The NOF Group has developed an internal control system for ensuring adherence to laws and regulations, the Articles of Incorporation, and various internal rules of the Company and appropriateness of business operations. Regarding observance of social norms and laws and regulations, the Company has formulated its NOF Basic CSR Policy, as well as corporate ethics, known as the NOF Group Corporate Code of Ethics, based on the Policy. The Compliance Committee has been established to ensure thorough adherence to the Policy and code. The planning of various compliance-related measures and the status of their operation are reported as appropriate to the Board of Directors for management and supervision.

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The society we live in faces challenges of unprecedented complexity, including pandemics, geopolitical risks, climate change, and rapid digitalization. Against this backdrop, the role corporations are expected to play is becoming increasingly important. Companies are now called upon to contribute to the realization of a sustainable future through activities that emphasize transparency, fairness, and social responsibility.
At the NOF Group, using the NOF Group Corporate Code of Ethics and the Compliance Manual as our foundation, we strive to ensure that each and every employee acts ethically in all aspects of their daily work. These efforts build trust with all of you and reinforce our significance as a company needed by society in every era.

Compliance is not limited to obeying laws and regulations; it is the foundation for being a trusted company that acts in good faith. In recent years, initiatives in areas such as anti-bribery efforts, human rights due diligence, and harassment prevention have become the key to enhancing corporate credibility.
NOF has established its Anti-Bribery Policy and works to enforce it thoroughly across the entire Group, both in Japan and overseas.
With regard to respect for human rights, we have established an internal whistleblowing and consultation contact point in multiple languages, including not only Japanese but also English, Chinese, and more, in each country where we operate, creating an environment where employees can feel safe to speak up at any time.
In fiscal 2025, we received 29 reports through these contact points, 19 of which concerned harassment. We responded to each report promptly and carefully, taking necessary corrective measures to improve the workplace and prevent recurrence of issues. We believe that harassment prevention is not only a risk management measure, but also an important opportunity to create a workplace where every employee can work with peace of mind. In our awareness-raising activities through internal newsletters and other means, we have strived to help employees recognize that compliance is a familiar matter that personally concerns them. Through approachable explanatory articles using mascot characters as well as the introduction of concrete examples, we work to foster a culture in which all employees practice compliance with the aim of an “open workplace environment.”

Within the NOF Group, each consolidated subsidiary has appointed an ethics and compliance manager and established a deliberative body. In addition to meeting regularly twice a year, NOF’s Compliance Committee convenes as needed in response to emerging issues to identify problems, formulate countermeasures, and follow up on their implementation. The results are reported to the Board of Directors and deliberated as necessary.

The NOF Group regularly holds compliance-related training sessions for employees.
In FY2025, we continued providing compliance training for new graduates and hires with experience. Regarding the amended Subcontract Act (SME Transactions Act), which came into force in January 2026, we conducted adequate in-house education by holding seminars for 36 on-site participants and 189 online participants in November 2025, and by providing separate training for 16 materials-related personnel.

As part of legal and compliance support for affiliated companies, we individually visited 13 domestic affiliated companies between September and October 2025. The agenda included introducing Legal Department measures implemented within NOF to maintain compliance and improving communication by identifying requests from each company.
Recognizing the urgent need to simplify access to NOF regulations to support affiliated companies in establishing systems and regulations, we confirmed with departments responsible for regulations whether they could be disclosed to affiliated companies, revised access-right descriptions, updated the internal regulations page on the NOF intranet (NICE), and notified all Group companies of the disclosure procedures in October 2025.

We have obtained information on the enactment and revision of laws and regulations by utilizing various sources on a continual basis while taking appropriate actions. In order to reduce risk of overlooking information on the enactment and revision of laws and regulations, the whole Group has introduced a system that enables us to automatically receive information on the enactment and revision of laws and regulations by email.

In today’s society, preventing corruption related to business activities is recognized as one of the major issues for companies. The NOF Group established and publicly announced the NOF Group’s Anti-Bribery Policy in the President’s name and rolled it out to Group companies in each country. We will ensure adherence to anti-bribery and corruption regulations in each country and region that have become increasingly strict in recent years.
As a result of these activities, there have been no cases of bribery offenses over the past five years.

NOF Group prohibits acts of unfair competition such as improper acquisition of trade secrets, actions that could lead to factual errors, and infringement of intellectual property rights, and ensures compliance with the Unfair Competition Prevention Act by providing detailed information in the Compliance Manual and making it thoroughly known.
As a result of these activities, there have been no cases of violations of the Unfair Competition Prevention Act over the past five years.

The NOF Group has set up consultation desks in Japanese, English, Chinese (Simplified Chinese), Korean, Indonesian, and Portuguese at external third-party institutions as contact points for whistleblowing and consultation in overseas countries where the NOF Group’s business bases are located. Employees can contact the desks if they become aware of a violation or potential violation of compliance rules.
Persons who report or consult on a violation or potential violation of compliance rules will not be treated disadvantageously because of the report or consultation, and the report or consultation will be handled with confidentiality. This system and contact points are communicated to executives and employees of the Group companies worldwide on a regular basis.
There were 29 whistleblower cases in FY2025, an increase from the previous fiscal year. The increase concerned harassment and workplace operations, which we view as indicating heightened employee awareness resulting from internal training and other initiatives. In addition, we carefully investigated the facts of any report promptly and without searching for the whistleblower, and took necessary corrective actions and measures to prevent recurrence.
For harassment, misconduct, fraud, workplace operation issues, and other matters deemed compliance violations, the Compliance Committee instructs relevant departments, in accordance with its rules, to investigate the facts and respond to requests and, where necessary, issues corrective recommendations and directs the implementation of recurrence prevention measures.
As a result of these activities, there have been no cases of violations of laws and regulations over the past five years.
We will continue to create a better environment by understanding the purpose of the whistleblowing system and operating it appropriately so that misconduct, corruption, human rights violations, harassment, and similar issues can be addressed promptly before they develop into serious incidents.

Number of whistleblowing incidents [Covered organizations：NOF Group]

• FY2025：29 cases
  Of these , Harassment：19 cases , Morals and misconduct：0 cases , Workplace operations：10 cases , Others：0 cases

The NOF Group has declared its position to prevent and prohibit sexual harassment and power harassment in the NOF Group Corporate Code of Ethics, the Compliance Manual, and other internal notifications, and is taking steps to make the Code of Ethics and other relevant norms extensively known and understood. For consultation desks regarding sexual harassment and power harassment, one each of male and female consultants who took a course is appointed in consideration of making workplaces transparent and pleasant.

Strengthening compliance entails short-term burdens, including higher costs, delayed decision-making, and reduced local responsiveness due to audits, training, and the introduction of management systems (for example, more approval steps delaying investment decisions and reduced discretion at subsidiaries). Conversely, by avoiding serious risks such as accounting fraud, bribery, illegal overtime, embezzlement, and false reporting, and preventing business suspensions, penalties, and reputational damage, it generates clear returns through maintaining investor confidence and brand value, ensuring long-term business continuity, retaining human resources, and improving productivity. The key is balancing short-term burdens with medium- to long-term value creation, and we believe risk reduction is the foundation of sustainable growth.