Kurita Group Procurement Policy
andKurita Group Sustainable Procurement
Guidelines

July 2023
Kurita Water Industries Ltd.

1. Kurita Group Procurement Policy
General Rules(1) Kurita Group will establish a system to engage in appropriate procurement activities based on this Policy.
(2) Each company among the Kurita Group will prepare rules and regulations based on the matters set forth in thisPolicy and in accordance with applicable laws and regulations, etc. of each country or each region.
(3) Officers and employees of Kurita Group shall comply with this Policy and ensure that appropriate procurement
activities are carried out throughout the supply chain.
(4) When officers and employees of Kurita Group discover any procurement activity that is in violation of, or any
event that is suspected of being in violation of this Policy, they shall immediately report such activity to thedepartment administering this Policy.

Procurement Policy
Kurita Group promotes social responsibility-oriented procurement activities throughout its supply chain, shares
recognition with business partners, and strives for mutual prosperity based on mutual trust, as follows:(1) To conduct transactions in consideration of basic human rights, occupational health and safety, and preservationof the global environment in compliance with laws and regulations as well as social norms;(2) To provide fair and equal business opportunities to business partners, to conduct transactions while ensuring
reliable quality at competitive and reasonable prices, based on appropriate specifications and standards;(3) To procure materials and services and enable continuous and stable supplies of our products and services tocustomers, and contribute to the sustainable development of society; and(4) To forbid entering into any transaction that would benefit antisocial forces or terrorist groups.

Confirmation and Improvement of Status of Procurement Activities
Kurita Group will periodically conduct an audit to confirm whether the procurement activities are carried out
appropriately, and work to improve each and every issue detected during the audit.

2. Kurita Group Sustainable Procurement Guidelines
Confirmation Items
PolicyCategory

Item

Page

Respect for basic human rights

Prohibition of forced labor3

Prohibition of child labor

3-4

Elimination of discrimination

4

Prohibition of inhumane treatment

4

Wages

4–5

Working hours management

5

Workers’ Rights

5

Possibility of human rights violations through raw

5–6

No.
(1)

material procurement
Occupational health and safety

Preservation

of

the

globalenvironment(2)Compliance

with

laws,

regulations and social norms(3)

7

Providing a hygienic workplace

7

Education and training

7-8

Management of chemical substances

8

Compliance with environmental laws and regulations

8-9

Reduction of environmental impact

9

Fair trade

9

Prohibition of abuse of a superior bargaining position

10

Prohibition of corruption and bribery

10

Prohibition of granting unjust benefits

10–11

Export and import control

11

Prevention of misconduct

11

Respect for intellectual property

12

Safety and stability of products

Quality and product safety assurance

12

and services

Business continuity in the event of emergency

Information management(4)

Ensuring safety in the workplace

Anti-social forces

12–13

Prevention of data falsification

13

Protection against threats to computer networks

13

Personal information management

14

Confidential information management

14

Elimination of any and all relations with antisocial forces

14–15

Kurita Group engages in procurement activities in accordance with the “Kurita Group Procurement Policy.” We haveestablished the following “Kurita Group Sustainable Procurement Guidelines,” which outline the points to bepracticed by all business partners based on this Policy. We would ask you to agree to the purposes and contents, andproactively promote your initiatives.

(1) We will observe laws, regulations and social norms, and do business in consideration of basic humanrights, occupational health and safety, and preservation of the global environment.
Respect for basic human rights
We ask that, in your business activities, you respect basic human rights, and in addition, eliminate discrimination
based on sex, nationality, religion, race or disability, etc., and do not engage in forced labor.

Prohibition of forced laborNot to accept forced labor by means of violence, threat, confinement, or any other restraint on mental or physicalfreedom in any business situation. Not to do business with operators who use forced labor.
Forced, bonded (including debt bondage), or compulsory labor, or involuntary or exploitative prison labor, slavery
or trafficking of persons shall not be used. This includes transporting, harboring, recruiting, transferring, or receiving
persons by means of threat, force, coercion, abduction, or fraud for the purpose of labor or service.
Points to be confirmed
・There are no unreasonable restrictions on employees’ freedom of moving in company-provided facilities including
unreasonable restrictions on entering or exiting the facilities.
・As part of hiring process, before an employee leaves his or her home country, the employment contract is provided
written in his or her native language that contains provisions regarding terms of employment.
・All work must be done voluntarily, and employees have the liberty to leave the workplace from time to time, or toterminate employment.
・ Employers and agents do not retain or otherwise destroy, conceal, confiscate employees’ identification orapplications for immigration such as government-issued identification, passports or work permits (except in casewhere it is required to retain these under the law), nor prevent employees from using them.

Prohibition of child laborNot to accept child labor in any business situation. Not to do business with any operators who use child labor.
Child labor shall not be used for any work. The minimum age for employment shall be the minimum age for
employment permitted by the laws of each country/region, the age for completing compulsory education, or the ageof 15, whichever the highest. Employees under the age of 18 shall not be used for hazardous work.
Points to be confirmed
・Any child who is under the minimum age for employment is not assigned to work.
・The age of each employee is confirmed by an official document upon employment.

・Statutory protection is enforced in consideration of health and safety in relation to the employment of employees
under the age of 18.

Elimination of discrimination
Respect laws and regulations, and culture of each country/region, and do not discriminate based on race, sex,
religion, political opinion, nationality, social origin, disability, or sexual orientation, etc. in all business activities.
“Discrimination” means to treat people differently in the recruitment, promotion, compensation, access to training,
etc. and treatment, based on factors other than reasonable ones such as their ability, suitability and performance.
Factors of discrimination are, for example, race, nationality, region of origin, age, sex, sexual orientation, disability,
religion, political opinion, union membership, and marital status. In addition, if a health examination or pregnancy
test impairs equal opportunities or equality of treatment, such act shall be considered as discrimination.
Points to be confirmed
・There is no discrimination in wages, promotion, compensation, and access to training, etc.
・There are corporate policies and statements from the management for eliminating discrimination.
・Internal system and procedures for eliminating discrimination are explained to all employees.
・Internal system is in place under which employees shall, when discovering any discrimination, report such act tothe company.

Prohibition of inhumane treatment
Respect employees’ human rights and eliminate any conduct that harms personal dignity (sexual harassment,
abusement, corporal punishment, mental suppression or verbal abuse and other harassment).
There shall be no harsh or inhumane treatment, including any sexual harassment, sexual abuse, corporalpunishment, mental or physical coercion, or verbal abuse of workers; nor shall there be such threats. Disciplinary
policies and procedures in support of these requirements shall be clearly defined and communicated to employees.
Points to be confirmed
・No inhumane treatment is tolerated in the workplace.
・Disciplinary procedures for inhumane treatment are established.
・There are corporate policies and statements from the management.
・Internal mechanisms and procedures have been explained to all employees.
・Mechanisms have been in place under which employees shall, when discovering the applicable matter, reportsuch matter to the company.

Wages
In compliance with all laws related to wages including minimum wage, overtime work, and statutory benefits, anappropriate salary shall be paid to an employee.
In compliance with the laws of each country/region, employees shall be compensated for overtime work at pay
rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted.
Salaries and other payments, benefits and deductions should comply with the laws of each country/region, and thebreakdown thereof must be clearly informed to employees in a timely manner. Any use of temporary employees,
dispatched employees and outsourced labor is subject to restrictions by the laws of each country/region.
Points to be confirmed
・The amount of wages under the employment contract is higher than the minimum wage stipulated by eachcountry/region.
・Wages are paid without delay.
・A statement of wages is distributed to each employee.
・Social insurance, etc. is withheld appropriately.
・Salaries are not reduced unreasonably.

Working hours management
Properly manage working hours, holidays, and leave of employees within legal ceilings.
Points to be confirmed• Annual working days do not exceed the legal ceiling.
・Working hours per week including overtime (excluding the cases of urgency and emergency) do not exceed
the legal ceiling.
・The rights to at least take one holiday per week and statutory annual paid leave are granted.
・Employees’ working hours are managed correctly.
Workers’ Rights
Respect the right of employees to organize as method of negotiating working environments, wage level and othermatters with employers.
Respect the rights of all workers to form and join labor unions of their choice to bargain collectively and participate
in peaceful assemblies in compliance with local laws as well as the rights to refrain from doing such activities.
Workers and/or their representatives may communicate openly and share with management their opinions andconcerns about working conditions and management practices without fear of discrimination, reprisal, threat or
harassment.
Points to be confirmed
・The company does not interfere with, discriminate or otherwise retaliate against labor unions or committees,or participants therein.
• The representatives thereof have been elected democratically and practice good communication withrepresentatives of the company.
・There are corporate policies or regulations that respect workers’ union activities.

Possibility of human rights violations through raw material procurement
Consideration must be given to the company’s procurement activities so that they do not directly or indirectly
violate human rights.
You are requested to strive to conduct appropriate procurement activities by confirming the possibility of humanrights violations in the process of procuring raw materials for the company’s products, by going back into the supply
chain.
Points to be confirmed
・The company has confirmed that there is no possibility of engaging, whether directly and indirectly, in any of thefollowing in its business activities:i)

Minerals: Using profits as a source of funding for inhumane or antisocial organizations. They are minedby children.

ii)

Pulp, wood, vegetable oil: Adversely affecting indigenous peoples and local residents in cultivation areas.

iii) Fuel, construction: Engaging in mining and/or plant construction activities that violate the rights ofindigenous inhabitants.
・Regarding minerals procured and used by the company that are “conflict minerals*1,” information is disclosed as
required by laws and regulations as well as at the request of customers.
*1 What are “conflict minerals

Rare minerals and their derivatives mined in the Democratic Republic of Congo and neighboring countries, which
are among the world’s main mineral resource countries. In Central Africa, where conflicts have been continuing forover 20 years since the 1990s, minerals illegally mined by armed groups become sources of funds to purchaseweapons and maintain their ability to fight, and this causes conflicts to be further prolonged.
In July 2010, the U.S. government enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (DoddFrank Act), which sets out the conflict minerals provision that requires listed companies (including foreigncompanies) in the U.S. using conflict minerals for their products to disclose information to the Securities andExchange Commission (SEC). Even though this Act does not provide punishment, it is designed to confirm whether
a company financially contributes to armed groups and assists serious human rights violations, and is indirectly
encouraging companies to reduce the use of conflict minerals. Reporting is required when using any conflict minerals
mined in the Democratic Republic of Congo, Angola, Uganda, the Republic of Congo, Zambia, Tanzania, the Central
African Republic, Burundi, South Sudan or Rwanda, and their derivatives. The conflict minerals and their derivatives
subject to reporting are as follows:i)

Tantalum ores (columbite and tantalite)…used for electronic devices and precision equipment, etc.

ii)

Cassiterite (tin ores)…used for food cans, solder and integrated circuits, etc.

iii)

Gold…used for jewelry and for dental applications

iv)

Wolframite (tungsten ore)… used for light bulbs, x-ray tubes and integrated circuits, etc.

v)

Other minerals additionally identified by the Secretary of State of the United States

Since 2014, companies have been required to disclose information going back to component suppliers and many
Japanese companies are therefore forced to respond to it.

Occupational health and safety
You are requested to strive to realize and maintain a safe, clean, and healthy working environment.

Ensuring safety in the workplace
Pursuant to the labor laws of each country/region, endeavor to ensure the safety of employees, placing toppriority on this, and strive to prevent work-related accidents during business activities.
“Occupational health and safety” means the company is fulfilling its obligation to protect employees from danger
to life and person.
Points to be confirmed
・All employees have participated in evacuation drills in case of an emergency in the workplace.
・Protective equipment in the number necessary for work is prepared.
・Hazardous work and repetitive heavy work, etc., are identified and managed (e.g. restrictions on working hours).
・Fire protection equipment stipulated by laws and regulations is in place.
・Safety of buildings (e.g., facility obsolescence, earthquake resistance ) is assured.
・Statutory health examinations of employees are carried out, and the results thereof are notified.
・Internal system is in place under which workplace safety shall be checked periodically, and necessary measures
are taken.

Providing a hygienic workplace
Providetoilets and resting areas, monitor the state of harmful substances , noise and bad odor, etc. in theworkplace, and implement appropriate measures.
Points to be confirmed
・Sufficient number of clean toilets that can be used by all employees are provided.
・Access to drinking water and food, as well as rest areas are provided.
・Adequate ventilation and air conditioning are provided, and a sanitary environment is maintained in the workplace.
・Because harmful organisms and chemical substances, noise, bad odors, etc. may also adversely affect nearby
residents, measures shall also be taken in consideration of the impacts on nearby residents and the environment.
・If the company owns any facilities that are available to employees other than workplaces, such as company
dormitories, safety and hygiene shall also be ensured in those facilities.

Education and training
Provide education and training on occupational safety.
Points to be confirmed
・Internal systems are established for education and training, which are systematically continued according to thecharacteristics of each employee’s work (e.g. related laws and regulations, production facilities, substances
handled, and composition of employees).

Preservation of the global environment
You are requested to minimize adverse effects on society, environment, resources, and public safety and health,which are brought about by your business activities, namely, manufacturing, production, construction, and otherprocesses.

Management of chemical substances
Properly manage chemical substances designated by laws and regulations, etc. which are handled in the
manufacturing process.
Chemicals and other substances that are hazardous to the human body and the environment should be managed toensure they are identified, labeled, and controlled, handled safely, transferred, stored, used, recycled or reused, anddisposed of properly.
Points to be confirmed
・Chemical substances handled by the company, which are hazardous to the human body and the environment as
designated by the laws and regulations, etc. of each country/region are identified.
・Internal system is established to comply with the laws and regulations of each country/region, and to confirm
the status of chemical substance management.
・Methods of handling chemical substances are specified, and employees are educated and instructed accordingly.
・The company has confirmed that chemical substances handled by the company do not contaminate the atmosphere,
water, or soil.
・The SDS (safety data sheet) is made available for inspection to persons handling chemical substances.

Compliance with environmental laws and regulations
Make efforts to substitute other chemical substances for chemicals that are potentially harmful to human healthand the ecosystem, or reduce the usage of such substances. Comply with the laws and regulations, etc. of eachcountry/region concerning waste water, emissions into the atmosphere, waste, noise, vibrations, and soil
contamination, etc., and, where necessary, promote further improvements based on voluntary standards.
Matters relating to typical pollution such as leakage of chemical substances, waste water, emissions into theatmosphere, wastes, noise, vibration, and light will impact local communities and the ecosystem. Harmony with local
communities is the basis for stable business activities, and you are required to comply with the laws and regulations
etc. of each country/region and, in addition, promote improvements based on voluntary standards, while having close
communication with stakeholders.
Points to be confirmed
・Use of chemical substances that are potentially harmful to human health and the ecosystem is recorded andcontrolled.
・Internal system is established to set voluntary targets for reducing the use of chemical substances that arepotentially harmful to human health and the ecosystem.
・Internal system is implemented to comply with the laws and regulations of each country/region, and to confirm
the status of preventing environmental pollution.

・The possibility of accidents and emergencies is clarified, and procedures to address, prevent, and mitigate the same
are established.

Reduction of environmental impact
Respect biodiversity and sustainability, improve daily business activities, and be creative to reduce theenvironmental impact.
With emphasis on efficiently using and recycling resources, energy and water, set voluntary targets to conserve
resources, energy, and water, as well as those related to reducing wastes and greenhouse gas emissions, etc., andlower the negative impact on the environment and ecosystem across the entire supply chain.
Points to be confirmed
・Environmental management systems such as ISO are adopted, and initiatives to reduce environmental impact
are practiced.
・Initiatives on conserving water and energy, using renewable energy, and reducing greenhouse gas emissions are
implemented.
・Considerations are being made for utilizing renewable materials and minimizing waste resources, from theperspective of a circular economy.

(2) We will offer fair and equal business opportunities to all business partners, and do business based on
appropriate specifications and standards with reliable quality and at competitive and reasonable prices
Compliance with laws, regulations and social norms
You are expected to confirm and comply with laws, regulations, rules, and norms related to fair and equaltransactions in your business activities.

Fair trade
Aim to earn the trust of business partners and society through fair and free competition, and not to engage inany act in violation of antitrust laws of each country/region.
It is prohibited to make prior agreements with companies in the same trade on product and service prices,
production volume, sales volume, sales areas, etc. (i.e. cartel), or make prior arrangements with other bidders on awinning bidder and successful tender price (bid-rigging). In addition, acts of improperly obtaining and using trade
secrets of other companies, impairing the reputations of other persons or other companies by fraudulent means, andmaking representations that mislead customers regarding the origins of the company’s products and quality, etc. areconsidered to be acts of unfair competition.
Points to be confirmed
・There are corporate policies and statements from the management concerning fair trading practices.
・Education on fair trade is provided to employees.

・Consideration is given regarding product information and advertisements so as not to make a false representation,or cause misunderstanding.

Prohibition of abuse of superior bargaining position
Not to engage in any act that would be disadvantageous to business partners by abusing a superior bargaining
position.
“Abuse of superior bargaining position” means that a business operator who is in a superior bargaining positionin business unfairly determines or changes the terms of business with business partners in an advantageous manner,or makes demands and imposes disadvantageous obligations on business partners by taking advantage of such
position. Procurement operations shall be performed in good faith in writing such as through a contract, in an equaland fair manner, and no act that abuses a superior bargaining position shall be conducted. In any countries and regions
having legislation concerning the abuse of a superior bargaining position there shall be compliance with such laws
and regulations (for example, the Antimonopoly Act in Japan, etc.).
Points to be confirmed
・Internal regulations and systems to prevent abuse of a superior bargaining position are implemented.
・Education is provided to employees to prohibit the abuse of a superior bargaining position.

Prohibition of corruption and bribery
Bribery and illegal political contributions and donations shall be strictly prohibited to ensure a sound andnormal relationship with politicians and governments.
“Bribery” means acts of offering money, entertainment, gifts, or other benefits and conveniences to public officials
or any equivalent persons, in pursuit of some business advantages in return, such as obtaining or retaining licenses
or business or access to undisclosed information. In countries and regions where providing benefits, etc., bearing
expenses or donations, etc. to or on behalf of officers and employees of private companies are restricted under local
laws and regulations, relationships with officers and employees of private companies shall be in accordance withthose with public officials.
“Illegal political contributions” means political contributions given, for example, in return for the pursuit of somebusiness advantages, such as obtaining or retaining licenses or business, or accessing non-disclosure information, or
giving political contributions without following normal procedures.
Points to be confirmed
・There are corporate policies and statements from the management concerning prohibition of corruption andbribery.
・A system is in place to check internally and ensure that no improper payments are made.
・Education is provided to employees regarding the prohibition of corruption and bribery.
・When giving political contributions, comply with the laws and regulations of each country/region.

Prohibition of granting unjust benefits
Not to grant unjust benefits or entertainment to business partners. In addition, not to receive unjust benefits orentertainment from business partners.
Below are examples of granting or receiving unjust benefits:i)

Providing or receiving to or from business partners premiums, prizes, prize money, etc. beyond thelimitations regulated by laws and regulations.
ii)

Providing or receiving money and goods or entertainment, or conducting a suspected act of bribery beyond
the extent of social norms.

iii)

Granting benefits to specific business partners.

iv)

Providing or receiving important undisclosed information and purchasing or selling shares of a company
in a way that is recognized as an act of insider trading.

Points to be confirmed
・There are internal regulations and rules under which the amount and frequency of gifts and entertainment given andreceived to and from customers and business partners shall not be excessive or beyond the bounds of social
acceptability, and an internal system for checking such acts is in place.
・Internal system is in place to blow the whistle when an act involving unjust benefits is found.

Export and import control
Properly export and import products, technologies, and services in accordance with export/import-related laws,
regulations and rules, such as the Japanese “Foreign Exchange and Foreign Trade Act,” so as not to cause any
situation or act that threatens international peace and security.
With respect to imports, in many cases, license, examination, and inspection are required for each product andorigin, mainly pursuant to the Japanese “Customs Act,” or for health and hygiene and other reasons. In addition, withrespect to exports, there are various regulations in each exporting country and for each product, and you are expected
to comply with the necessary export and import controls. Although the EAR (Export Administration Regulations) isa U.S. law, it will be applied in any country when using the products of the United States.
Points to be confirmed
・In relation to imports and exports, the necessary procedures are in compliance with applicable laws andregulations, and restrictions.
・Invoices and customs declaration forms are completed correctly.

Prevention of misconduct
Carry out activities for preventing misconduct and establish a system forearly detection and handling of

misconduct.
“Activities to prevent misconduct” means to educate and enlighten employees as well as to create a richcommunication environment in the workplace.
Matters to be confirmed
・Whistleblowing system for misconduct is established internally and/or outside the company.
・System is in place to maintain confidentiality and properly protect whistle-blowers.
・With regard to the preceding two paragraphs, employees are educated, kept informed and enlightened.
・Prompt countermeasures are taken for any detected misconduct.

Respect for intellectual property
Respect the value of intellectual property, properly manage the company’s intellectual property, and do not
infringe

other companies’ intellectual property.

“Intellectual property rights” means patent rights, utility model rights, design rights, trademark rights, copyrights
and trade secrets, etc. When developing, producing, selling or otherwise providing products and services, it isnecessary to conduct a preliminary survey on third parties’ intellectual property rights. Improperly obtaining trade
secrets of third parties also constitutes the infringement of intellectual property rights.
Points to be confirmed
・There are policies and/or regulations concerning intellectual property.
・Department or person responsible for protecting intellectual property and preventing infringement is established.
・System is in place to keep employees informed on protecting intellectual property and preventing infringement.

(3) We will procure materials and services that enable us to provide products and services to customers in acontinuous and stable manner and contribute to sustainable social development.
Safety and stability of products and services
In your business activities, you are requested to comply with laws and regulations concerning product safety, andprovide products and services of high quality, as well as provide adequate information.

Quality and product safety assurance
In carrying out business activities, comply with the laws and regulations of each country/region concerning
product safety, and provide products that meet such levels as required by business partners including the Kurita
Group.
Product safety, in addition to complying with laws and regulations, shall meet the requirements of business partners.
When designing and developing products at the responsibility of the company, it shall be confirmed that there isadequate product safety at the stages of design and development. When manufacturing products, use designated raw
materials and assure product safety through appropriate manufacturing.
Points to be confirmed
・Internal standards for product safety and quality assurance are implemented.
・Education is provided to employees regarding product safety and quality assurance.

Business continuity in the event of emergency
To successfully provide a stable supply of products, Business Continuity Plan (BCP) is established, in order topromptly
resumecore operations in the event of unforeseen circumstances.
Matters
to beconfirmed
Points to be confirmed
・The target levels for business continuity and priority work are determined, and an operations manual to be usedni the event of a crisis is provided.

・Employees are well trained and educated.

Prevention of data falsification
Accurately measure and record data regarding the quality and performance of products and services, and not
engage in improper conduct such as data falsification or fabrication.
Accurate information means as follows:i)

Specifications, quality and handling methods regarding the delivered products and services are accurate;ii)

Information regarding substances contained in a product’s raw materials and packaging materials areaccurate.

iii)

False expressions or any expressions that could mislead business partners are not used in information in
catalogs and any advertisements for products and services.

Points to be confirmed
・System is implemented to ensure data submitted to business partners are not falsified.
・Education and guidance are provided regarding damage to social reputation and impact on society of data
falsification.
・Investigations are conducted to ensure that the suppliers’ data are not falsified.

Information management
Strictly manage personal information and confidential information obtained in the course of business in accordancewith your internal regulations, and conclude non-disclosure agreements.

Protection against threats to computer networks
Take protective measures against threats to computer networks and manage them so as not to cause damage to you
or other companies.
When a computer is infected with a computer virus, customer information and confidential information stored on
the computer may be lost or leaked outside through the network. In addition, if a password for a user ID is not strictly
managed, there is a risk of data leakage or falsification due to unauthorized access to the computer, and if it becomesa cyber attack target, you may suffer damage such as suspension of business.
Points to be confirmed
・The OS and software on computers used for business are the latest versions and are always updated.
・Anti-virus software is installed on computers used for business, and an up-to-date virus definition file (pattern file)is used.
・Passwords are complicated enough to prevent anyone from guessing them.
・Firewall to prevent unauthorized infiltration from the Internet is implemented.
・Education on information security is provided to employees periodically, in order for them to understand threats
and attack methods

Personal information management
Properly manage and protect personal information of customers, third parties and employees.
“Personal information,” if not handled properly, may lead to an accident involving the relevant individual.
Approaches to personal information and privacy vary from country to country. However, it is necessary that, aftersufficient research, measures shall be implemented in accordance with the relevant approach.
Points to be confirmed
・In relation to the handling of personal information, the laws and regulations of each country/region are complied
with.
・Education on the handling of personal information is provided to employees.
・Periodic check is conducted to verify that personal information is properly managed and protected.

Confidential information management
Properly manage and protect confidential information received from business partners and third parties including
Kurita Group.
With regard to information disclosed by a business partner company after conclusion of a non-disclosure agreement(it is mutually agreed that such information is confidential), you must handle the information as stipulated in theagreement.
Points to be confirmed
・In accordance with the non-disclosure agreement, there are provisions to prevent information leakage.
・Guidance is provided to employees regarding the fact that if confidential information is leaked or is found to be
used for any purpose other than the intended purpose in violation of the agreement, it may cause a serious problem
such as receiving a claim for a large amount of damages.

(4) We will forbid entering into any transaction that would benefit antisocial forces or terrorist groups.
Antisocial forces

Elimination of any and all relations with antisocial forces
Eliminate any and all relations with antisocial forces such as organized crime groups or terrorist groups, anduncompromisingly maintain a resolute attitude against such groups.
“Anti-social forces” refer to criminals, groups, and enterprises who are listed in “Information regarding Important
Criminals and Terrorists, etc.,” “Denied Persons List,” “Asset Freeze List,” and other lists published by thegovernment of each country/region.
The Company ensures that it will uncompromisingly maintain a resolute attitude against antisocial forces that pose athreat to the order and safety of civil society and take a resolute stance and never comply with unreasonable demands
from such forces. When concluding a basic business agreement with any business partner, we will receive a written
declaration from such business partner, stating that it has no relation with antisocial forces, and confirm there is norelation with antisocial forces.
Points to be confirmed
・There are corporate policies and statements from the management on eliminating any and all relations with
antisocial forces.
・Investigation is conducted on business partners and suppliers so that no benefits will be offered to antisocial forces.

(5) Responsible departments
Procurement Department 1 & 2, Supply Management Group, Engineering Division, Kurita Water Industries Ltd.

(6) Supplemental Provision
1. These Guidelines are established and come into force as of July 5, 2018.
2. These Guidelines are revised and come into force as of July 5, 2023.