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.

The NOF Group instituted the Code of Ethical Conduct in April 2002 to ensure that each member Company and each employee always conforms to social ethics and wins society’s trust (the Code was revised in April 2025 as the NOF Group Corporate Code of Ethics). Alongside this, the Group set up the Ethics Committee (the name was changed to the Compliance Committee in April 2020) in an effort to strengthen its responsibility to society and ensure the transparency of its business activities. In April 2023, the corporate philosophy system was revised with the corporate philosophy (mission and vision), values, and code of conduct at the core. This prompted the revision of our previous Code of Ethical Conduct as the NOF Group Corporate Code of Ethics, which is structured around the three values important to the NOF Group, which are “Challenge,” “Fairness,” and “Harmony.” In addition, desks for whistleblowing and consultations from employees have been set up at the Compliance Committee Secretariat, the Audit and Supervisory Committee’s office, and external third party institutions.

I would like to express my heartfelt gratitude for your continued support. I would also like to sincerely thank for reading our Website.
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 2024, we received 19 reports through these contact points, nine 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.”

By putting into practice our values of “Challenge,” “Fairness,” and “Harmony”, we aim to walk alongside all our stakeholders, strengthening our environmental conservation activities, contributions to local communities, and initiatives for respect for human rights as we continue working toward the realization of a sustainable society.
In addition, as the progress of digitalization brings increasing risks of information leaks and cyber security issues, we have strengthened our information security policy initiatives, enforced strict security export controls of our products and technical information, and built a robust system that can comply with international regulations. Going forward, we will continue to value our relationship of trust with all of you as we strive for further sustainable growth.
Finally, the trust each of you places in us is the NOF Group’s greatest asset. We sincerely ask for your continued warm support.

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.

In order to instill a sense of compliance in its executives and employees, the NOF Group has prepared a Compliance Manual, which explains compliance matters of the NOF Group Corporate Code of Ethics in detail and in easily understood terms. The universal Global Compliance Manual has been published in eleven different languages.

• Japanese, English, German, French, Dutch, Italian, Portuguese, Chinese (Simplified), Indonesian, Vietnamese, Korean

The NOF Group is preparing country-specific compliance manuals based on the legal systems of each country. Following the publication of versions for the U.S.A., China, Indonesia, France, Germany, Belgium, Italy, South Korea, and Brazil where the Group has a large number of employees, the manuals are being utilized in Group companies.

The NOF Group regularly holds compliance-related training sessions for employees. 
In fiscal 2024, we continued providing compliance lecture for new employees and hires with experience, as well as ensuring awareness of precautions related to the Subcontract Act. In addition, we implemented lecture on the Subcontract Act for personnel in charge of purchasing at affiliates, as well as lecture on strengthening workplace response capabilities against harassment for managers within the Company.

NOF uses its quarterly in-house newsletters to help raise employees’ awareness of compliance.  NOF continues activities to raise awareness through relatable articles using cartoon characters.

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. NOF set forth the NOF Group Anti-Bribery Policy and announced it in the name of the President. We have also promoted its adoption at the 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 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.

Consultation desks in Japanese, English, Chinese (Simplified Chinese), Korean, Indonesian, and Portuguese have been set up at external third-party institutions as contact points for whistleblowing / consultation in overseas countries where NOF’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.
In fiscal 2024, there were 19 whistleblower cases, an increase from the previous fiscal year, and the share of harassment cases remained high. 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.
Any matters deemed to be in violation of compliance will be handled in accordance with the Compliance Committee regulations. The Compliance Committee will instruct the relevant departments to investigate the facts, issue requests, and if necessary, provide corrective recommendations and implement measures to prevent recurrence.
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 by appropriately operating the system to respond to misconduct, corruption prevention, human rights violations, harassment, etc. in a timely manner before they become serious incidents.

Number of whistleblowing incidents

• FY2024：19 cases

Of these

• Harassment：9 cases
• Morals and misconduct：4 cases
• Workplace operations：4 cases
• Other：2 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.

The NOF Group recognizes compliance as a foundation that supports companies. We believe it is important to prevent violations of laws and regulations or the NOF Group Corporate Code of Ethics beforehand or take corrective actions at an early stage, so that they do not become more serious or prolonged, and set up a Compliance Hotline on our website for our business partners and other external parties.
To date, we have not received any reports on the following matters through the hotline.

Total number of substantiated complaints concerning breaches of customer privacy
［Covered organizations：NOF Group］

None

Total number of customer data breaches, thefts, and losses
［Covered organizations：NOF Group］

None