The NRI Group employees (“Employees”) shall comply with all applicable laws, regulations, and rules as well as the standards of conduct outlined below in order to realize the NRI Group’s “Corporate Philosophy” and “Code of Business Principles.”

Relationship with Society

1．Good Corporate Citizen

1. Employees shall engage in forward-looking studies and research; they shall contribute to the development of a vibrant future society and shall strive to be future leaders, in accordance with the NRI Group's corporate philosophy "Dream up the future."
2. Employees shall strive to participate in volunteer activities as well as local community activities and to proactively contribute to society.

2．Consideration for the Environment

With the understanding that environmental protection is the responsibility of the corporate citizen, Employees shall strive to conserve energy and resources in order to prevent global warming.

3．Respect for Human Rights

Employees shall understand internationally-recognized standards for human rights, recognize that the NRI Group’s business activities may affect human rights, and strive to conduct business activities in a manner that respects human rights.

4．Legal Compliance

Employees shall comply with all laws and regulations that are applicable to corporate activities and shall conduct competition based on fair, legal, and ethical business practices.

5．Avoidance of Relationships with Anti-Social Forces ^*

Employees shall not enter into any relationship whatsoever with any Anti-Social Force. Employees shall immediately report to or consult with a supervisor in the event of any questions or doubts regarding a transaction or request from any suspected Anti-Social Force.

• ^*

  "Anti-Social Forces" means persons, entities or organizations that are considered to be, or have connections to: (i) an organized crime group; or (ii) a corporate racketeer or extortionist.

6．Respect for Intellectual Property Rights of Third Parties

Employees shall not infringe upon any intellectual property rights owned by any third party.
Employees must not use software for which a license has not been properly obtained.

Relationship with Clients

1．Fulfilling Professional Responsibilities

Employees shall provide the best and most appropriate services and solutions, from the perspective of the client. If an Employee encounters an issue that is outside the individual Employee’s field of expertise, we will utilize the NRI Group’s collective strength and do our best to resolve the issue.

2．Client Proposals, Contract Negotiations, and Contract Fulfillment

Employees shall strive to conduct transactions that are mutually advantageous to the interests of both the client and the NRI Group. Contracts shall be examined by the supervising department before they are signed. After a contract is signed, Employees must fulfill the terms of the contract in good faith.

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 quality improvement activities.

Role as an NRI Group Employee

1．Responsible Behavior

Employees must act with awareness of the expectations and responsibilities assigned to us as professionals and members of society.

2．Rejection of Inappropriate Business

1. Transactions must be carried out under fair terms based on appropriate competition.
2. Employees must avoid business partners and transactions that are inappropriate.
3. Employees must not engage in business that would be irresponsible to clients.

3．Information Security

1. Recognizing that information security is the NRI Group’s lifeline, Employees must properly understand and comply with applicable laws and internal regulations.
2. As a general rule, personal information and confidential information of other companies should not be obtained. However, if such information must be obtained for business purposes, such information must be appropriately handled in accordance with applicable laws and internal regulations and must not be improperly disclosed to third parties.
3. Employees shall use only designated internal information systems and telecommunications equipment and shall comply with all internal regulations applicable to their use. As a general rule, Employees must not use such systems and equipment for personal purposes.

4．Creating an Environment Conducive to Working

1. Employees shall respect each other’s character and individuality, and must not engage in unlawful discrimination, harassment of any kind, abuse of authority, or any other act that infringes on an individual’s rights.
2. Employees shall comply with applicable labor laws and regulations and shall strive to maintain a healthy and positive work environment.

5．Compliance with Final Decisions and Accounting Rules

Employees shall comply with internal regulations covering the process from decision-making to accounting, and must perform accounting procedures accurately and promptly.

6．Appropriate Management of Company Assets

Employees shall strive to appropriately manage company assets and intellectual property.

7．External Announcements

1. Before external announcements may be made, Employees shall request and obtain necessary approval in accordance with internal regulations.
2. Employees must select the appropriate forums and media for external announcements.

8．Purchase and Sale of Securities

Employees shall not purchase or sell securities using insider information ^* .

• ^*   

  “Insider Information” means material, nonpublic information.

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 related laws when dealing with business partners.

2．Entertainment in Moderation

1. Employees shall not participate in business entertainment that deviates from accepted standards or that could be construed as bribery.
2. In principle, Employees shall not give or accept any gifts, with the exception of items of nominal value or gifts that are given to a large group.
3. Contributions to politicians, political candidates, political organizations, or election campaigns shall not be made in connection with corporate activities.

Relationships with Shareholders and Investors

1．Information Disclosure and Increasing Corporate Value

1. Employees shall prevent damage to the NRI Group’s corporate value, pursue sustainable growth, and strive to improve shareholder profit.
2. Employees shall comply with business accounting principles, laws, regulations, internal policies, etc., which form the basis for appropriate disclosure of corporate information, and strive to ensure that all disclosures of information are accomplished accurately and properly.

2．Management of Insider Information

Insider Information that relates to the NRI Group and other companies must not be conveyed to persons who do not have a need to know such information for business purposes or be disclosed externally until such information is made public.

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