misleading Representations and the Unfair Competition Prevention Act.
The quality and price of a product or service must be well-grounded and appropriately
indicated to give customers a reliable basis for their selection of products.

1-4. Preventing and responding promptly to complaints and accidents

The quality management needed to provide quality products and services and to preventthe occurrence of complaints and accidents is among our basic responsibilities. In theevent of complaints or accidents, we are responsible for responding promptly and in goodfaith. In cases involving safety issues, we are responsible for taking every action tominimize damage in cooperation with relevant departments. Additionally, we are
obligated to investigate causes from every angle and to adopt measures to avoid
recurrences. Such responses help restore customer faith and confidence. Alongside
efforts to develop better products, such actions can further strengthen the bond of mutual
trust. To this end, we are committed to improving our internal systems and to providing
the necessary training and education.
22. Code of conduct for compliance with applicable laws, ordinances, andsocial norms
The Nittobo Group recognizes that companies are public entities operating within a societal
framework, responsible for compliance not just with laws and ordinances, but with social
norms, as part of efforts to justifying societal trust and confidence. This is the raison d’etre
for any company, one that continues to apply so long as a company is a member of society. A
wide range of laws and ordinances, including the Companies Act, apply to companies.
However, the goal is not just compliance with the letter of the law, but pursuit of businessactivities in a fair and impartial manner, based on the spirit of legal compliance and an
unshakable sense of ethics. For this undertaking, it is important that we pay special attention
to the following topics:
2-1. Full compliance with Anti-Monopoly Act

Established to promote free and fair competition and to ensure that companies can act
freely based on their own judgment, the Anti-Monopoly Act requires the special attentionof every individual engaged in business activities. It is a violation of the Anti-Monopoly
Act to agree on supplied quantities or prices or to engage in market share allocation withcompetitors; or to capitalize on advantageous positions to force unfair trade practices on
counterparties. Similar laws in place overseas are referred to as competition laws. Suchactions, when committed in relation to a product destined for an overseas market,
constitute violations of the relevant country’s competition laws. Violations of the AntiMonopoly Act or competition laws not only impair societal trust in a company; theysubject the company and persons in question to civil and criminal liability. We must fully
understand the spirit and intent of these laws; avoid such actions, even in highly
competitive environments; take all due safeguards to avoid wrongdoing; and act in a fair
and transparent manner. We must be especially vigilant concerning participation inmeetings of trade associations and making contact with competitors.

2-2. Respecting intellectual property rights

Intellectual property rights are intangible property rights arising from creative
intellectual endeavors, including patents and utility model, design, trademark, and otherindustrial property rights, as well as copyrights to works of art, papers, or computer
software. We are bound to respect these rights as the product of the wisdom and efforts
of companies and individuals and to avoid any infringements thereof across our supply
chains from a global perspective. We must refrain from actions such as unauthorized useof patented inventions, registered trademarks, and copyrighted works belonging toothers.
Likewise, we are obligated to protect the intellectual property rights of the Nittobo Group.
We will acquire, manage, and use intellectual property rights appropriately from a global
perspective based on good faith considerations for the technological development andbusiness activities of the Nittobo Group, our customers, and competitors. Conversely, wemust respond effectively and appropriately to any infringements by others of Nittobo
Group intellectual property rights.
In addition, trade secrets, or technical and business information kept in confidence,
aspects widely recognized or well known as representations of products or businesses,
and even the shapes of products also constitute intellectual property (rights). Note thatobtaining or using other parties’ trade secrets by inappropriate means, improperly
impersonating something widely recognized or well known as a representation of3

another’s product or business, or mimicking the shape of another product may violate
the Unfair Competition Prevention Act.
The trade secrets of the Nittobo Group, on the other hand, must be managed
appropriately in accordance with the Intellectual Property Management Regulations andthe Trade Secret Control Policy and Procedures. Likewise, the trade secrets of otherparties, appropriately obtained, must be appropriately managed in accordance with theTrade Secret Control Policy and Procedures.

2-3. Export controls

Maintaining international peace and safety is essential for corporate activities. Control
procedures must be established to prevent the use or diversion of exported products andtechnologies to develop or manufacture weapons of any kind, whether conventional or
weapons of mass destruction. Before exporting products or technologies, we are boundto confirm that they can be legally exported under the Export Control Regulations.
Similar confirmation is required for products and technologies sold or provided forexport purposes, even if they are not exported by us.

2-4. Ensuring compliance with applicable laws, ordinances, and social norms within
the company

We must strive to collect information proactively, on a daily basis, on the social situationand the establishment, revision, and abolition of domestic and overseas laws andordinances relevant to business activities and to deepen our understanding of these andrelated issues. Full compliance with such laws, ordinances, and social norms requires
establishing necessary internal rules and promoting awareness within the company
through education, training, and publicity activities.
If you suspect an action may be illegal or deviate from social norms, consult your superior
and relevant departments to ensure appropriate action.

2-5. Tax compliance initiatives

Contributing to social progress by fulfilling tax obligations through corporate activities isanother corporate social responsibility. It is vital to recognize appropriate tax paymentsin accordance with applicable domestic and international laws and ordinances as animportant topic that contributes to economic and social development and to implement
proactive tax compliance initiatives. Tax compliance failures can lead not just to directrisks such as tax litigation or penalties, but to loss of trust in the organization anddeclining relations between the Nittobo Group and the countries and regions in which itdoes business.
To fulfill its social responsibilities regarding tax affairs, the Nittobo Group consistently
strives to promote awareness on tax compliance in accordance with the Tax Compliance
Guidance.

3. Code of conduct for information

To ensure its survival as a trusted company, the Nittobo Group is obligated to increase its
transparency and to disclose information on its business activities to the general public in atimely and appropriate manner.
Information is a key management resource for ensuring the smooth undertaking of businessactivities whose handling and management requires the utmost care because information
improperly handled can threaten the very existence of a company.
43-1. Disclosing information in a timely and appropriate manner
As part of efforts to further dialogue with all stakeholders, we pledge to disclose in an
accurate, impartial, and timely manner not just the information we are legally required todisclose, but information that may be useful in understanding our company, including
management policies, management philosophies, and lines of business.
The Nittobo Group maintains internal systems to ensure timely and appropriate
disclosure. When we receive disclosure requests from outside, the public relations orother department in charge will respond in good faith. When we receive inquiries about
any information whose published/unpublished status is unclear, we must always consult
the relevant departments before taking action.

3-2. Gathering and managing information appropriately(1) Gathering information

When gathering information necessary for our business activities, we pledge toobtain this information by legal means and to refrain from illegal activities. We pledge
to refrain from gathering information not needed for our business activities,
especially personal information that may lead to discrimination.

(2) Managing trade secrets

Every piece of information in the company’s possession (whether in the form of
document, data, physical article, equipment, or otherwise) constitutes a trade secret.
Any leakage of a trade secret poses the risk of crippling the company’s ability to carryon. Employees have the duty of maintaining the confidentiality of company
information and must manage company information appropriately and in accordancewith the provisions of the Trade Secret Control Policy and Procedures.

(3) Managing personal information

Personal information is an information asset business enterprises are required tosafeguard under the Personal Information Protection Act and other laws. Businessenterprises must manage collected personal information so that the information is
not leaked. Note that the Act basically prohibits the collection of information forunspecified purposes and the disclosure of personal information to third parties
without the consent of the subject of the information.
The company retains personal information on its customers, employees, and so on.
This information must be handled with the greatest care, used only for the intended
purposes, and placed under strict controls to prevent improper disclosure.

(4) Managing information on information networks

The growth of information networks used for advanced information processing andinformation sharing increases the risk of unintended information disclosure. Whenusing network systems, we must take precautions to prevent the misappropriation,
alteration, or leakage of information, keeping in mind at all times our obligation torespect information belonging to or concerning others and to avoid damage to suchparties.

3-3. Prohibition of insider trading

The Financial Instruments and Exchange Act bars insider trading, defined as selling or
buying company shares or other negotiable securities based on important information5

concerning the company’s businesses (the issuance of shares, a dividend increase or
decrease, a merger plan, a revision of a financial forecast, etc.) prior to publicdissemination.
In accordance with Insider Trading Management Rules, the employees of the Nittobo
Group must obtain advance permission before trading Nittobo shares. Any trading of
Nittobo shares must follow these rules.

4. Code of conduct for the environment

Deeply aware of its obligations to transfer our precious global environment to the next
generation in the best condition possible, the Nittobo Group recognizes environmental
protection as a prerequisite in all phases of corporate activities and business development,
both domestic and overseas, for corporate growth and survival. This entails a responsibility
for the following issues:
4-1. Addressing environmental issues

We pledge not merely to abide by legal requirements, but to grasp their underlying
philosophies and principles; prioritize environmental protection; and address climatechange, make effective use of resources, reduce hazardous substance emissions, preserve
biodiversity, and implement other measures to lessen our environmental impact
systematically and continuously. Based on this commitment to environmental issues, we
generate new business opportunities and social value.

4-2. Addressing climate change

We pledge to address the global issue of greenhouse gas emissions by promoting energy
conservation and expanding use of renewable energy.

4-3. Making effective use of resources

We must make effective use at all times of our limited resources and promote
environmentally-aware activities in all our business activities, ranging from research anddevelopment to procurement, production, distribution, and sales, as well as in all phasesof the product life cycle, from use to disposal. This focus will contribute to environmental
protection and to technological innovation and long-term profitability.

4-4. Reducing hazardous substance emissions

Reducing hazardous substance emissions is key to protecting the earth’s environment.
We are responsible for reducing emissions of hazardous chemical substances, including
those regulated under the PRTR Act, and for promoting substance control and systematic
emissions reductions to reduce environmental risks such as air, soil, and water pollution.
Additionally, we pledge to encourage our counterparties to make similar efforts.

4-5. Preserving biodiversity

Recognizing that biodiversity is essential to a sustainable society, we pledge to contributeto society through efforts to preserve biodiversity and the development and promotionof products and technologies that help preserve biodiversity.
(1) We will account for the impact of business activities on biodiversity and strive topreserve biodiversity and make sustainable use of resources.
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(2) We will account for the impact of our supply chains on biodiversity and strive toachieve coexistence with nature.

(3) We will strive to develop products and technologies that account for the environmentand contribute through their provision and promotion to the preservation of
biodiversity.

(4) We will comply with domestic and international laws, ordinances, and otherprovisions concerning biodiversity.
(5) We will help establish a society that nurtures biodiversity by raising employee
awareness of biodiversity and through communication with stakeholders.

4-6. Consideration for local communities

Efforts toward harmonious coexistence with local communities are a critical aspect ofbusiness activities. We must pay attention at all times to the safety, health, and theenvironment of local communities when engaging in business activities; strive to enhanceinteractions with community stakeholders; and promote communication to gain trust
and understanding of our efforts.

4-7. Enhancing environmental awareness and practicing green activities

We pledge to promote and undertake education, information provision, and otheractivities that will help all employees maintain high awareness of issues related to theenvironment, safety, and health, striving to pass on to the next generation our recognitionof the importance of environmental awareness.
There are many daily opportunities for both the company and employees to consider
environmental issues and to practice green activities, including waste reduction. Each
such activity contributes to the environment.
To implement these policies, we are committed to voluntary, proactive environment
management pursuant to the Environmental Charter.
As specific goals, we pledge to establish voluntary environmental policies, management
standards, and action plans for each business site; make continuous improvements; andprovide the general public with information on these activities.

5. Code of conduct for human rights

The Nittobo Group recognizes respect for human rights as an important aspect of its
corporate social responsibility. We support international norms such as the Universal
Declaration of Human Rights, the United Nations Global Compact, and the United Nations
Guiding Principles on Business and Human Rights. Accordingly, we have identified thefollowing policies concerning respect for human rights and will promote their permeation
both inside and outside the organization. We believe it is vital for each and every employee toact based on these policies to fulfill our responsibility to respect human rights in all businessactivities.
5-1. Understanding of and respect for human rights

In addition to efforts to understand internationally acknowledged human rights, we will
strive to respect the human rights of all those involved in the business activities of the
Nittobo Group and to refrain from any violation thereof. We will also promote thepermeation of this outlook through appropriate education and training and other efforts.
75-2. Human rights due diligence
We will develop and properly implement a set of processes (human rights due diligence)necessary to investigate, assess, and address the impact of business activities on humanrights.

5-3. Prevention and rectification of human rights violations

In addition to advance efforts to ascertain in advance, prevent, and mitigate potential
violations of human rights, we will act to swiftly rectify and remedy any violations that
may arise through appropriate internal and external procedures.

5-4. Prohibition of discrimination

In hiring, treatment, and all other corporate activities, we will pay due regard toindividual human rights. We will refrain from discrimination and other actions
detrimental to individual dignity for reasons such as race, ethnicity, nationality, language,
religion, belief, creed, social status, age, gender, academic background, disability, sexual
identity, or sexual orientation.

5-5. Prohibition of child labor and unfair labor practices

We will employ employees in accordance with the laws and ordinances of individual
countries and regions and with international norms. We prohibit forced labor and childlabor of children under the minimum working age specified by laws and ordinances.

5-6. Respect for basic labor rights

We respect the rights of employees to organize and to engage in collective bargaining,based on international norms, while complying with all laws, ordinances, and labor
practices of each country and region.

5-7. Contributing to an inclusive society

The Nittobo Group seeks to contribute to an inclusive society in which all can findacceptance and support, free of exclusion, through efforts to support the independenceof the most vulnerable in society, who are most at risk of human rights violations.

6. Code of conduct for respect for individuality and personality

The Nittobo Group is firmly committed to establishing sound working environments in which
all employees are accorded due respect in the spheres of human rights, individuality,
personality, and privacy and in which all employees receive fair, impartial treatment and equal
opportunity, free of illegal labor and discrimination. We must create an environment ofmutual trust in which all are free to work to the best of their abilities. These are the baseline
requirements both for establishing a working environment characterized by flexibility andopportunity and for business activities at the highest levels. We consider compliance with thefollowing guidelines to be crucial to achieving these goals.
6-1. Creating a working environment that makes the most of every employee’s
originality

The Nittobo Group will be fair, impartial, and transparent in its personnel affairs,
including employment, assignment, evaluation, and promotion, so that every employee’s
originality, creativity, and self-motivation are turned to good account, regardless of
8

factors such as nationality, gender, age, disability, sexual identity, or sexual orientation.
We seek to create working environments in which each and every individual is respected
and can fully demonstrate their individual abilities, based on effective support in areas
such as career building and skills development. We pledge to establish working
environments that provide flexibility with respect to annual leave (in hourly
installments) and in working formats, including flextime and work from home. We will
maintain and improve work systems that enhance both productivity and employee
satisfaction and allow personnel to exhibit their individual capabilities and originality.
However, it is the people at the workplace who actually use these systems and create theworking environments in which they can exhibit their own capabilities and are motivatedto take up new challenges. We have high expectations for our employees with regard totheir enthusiasm to build workplaces in which they can achieve self-realization and job
satisfaction.

6-2. No discrimination, no harassment

The workplace must remain free of discrimination or harassment based on race, ethnicity,
nationality, language, religion, belief, creed, social status, age, gender, academic
background, disability, sexual identity, sexual orientation, and other such factors. We
pledge to take stringent action to ensure that this remains the case.
One social issue prevalent in these times is harassment (sexual harassment, power
harassment, etc.). Harassment constitutes an encroachment of human rights anddegrades the working environment. In addition to harassment, practices such as child orforced labor, improper treatment of foreign workers, and unreasonable disparities basedon differences in forms of employment must not be tolerated. We will commit ourselvesto their prevention and proper settlement.

6-3. Adhering to the Equal Employment Opportunity Act for Men and Women, etc.

Creating a working environment in which employees can work pleasantly anddemonstrate their capabilities is not only a must for a society supported by both men andwomen, but important for maintaining the vitality of society.
The Equal Employment Opportunity Act for Men and Women prohibits discrimination
based on gender and disadvantageous treatment due to pregnancy and childbirth. The
Nittobo Group is committed to realizing substantial equality of opportunity and fostering
a working environment in which both male and female employees can work with a senseof security.

6-4. Compliance with labor laws

The Nittobo Group abides by the Labor Standards Act and other labor-related legislationand pledges to refrain entirely from the use of illegal labor.

7. Code of conduct for safety and health

The Nittobo Group strives to maintain the safety and comfort of its workplaces, spaces inwhich much of our time is spent. As part of these efforts, we abide by all applicable laws andrules, monitor workplace safety, implement precautions to prevent industrial accidents, andstrive to promote mental and physical health. We believe the following guidelines are crucial
to achieving these goals:
7-1. Preventing industrial accidents

9Eliminating industrial accidents is a precondition for creating safe, comfortable, andpleasant working environments. This goal requires 100% compliance with all applicable
rules by all of us. Daily education, guidance, and training are essential to preventing
industrial accidents. All employees are responsible for maintaining high safety awarenessat all times and for taking an active role in safety activities, including proposing
improvement plans. Safety equipment must be inspected and maintained at all times. In
particular, it is vital for equipment used to handle hazardous materials and explosive andhigh-pressure gases to be inspected and maintained at periodic intervals.
Other efforts to prevent industrial accidents include establishing themes and techniques
for the entire company, including activities to strengthen 5S activities and develop risk
assessments. Traffic accidents pose another major issue. We are all responsible for taking
appropriate measures to ensure traffic safety, whether on or off duty.

7-2. Managing health

The mental and physical health of employees is crucial not just for themselves, but for
their families and for the company. Each and every employee is responsible for being
aware of and managing his or her own health condition.
The company takes all necessary measures to help employees improve and maintain theirhealth. In addition to periodic health and stress checkups and workplace hygiene
management, the company strives to constantly improve the systems needed tosafeguard employee health, including medical counseling to prevent
lifestyle/occupational diseases and for mental health.

8. Code of conduct for corporate philanthropy

Business enterprises today are expected to carry out business activities in harmony withsocietal interests and to act as good corporate citizens in supporting society and advancing
alongside it.
The Nittobo Group contributes to social progress by providing improved products andservices. Beyond this, the Nittobo Group pursues social contribution activities in recognitionof its responsibility to contribute to society.
In developing our business overseas, we also engage in social contribution activities while
operating businesses based on due consideration of local cultures, customs, and situations.
8-1. Communicating with local communities

Growing and operating in harmony as well as valuing relations with local communities as
good corporate citizens is vital for business enterprises.
We must maintain steady efforts, such as allowing local communities to make use ofcompany facilities, holding factory tours and public meetings, participating in cleanup
campaigns, and supporting education.
We consider it our duty to provide aid and support for disaster prevention and relief
activities in the event of a disaster or other emergency.

8-2. Supporting social contribution activities

Volunteering for disaster relief and working to improve community welfare are
significant activities for society. The company encourages and supports volunteerism andsocial contribution activities among its employees and strives to maintain and improve
its internal systems to allow employees to proactively participate in such activities.
109. Code of conduct for relationships with counterparties
In its sales and purchasing transactions, the Nittobo Group pledges to abide by all applicablelaws, ordinances, social norms, and customary trade practices; respect the position of allparties involved; and implement fair trade practices. We must follow proper procedures andact in moderation at all times, seeking to avoid unjust benefits, whether given or gained. Gifts
and entertainment must remain within the bounds of common sense. We must take all due
care to avoid violating legal provisions and social norms in these activities.
9-1. Fair sales transactions

Sales transactions must be based on appropriate negotiations in good faith. Explanationsof products and services must be accurate and well-grounded.
Rebates and discounts for sales promotion must comply with established standards, freeof arbitrary judgments by individuals. They must be paid only to direct purchasers orothers of a similar nature.

9-2. Proper purchasing

When purchasing the materials needed for our business activities, we are responsible forproviding business opportunities to a wide range of potential suppliers. We arecommitted to avoiding special and undue treatment for any party and for providing fairand rational evaluations of quality, price, delivery, and other parameters. We will neverprioritize personal interests or relations or provide preferential treatment to specificparties.
The Subcontract Act prohibits certain price undercutting practices, refusing to receive
delivery, and delaying payment without reasonable justification. We are obligated to takeall due care to ensure that our terms of business with partners and other parties do notdiffer unfairly from those with general suppliers. Purchasing conditions must be
evaluated and determined for each transaction. We must ensure that no single purchasingtransaction is conditional upon another transaction, whether a specific exchange,
aggregation, or lending or borrowing.
The Nittobo Group’s business activities would not be possible without the cooperation of
our counterparties. We strive to achieve coexistence and coprosperity alongside ourcounterparties through fair and transparent transactions based on mutual respect foreach other’s position.

9-3. Responsible procurement for a sustainable society

Business enterprises must engage in responsible procurement in support of a sustainable
society. The Nittobo Group has established the Nittobo Group Sustainable Procurement
Policy, which sets forth our approach to achieving a sustainable society through our
supply chains. The Nittobo Group will communicate this Group policy to our suppliers
and ask for their understanding.
In addition, we will monitor supplier initiatives through questionnaires and on-site
inspections and provide support as needed when issues must be rectified.

9-4. Maintaining moderation when giving or receiving gifts and entertainment

As part of our business activities, we may give gifts and entertainment as needed tobusiness counterparties and other stakeholders to build deeper relationships.
Nevertheless, we must take care to ensure that such gifts and entertainment remain
within the bounds of common sense in terms of content and frequency; that they will not11endanger our reputation or that of our counterparties; and that they are not subject tolegal restrictions. The same applies to gifts and entertainment offered to us. We must also
be mindful of the standards of conduct our counterparties are obligated to observe, if they
happen to have such. Further, we must keep in mind the following, depending on thenature of the counterparties:(1) As a general rule, we do not give gifts or entertainment to officers or employees ofgovernment agencies and similar public organizations. Should gifts or entertainment
be appropriate under certain conditions, they may be provided with the approval of
the relevant superior and in accordance with the standards of ethical conduct of therelevant government agency or the like.

(2) Offering gifts or entertainment to foreign government employees and to the officials
and employees of similar public organizations may constitute a violation of the Unfair
Competition Prevention Act of Japan or may be punishable under applicable foreignlaws and regulations. Since even gifts and entertainment through third parties may
create the impression of Company wrongdoing, it is vital when hiring local
representatives to employ sufficient care: for example, by evaluating their trackrecord and reputation and verifying their business operations in a timely andappropriate manner.

(3) Receiving and providing gifts and entertainment between Group companies is
prohibited. The same applies in principle to our business partners. Keep in mind thespirit of moderation at all times for luncheons/banquets that form an integral part ofmeetings and specific events as well.

(4) Receiving gifts and entertainment requires an equal degree of care and sense of
propriety to providing them. The company may be harmed if receipt of gifts andentertainment unduly affects vendor selection.

9-5. Addressing conflict minerals

Conflict minerals refer to minerals extracted under conditions that involve conflict orhuman rights violations. Since use of conflict minerals may unwittingly provide support
to armed groups or contribute to human rights violations such as child labor, it is vital todemand that suppliers refrain from procuring materials that may contain conflictminerals and to conduct the necessary checks.

10. Code of conduct for risk management

To fulfill their social responsibilities while increasing corporate value in the face of theincreasingly diverse and complex risks accompanying increased globalization, businessenterprises must establish risk management structures and respond systematically. It isessential to avoid and minimize risks and reduce potential losses by ascertaining andassessing them at all times and implementing preventive measures. We pledge to consider
disaster prevention in our everyday practices, both domestically and internationally, thereby
safeguarding the lives, property, and health of employees and their families. We believe actingin accordance with the following guidelines is critical to achieving these goals:
10-1. Development of risk management structures

The Nittobo Group has established basic policies and management structures for risk
management in its Rules for Risk Management. Based on these basic policies and12management structures, the Risk Management Committee, chaired by the Representativeand CEO, manages various business risks appropriately and strives to minimize risk.

10-2. Rejection of antisocial forces

The Nittobo Group categorically rejects any illegal and undue demands from and any
relationship with organized crime groups; companies affiliated with organized crimegroups; corporate racketeers; and other antisocial forces seeking to gain economic gain
through violence, intimidation, or fraud. Pursuant to the basic principle articulated in thefollowing phrase—“No fear of, funds to, use of, or affiliation with” antisocial forces, weare committed to a firm response to and sustained systematic efforts against any
relationships with antisocial forces.
Keep in mind that any ties to antisocial forces pose the risk of instant and total loss of thereputation nurtured and established over many years of operations, jeopardizing theexistence of the company.

(1) Antisocial forces seek to gain their operating funds from business enterprises by
various means, including demands for financial support or subscriptions to or
advertisements in magazines and newsletters; taking advantage of corporate
weakness to extort money or goods; demanding ongoing sales transactions; orestablishing companies pursuant to legal procedures to enter into business
relationships.
We must categorically reject all such demands, even if they pose potential benefits toour company. Even ordinary commercial transactions with persons whom werecognize as antisocial forces constitute the provision of benefits banned under the
prefectural Organized Crime Exclusion Ordinances and will result in social sanctions.
The fact of simple association with antisocial forces will help them proliferate.
Business enterprises are required to sever all links to antisocial forces.

(2) At the Nittobo Group, we are prepared to take quick, organized action, while
prioritizing the safety of employees, in accordance with our basic policy that we will
categorically reject any illegal and undue demands from and relationships of any kindwith antisocial forces. Immediately report any such demand to your superior, whether
actually made or anticipated. Your superior in turn will contact and consult with the
Risk Management Department concerning the subsequent course of action. The Risk
Management Department will contact law enforcement authorities and take otherappropriate measures at the earliest possible stage.
Keep in mind that you must not seek to resolve such issues on your own. Share yourconcerns across the entire organization to ensure the fastest and most effective
response, free of undue fear. Taking the easy way out can often highlight weaknesses
that counterparts may seek to exploit, eventually leading to even more serious
consequences.

10-3. Preparing for disaster

Earthquakes, wind damage, flooding, fires, and other disasters happen without warning.
For us to be able to promptly confirm the safety of employees and damage to facilities andequipment in the event of an emergency and to make the quickest possible recovery,
preparedness in normal times is a must. Training and education pursuant to the Nittobo
Group Disaster Prevention Regulations and a business continuity plan (BCP) is crucial tohoning our ability to respond promptly to emergency situations. Keep in mind that things
that are difficult under normal conditions become near-impossible in emergencies.
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Furthermore, all disaster equipment and supplies must be constantly inspected andmaintained.

10-4. Managing crises overseas

With the expansion of the company’s business operations overseas, opportunities foroverseas assignments and business travel are also increasing, putting us at greater risk of
exposure to civil disturbances, riots, and terrorism. We have already established Overseas
Crisis Management Regulations to ensure the safety of and to manage risks associatedwith employees working abroad. We have also introduced internal systems that put the
lives and safety of employees first. In contrast to accidents in Japan, however, we can
expect significant difficulty in contacting employees in the event of overseas incidents.
Every employee must be duly prepared for emergency situations, including the
preparations needed to maintain a level perspective and to permit calm, decisive actionin the event of an emergency.
We will devote considerable energy to crisis management training and education for
those slated to travel or transfer overseas, striving to collect and convey information on
dangerous regions and emergencies. You must pay careful attention to this information
and act accordingly.

10-5. Cybersecurity

11.

Cybercrime and cyberterrorism are increasing every year, with wide-ranging
consequences. Recognizing cyberattacks targeting information networking
environments as significant risks, the Nittobo Group strives to ensure cyber security on
an everyday basis based on compliance with the Information Systems Management
Regulations and various internal notices on IT security.

Code of conduct for thorough compliance with the Nittobo Behavior
Program and the Nittobo Code of Conduct

To remain a company trusted by society, it is vital that Nittobo Group executives andemployees act in accordance with the Nittobo Behavior Program and the Nittobo Code of
Conduct. For this reason, executives, including senior management, must take the lead andset a good example, while also developing and maintaining internal systems that are sound,
efficient, transparent, and effective. For the Nittobo Behavior Program and the Nittobo Codeof Conduct to become firmly established and permeate among all employees as the basis ofeveryday activities, it is essential to implement continuous and proactive education andtraining and to recognize that compliance with laws, ordinances, and social norms andthorough enforcement of corporate ethics are fundamental to organizational survival andincreasing corporate value.
11-1. Development and operation of internal control systems

The Nittobo Group maintains and strives to appropriately implement systems forcarrying out everyday business activities properly and efficiently in accordance withrules and for preventing improprieties and errors (internal control systems). Employees
must perform their duties appropriately in thorough compliance with laws, ordinances,
social norms, and corporate ethics under these systems. In addition to sharing andensuring thorough understanding of their details within the organization, it is importantto review the systems periodically in light of current circumstances and to take steps toensure that they function effectively and appropriately in the workplace.
1411-2. Use of the Corporate Ethics Helpline (internal whistleblowing system)
Overlooking a real or potential violation of the Nittobo Behavior Program and the Nittobo
Code of Conduct may lead to significant damage to the company. Rather than keeping suchmatters to oneself, employees who have learned of such actions must seek to resolve themin the workplace by consulting with or reporting to a superior or colleague. In most cases,
such issues are solvable within the workplace through discussions or consultations witha superior. In certain cases, it may be difficult to resolve the situation in the workplace
due to an uncooperative workplace or a situation in which it is difficult to consult with orreport to a superior or colleague. The Nittobo Group has established and operates the
Corporate Ethics Helpline as an internal whistleblowing system that thoroughly protects
whistleblowers—for example by protecting their privacy and prohibiting any
disadvantageous treatment—and as a contact point at which employees can consult onor report such cases with peace of mind. The Corporate Ethics Helpline may be used inaddition to organizational reporting lines to resolve such issues.

11-3. Encouraging cooperation in supply chains

Establishing a truly prosperous and sustainable society requires the promulgation of thespirit and behavior of the Nittobo Group set forth in the Nittobo Behavior Program andthe Nittobo Code of Conduct—not just within the Group, but throughout its supply chains.
We will strive to make all members of our supply chains aware of the Nittobo Behavior
Program and the Nittobo Code of Conduct and encourage them to take similar actions
based on an understanding of and shared approach to our social responsibility.

[Revised on April 1, 2023]

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