NRI Group employees (hereafter "Employees") should comply with laws, regulations and social mores as well as the standards of behavior outlined below in order to realize the Group's corporate philosophy and the NRI Group's Code of Business Principles.

Relationship with Society

1．Role as a good corporate citizen

1. Employees shall engage in studies and research looking ahead to the future and contribute to the developing energetic future society as well as developing future leaders of tomorrow, in accordance with the NRI Group's corporate philosophy "Dream up the future."
2. Employees shall participate in volunteer activities as well as local community activities, and proactively contribute to society

2．Consideration for the environment

Employees view efforts to address environmental protection as their responsibility as good corporate citizens, and will continue their activities to conserve energy and resources to prevent global warming.

3．Legal compliance

Employees will comply with all laws and regulations related to corporate activities and compete fairly in accordance with business practices.

4．Stance toward antisocial forces

Employees shall not have any relationship whatsoever with antisocial forces, such as violent organizations, nor with any individual or groups engaging in criminal activity. Employees shall report quickly to or consult with supervising departments in the event of any doubts regarding a transaction or illegitimate requests from antisocial or other forces.

5．Respect for the intellectual property rights of third parties

Employees shall not infringe upon intellectual property rights held by a third party.
Employees shall not use software without obtaining the officially sanctioned license.

Relationship with Clients

1．Fulfilling specialist responsibilities

Employees shall provide the best, most optimum services and solutions from the perspective of the client. In the event that an issue exceeds individual levels of expertise, Employees shall harness its collective strengths to resolve the issue.

2．Client proposals, contract negotiations, and contract fulfillment

Employees shall strive to ensure that their transactions are advantageous for both the client and the NRI Group. The supervising department shall screen contracts before they are signed, and the terms of the client shall be faithfully fulfilled after the contract is signed.

3．Commitment to quality

Employees shall have a good understanding of Company-wide initiatives to improve quality, and shall strive to enhance client satisfaction through ongoing activities to improve quality.

Role of NRI Group Employees

1．Responsible behavior

Employees must act with an awareness of the expectations placed on them and their responsibilities as members of society and as professionals.

2．Rejection of inappropriate business

1. Transactions must be carried out on equitable terms based on appropriate competition.
2. Employees must avoid business partners and transactions that are inappropriate.
3. Employees must avoid business that would be irresponsible in the context of its clients' needs.

3．Information security

1. Employees must be fully aware that information security is the NRI Group's lifeline, and must accurately understand and comply with laws, regulations and Company rules.
2. In principle, Employees must not acquire personal information and other companies' confidential information. In the event that such information must be obtained for business purposes, this information must be managed appropriately in accordance with the relevant laws, regulations and Company rules, and cannot be disclosed to third parties without prior consent.
3. The internal information systems and telecommunications equipment used must be that stipulated by the Company. In principle, employees shall strive to use the equipment appropriately in accordance with Company rules, and shall not use it for personal purposes.

4．Creating a workplace conducive to job performance

1. Employees shall respect each other's personal attributes and individuality, and must not infringe on each other's human rights, for example through irrational discrimination, sexual harassment or bullying from the boss.
2. Employees shall comply with labor-related laws and shall maintain a healthy workplace environment conducive to job performance.

5．Compliance with final decisions and accounting rules

Employees must comply with the Company's accounting rules, and must complete accounting procedures accurately and promptly.

6．Appropriate management of Company assets

Employees must strive to appropriately manage Company assets and intellectual property.

7．External announcements

1. External announcements must conform to Company rules, all applications and submissions must be made, and the stipulated approval must be obtained.
2. Employees must select the appropriate forum and media for external announcements.

8．Marketable securities and other transactions

1. Employees shall not trade marketable securities and other instruments using insider information.
2. Employees must apply to the supervising department in advance and obtain authorization when trading marketable securities and other instruments.

Relationship with Business Partners

1．Relationship with our Business Partners

1. Employees must recognize our business partners as equals and always treat them with sincerity to build a relationship of mutual understanding and trust.
2. Employees shall eliminate arbitrariness and perform comprehensive evaluation of the quality, lead time, price, and reliability of their products and services, their business conditions, and their approaches to environmental, social, and governance factors, in order to select the most suitable business partners.
3. Employees shall be aware of the status of any contracted work and encourage our business partners to comply with laws, regulations, and social norms as well as to give due consideration to the environment and society.
4. Employees must understand and comply with all applicable statutory requirements when dealing with business partners.

2．Temperate interaction

1. Employees shall not be involved in business entertainment that deviates from socially accepted standards or that could be mistakenly construed as bribery.
2. In principle, Employees shall not give or receive any gifts, with the exception of inexpensive items or gifts that are given to a large group.
3. Employees shall not give political contributions and election campaign support to politicians, candidates and political body directly through their corporate activities.

Relationships with shareholders and investors

1．Raising corporate value and the quality of information disclosure

1. Employees prevent any damage to the NRI Group's corporate value, pursue sustainable growth and strive to raise shareholder returns.
2. Employees comply with those business accounting principles, laws and regulations as well as the Company's rules that form the basis for appropriate disclosure of corporate information, among others, and strive to accurately and quickly disclose information warranting disclosure.

2．Management of insider information

The NRI Group and other companies' insider information is not conveyed to people who do not need to know such information for business purposes and is not presented externally until this information is disclosed.

Additional Clause

1. The NRI Group's Code of Business Conduct went into effect on Apr. 1, 2021.
2. The NRI Group's Code of Business Conduct shall be treated as the primary regulation as stipulated in the administrative provisions for rules and regulations.

History
Established:May 1, 2003
Revised:Apr. 1, 2021