KOKUYO Group Sustainable Procurement Guidelines
To ensure that the earth and society remain sustainable, the KOKUYO Group establishes theseKOKUYO Group Sustainable Procurement Guidelines as a statement of what we want to achieve incollaboration with trading partners based on the KOKUYO Group Code of Conduct and KOKUYOGroup Sustainable Procurement Policy. We also ask our trading partners to ensure that therequirements stated below are implemented, and that they in turn seek their trading partners’
understanding of the KOKUYO Group Sustainable Procurement Guidelines and promotion of therequirements therein.
1. Quality management
By providing products and services that enrich “work, learning and living,” we will continue torespond to the trust of customers and pursue customer satisfaction. We will conduct comprehensive
risk management and provide accurate product and service information.
1-1 Ensuring product safety
We will fulfill our responsibilities as a supplier by designing, manufacturing, and selling productsthat satisfy safety standards established by the laws and regulations of each country and ensuring
adequate product safety.
1-2 Quality management
We will comply not only with applicable laws and regulations relating to product and service quality,
but also KOKUYO Group quality standards and customer requirements.
1-3 Provision of accurate product and service information
We will appropriately disclose information relating to our business activities, product quality andsafety, and so on and will strive to understand and provide product and service information inresponse to requests from stakeholders.
1-4 Management of the risk of disasters and other risks
We will create risk management systems during normal times and provide stable supplies ofproducts to customers.
2. Respect for human rights
We understand the culture and business customs of various countries and regions and aim for asociety where the rights of all people are respected. We will not permit unfair discrimination or childand forced labor. Moreover, we will not conduct transactions with companies, groups, or otherentities that engage in such practices. We will not allow sexual harassment, power harassment,
bullying, or other such violations of human rights.
2-1 Prohibition of child labor and forced labor
We will not permit unfair discrimination or child and forced labor. Moreover, we will not conducttransactions with companies, groups, or other entities that engage in such practices.
2-2 Prohibition of sexual harassment, power harassment, and discrimination
We will not allow sexual harassment, power harassment, bullying, or other such violations ofhuman rights. Furthermore, we will give appropriate consideration to requests from workers
relating to religious practices.
2-3 Freedom of association and right to collective bargainingWe will comply with local laws and regulations and respect the right of workers to organize as ameans of conducting labor-management discussions regarding working environments, wagelevels, and other issues.

3. Health and safety
We will comply with health and safety related laws and regulations including the Industrial Safety
and Health Act. We will pay appropriate wages and allowances, provide welfare programs, properly
conclude labor agreements, comply with applicable laws and regulations, and protect the rights ofworkers. We will encourage continuous and self-initiated workplace improvement and strive toprevent occupational accidents and illness.
3-1 Occupational health and safety
We will give due consideration to employee health and safety and strive to create comfortableworkplaces.
3-2 Consideration for work hours
We will not require workers to work in excess of the limits set by laws and regulations in theregions where they work. Furthermore, we will appropriately manage workers’ work hours anddays off with due consideration for international standards.
3-3 Appropriate wages and allowances
We will comply with all applicable laws and regulations concerning compensation (including
minimum wages, overtime pay, and allowances and deductions from wages required by law) paid
to workers. We will also take into consideration wage levels that can provide for the necessities
of life (living wages).
3-4 Responses to emergency situations
To prepare for emergency situations such as disasters and accidents that could harm human lifeand physical safety, we will identify such emergency situations including the likelihood ofoccurrence, prepare action procedures for emergency measures that will minimize harm toworkers and assets, install necessary facilities and so on, and conduct education and training sothat action can be taken in the event of a disaster.
3-5 Occupational accidents and occupational illnesses
We will identify, assess, record, and report on the status of occupational accidents andoccupational illnesses and take appropriate countermeasures and remedial measures.
3-6 Industrial safety
We will identify, assess, and appropriately manage the risk of worker exposure to harmful
biological, chemical, and physical effects in the workplace.
3-7 Consideration for work that imposes physical burdens
We will identify and assess work that imposes physical burdens on workers and appropriately
manage such work so that it does not lead to occupational accidents or occupational illnesses.
3-8 Safety measures for machinery and equipment
We will assess whether there are any safety-related risks concerning machinery and equipmentthat workers use in their work and take appropriate safety measures.
3-9 Facility health and safety
We will appropriately ensure health and safety in facilities provided for workers (dormitories,cafeterias, bathrooms, etc.).

3-10 Health and safety communication
We will provide education and training on appropriate health and safety information regarding thevarious hazards that workers may be exposed to while working using language and methods thatworkers can understand and establish systems for workers to provide feedback concerning theirsafety-related opinions.
3-11 Worker health management
We will perform appropriate health management for all employees.
4. Environmental preservation
The Group takes environmental protection initiatives on a global scale, and by actively participatingin communities and acting as a good corporate citizen, seeks to create mutually beneficial
relationships with society.
The Group respects and observes environment-related laws, and in all its activities, takes initiatives
to protect the environment. Moreover, the Group conducts activities that give consideration to thenatural environment and biodiversity.
4-1 Reduction of energy consumption and greenhouse gas emissions
We will strive to improve energy efficiency and take measures to continuously reduce ourenergy consumption as well as greenhouse gas emissions across our entire supply chain.
4-2 Atmospheric emissions
We will implement appropriate measures to reduce atmospheric emissions of harmful substances.
4-3 Water management
We will appropriately manage the impact of water intake and discharge on the surrounding naturalenvironment. To do this, we will monitor the use and release of water and strive to conserve water.
Before wastewater is discharged or disposed of, we will monitor, control, and process it and wewill identify sources of pollutants that could cause water contamination and appropriately manage
them.
4-4 Preservation of biodiversity
We will strive to conserve the raw materials used in our business and preserve biodiversity in theregions where we conduct business.
4-5 Effective use of resources and waste management
We will promote the 3Rs (reduce, reuse, recycle) and strive to effectively use resources and curtail
the generation of waste.
4-6 Management of chemical substances
We will identify, label, and manage chemical substances and other materials that pose risks topeople and the environment and manage them to ensure safe handling, transportation, storage,use, recycling or reuse, and disposal.
4-7 Management of chemical substances in products
We will comply with applicable laws and regulations and customer requirements concerning theprohibition or restriction of use of specific substances in products.
4-8 Social contribution
We will actively participate in social, educational, and cultural support initiatives, interaction withlocal communities, beautification programs, volunteer programs, and so on.
5. Fair tradeWe will establish and implement an appropriate system for internal control to obtain logicalassurance that we are achieving the four goals of effectiveness and efficiency in operations,reliability of reports, compliance with laws and regulations related to our business activities, andthe maintenance of assets.
When engaging in procurement, we will comply with the applicable laws, regulations, treaties, andso on in each country and region and follow industry standards and international norms (including
standards formulated by the KOKUYO Group). We will take a firm stand and not accede to any
improper demands made by criminal organizations that threaten the good order and safety of civilsociety. Furthermore, we will not have any business dealing with such organizations. We will
respect the rights of trading partners, take action to prevent all corruption including extortion andbribery, and will practice sound, proper, and fair trade.
5-1 Compliance
We will comply strictly with national and regional laws and regulations, social norms, andcorporate ethics and strive to educate employees.
5-2 Fair and transparent trade
We will conduct fair and transparent trade that respects free competition. Furthermore, we will notuse our status as the buyer to demand money, goods, or special treatment from trading partners.
5-3 Prohibition of dealings with criminal organizations
We will take a firm stand and not accede to any improper demands made by criminal organizations
that threaten the good order and safety of civil society. Furthermore, we will not have any businessdealing with such organizations.
5-4 Protection of intellectual property rights
We will protect intellectual property rights and not engage in any improper use.
5-5 Prohibition of conflicts of interest
We will not engage in any conduct where officers or employees use their status to gain personal
benefit contrary to the proper interests of the company.
5-6 Protection of whistleblowers
We will protect the confidentiality of information relating to whistleblowing and the anonymity ofwhistleblowers and eliminate any retaliation against whistleblowers.
5-7 Prohibition of insider trading
We will not engage in insider trading including trading of the shares of our own company oraffiliated companies based on non-public material inside information and will not engage in any
conduct that induces insider trading.
5-8 Responsible minerals procurement
We will confirm that the tantalum, tin, tungsten, and gold minerals used in the products that wemanufacture do not cause or contribute to any serious human rights violations, environmental
destruction, corruption, conflict, and so on in conflict and high-risk regions.
5-9 Ensuring reliability of reports
We will ensure the reliability of reports (including nonfinancial information) and will not tolerate thefalsification of records or significant misrepresentations in applications, reports, and such.
6. Information security

We will properly manage confidential corporate information including sales, technical, andmanagement information as well as personal information and prevent loss and leaks of information.
We will not engage in insider trading including trading of the shares of our own company or affiliatedcompanies based on non-public material inside information and will not engage in any conduct thatinduces insider trading.
6-1 Defense against cyber attacks
We will take defensive measures against cyber attacks and other threats and conduct
management to prevent harm to the company and others.
6-2 Protection of personal information
We will comply with relevant laws and regulations relating to and appropriately manage andprotect all personal information including the personal information of suppliers, customers,consumers, and employees.
6-3 Prevention of leaks of confidential information
We will appropriately manage and protect not only our own confidential information, but also
confidential information received from customers and third parties.