NITTA Group Human Rights Policy

1. 1. Priority and Scope of Application of This PolicyThis Policy takes priority over all human rights-related rules and norms within the Group aimed at preventing human rights violations.
   This Policy applies to all Group executives and employees (including part-time workers, contract employees, and dispatched employees). In addition, all Group business partners are required to understand and support this Policy.
2. 2. Fulfillment of Responsibility to Respect Human RightsRespect for human rights underlies all of the Group’s business activities and is considered a key corporate responsibility.
   Within the Group, respect for human rights is understood in terms of internationally recognized human rights, specifically as defined in the International Bill of Human Rights and the fundamental principles of the eight core conventions of the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work. The responsibility for respecting human rights is fulfilled through activities that accord with the UN Guiding Principles on Business and Human Rights.
   Also, as a corporate signatory to the UN Global Compact, the Group supports the Ten Principles of the UN Global Compact.
   The Group complies with the national laws and other regulations of each country and territory where it conducts business. However, in cases where national laws differ from international human rights norms, the Group shall seek means of remaining respectful of international human rights norms. Further, when deciding on a response, the Group shall solicit the opinion of trustworthy outside experts.
3. 3. Human Rights Due DiligenceThe Group recognizes the possibility that its business activities could directly or indirectly affect the human rights of stakeholders (customers, employees, suppliers, business partners, indigenous people, and other members of society). In order to prevent or mitigate negative impacts on stakeholders’ human rights, the Group adheres to the UN Guiding Principles on Business and Human Rights in establishing human rights due diligence mechanisms for proactively investigating and ascertaining human rights risks. The Group continuously implements these mechanisms and, in the event that human rights are negatively impacted, it shall take appropriate corrective action in response.
4. 4. Remedial ActionIn the event that it becomes clear that the business activities of the Group have negatively impacted human rights, the Group shall take action to remedy the situation through appropriate means.
   The Group provides a system for reporting human rights concerns without fear of reprisal and a system for responding to such reports. In the event that a human rights allegation is brought forward, the Group shall investigate the facts of the allegation, after which it shall take all appropriate remedial measures to correct any negative impact on human rights. The Group shall also implement preventative measures to mitigate the risk of future human rights violations.
5. 5. Education and TrainingThe Group provides executives and employees with ongoing education and training necessary for the implementation of this Policy.
6. 6. Utilization of Outside Experts and Dialogue with StakeholdersIn its implementation of this Policy, the Group shall make use of the knowledge and advice of outside human rights experts and shall engage in dialogue with stakeholders to find ways of strengthening its efforts to respect human rights.
7. 7. Monitoring and ReportingThe Group shall continuously monitor, and work to improve, compliance with this Policy. Through the Group website, integrated reports, and other means, the Group shall regularly disclose what it is doing to disseminate this Policy and ensure respect for human rights.

Enacted November 5, 2021
Nitta Corporation
Representative Director/President