Company Receives Whistleblowing from Outside the Company

　We recognize that compliance is a foundation that supports a company and believe that it is important to prevent incidents from happening in which laws, regulations, or the Code of Ethical Conduct may be violated, or stop them from becoming serious or prolonged by taking corrective measures at an early stage. For that reason, we have established a contact point for whistleblowing, or making a disclosure, from outside the company, including that from our business partners.

(1) What the Compliance Hotline Receives
　If you are a person who works for one of our business partners or otherwise a person who does not work for the Company, and have learned of an act that violates laws, regulations, or the Code of Ethical Conduct, or an act that may or is likely to do so, the Compliance Hotline receives the disclosure from you.
Please refrain from blowing the whistle about matters unrelated to such an act or for an improper purpose, such as insulting or libeling.

(2) How to Blow the Whistle to the Compliance Hotline
　Disclosures to the Compliance Hotline are received via the Whistleblowing Form you will find below. For the sake of thorough fact-checking, we request, as a general rule, that you state your real name and contact information when blowing the whistle. You may also blow the whistle anonymously. However, please understand that there will be limits to what we will be able to do to investigate the facts and that we will be unable to give you feedback regarding our response and other matters.

(3) How the Company Deals with Whistleblowing
　A disclosure to the Compliance Hotline will be received by the NOF Compliance Committee Secretariat, and if it is determined that fact-checking investigations and corrective measures are necessary, we will make an effort to take swift action. Please note that we will not, in most cases, report on the progress and outcome of our response on an individual basis unless we decide that it is necessary.
　We will give the highest priority to the protection of the whistleblower and will not perform fact-checking activities he/she does not want. However, if the content of the disclosure is determined to be serious, we may fact-check without obtaining the whistleblower’s consent. In addition, we will protect the privacy of the whistleblower, and the fact that he/she has blown the whistle, the content of the disclosure, etc., will be kept confidential except when it is necessary to release such information for investigation. Moreover, we will not treat the whistleblower unfavorably in business transactions on the ground that he/she has blown the whistle. This does not apply, however, if the whistleblower himself/herself is complicit in violation, such as whistleblowing for an improper purpose or intentionally communicating incorrect information.

(4) How the Company Handles Personal Information
　Please refer to the Privacy Policy for our policy on protection of personal information.

Matters You Should Keep in Mind When Whistleblowing
•When blowing the whistle, please read the explanation provided above under the title of “Compliance Hotline” and fill out the Whistleblowing Form below. Please provide us with as detailed and specific information as possible.
•Please refer to the Privacy Policy for our policy on protection of personal information.

• Whistleblowing Form