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”.

In response, we have recognized that compliance means complying with laws and social norms, formulated Compliance Rules, and established a Compliance Basic Policy.

We have also established the Compliance Manual which applies to our Company, our affiliates, and their subsidiaries. The Compliance Manual clearly indicates specific rules to be observed for our Group employees, and we will promote our day-to-day activities even more sincerely than ever before.

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 is held twice a year, has been established as an organization to enhance the effectiveness of risk management, and to maintain and promote compliance. The committee is chaired by the Chief Risk Management Officer (CRO), who is appointed at the Board of Directors meeting, and is composed of the Risk & Compliance Managers of each division / department, plant / laboratory, and domestic consolidated subsidiary appointed by the CRO. The important matters and countermeasure plans, etc. related to compliance are approved at the Board of Directors meeting after discussion at the committee.

In addition, the Risk Management & Compliance Office under the Corporate Planning Department has been established as a specialized organization to promote continuous improvement in all of our Group's compliance activities. In addition to providing education and guidance on risk management and compliance, the Risk Management & Compliance Office receives reports on the status of compliance with laws and regulations and the status of education and training in each department on a regular basis from Risk & Compliance Managers, and when necessary, supports improvement and shares information within our Group.

Moreover, we have established the Consultation Hotline based on Whistleblower Protection Act to serve as an internal reporting system to prevent compliance violation or resolve the problem early on.

Indicators

Compliance Violation

• Includes unconsolidated group companies in Japan

Expenditures to Industry Organizations and Political Contributions

Activities

Top Message Transmission

Every year, top message is transmitted to all employees in order to clearly convey the Group's stance for compliance.

Compliance Status Reporting

Twice a year, the entire Group, including each division / department, plant / laboratory, and affiliate, checks the status of compliance, and in case of a risk of compliance violation or potential compliance violation, the Risk Management & Compliance Office receives reports including the response status. The content is 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 around every third year. Based on the awareness survey on the Group’s policies and common rules of conduct, we objectively acknowledge the current organizational culture for compliance and reflect its result to future education programs and activities for raising compliance awareness.

Consultation Hotline

We have Consultation Hotline as an internal reporting system to prevent compliance violation or resolve the problem early on. When an employee discovers a compliance violation or potential compliance violation, he or she shall address the problem in normal operation in principle, through measures that include reporting the matter to their superior. However, if he or she thinks it is difficult to address the problem promptly and effectively, they can use the Consultation Hotline.

The contact point for reporting shall be the Risk Management & Compliance Office, outside attorneys, or outside audit & supervisory board members, and the means for reporting may be selected from e-mail, mail, or telephone. 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 status of the operation of the internal reporting system and supervises it.

While accepting anonymous consultations, we have established a system that allows us to provide peace of mind by clearly defining in our rules the prohibition of interference with investigations, finding informants, and harassment.

Compliance Training

We hold participatory training sessions on corporate ethics for officers and employees, including new employee, working to ensure that each and every one of us looks at compliance and actively promotes it.

Regarding various laws and regulations, we regularly hold training on important business themes such as the “Antitrust Law”, insider trading regulations, and regulations on the “Combating Bribery of Foreign Public Officials”. We also conduct training with an emphasis on practicality, such as in-house seminars on familiar legal matters lectured by internal instructors and on-demand online training.

Various trainings are provided to officers and employees of our company as well as those of affiliated companies as efforts to improve the knowledge of the entire Group.

Compliance Manual

The Compliance Manual sets forth rules so that executives and employees, etc. (regular employees, contract employees, part-time workers, temporary workers and dispatched workers) of the Nissan Chemical Group comply with laws and regulations, company rules, social norms, and ensure compliance. It is regularly reviewed depending on the situation, such as the enforcement and revision of laws and regulations. In addition, by including information about the Consultation Hotline system and details about its features in the Compliance Manual, we are raising awareness about our internal reporting system.

Compliance Rules

Tax Transparency

• Tax Policy