Policy（our fundamental view）

　We have been deploying compliance and adaptation to relevant laws and regulations, management and handling of chemical substances, management and reduction of environmental impacts, and customer safety as elements of chemical safety in our Responsible Care (RC) activities.
　We comply with relevant laws and regulations set forth in each country and region and adapt to environmental laws and regulations by disclosing chemical substance risk information, participating in industry associations and gathering information on regulatory trends.
　In the management of chemical substances, we are also working to assess product safety risks, including new chemical substances, and enhance the functions of our management system to improve transparency and visibility. Moreover, to ensure the safety of our employees, we require the wearing of appropriate protective equipment and measure working environments based on chemical substance risk assessments.
　We are also actively working to manage and reduce environmental impacts, and are managing PRTR Act-controlled substances, reducing emissions into the atmosphere and controlling CFCs in accordance with the law.
　Further, to ensure the safety of our customers, we provide information obtained from product safety risk assessments listed on product labels and safety data sheets (SDS), as well as ensuring hat Yellow Cards are carried for safety during transportation. Through RC activities utilizing the PDCA cycle, we are working to improve the level of chemical safety each year.

Management approach

　In order to meet the needs of our customers now and in the future, the NOF Group promotes appropriate risk-based management of chemicals and conducts product safety risk assessments for all products, including new products.
　Many countries and regions are now actively enacting or revising laws and regulations related to chemicals management. In cooperation with Group companies in Japan and overseas, NOF is strengthening its ability to gather information on regulatory trends and enhancing its functions using a comprehensive chemicals management system in order to ensure compliance with the following items.

●We maintain a comprehensive understanding of the hazards, risks, and impacts of each product as they relate to all phases of the product’s life cycle and intended use(s).

●We update the quality and quantity of information as necessary to ensure global consistency and to comply with local requirements for product information.

●We keep records of all necessary and requested product safety information to ensure that our products are useable throughout their entire life cycle.

●Standardized safety data sheets (SDS) are provided to customers at the time of initial delivery and upon request in local areas. We consistently maintain this critical information provision mechanism, and conduct distribution to all customers worldwide for all products, in compliance with local regulations and in the language requested by the customer.

Initiatives by the NOF Group

　The NOF Group believes that a sound understanding of its products’ chemical properties, hazards, and impacts on people and the environment, as well as the management of risks associated with the handling of products, are fundamental to providing the market with a safe and competitive product portfolio in the future. The NOF Group works to ensure reliable operation of the mechanism for providing SDSs so that hazard information related to our products is easily available to our customers and employees, and we continuously provide updates on the latest information.
　The NOF Group currently delivers over 5,000 products to markets in 82 countries around the world, and provides SDSs to these markets. We are also responsible for making revisions in response to changes in laws. We provide customers with appropriate information and technical assistance to ensure thorough understanding of our products and safe usage and handling practices. We are currently introducing a system to manage product information. As laws and regulations evolve, we are collecting more information on the conditions of use of our products to record and assess the associated risks, and reflect this in our SDSs.
　In addition, NOF has made a list of controlled substances specified in the POPs Convention, RoHS Directive, and the like, and promotes thorough management and volume reduction by ranking them as:
　(1) All chemicals prohibited to be handled
　(2) Chemicals for which we will consider alternatives and strive to reduce the amount
　　 handled, and
　(3) Chemicals to be handled under appropriate management.
　We also comply with relevant regional and national chemical regulations, such as REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) in the European Union (EU), K-REACH in South Korea, and the Toxic Substances Control Act (TSCA) in the United States. NOF has a total of 43 EU-REACH registrations (as of the end of 2023).
　Since the implementation of the EU’s REACH system, no products have been subject to the system for substances of very high concern (SVHCs).
　In addition, in Japan, the Group is promoting making lead-free products for pyrotechnic devices such as detonators, which contain lead that can affect water pollution.

Initiatives in the supply chain
【Product development】
　We are promoting the development of eco-friendly products that are biodegradable and do not contain hazardous substances, which contribute to recycling and energy conservation for the final products. In addition, we conduct screening tests on the risks and harms of all chemical substances we handle during design screening of new products and assessments in the commercial production transition phase, thereby developing products with low environmental impact.

【Procurement】Procurement of raw materials
　We conduct CSR procurement for the raw materials we use, which considers impact on the environment and health in addition to quality, cost, and delivery time. The list of controlled substances regarding hazards and toxicity is determined based on the POPs Convention, RoHS Directive, REACH regulations, and Japan's Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., Industrial Safety and Health Act, and Poisonous and Deleterious Substances Control Act. The list is reviewed once a year.

【Production】
　We verify that new products are manufactured according to plan before commencing commercial production. We work to reduce environmental impact through stable operation of our environmental treatment facilities and optimizing the collection conditions of chemical substances. We started working on Chemical Substances Risk Assessment (RA) in 2008, before relevant laws and regulations made it obligatory in 2016. We conduct a risk assessment and review of chemical substances as needed to contribute to employee health and safety.

【Distribution and use】(chemicals management and information provision)
　In fiscal 2020, NOF built and introduced an SDS creation support system, and has centralized management of SDS throughout the company.

【Disposal and recycling】
　We are conducting activities with the target of a zero emissions rate* of 0.10% or less. Substances that are no longer needed are separated. The useful substances are put in the recycling process, while those that are not are thermally recycled. In addition, we promote the separate collection and recycling of waste plastics and work to recycle them. With regard to waste disposal destination, we outsource the waste treatment to external companies that not only have received certification of excellence by the government but also satisfy our certification requirements. We provide them with information on hazard assessment and conduct audits on a regular basis to ensure compliance with the Waste Management and Public Cleansing Act.
　
＊NOF’ s definition of zero emission: Volume of final disposal by landfill/volume of waste, etc. generated × 100 ≦ 0.10

Compliance and Adaptation to Relevant Laws and Regulations

Response to international chemical substance management
　Chemical substances are being subject to stricter control on a global basis. At the World Summit on Sustainable Development (WSSD) held in 2002, a target was set as part of the international agenda to "use and produce chemicals in ways that minimize significant adverse effects on human health and the environment by 2020," in an effort to realize sustainable development. Based on this agenda, countries around the world including the emerging countries are being encouraged to adopt and firmly establish risk-based management of chemicals and implement GHS*. In terms of chemical substances, there is a rising trend requiring control of relevant risks from the standpoint of the entire supply chain, i.e. from manufacture to disposal, while also being required to disclose information on the risks caused by chemical substances and its control to the general public including our customers and consumers.
　The NOF Group is implementing control of chemical substances in line with this trend to tighten controls over chemical substances by complying with the laws of each country and region. To this end, in fiscal 2020, NOF introduced and built a company-wide SDS (safety data sheets) creation support system, and has begun centralized management of SDS throughout the company.

＊Abbreviation for Globally Harmonized System of Classification and Labelling of Chemicals, which classifies the hazardous properties of chemicals according to certain globally standardized criteria and displays them in an easy-to- nderstand manner using pictorial labels and other means.　

Domestic correspondence
　In Japan, prior notification of new chemical substances is mandatory, pursuant to the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. and the Industrial Safety and Health Act.
　In order to make proper notifications, when starting to manufacture a new chemical substance, the Responsible Care & Production Engineering Department confirms compliance with laws, and such substances remain under strict control as internal audits are conducted to ensure that there are no excesses beyond the volume that has been authorized for manufacture or import. NOF also trains its responsible personnel regarding related regulatory matters in order to keep them up-to-date with the latest information.
　In terms of reports on the actual quantity of general chemical substances manufactured, we practice appropriate control with the cooperation of our clients.
　We also positively disclose information on the risks and other negative aspects of chemical substances through the Japan Initiative of Product Stewardship, which is the chemical industry’s institution for voluntary activities for the control of chemicals.
　In addition, we participate in the Long-Range Research Initiative (LRI) implemented through the Japan Chemical Industry Association (JCIA), support research that leads to safety and security from a viewpoint that a company should "meet the needs of society," and work together to solve social issues.　

REACH compatible
　REACH^※is a comprehensive system of registration, evaluation, authorization, and restriction of chemical substances within the EU. REACH aims to protect human health and the environment, and to maintain and enhance ompetitiveness of the EU chemicals industry, among others, and includes almost all chemical substances exported to the EU within its
jurisdiction.
　The NOF Group engages in active exports to the EU region and complies with REACH in accordance with the export volume of the chemical substance involved. We practice appropriate compliance by obtaining the latest information from industrial associations and related authorities.

※Acronym for Registration, Evaluation, Authorization & Restriction of Chemicals. REACH represents the EU’s quality control regulations on chemicals and is applied to the registration, evaluation, authorization, and restriction of chemicals.　


Other countries and regions
　There has been increasing legislation of late for stricter controls over chemical substances not only in the US but also in Asian countries and regions such as South Korea, China, and Taiwan, and we are gathering the latest information regarding exports to such countries, and practicing appropriate compliance, when the situation arises.


Proper management of polychlorinated biphenyl (PCB)
　The NOF Group properly stores and manages PCB waste in accordance with the Law Concerning Special Measures Against PCB Waste, and disposes of such waste by commissioning disposal operators as prescribed by laws and regulations.
　All treatment of high-concentration PCB has been completed as of the end of March 2023, the final deadline for treatment. As for low-concentration PCB, we have completed the survey of all equipment containing PCB, including PCB components contained in paint coatings, and are systematically replacing the equipment and changing the coatings to meet the treatment deadline of the end of March 2027.


Compliance status to Acts related to the environment
　There was no violation of acts related to the environment.

Customer Safety

Joint Article Management Promotion-consortium (JAMP)
　JAMP* was formed in 2006 for the purpose of establishing and promoting specific structures for facilitating the disclosure and communication of information over the whole supply chain by appropriately managing and disclosing information on chemical substances. The NOF Group utilizes the chemSHERPA tool for sharing information recommended by JAMP to supply downstream users with information on chemical substances.

※ Acronym for Joint Article Management Promotion-consortium. JAMP was inaugurated in September 2006 by 17 companies subscribing to the underlying idea as promoters to serve as a cross-sectorial body to promote safety activities

Construction and operation of NOF's company-wide SDS creation support system
　GHS is a kind of criteria for the classification of health, environmental, physical and chemical hazards of chemical substances and mixtures according to a given set of standards. This information must be reflected in the SDS and GHS labels to reflect the latest information, and all parties involved in handling chemical substances, including users, distributors, and transporters, must be alerted to the need for safe handling.
　To this end, in fiscal 2020, NOF introduced and built a company-wide SDS creation support system, and has centralized management of SDS throughout the company. This system enables us to manage all chemical substances used in our products on a company-wide server, and to provide our customers with the latest information on chemical substances in our products by timely updating SDS and GHS labels issued by each business unit to reflect changes in the laws and regulations of major countries.
　We have completed our response to the revision of the Chemical Management Act from fiscal 2023. To improve transparency and visibility, we are also working to expand our system capabilities to track and manage important information such as chemical substance usage conditions and handling history

PRTR

PRTR Act-controlled substances
　The emission volume of PRTR Act-controlled substances by the Domestic Group in fiscal 2023 was 167.0 tons, a increase by approximately 17% from 143.3 tons in fiscal 2022. As a result, approximately 38% reduction of emission volume was achieved from the 269 tons in fiscal 2010, the reference year of the Mid-term Target.
　PRTR Act-controlled substances with an emission volume of 10 tons or more are indicated in the table below.

Measures to reduce emissions of PRTR Act-controlled substances
　NOF has set a KPI of reducing emissions of PRTR Act-controlled substances to 170 tons or less each year. In particular, we are examining manufacturing methods in which PRTR Act-controlled substances are not used in order to reduce the amount of substances with high environmental emissions. We aim to reduce emissions through the adoption of alternative substances and environmentally friendly manufacturing methods.

　In addition, the operating conditions of recoveryequipment are optimized to improve the recovery rate of emissions. Regular maintenance and proper operation and management ensure effective recovery and lead to reduced emissions. NOF will continue its efforts to reduce emissions of PRTR Act-controlled substances and promote more environmentally friendly manufacturing activities. In this way, we will contribute to the achievement of a sustainable society and work to protect the global environment.