The NRI Group strives to ensure total compliance with ethical codes and law and regulations, and to help maintain society's confidence in the Group. As a corporate member of Nippon Keidanren (Japanese Business Federation), NRI respects the spirit of the Federation's Charter for Corporate Behavior and puts it into practice.

• NRI Group Policy on Human Rights
• NRI Group AI Ethics Guidelines
• NRI Group Anti-Bribery Policy
• NRI Group Competition Law Compliance Policy
• NRI Group Global Tax Policy

NRI Group Policy on Human Rights

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 encourages all business partners to adhere to and comply with the policy, thereby collaboratively bearing the responsibility to promote human rights.

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 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. If a business partner is suspected to have an adverse impact on human rights linked to our business, and if this is in connection with the NRI Group's business, the NRI Group will request our business partner to abide by international human rights standards.

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
Latest update on Mar.7, 2023

Shingo Konomoto
President & CEO
Chairman, Member of the Board
Representative Director
Nomura Research Institute, Ltd.

NRI Group AI Ethics Guidelines

As the NRI Group (hereinafter "NRI") is "Company creating future society," NRI strives to unlock the future through innovation, solve social issues, and contribute to achieving a sustainable society.
While the use of AI has recently become a key component to creating such a society, there are also concerns about social impacts of AI. In light of these circumstances, NRI has formulated “NRI Group AI Ethics Guidelines” to be followed by all officers and employees of the NRI Group.
The guidelines shall apply to AI research, design, development, operation, and utilization at NRI.
Going forward, NRI will continue working toward a future society in which humans utilize AI effectively.

1. Engaging in dialogue and co-creation with stakeholders

Considering the social impact of AI, NRI aims to solve social issues and contribute to achieving a sustainable future while striving to utilize AI for the appropriate scope and applications. To accomplish this, NRI engages in dialogue and co-creation with various stakeholders.

2. Advancement of AI and human resources development

As the NRI Group is "Company creating future society," NRI will discover the social impact of AI, then actively engage in research, design, development, operation, utilization, and fostering professional human talent for AI that can create a better future society.

3. Respecting fairness

NRI recognizes that the representativeness of data used in training and social biases contained within datasets can cause the decisions made by AI to be biased. In accordance with “NRI Group Policy on Human Rights”, NRI will respect human rights and strive to ensure that its utilization of AI does not discriminate against any individual.

4. Ensuring safety and security

NRI engages in design and development with the aim of creating AI that people can always feel secure in using. Throughout the entire life cycle of AI design, development, and operation, NRI will implement security measures and enhancements while striving to prevent misuse that undermines human dignity. Should any unforeseen circumstances arise, NRI will strive to take the appropriate actions in response.

5. Protecting data and privacy

Throughout the entire life cycle of AI design, development, and operation, NRI will strive to build frameworks for data to be acquired, used, and provided appropriately while preventing unauthorized access, and will protect data and privacy, in accordance with laws, regulations, and NRI’s own company rules.

6. Ensuring transparency

NRI aims to design and develop AI that enables explanations regarding the results of its decisions. Should any unforeseen errors or biased decisions arise, NRI will strive to provide the appropriate explanation.

Enacted on Oct. 8, 2019

NRI Group Anti-Bribery Policy

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"). By preventing any acts of bribery and any acts that may be considered as bribery, NRI Group will maintain its reputation as a company that is trusted by the customers and the society.
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 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.
• 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.

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.

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

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.
This policy has been approved by the Group CFO of the NRI.

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
Last revised on Apr. 1, 2021

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