NIPPON YAKIN KOGYO CO., LTD

The Company shall establish a “Code of Conduct” that all officers and employees are required to follow. In carrying out business operations, the Company shall not only comply with domestic and international laws and regulations but also respect social norms and conduct business activities with integrity.
In addition, a Compliance Committee headed by a full-time director other than a member of the Audit & Supervisory Committee shall establish a system to prevent violations of laws and regulations or conduct that may lead to such violations.

The Company shall establish information management rules based on relevant laws and regulations in its internal regulations governing business operations, such as the “Board of Directors Regulations,” and shall establish a system for the proper storage and management of information, including IT security.

The Company shall establish the “Risk Management Regulations” to accurately assess the risks arising from business operations and to establish a framework for their appropriate management. In addition, the Company shall establish specific regulations addressing critical risks, such as emergency response procedures and business continuity plans.
Furthermore, in conjunction with the activities of the standing committee established to ensure the smooth operation of these regulations, the Company shall ensure the implementation of these measures to ensure the appropriate management of risks.

To ensure the smooth operation of its internal organization, the Company shall make appropriate and prompt management decisions based on the importance of each matter, in accordance with the “Regulations on Division of Duties,” “Regulations on the Management Committee,” and “Regulations on Business Operations.” In addition, to revitalize and strengthen the Board of Directors and to respond effectively to changes in the business environment surrounding the Company and intensifying global competition, the Company shall adopt an executive officer system. This system clarifies the responsibilities and roles related to business execution, with the aim of further accelerating management decision-making and business operations.
Furthermore, the Internal Control Office, which reports directly to the President and Representative Director, shall conduct operational audits and other activities aimed at evaluating the effectiveness of internal controls and promoting improvements.

1. (1)Systems for reporting to the Company on matters related to the performance of duties by directors of the Company’s subsidiaries
   The Company shall establish basic management policies to be applied to and specific operational procedures, such as approval requests, for each subsidiary and other entity comprising the corporate group (hereinafter referred to as the “NAS Group”), and shall establish a system to ensure that all important information within the NAS Group is communicated to the Company without omission.
2. (2)Regulations and other systems for managing the risk of losses at the Company’s subsidiaries
   Each company within the NAS Group shall apply the “Risk Management Regulations” shared with the Company and, where necessary, shall establish specific regulations regarding significant risks; by effectively implementing these measures, they shall ensure the appropriate management of risks.
3. (3)Systems to ensure the efficient performance of duties by directors of the Company’s subsidiaries
   Each company within the NAS Group shall establish, through internal regulations, the division of duties and standards for business execution according to the actual conditions of each company to ensure smooth internal organizational activities and to make appropriate and prompt management decisions based on the importance of each matter. In addition, our Internal Control Office shall conduct business audits and other activities targeting each company within the NAS Group for the purpose of evaluating the effectiveness of internal controls and promoting improvements.
4. (4)Systems to ensure that the performance of duties by directors and employees of the Company’s subsidiaries comply with laws, regulations, and the articles of incorporation
   In conducting their business operations, all NAS Group companies shall not only comply with domestic and international laws and regulations but also respect social norms and conduct their business activities with integrity.
   Furthermore, the Company shall establish a system to prevent violations of laws and regulations, or any conduct that may lead to such violations, in collaboration with the compliance departments of the Company and all NAS Group companies.

The Company fully recognizes that financial reporting is of paramount importance to both internal and external stakeholders in assessing the activities of the Company, and that any errors in such reporting not only cause unforeseen harm to many stakeholders but also significantly undermine trust in the Company. The Company shall be committed to ensuring the reliability of its financial reporting through a company-wide effort.
In addition, the President and Representative Director shall establish and properly operate a system to ensure the reliability of financial reporting, and shall promptly take corrective measures if any material deficiencies requiring disclosure are discovered.

The Company shall appoint employees to assist the Audit & Supervisory Committee in its duties upon the Committee’s request, and shall consult with the Audit & Supervisory Committee regarding the personnel appointments and performance evaluations of such employees.

If the employee in question holds concurrent positions, special care shall be taken to ensure that the employee’s independence is safeguarded and that the performance of the employee’s duties on the Audit & Supervisory Committee is not hindered.

1. (1)System for directors and employees, etc. other than the Company's Audit & Supervisory Committee members, to report to the Company's Audit & Supervisory Committee
   Upon request from the Audit & Supervisory Committee, the Company shall consult with the Committee to specifically determine, on a regular basis and as necessary, the matters to be reported to the Audit & Supervisory Committee. Such determinations shall include matters to be reported by subsidiaries.
2. (2)System for directors, auditors, and employees of the Company's subsidiaries, or those who have received reports from them, to report to the Company's Audit & Supervisory Committee
   The Audit & Supervisory Committee shall receive regular reports from the accounting auditors and directors other than members of the Audit & Supervisory Committee, or other persons, as necessary.

To ensure that individuals who made a report as described in the preceding section are not subjected to any adverse treatment as a result of such reporting, the Company shall establish the “NAS Group Helpline Regulations” and shall thoroughly communicate the purpose and content of these regulations to all directors, auditors, and employees of the Company and the NAS Group.

If a member of the Audit & Supervisory Committee requests an advance payment or reimbursement of expenses incurred in the performance of their duties, the Company shall promptly settle such expenses or liabilities.

When the Audit & Supervisory Committee deems it necessary to conduct an operational audit, directors and employees other than members of the Audit & Supervisory Committee shall cooperate with such audit.

Established: May 12, 2006
Seventh revision: June 26, 2025
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