NRI Group Policy on Human Rights

Kaga Yanagisawa
President & CEO, Member of the Board, Representative Director
Nomura Research Institute, Ltd.

The NRI Group is committed to respecting the human rights of all people impacted by our business activities in the process of achieving our business philosophy, and will make Group-wide efforts to carry out our responsibility in promoting human rights.

Basic Concept

The NRI Group adheres to international standards of human rights including the International Bill of Human Rights, The International Labour Organization's Declaration on Fundamental Principles and Rights at Work, and The Ten Principles of the United Nations Global Compact. The NRI Group commits to respect these standards and the United Nations Guiding Principles on Business and Human Rights, and establishes the human rights activities to be implemented by NRI Group companies and their officers and employees.

Scope of Application

This policy applies to all officers and employees of the NRI Group. The NRI Group also requests stakeholders that conduct business with the NRI Group (such as business partners, suppliers and third parties that the NRI Group invests in or collaborates with) to adhere to and comply with the policy, thereby collaboratively bearing the responsibility to promote human rights with respects to the following “Respect for Human Rights” and beyond throughout the entire supply chain.

Respect for Human Rights

The NRI Group prohibits all types of discrimination and harassment based on such as race, ethnicity, nationality, place of origin, social status, social origin (lineage), gender, marital status, age, language, disability, health, religion, belief or creed, wealth, sexual orientation, gender identification, and type of job or occupation. The NRI Group rejects any type of forced labor or child labor.
The NRI Group upholds the principles of equal pay for equal work and pays appropriate wages.
The NRI Group respects freedom of expression.
The NRI Group respects workers' right to freedom of association and the basic labor rights to collective bargaining and collective action.

Responsibility to Respect Human Rights

The NRI Group understands the risk of affecting human rights directly or indirectly through our business activities. The NRI Group seeks to avoid causing or contributing to violation of human rights which we may be involved through its business activities, and in the event it causes adverse human rights impacts through its business activities, the NRI Group will take appropriate actions to correct them.
In addition to our existing businesses, we also conduct risk assessments and investigate countermeasures in consideration of human rights when performing due diligence for M&A. When a negative impact on human rights is suspected in the supply chain and is directly related to business, the NRI Group requests the relevant stakeholders to respect human rights and prevent violation.

Compliance with Applicable Laws and Regulations

The NRI Group will strictly comply with applicable laws and regulations in the countries and regions in which it carries out business activities. Where there are conflicts between internationally recognized human rights standards and the laws of a country or region, the NRI Group will strive to respect the internationally recognized human rights standards.

Training and Education

The NRI Group will offer appropriate training and education to all officers and employees to ensure that this policy is embedded throughout our business activities, is well understood, and is implemented effectively.

Human Rights Due Diligence

The NRI Group will establish a system for human rights due diligence and will operate it continuously. The human rights due diligence system will identify and prevent/mitigate adverse human rights impacts.

Remedy

Where we identify that we have caused or contributed to adverse human rights impacts directly or through a business partner, the NRI Group will take appropriate corrective measures to provide remediation.

Dialog and Discussion

The NRI Group will make use of independent expert external knowledge on human rights and engage in discussions with stakeholders about addressing potential and actual human rights impacts.

Disclosure of Information

The NRI Group will report on the progress of its efforts to respect human rights pursuant to this policy on our official website and elsewhere.

Enacted on Feb. 5, 2019
Revised on July 1, 2023

NRI Group AI Policy

NRI Group AI Policy

NRI Group ("NRI") aims to realize a prosperous society that nourishes potential and brings dreams to life based on our corporate philosophy "Dream up the future". While the development of AI technologies brings various benefits to our lives and social activities, there are also concerns that they may have adverse effects. Recognizing these possibilities and our responsibility as a company that promotes research, development, and utilization of AI, NRI has established the "NRI Group AI Policy". All NRI executives and employees are committed to utilizing AI in accordance with this policy and contributing to the creation of a sustainable future society.

1. Dialogue and co-creation with stakeholders

NRI aims to solve social issues and realize a sustainable society while considering the impact of AI on society and utilizing AI within an appropriate scope for appropriate purposes. To this end, NRI will promote dialogue and co-creation not only internally but also with various external stakeholders.

2. Fairness and respect for human rights

NRI recognizes that the accuracy and representative bias of the data used for AI training, etc., as well as social biases inherent in the data, may cause errors or biases in the results of AI judgments. To this end, NRI respects human rights in accordance with the "NRI Group Human Rights Policy," and strives to ensure that no individual or group is unfairly discriminated against in the use of AI. NRI also strives to prevent the misuse of AI that threatens human dignity and privacy.

3. Transparency and accountability

NRI aims to design and develop AI so that the results of judgments can be explained, considering the nature and purpose of the development and services that utilize AI. In case of unexpected errors or biases in judgment results, NRI will work to ensure transparency and quality by remaining accountable.

4. Information security and safety assurance

NRI aims to realize AI that people can always use safely. To this end, NRI will implement and strengthen information security measures throughout the entire lifecycle of AI research, development, and utilization, and strive to ensure safety by building a system to appropriately acquire, protect, use, and provide data and prevent unauthorized access. In the unlikely event that an unforeseen situation should arise, we will endeavor to take appropriate measures to rectify the situation.

5. Compliance & regulations and protection of rights

In accordance with laws, regulations, and relevant internal rules, NRI shall endeavor to prevent infringement of third-party rights, including copyrights, throughout the entire lifecycle of AI research, development, and utilization.

6. AI governance and human resource development

NRI will establish and operate an AI governance process to further enhance the effectiveness of the efforts of this policy and strive for fair and sound utilization of AI. In addition, NRI will proactively work to develop professionals who appropriately utilize AI.

Enacted on: Oct. 8, 2019
Revised on: Feb, 13, 2024

NRI Group Anti-Bribery Policy

Kaga Yanagisawa
President & CEO, Member of the Board, Representative Director
Nomura Research Institute, Ltd.

Policy

In order to pursue business fairly and in compliance with the laws and social norms, NRI Group will comply with the Japanese Unfair Competition Prevention Law, the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, the Chinese Criminal laws on anti-bribery, and other applicable anti-bribery laws and regulations (hereinafter collectively called "anti-bribery laws and regulations"). We will continue to be a company that is trusted by our customers and society by preventing bribery, corruption, and acts that may fall under them, before they occur.
NRI Group has established the following code of conduct, applicable to all directors, officers and employees of NRI Group. NRI Group requires its agents and business partners to comply with such standards.

Code of Conduct

• NRI Group shall not, directly or indirectly, give, accept, or request or promise to give, accept any bribe. Such restriction shall apply to all dealings with any public officials or other persons/entities, regardless of whether at the expense of NRI Group or the individual.
• With respect to donations to charitable organizations, we will give due consideration to the necessity and appropriateness of such donations and will do so in accordance with the anti-bribery laws and regulations.
• When engaging agents who act on behalf of the NRI Group or act as intermediaries for NRI Group and other business partners, NRI Group shall conduct adequate due diligence procedures as well as make known and require compliance with the anti-bribery laws and regulations.
• We do not act in a manner that conflicts with the interest of the NRI Group.

Bribery Risk Management

• NRI Group will conduct bribery risk assessments periodically to prevent violations of the anti-bribery laws and regulations.
• NRI Group will conduct education and training regularly to ensure due compliance with the anti-bribery laws and regulations and this Policy.
• NRI Group will retain relevant approvals and accounting books and records, and establish an internal control system, to comply with the anti-bribery laws and regulations.
• NRI Group will periodically review and update, as it may become necessary, its anti-bribery compliance program.
• Compliance Hotline will receive and respond to any consultation, notification or report regarding any acts that violate, or may violate, the anti-bribery laws and regulations or this Policy.

Revised on July 3, 2024

NRI Group Competition Law Compliance Policy

Policy

In order to pursue fair competition, NRI Group will comply with the Japanese Anti-Monopoly Law, the Subcontract Proceeds Law and other Japanese Laws, the US Antitrust Law, the EU Competition Law, the Chinese Anti-Monopoly Law and other applicable competition laws and regulations.

Code of Conduct

NRI Group shall not participate in any of the acts listed below as examples that violates, or is suspected to violate, the applicable competition laws and regulations in any country or region.

• Entering into agreements with competitors, formally or informally, that would impede fair market competition.
• Unreasonable monopolization, predatory pricing that would impede fair market competition and other abuse of dominant position.
• Discussions and exchanges of information with competitors on prices, contract terms, costs, inventories, marketing and product plans, market research and analysis, production plans and capabilities, and other commercially sensitive information.

Competition Law Compliance Risk Management

• NRI Group will conduct competition law risk assessments periodically.
• NRI Group will conduct education and trainings regularly to comply with the applicable competition laws and regulations and this Policy.
• NRI Group will periodically review and improve, as it may become necessary, its competition law compliance program.
• Compliance Hotline will receive and respond to any consultation, notification or report of any act that violates, or may violate, the applicable competition laws and regulations or this Policy.

NRI Group Global Tax Policy

Kaga Yanagisawa
President & CEO, Member of the Board, Representative Director
Nomura Research Institute, Ltd.

Basic Policy

This policy defines the NRI Group’s governance policy regarding taxes.
The NRI Group strives to achieve sustainable growth and enhance its medium to long-term corporate value while observing all applicable laws, regulations, social norms, and its own internal rules, and conducting its business in a fair and highly transparent manner. Based on this policy we actively endeavor to improve our tax-related governance as well.
The NRI Group acts with the sensibility of being a conscientious enterprise that contributes to the development of communities by fulfilling our duty of making appropriate tax payments.

Tax Compliance

The NRI Group complies with spirits as well as the letters of the tax laws and regulations of each country in which we operate, paying appropriate taxes in the appropriate jurisdictions where we operate based on the value which is created through our business activities. Regarding prices of the transactions within the group, NRI follows the Arm’s Length Rule in accordance with the OECD Transfer Pricing Guidelines and the NRI Group Transfer Pricing Policies.

Tax Governance

NRI’s Group CFO is responsible for NRI Group tax governance.
Tax governance is managed daily by each NRI Group company with support by NRI and outside experts as needed. NRI is responsible for managing tax risk for the NRI Group as a whole. Tax-related matters in the NRI Group are reported as needed to NRI management, which handles tax management.

Tax Risk Control

The NRI Group identifies, evaluates, and manages tax risk appropriately, taking importance and rationality into consideration. The NRI Group makes the appropriate organizational considerations such as consulting with outside experts and making prior inquiries with tax authorities to properly control tax risk when tax laws are unclear, have multiple possible interpretations, or when key uncertainties are foreseen.

Tax Planning

The NRI Group utilizes applicable favorable tax measures and incentives within the scope of our business activities according to our purposes for doing business and commercial rationality. We do not conduct tax planning in ways that seek only to pay less taxes, which would be inconsistent with our business goals and the composition of our business operations. We do not avoid taxes through use of tax havens, low tax jurisdictions nor do we exploit tax structures by using commercial substances as a method of tax evasion.

Relationship with Tax Authorities

The NRI Group endeavors to establish open, transparent relationships with tax authorities and to maintain those relationships. We provide disclosures to tax authorities to the extent possible upon request and provide them with explanations of our NRI Group Global Tax Policy and the logic of our business dealings.

Enacted on Sep. 1, 2018
Revised on July 1, 2023