Nittobo Group

Sustainable Procurement Policy

Introduction
As a corporate group, the Nittobo Group will seek to enhance its significance by striving tocreate healthy and comfortable lifestyles, thereby continuing to contribute to the realization ofprosperous communities. Based on this Corporate Philosophy, we pursue our businessactivities with a strong sense of our corporate mission and roles in society.
Our business activities are built on a sense of partnership with the suppliers who make up oursupply chain. Activities across the entire supply chain are vital for putting into practice andachieving our missions and roles.
We have established the Nittobo Group Sustainable Procurement Policy to share with oursuppliers the ideas and issues underlying the Group’s social missions and to promote ourconcerted efforts to put them into practice, thereby contributing to our mutual progress andfurther contributing to society as a whole across the entire supply chain. We kindly request theunderstanding and compliance with this policy of our suppliers, as well as their cooperation inenlisting the support of their upstream suppliers.

1) Compliance and business ethics
1. Compliance broadly defined◆ Comply with not just national and regional laws and regulations, but their intent andpurpose and the social norms of local communities.
◆ Strive to ensure a thorough understanding of compliance within your organization andto ensure that all employees understand that their personal conduct must be based oncompliance.

2. Fair transactions, anticorruption◆ Employ fair transaction methods and refrain from actions that qualify as abuse ofadvantageous positions.
◆ Refrain from bribery and offering improper gains, and other such acts.
◆ Refrain from improper accounting practices and transactions that might create theimpression thereof.

3. Protecting intellectual property rights◆ Refrain from improperly obtaining or using patents, utility model rights, design rights,
trademark rights, copyrights, and other intellectual property rights.

4. Security trade controls◆ Maintain internal structures capable of controlling export transactions in accordancewith laws and regulations, including periodic internal inspections.

5. Avoidance of conflict minerals◆ Tin, tantalum, tungsten, or gold, which might be conflict minerals (i.e., minerals
related to funding sources for armed forces and human rights violations) or products
containing them used by you or by your suppliers must be inspected in advance toconfirm that they are not sourced from the Democratic Republic of the Congo orneighboring countries.

6. Exclusion of antisocial forces◆ Maintain internal structures to exclude antisocial forces and groups that threaten theorder and safety of civil society.

7. Whistleblowing programs, corporate culture◆ Establish whistleblowing programs pursuant to laws and regulations.
◆ Establish structures to protect whistleblowers from retaliation and similar actions.
◆ Establish as a top management policy the maintenance of a free and open corporate
culture wherein compliance violations and related matters can be reported tomanagement in a timely manner.

2) Respect for human rights
1. Prohibition of discrimination and respect for diversity◆ Prohibit discrimination in employment, including hiring, promotion, transfer, wages,
and discipline, based on gender, ethnicity, origin, creed, religion, or disability.
◆ Respect individual diversity and create workplace environments in which individuals
can demonstrate their capabilities to the utmost.

2. Prohibition of harassment◆ Prohibit all forms of harassment, including sexual harassment, abuse of power,
maternity harassment, and pressure to conform.
◆ Respect individual dignity and refrain from interacting with others with intimidating oroverbearing attitudes.
◆ Maintain systems to receive reports and complaints of harassment or potentialharassment.

3. Prohibition of child labor and forced labor◆ Prohibit employment of children under legal working age.
◆ Prohibit employment contrary to the will of workers, whether through violence,
intimidation, debt, fraud, etc.

4. Consideration for youth, seniors, and expectant mothers, and work-lifebalance◆ When employing youth, seniors, and expectant mothers, employ consideration
regarding matters such as hazardous or dangerous jobs and workplaces, as well asworking hours.
◆ Maintain employment systems that duly consider work-life issues, including childcare,long-term care, self-improvement, and recuperation leave.

5. Human resource development◆ Maintain organized and systematic human resource development structures tostrengthen the skills of individual employees.
◆ Actively support the attendance of external seminars, networking across industry
boundaries, and skills development.

6. Wages and working hours◆ Pay at least the legal minimum wage and comply with laws and regulations regarding
working hours.

7. Protecting the right to organize◆ Respect employees’ right to organize.
◆ Engage in sincere discussions and dialogue with employee representatives.

3) Occupational safety and accident prevention
1. Workplace environments reflecting consideration for occupational
health and safety◆ Managers should make it clear in policies that employee health and safety are toppriorities in production workplaces.
◆ Require the establishment of a risk assessment system and safety measures based on
the results of risk assessments (e.g., failsafe structures, foolproof structures, andinterlocks), to keep workplaces safe.
◆ Promote awareness among employees concerning health and safety management
through proactive prevention of potential accidents and maintaining Five S activities(seiri [sorting], seiton [straightening], seiso [systematic cleaning], seiketsu[standardizing], and shitsuke [sustaining]).

2. Mental health◆ Promote mental health measures and strive to be aware of and respond appropriately
to mental health issues (e.g., by encouraging employees to greet each other regularly,speaking up to each other, and encouraging everyday communication).
◆ Develop structures for managing working hours and addressing overwork (e.g.,through meetings with industrial physicians).

3. Disaster prevention◆ Carry out periodic inspections to prevent damage to your facilities due to fires,explosions, earthquakes, etc.
◆ Implement disaster drills to ensure preparation for earthquakes, fires, floods, etc.;
formulate and publicize emergency guidance and evacuation routes.

4. Business continuity planning◆ Draft a business continuity plan and implement drills to ensure preparedness fordisasters.

4) Environmental protection, resource conservation
1. Greenhouse gas reduction and energy conservation◆ Strive to improve and manage production methods, processes, and equipment toreduce greenhouse gas emissions and conserve energy in connection with productmanufacturing.

2. Waste reductions and recycling◆ Practice product design based on consideration for waste reduction and ease ofrecycling when commencing use, during use, and after use.
◆ Set targets for waste reductions and recycling in production workplaces; take action toachieve these targets.

3. Use and management of water resources◆ Promote measures such as effective use of water resources (e.g., recycling andcascading) and water conservation with consideration for the local water environment.

4. Control of chemical substances◆ Refrain from use of prohibited substances in connection with manufacturing. Use andcontrol chemical substances, including harmful and dangerous substances,appropriately.
◆ If releasing chemical substances into the environment through smoke or water
discharge, strictly maintain levels called for in laws and regulations; strive to minimize
environmental impact.

5. Green procurement◆ Establish green procurement standards and procure eco-friendly products andmaterials with low environmental impact.

6. Coexistence with nature◆ Ascertain the impact of business activities on biodiversity; carry out business activities
and contribution activities reflecting consideration for the preservation of the naturalenvironment.

5) Quality control, cost controls
1. Quality first◆ Supply products of the highest quality for customers.
◆ Maintain inspection and assurance structures to ensure quality.

2. Product safety◆ Ensure that products are safe for users and meet the safety standards of laws andregulations.
◆ Provide appropriate product safety information.

3. Cost competitiveness◆ Strive to reduce costs based on ongoing production technology development.

4. Traceability◆ Ensure traceability of raw materials, other materials, parts, etc., for use in solving
quality and safety issues.

6) Information management and communication
1. Control of trade secrets◆ Strictly control trade secrets and use them appropriately.
◆ When obtaining information and other materials concerning other companies, do soby fair and appropriate methods.

2. Collection and use of personal information◆ Obtain, retain, and dispose of personal information concerning employees, trading
partners, and customers appropriately and in compliance with laws and regulations.
◆ Prohibit use of personal information for purposes other than those intended; refrainfrom collecting information not needed for business operations. Promptly dispose ofpersonal information that is no longer needed in accordance with laws andregulations.

3. Disclosure◆ Provide timely and appropriate disclosure of management information, financial
information, and other information concerning stakeholders.
◆ Strive to achieve mutual progress through appropriate communication withstakeholders.

4. Cybersecurity◆ Fully implement cybersecurity measures to protect IT information essential for social
and business activities.
◆ Educate employees concerning cybersecurity threats (e.g., unauthorized access,infection with computer viruses, spoof email).

7) Social contributions to and consideration for the community
1. Contribute to local community development◆ Communicate with local communities through dialogue and other means, as a good
corporate citizen, and cooperate and participate in community activities to contributeto community development.

2. Consideration for local communities◆ Engage in business activities based on due consideration for local culture, customs,and circumstances.

8) Cooperation with the supply chain
1. Involvement of your supply chain◆ Fulfill your responsibilities throughout the supply chain by promoting the concepts ofthis Sustainable Procurement Policy to your own suppliers.

2. Communication◆ Deepen mutual understanding and contribute to mutual progress through surveys andsite visits (or site inspections).

Established by:
Purchasing Department
Corporate Business Planning Division
Nitto Boseki Co., Ltd.
(First Edition)
April 2023