Corporate Ethics

Formulated October 2, 2023

The Nisso Group respects basic human rights and maintains work environments that can be used safely and healthily, in addition to developing fair and sincere corporate activities with the aim of creating enriched lives. In addition to complying with laws and regulations, as a company that possesses high ethical standards, accepts diverse sets of values, and prizes the sense of fulfillment and job satisfaction of each individual, we pledge to take responsible actions, and have established the "Nisso Group Charter of Corporate Behavior".

Scope of Application

This Charter shall be applicable to all Corporate Officers and employees working at the Nisso Group.

Regarding the Enforcement of the Charter

Officers and employees shall comply with this Charter, and strive to ensure that all people involved with the Nisso Group, including clients, business partners and shareholders, understand the purpose of this Charter, and be able to receive cooperation from them. Officers and executives shall be obligated to take the initiative in the establishment, and the understanding and dissemination of this Charter both internally and externally.

<Sincere Business Activities>

• By positioning the improvement of our clients' satisfaction as the basis of our activities, we shall constantly strive for ingenuity and enhancement, and provide services that are beneficial to our clients.
• We shall fully utilize the organization and functions of the entire company in order to address problems that may arise in the workplace.
• We shall conduct fair and transparent corporate activities, and constantly strive to enhance corporate values and redistribute profits appropriately.
• We shall create employment through our businesses, and strive to actively contribute to society as a support function for the selffulfillment of workers.

<Respect for Human Rights>

• We shall respect the international norms on human rights, and shall not participate in any action that may interfere with or impede human rights.
• We shall respect fundamental human rights, the diversity and individuality of employees, and shall not prejudice nor discriminate against individuals by reasons such as race, nationality, creed, gender, religion, physical characteristics, personal possessions, birthplace, etc.
• We shall comply with labor laws and regulations related to working conditions such as employment and wages. We shall not allow for child labor of those below the minimum age for employment, nor forced or unfair labor that is against the intentions of employees. In addition, we shall not purchase materials or products, etc., produced through child labor or forced labor.

<Communication with Social and Information Disclosure・Information Protection>

• We shall manage company information appropriately, and disclose information deemed to be necessary in a prompt, adequate and accurate manner.
• We shall thoroughly protect and manage various kinds of information, including personal and client information, as well as intellectual property rights, and shall not unjustly infringe upon nor use such information.

<Exclusion of Anti-social Forces>

• We shall take a resolute stance against anti-social forces and organizations, and shall not respond to any unjust or unlawful demands

<Creation of a Vibrant Workplace>

• We shall respect the existence of each employee, and actively create opportunities to maximize the abilities of each individual.
• We shall create a lively and vibrant working environment where employees can speak freely.
• We shall value our stance of seeking the reform and innovation of employees, and nurture employees who will lead the next generation.
• We shall respect fundamental labor rights, such as the right for employees to unite and/or bargain collectively, and shall not infringe upon such fundamental labor rights.

<Securement of Safety and Initiatives for the Environment>

• We shall recognize the importance of environmental problems, utilize resources effectively, promote energy conservation and actively address environmental improvement.
• We shall regard safety and "no accidents" as societal responsibilities, and strive to ensure safety not only during working hours, but also during commuting times.

<Responsibilities of Management>

• We shall consider the securement of safety and the maintenance of health of employees as a top priority, and shall spare no investment of management resources to maintain and improve the lives of employees.
• When operating the company, we shall listen to both internal and external comments/opinions with sincerity, and choose the best ways to fulfill our social responsibilities.

<Responses to the Occurrence of Problems>

• In the event of an incident or problem that contravenes this Charter, management shall show their determination to resolve such issues both internally and externally, take the initiative to promptly and reliably respond to such matters, and endeavor to investigate its cause and prevent its recurrence. In addition, management shall disclose such information and fulfill their accountability to society in a prompt and accurate manner, and implement strict disciplinary measures, including on themselves, upon clarifying the authority and responsibility of those involved.

Formulated October 2, 2023

For the realization of the spirit of the Nisso Group Charter of Corporate Behavior, as a standard of behavior that officers and employees of the Group should uphold on a daily basis, a more specific "Nisso Group Employee Code of Conduct" has been established. Officers and employees must recognize that they are responsible for compliance with this Code of Conduct, and act accordingly.

<Sincere Business Activities>

• We shall conduct fair and transparent transactions based on law and ethics and strive to gain the confidence of society as a whole.
• We shall maintain sound and moderate relationships with stakeholders, and shall not accept entertainment, gifts, or money for the purpose of acquiring unfair profits.
• We shall respond to the voices of clients' with integrity, and reflect such actions in the provision of services and the improvement of business operations in the future.
• We shall observe the Charter of Corporate Behavior, laws, rules of employment, internal regulations, etc., and act with dignity and discipline.

<Respect for Human Rights>

• We shall abolish discrimination based on race, creed, gender, social status, religion, nationality, age, physical and mental disability, and respect individuals.
• We shall always respect fundamental human rights in various aspects of corporate activities, and shall not engage in discriminatory behavior or actions that harms the dignity of individuals.
• We shall eliminate forced labor or labor that is against one's will, and child labor of those below the minimum age for employment.
• We shall not disrupt the morals, environment and the order of the workplace by acts that violate public order and standards of decency such as various types of harassment.

<Communication with Social and Information Disclosure・Information Protection>

• We shall deepen mutual understanding with society and establish relationships based on trust through communication.
• We shall conduct the accurate disclosure of corporate information to stakeholders in a timely and appropriate manner.
• We shall strictly manage confidential and personal information, including client information acquired in the course of business, and shall not divulge such information elsewhere. Such obligations shall also be fulfilled following employment at NISSO and/or after retirement.
• We shall not infringe upon intellectual property rights, including copyrights and patent rights, of others.
• We shall not use internal information obtained in the course of duties for personal purposes. In addition, we shall not conduct acts that will be of self-interest based on insider information obtained during the course of duties.

<Dissociation with Anti-social Forces>

• We shall not have any relationships or business dealings with anti-social forces.
• We shall not make concessions by means of money, etc., against unreasonable demands from anti-social forces.

<Creation of a Vibrant Workplace>

• We shall comply to laws and regulations concerning labor, and strive to realize a healthy and comfortable working environment so that harmony between work and life can be achieved.
• With the stance to take on challenges to achieve higher goals, we shall strive to improve our abilities and to nurture subordinates and junior employees.

<Securement of Safety and Initiatives for the Environment>

• With regards to business activities, we shall strive to conserve resources and energy, and make efforts to preserve the environment and reduce waste. In addition, we shall actively cooperate with clients, business partners, etc., in their global environmental preservation efforts.
• We shall comply with laws, internal regulations and workplace rules related to occupational health and safety, promote the prevention of occupational accidents and mental health initiatives, and strive for the creation of a safe workplace.
• We shall strive to improve our compliance of laws, regulations and traffic manners, and make efforts to prevent traffic accidents by practicing safe driving.

Formulated October 2, 2023

The Nisso Group, as well as our officers and employees, shall uphold and comply with the following policy in order to share our commitment to and ensure the awareness of compliance, which is fundamental to corporate management.

1.（Ethical compliance with laws and regulations）

With high ethical standards, we shall act with integrity and respect both the letter and the spirit of the law both at home and abroad.

2.（Elimination of improper benefits）

We shall prohibit bribery, corruption, extortion, and embezzlement of any kind. In addition, we shall not engage in acts that fall within the scope of bribery, such as granting, accepting, requesting, authorizing, or making promises for (improper) benefits, with the aim of engaging in inappropriate acts which violate laws and internal regulations by abusing our authority or position in the course of our duties.

3.（Information disclosure and transparency）

We shall disclose corporate information to our stakeholders, such as clients, shareholders・investors, business partners, the government, local communities, and society in a timely・accurate manner in order to enhance transparency.

4.（Protection of intellectual property）

We shall respect the intellectual property of others obtained through our corporate activities, and protect confidential information.

5.（Fair・transparent・free competition and business transactions）

We shall always engage in fair・transparent・free competition and business transactions in domestic and overseas markets.

6.（Protection of identities and elimination of retaliation）

In conformity with laws and internal regulations, we shall protect those who report any wrongdoings (whistle-blowers) using internal systems, such as by telephone or e-mail, from being forced into disadvantageous situations or from being retaliated against.

7.（Dissemination and thorough observance）

In order to ensure the thorough observance of this policy, we shall appropriately implement education for our officers and employees, disseminate its content, and conduct checks on a regular basis to further promote compliance management.

Formulated October 2, 2023

Recognizing that respect for human rights is the foundation of business in our daily activities, NISSO HOLDINGS Co., Ltd. and its affiliates (hereinafter, the " Nisso Group ") shall uphold and commit to the following policy in order to advocate international standards on human rights, such as the United Nations Global Compact's principles concerning human rights・labor, and conduct the management of respect for humanity.

1.（Free choice of employment）

The Nisso Group is committed to not employing any kind of forced labor in our business activities.

• We shall not employ forced labor, bonded or indentured labor, or involuntary prison labor.
• Certification documents belonging to individuals, such as passports and ID cards, shall be kept・managed by employees, and NISSO shall not retain any of the original documents.
• The relationship between workers and NISSO shall be voluntary, and workers shall have the freedom to leave their workplaces or to terminate their employment at any time.

2.（Young workers）

The Nisso Group is committed to complying with the minimum age laws and requirements of each country, to not employing child labor, and to ensure fair treatment of student workers, interns, apprentices, etc., regardless of their employment status.

• We shall not hire children under the age of 15 in Japan.
• We shall also give appropriate consideration to young workers under the age of 18 in conformity with domestic laws.
• When employing student workers, interns, apprentices, etc., we shall ensure compliance with domestic laws, appropriate training and management, and shall not use such employees as cheap labor.

3.（Working hours）

The Nisso Group is committed to complying with the laws and regulations related to labor of each country regarding working hours・holidays・vacations (paid leave).

4.（Wages and welfare・benefits）

The Nisso Group is committed to complying with the wage-related laws of each country, to making appropriate salary payments, and to not making unjust reductions or deductions./p>

• We shall provide workers with ways to accurately confirm their compensation on a regular basis.
• Compensation shall be paid by cash or bank transfer on a regular basis.

5.（Humane treatment）

The Nisso Group is committed to taking strict measures to prevent harsh and inhumane treatment, such as abuse and harassment.

• We shall not tolerate or engage in acts such as sexual harassment・sexual abuse・corporal punishment・mental or physical coercion・verbal abuse.

6.（Elimination of discrimination）

The Nisso Group is committed to respecting the diversity of each individual and to creating a workplace free of harassment and unlawful discrimination.

• We shall eliminate discrimination based on human rights・creed・gender・age・social status・family origin・nationality・ethnicity・religion・sexual orientation・gender identity/expression・marital status/history・pregnancy status・protected genetic information・presence/absence of military experience・political affiliation・status of labor union participation, or presence/absence of disabilities.
• We shall give due consideration to requests from workers related to religious and ethnic customs, etc., to the appropriate extent, and eliminate discrimination in the workplace due to such matters.
• We shall value personality・individuality, and shall provide fair opportunities for recruitment・employment・skills development・education・salary increases・advancement/promotion, etc., according to ability.

7.（Freedom of association）

In accordance with the laws and customs of each country, the Nisso Group is committed to respecting the operation of labor unions and organizations of employees, and to respecting the rights of workers, including their formation of and participation in such organizations, and their right to collective bargaining.

8.（Full dissemination）

In order to ensure the thorough observance of this policy, we shall appropriately implement education for our officers and employees, disseminate its content, and conduct checks on a regular basis to further promote the management of respect for humanity.

In order to prepare for various risks that may interfere with business continuity, such as large-scale disasters, pandemics, etc., the Nisso Group has established the "Nisso Group Business Continuity Plan (BCP) Basic Policy" in accordance with the spirit of the Nisso Group's management and corporate philosophies.
Group employees shall recognize the basic concept of this policy, and make appropriate decisions・actions as members of a socially responsible company.

1. We shall develop a plan to achieve the following objectives:

1. We shall place top priority on the safety・security of our employees, their families, and our service users.
2. We shall support the business continuity of our clients and business partners.
3. We shall support the reconstruction of disaster-stricken areas and contribute to local communities.

2. We shall clarify the operations to be continued・restored, and implement specific measures in a planned manner.

3. We shall conduct education・training for our employees and throughout our organization on a regular basis in order to make continuous improvements.