2-1．Respect for diversity and anti-discrimination

We uphold the Universal Declaration of Human Rights and the Ten Principles of the UN Global Compact. We will protect human rights and respect diversity, individuality, and personal characteristics. We must not engage in any conduct that could lead to unfair discrimination. We will not tolerate unreasonable discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, marital status, religion, or political affiliation. We will not tolerate discriminatory practices, violence, or sexual or other harassment.

2-2．Prohibition of forced labor

We prohibit utilizing labor force by human trafficking, forced labor exploitation in the form of slavery and will not employ children under the age of 15. We must comply with the relevant laws and regulations on late-night work or hazardous work when employing young workers over the age of 15 but under the age of 18. Board members and managerial staff of the NDK Group must comply with the effective laws and regulations of each country in regard to managing the working hours of their employees. We will make efforts to ensure that our staff's working hours including overtime do not exceed 60 hours per week. Further, we must provide employees with holidays in accordance with the relevant laws and regulations of each country and ensure that they receive at least one day off in every seven-day period. The NDK Group executives and managers must not impose unreasonable restrictions on employees' entry to or exit from company-provided facilities, nor impose unreasonable restrictions on employees' freedom of movement within such facilities.

2-3．Proper recruitment process

The NDK Group companies in regard to hiring employees must comply with the laws and regulations of the respective countries and provide terms and conditions of employment or execute an employment contract, in a language that a new staff can understand. We must not retain an employee's original passport, driver's license, work permit, or any other original identification document with us. We must not improperly demand any money or anything of value when hiring staff.

2-4．Payment of minimum wage

Wage payable to employees of the NDK Group must not be lower than the minimum wage allowed by law in the relevant countries. The NDK Group companies must pay allowances for overtime work or holiday work in accordance with the laws and regulations of their respective countries. We must provide employees with timely and understandable wage statements for each pay period, containing sufficient information to verify accurate compensation for work performed.

2-5．Labor unions

The NDK Group companies must permit the establishment of and membership in labor unions in accordance with the laws and regulations of their respective countries. Similarly, we will respect the rights of workers who choose not to participate in such activities.

3-1．Providing a safe environment

We will conduct workplace safety risk assessments and implement appropriate safety measures for machinery and equipment used in the NDK Group companies. We will address, deal with, and eliminate potential safety hazards by controlling design and technical aspects of the machinery and equipment, and providing training. We must comply with the designated procedures for using machinery and equipment. If these measures cannot adequately control the hazards, we will provide employees with appropriate protective equipment at no cost. We will release and mitigate a health and safety risk related to pregnant women/nursing mothers such as to take reasonable steps to remove them from working condition with high hazards.

3-2．Providing a clean and hygienic environment

We must keep our workplace clean and hygienic, and take appropriate action to deal with potential health and safety hazards posed by toxic chemicals. We must comply with the designated procedures for using chemicals and the designated rules for using protective gear. Facilities used by executives and employees of the NDK Group (e.g. dormitories, cafeterias, or restrooms), if any, must be kept clean and hygienic. Inhumane living conditions (e.g. dozens of people living in the same room) must not be tolerated.

3-3．Ascertaining work-related accidents, illnesses and injuries

The NDK Group companies must ascertain work-related accidents, illnesses, and injuries, and take appropriate measures. We must also take measures to prevent work-related accidents, illnesses, and injuries to a reasonable extent.

3-4．Response to emergency situations

We will identify potential incidents or accidents that can happen to us and prepare ourselves for any emergency situation in order to protect the safety of lives, prevent personal injury, and minimize damage to company assets. We must participate to the extent possible in training and education such as emergency evacuation drills required by related NDK company.

3-5．Consideration of work that may cause physical stress to workers

We will identify and give due consideration to work that may cause significant physical stress to workers in order to prevent accidents, illnesses, or injuries. We must act according to the company criteria for work that have a high physical load.

3-6．Providing health and safety information/training

The NDK Group companies must provide information on workplace health and safety in a language that all executives and employees of their companies can understand. Health and safety training must be provided to all workers prior to the beginning of work and regularly thereafter.

4-1．Environmental philosophy and policy

As stated in the NDK Group environmental philosophy and policy, we recognize the importance of reducing the impact of our business on the environment and creating a recycling-oriented society. We are committed to and responsible for proactively and continuously undertaking initiatives to protect the environment and preserve this precious Earth for all future generations.

4-2．Environmental Permits and Reporting

We will obtain and maintain all required permits in accordance with applicable laws and regulations, and comply with operational and reporting requirements.

4-3．Prevention of Environmental Pollution

We will minimize or eliminate the emission and release of pollutants, as well as the generation of waste. We will also properly manage wastewater, exhaust emissions, and other discharges in accordance with the laws and regulations of each country.

4-4．Hazardous Substance Management

We must ensure that our products do not contain any chemicals prohibited or restricted by law nor do they contain such chemicals in quantities exceeding permitted limits. We must comply with applicable labeling requirements. We must manage hazardous waste to ensure proper disposal, and we must track and document hazardous waste data.

4-5．Solid Waste Management

We will identify, manage, and reduce solid waste (other than hazardous waste) generated from our business activities, and responsibly dispose of or recycle such waste. We will also maintain proper management of waste data.

4-6．Material Restrictions

We will comply with the applicable laws and regulations regarding the prohibition or restriction of specific substances in products and manufacturing processes.

4-7．Energy Consumption and Greenhouse Gas Emissions

We must establish and report greenhouse gas reduction targets. We must track and manage energy consumption and greenhouse gas emissions for Scope 1, Scope 2, and material categories of Scope 3. We will also strive to improve energy efficiency.

5-1．Disclosure of corporate information

We must disclose to our stakeholders, including shareholders and investors, information that we are required by laws or related regulations to disclose, and we must also disclose information that we determine should be disclosed, in accordance with the company's procedures and in a correct and timely manner.

5-2．Information management

We must not disclose or divulge to any third party or use for any purpose other than for business purposes any personal information that may come to our knowledge in the course of business, unless we are permitted to do so by company policies or rules. The same applies to customer information that may come to our knowledge in the course of business. While employed by NDK company and thereafter, we must not disclose or divulge to any third party, or use beyond the extent necessary to perform our job duties, any confidential information of the NDK Group or any confidential information that we may receive from customers or suppliers, unless we are permitted to do so under the relevant agreements or by company rules. Further, we must respect third party intellectual property rights and must not unlawfully or improperly obtain or use any third party's trade secrets.

5-3．Protection of assets

We must properly maintain and manage the NDK's assets in accordance with company rules and must not use such assets for any purpose other than for the designated business purposes. We must not charge any personal expenses to NDK company.

5-4．Use of information systems

We must use the company's information system in accordance with the information security policy that is separately provided, as well as other company rules, and must not use the same for any private purposes. We must use the information system properly and strive to prevent information leaks or theft, or virus infections.

9-1．Maintenance and improvement of ethical standards

We recognize that the creation of a sustainable society is essential to the continued growth and development of the NDK Group and that we should, therefore, promote this CSR Guideline. In order to uphold high ethical standards and fulfill our social responsibility, we must maintain and further improve our ethical standards. For this reason, we will attend training sessions held within each of the NDK Group companies and take other constructive steps to gain a better understanding of this CSR Guideline and other relevant laws and regulations.

9-2．Assessment and improvement

The NDK Group companies must from time to time verify and assess whether this CSR Guideline is being promoted and disseminated utilizing violations of this CSR Guideline and the whistle-blowing policy, and endeavor to make further improvements, if necessary. We also will make efforts to assess and improve, if necessary, the ethical standards of our suppliers in the supply chain.

9-3．Reporting duties

Employees may report on violations of this CSR Guideline to their superiors, and raise or report concerns to internal or external hotlines in accordance with the NDK Group whistle-blowing policy or other related procedures. The NDK Group companies must keep the whistle-blower's identity and the information given by him/her confidential in accordance with such policy. The whistle-blower must not be treated unfairly.

9-4．Consulting superiors and seeking advice

If we are unsure of or concerned about whether a contemplated action conflicts or threatens to conflict with this CSR Guideline, we will seek advice of superiors or the relevant departments.