Corporate Profile

Compliance

Policy/Philosophy

Since our Group regards compliance with laws and social norms as a condition for the survival and development of the company, our Course of Action stipulates that we need to conduct “sensible business activities” and conduct ourselves as “good corporate citizens and decent members of society”.

Based on this principle, we recognize compliance as adherence not only to laws and regulations but also to broader social norms. Accordingly, we have established Compliance Rules and adopted a Compliance Basic Policy.

In addition, we have established the Code of Conduct as a common standard of conduct across the Nissan Chemical Group. We also operate “Minna no Compliance Navi,” an internal portal site serving as a practical compliance guide for domestic group companies. Through these initiatives, each officer and employee puts compliance into practice in their daily work and promotes sincere and responsible business activities.

Compliance Basic Policy

1. We consider compliance to be an important management issue and ensure thorough compliance in every aspect of its business activities, thereby establishing corporate ethics.
2. All officers and employees of Nissan Chemical Group shall be sufficiently aware of compliance and prevent the occurrence of a compliance violation.
3. In the event that a compliance violation has occurred or is likely to occur, we take a prompt and appropriate response.

System

The Risk Management & Compliance Committee, which meets twice a year, has been established as a body to further enhance the effectiveness of risk management, and to maintain, strengthen and promote compliance. The Committee is chaired by the Chief Risk Management Officer (CRO), who is designated by the Board of Directors, and consists of the Risk & Compliance Managers from each division / department, plant / laboratory, and domestic consolidated subsidiary appointed by the CRO. Important compliance-related matters and actions are deliberated by the Committee and approved by the Board of Directors.

In addition, the Risk Management & Compliance Office under the Risk Management Department has been established as a specialized organization to promote the continuous improvement of compliance activities throughout our Group. In addition to providing education and guidance on risk management and compliance, the Risk Management & Compliance Office regularly receives reports from Risk & Compliance Managers on the status of legal compliance and the implementation of education and training in each department and company. When necessary, it provides support for improvement measures and shares information within our Group. Summaries of legal compliance status and compliance initiatives are reported to the Board of Directors at least once a year, where they are evaluated and reviewed.

Moreover, we have established the Consultation Hotline based on the Whistleblower Protection Act as an internal reporting system to prevent compliance violations and facilitate their early detection and resolution.

Indicators

Compliance Violation

• Includes unconsolidated group companies in Japan

Expenditures to Industry Organizations and Political Contributions

Activities

Message from Top Management

Every year, a message from top management is delivered to all employees in order to clearly convey the Group's commitment to compliance.

Compliance Code of Conduct

The Nissan Chemical Group has established the Compliance Code of Conduct as a standard of conduct for practicing compliance. The Code sets forth the fundamental principles and practical guidelines for all officers and employees of the Group to act in compliance with laws, company rules, and social norms, and in accordance with corporate ethics. To ensure that the Group continues to be trusted by society under a shared set of values, we conduct ongoing communication and training activities.

• Compliance Code of Conduct

Minna no Compliance Navi

We operate “Minna no Compliance Navi,” an internal compliance portal site that serves as a practical compliance tool for domestic group companies.

The portal provides easy-to-understand explanations of compliance-related issues and case studies that employees may encounter in their daily work. It also facilitates access to consultation contacts and relevant internal rules, thereby supporting each employee in proactively practicing compliance.

Examples of topics covered in “Minna no Compliance Navi”:

• Respect for Human Rights (including the prohibition of discrimination)
• Elimination of Relationships with Antisocial Forces
• Prohibition of Bribery
• Fair Dealings with Business Partners
• Appropriate Management of Confidential Information
• Other key compliance topics

Compliance Training

We hold various training sessions on corporate ethics for officers and employees, including training for new graduates and mid-career hires, working to ensure that each and every one of us considers compliance seriously and actively promotes it.

Regarding various laws and regulations, we regularly hold training on important business-related topics such as antitrust laws, insider trading regulations, and regulations concerning the prevention of bribery of foreign public officials. We also conduct practical training including in-house seminars on familiar legal topics delivered by internal instructors and on-demand training programs.

These training programs are provided to officers and employees of our company as well as those of affiliated companies, helping to improve knowledge throughout the Group.

Legal Compliance Status Reporting

Twice a year, the entire Group, including each division / department, plant / laboratory, and affiliate, checks the status of compliance with laws and regulations. In cases where compliance violations or potential violations are identified, the Risk Management & Compliance Office receives reports including information on the actions taken. Such matters are reported to management and shared within the Group through the Risk Management & Compliance Committee to help prevent recurrence.

Compliance Awareness Survey

We conduct a compliance awareness survey for all the employees (including part-time employees, contingent workers, and temporarily dispatched workers) of the Group companies approximately once every three years. Based on the survey of awareness regarding the Group’s policies and common rules of conduct, we objectively assess the Group’s compliance culture and reflect the results in subsequent education programs and awareness-raising activities.

Consultation Hotline

We have established the Consultation Hotline as an internal reporting system to prevent compliance violations or facilitate their early resolution. When an employee discovers a compliance violation or potential compliance violation, he or she shall address the problem through normal business channels in principle, including reporting the matter to his or her superior. However, if he or she thinks it is difficult to address the problem promptly and effectively, the Consultation Hotline may be used.

The contact point for reporting shall be the outsourced reporting desk, the Risk Management & Compliance Office, outside attorneys, or outside Audit & Supervisory Board Members, and reports may be submitted via a website, e-mail, or postal mail. Upon receipt of a report, the contents are reported to the Audit & Supervisory Board Members. The Board of Directors periodically receives reports from the Risk Management & Compliance Office on the operation of the internal reporting system and supervises it.

While accepting anonymous consultations, we have established a system that clearly defines in our rules the prohibition of interference with investigations, attempts to identify informants, and harassment, thereby ensuring that employees can report concerns without fear.

Related Policies and Systems

Tax Transparency

The Nissan Chemical Group complies with the tax laws and regulations of each country and region and regards the proper payment of taxes as a fundamental aspect of fulfilling its social responsibilities.

• Tax Policy

Fair Management of Public Research Funds

We recognize the proper management of research activities funded by public research funds and the prevention of research misconduct as important responsibilities. We have established systems for the appropriate management and use of public research funds and strive to ensure the integrity and reliability of research activities.

Prevention of Customer Harassment and Recruitment Harassment

The Nissan Chemical Group has established Guidelines for the Prevention of Customer Harassment to ensure a safe and comfortable working environment while respecting the dignity and human rights of employees.

We respond appropriately as an organization to unreasonable behavior or demands from customers and business partners from the perspective of protecting employees, while striving to build trustworthy relationships through sound communication.

The Nissan Chemical Group has also established Guidelines for the Prevention of Recruitment Harassment to ensure fair and appropriate recruitment activities while respecting the dignity and human rights of job applicants.

We are committed to providing an environment in which applicants can participate in recruitment processes with confidence and continue to conduct education and awareness activities for officers and employees involved in recruitment.

External Compliance Reporting Desk

To identify and correct compliance violations or potential violations at an early stage, the Nissan Chemical Group accepts reports and information from business partners and other stakeholders regarding legal violations, human rights concerns, and other compliance-related issues associated with the Group’s business activities.

Reports and information received will be reviewed and addressed as appropriate, with due consideration given to the confidentiality of the reporter and protection against disadvantageous treatment.

• Reporting of compliance violations* (handled by an external service provider)
  * Examples include embezzlement, breach of trust, bribery, bid-rigging or price-fixing, accounting fraud, human rights violations (including child labor and forced labor), quality misconduct, and information leakage.