Compliance

Basic Approach to compliance

For many years, the NAGASE Group's Management Philosophy has upheld the ideal of maintaining the highest integrity as a member of society, and we hold dear the observation of laws, regulations, and rules.

In response to the globalization of the Group’s business activities, the diversification of the types of its transactions, and the growing demand in society for corporate social responsibility in corporate activities, we formulated the NAGASE Group Basic Compliance Policy in October 2002 (revised into the Introduction to the Code of Conduct for Risk Management & Compliance in April 2024). In December 2003, based on this policy, we also established the NAGASE Group Code of Conduct for Compliance (revised into the Code of Conduct for Risk Management & Compliance in April 2024) and the Compliance Help Desk Rules (partially revised in 2024. The Corporate Crisis Management Policy was also revised in April 2024 to clarify the reporting lines to use when compliance violations occurred or were suspected and to specify how to collect the necessary information, respond to such situations, and give instructions.) In October 2008, we established the NAGASE Group Product Safety Principles, which have been adopted across all of the NAGASE Group’s domestic and overseas entities.

In recent years, with the ever-accelerating changes in the external environment, restrictions from laws and regulations have become more borderless, complex, and stringent. There have been particularly stringent demands for compliance with the prohibition of bribery and the rules on fair competition. The demands and expectations that society places on corporations also continue to evolve, and there is an ever-increasing demand on corporations to act in a socially-responsible manner. In light of these changes and trends, we reevaluated and revised the Basic Compliance Policy, the NAGASE Group Code of Conduct, and Compliance Help Desk Rules in 2017, and will continue to constantly and rigorously ensure compliance in keeping with the changing times. In addition, since we felt the need to raise the awareness of risk management to respond to the significant changes in the external environment in recent years, we incorporated risk management into the NAGASE Group Basic Compliance Policy and the NAGASE Group Code of Conduct and changed the names to Introduction to the Code of Conduct for Risk Management & Compliance and Code of Conduct for Risk Management & Compliance, respectively, in 2024.

The Code of Conduct for Risk Management & Compliance

Based on our management policy that “We recognize our responsibility to society and offer beneficial products and services while maintaining the highest standards of integrity. Through our growth, we will contribute to society and enrich the lives of our employees.”, We hereby establish and execute the Code of Conduct for Risk Management ＆ Compliance as follows.

This Code of Conduct defines the behavior standards that the NAGASE Group and its officers and employees will observe as they carry out their work.

We require our officers and employees to comply with these standards and team them to others by example—particularly to co-workers. Any danger of non-compliance must be addressed without delay, and officers or employees should identify the root cause of the issue, taking steps to prevent any recurrence.

• Comply with applicable laws and regulations; conform to internal rules

  Conduct business fairly and in good faith, in keeping with laws, company rules and social norms.

  Conduct work in keeping with internationally accepted norms to ensure our growth as a global enterprise.

  Comply strictly with domestic and foreign laws including laws regarding bribery and competition laws.

• Eliminate anti-social elements

  We firmly reject any anti-social elements that threaten the public order and safety.

• Provide useful products and services

  Contribute to society through useful goods and services.

• Respecting the Rights of people Involved in the Business

  We foster a corporate culture in which employees can contribute with their independence and creativity.

  We respect the rights of our employees as well as all of those who are involved in the NAGASE Group’s supply chain and business activities, and those who contribute to the realization of a sustainable economy and society.

• Disclose information

  We will ensure management transparency by fairly disclosing corporate information to our stakeholders, including our customers, suppliers, employees, and shareholders.

• Protect the global environment

  We recognize and perform on our responsibility to improve the environment.

• Risk Management

  the NAGASE Group will promote risk management to achieve stable business continuity and sustainable growth, in a rational and optimal manner, by managing risks that may become barriers to the management of the NAGASE Group.

• Responsibilities to top management

  The top management of all the NAGASE Group members including NAGASE & CO., LTD.., Ltd. shall take the lead to ensure that the business is administered “with the highest standard of dignity as a member of society”.