Sustainability

Promotion of Fair-Trading

Policy/Philosophy

With economic globalization and strengthening of regulations, there is growing demand by society for compliance with laws and corporate ethics and promotion of fair and just transactions.

Our Group specifies strives to ensure the transparency of transactions. In our compliance manuals, we have specified matters to be observed: Comply with antitrust laws, Conduct fair transactions with suppliers and comply with the "Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors", Prevent unfair competition, Prohibit excessive entertainment and gifts, and Prohibit bribery of foreign officials, etc. In addition, with regard to anti-corruption advocated by the 10 principle of the UN Global Compact, we have established anti-corruption policies covering the scope of our company, affiliated companies and their subsidiaries, and aim to be valued by society as a good corporate citizen.

Nissan Chemical Group Anti-Corruption Policy

The Nissan Chemical Group supports international standards, including the United Nations Global Compact, and establishes the Nissan Chemical Group Anti-Corruption Policy (this "Policy"). This Policy complements the Nissan Chemical Group’s position on compliance with respect to anti-corruption, and shall apply to all officers and employees working for the Nissan Chemical Group.

• 1)Definitions
  "Corruption" means the abuse of entrusted official authority for personal or company gain, including bribery.
  "Bribery" means that, when company conducts its businesses,
  • any of its officers or employees provides improper benefits to a third party for the purpose of inducing a third party to conduct fraudulent or illegal acts, or upon request from a third party, or
  • any of its officers or employees demands or receives improper benefits from a third party.
• 2)Commitment to Anti-Corruption
  The Nissan Chemical Group has zero tolerance for corruption of any kind.
  It shall not engage in any form of corruption relating to public officials, governmental agencies and any other clients (“Business Partners”). It shall also continuously ask the Business Partners not to engage in any corruption.
• 3)Compliance with respect to Anti-Corruption
  The Nissan Chemical Group shall comply with and require the Business Partners to comply with domestic and international laws and regulations concerning the prohibition of bribery and corruption, such as the Unfair Competition Prevention Act, the U.S. Foreign Corrupt Practices Act and the Anti-Unfair Competition Law of the People's Republic of China (commercial bribery rules). It shall also keep and maintain accurate financial records relating to business transactions involving itself.
  
• 4)Remediation
  In the event that the Nissan Chemical Group violates this Policy in the course of its business activities, it shall make efforts to remedy and correct the said violation through appropriate means and fully cooperate with investigations by the relevant authorities.
  

Date of Establishment: April 1, 2019

Compliance Manual (Excerpt)

Relating to Nissan Chemical Group Anti-Corruption Policy, our Compliance Manual specifies the matters all the officers and employees must comply with, as below. In addition, we are focused on ensuring a healthy management environment by holding training sessions periodically, and taking other necessary measures.

Prohibition of Excessive Entertainment and Gifts

• 1)None of us shall provide or offer to a public official or quasi-official any entertainment or gift that conflicts with the restrictions under the National Public Service Ethics Act and related laws and regulations.
• 2)Providing or offering entertainment or gifts to a business partner shall remain within the boundaries of common sense.
• 3)When we receive an entertainment or gift from a third party, such as a client or business partner, and if there is concern that it is likely beyond common sense, we shall consult our supervisor on how to respond.

Prohibition of Providing Entertainment and Gifts to Foreign Public Officials

• 1)None of us shall provide or offer to an official of a foreign national or local government or public entity (“Foreign Public Officials”) any entertainment or gift that conflicts with anti-bribery and corruption-related laws and regulations in and out of Japan.
• 2)When retaining a consultant, we shall be mindful not to provide or offer any entertainment or gift to the Foreign Public Officials via the consultant or another third party.
• 3)None of us shall make payment for facilitating any administrative service, so-called “facilitation payment.”

System

Organizational structure for prevention of bribery

We have established the Risk Management & Compliance Office under the Corporate Planning Department as a specialized organization to promote continuous improvement of overall our compliance activities, and we strive to prevent bribery through the fair and impartial operation of the internal whistleblowing help desk.

Across our entire group, under the supervision of the Risk & Compliance Managers, we check the status of compliance with laws and regulations every six months, including matters related to our Anti-Corruption Policy, such as the "Prohibition of excessive entertainment and gifts" and the "Prohibition of providing entertainment and gifts to foreign public officials." Additionally, if there are any violations or potential violations of laws, the Risk Management & Compliance Office receives reports on the response status each time, and the contents are reported to the management, shared within our group, and utilized for preventing recurrence.

Furthermore, the summary of the status of compliance with laws and regulations and compliance measures are reported to the Board of Directors at least once a year, where they undergo an evaluation of their appropriateness and are reviewed.

Indicators

Compliance Violation

• Includes unconsolidated group companies in Japan

Expenditures to Industry Organizations and Political Contributions

Activities

Training

To cultivate ethical values and awareness on preventing bribery, we periodically hold education and training sessions for all the officers and employees.