Compliance

01Basic View

We have established the “Nisso Group Charter of Corporate Behavior,” which presents the fundamental principles of conducting fair and sincere business activities, and the “Nisso Group Employee Code of Conduct,” which provides specific action guidelines. We distribute a pocket leaflet “NISSO Michishirube” (literal meaning: NISSO Guidelines), which contains the aforementioned Charter and Code to officers and employees of the Nisso Group in order to ensure that they are fully aware of legal compliance and ethical behavior.
Furthermore, the “Risk Management Committee,” chaired by one of our Directors, discusses the promotion of corporate ethics and compliance, as well as the development of systems for the prevention and detection of misconduct, and the “Board of Directors” supervises, manages, and approves these initiatives.

02Nisso Group Ethics Policy

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.

03Anti-corruption

In accordance with the Employee Code of Conduct and the Ethics Policy, we prohibit the exchange of inappropriate gratuities and gifts, illegal or improper political donations, and the exchange of benefits contrary to social norms. In addition, in order to eliminate and strive to prevent all forms of corruption, we established the "Bribery and Corruption Prevention Guidelines" in January 2026.

（Scope of Application）
・Applicable to all Officers and employees of the Group.
・In addition, we will seek the understanding and cooperation of third parties and business partners, such as clients, to whom we outsource our business operations.

（Definition）
・Bribery: The act of offering money, goods, entertainment, favors, etc., to public officials, etc., in connection with their duties in return for an unjust reward.
・Corrupt behavior: Wrongful acts, including conflicts of interest, excessive hospitality and gifts, and violations of laws and regulations.
・Public officials, etc.: Public officials, politicians, employees of government-affiliated companies, or persons in positions of influence over them and their family members, etc.

（Prohibited Matters／Compliance Matters）
・Bribery, entertainment, and gifts to public officials, etc., are strictly prohibited.
・Facilitation payments (small, informal payments intended to expedite routine administrative procedures) are prohibited.
・Entertainment and gifts to the private sector must be within socially acceptable limits and, in principle, require prior approval.
・Donations and contributions for the purpose of reciprocation are prohibited, and even if they are implemented as social contribution activities, strict compliance with the laws and regulations of each country is required, as well as thorough adherence to internal approval procedures and record keeping.

（Operation・Management Structure）
・The Compliance Division will be responsible for implementing these Guidelines, and the Compliance Officer will oversee their implementation.
・An internal reporting system will be established to ensure that whistleblowers are not subject to adverse treatment.
・All Officers and employees will undergo regular internal training on relevant laws and regulations and these Guidelines to ensure thorough understanding and compliance.
・The Risk Management Committee will verify the status of compliance with these Guidelines through monitoring and internal audits. For any violations, it will investigate, consider corrective actions and disciplinary measures, etc., and report and submit recommendations on the results to the Board of Directors and relevant Divisions.

04Establishment of a Point of Contact Based on the Internal Reporting System

We have established the “Nisso Group Internal Reporting Counter,” which enables anonymous reporting of any corrupt practices, including bribery. At the same time, we prohibit any disadvantageous treatment of informants and have established a system to conduct investigations, implement corrective actions, and take measures to prevent recurrence in the event of such reports. In FY 3/2025, there were 10 consultations and reports submitted to the “Nisso Group Internal Reporting Counter” (disclosed in accordance with the Whistleblower Protection Act Guidelines). Each consultation and report was investigated and verified while thoroughly ensuring whistleblower protection, and necessary measures were implemented. Responses to all reports and consultations have been completed.

05Internal Audits

Internal audits at NISSO HOLDINGS are conducted by the Internal Auditing Division, an organization under the direct control of the Representative Director, comprising one Division Head and three staff members. Audits are conducted in accordance with the annual plan, covering the Headquarters, subsidiaries, and sub-subsidiaries. Results are reported to the Representative Director and the Audit and Supervisory Committee, as well as to the Board of Directors. In addition, instructions for improvements based on the results of the audits are issued to the department/division that has received the audits, and the status of improvements are reported by them and confirmed by the Internal Auditing Division without delay. Follow-up audits and special audits are conducted as deemed necessary. In addition, the Internal Auditing Division exchanges information with the Audit and Supervisory Committee and the Accounting Auditor as required to strengthen mutual coordination.

06Compliance Education

In order to ensure thorough compliance, we provide compliance training for all officers and employees in accordance with our Ethics Policy. In FY 3/2025, a total of 15,711 officers and employees of NISSO CORPORATION participated in compliance-related training.