Basic Policy on Human Rights

The Nitto Group will continue its status as a company that highly values human rights

The Nitto Group respects human rights in accordance with international standards^*1 regarding human rights. The Nitto Group not only complies with the laws of Japan but also respects the laws and regulations of the nations and regions where its business activities take place. In the event of conflicts between internationally-recognized human rights and the laws and regulations of Japan or the nations and regions where its business activities take place, the Nitto Group will work to adhere to the international principles of human rights.

Concrete actions taken by the Nitto Group

• The Nitto Group Basic Policy on Human Rights applies to everyone who works at the Nitto Group, including all Nitto Group officers and employees. Furthermore, the Nitto Group requires all persons and corporations (business partners) engaged in the provision of Nitto Group products or services to comply with this policy.
• The Nitto Group works to eliminate confined labor, child labor, forced labor, and slave labor and labor arising from human trafficking, and to eliminate discrimination based on race, ethnicity, color, religious beliefs, gender, gender identity or expression, sexual orientation, nationality and lineage, mental or physical disability, age, health condition, marital history. Furthermore, the Nitto Group endeavors to promote diversity.
• The Nitto Group will fully understand this policy and conduct human rights due diligence^*2 as one foundational aspect of all business activities. The Nitto Group will not infringe upon human rights. Furthermore, the Nitto Group will fulfill its responsibility to respect human rights and ensure that its business activities do not create negative impacts on human rights.
• In the event any Nitto Group business activity is discovered to have a clear negative impact on human rights, or in the event the Nitto Group is found to clearly contribute to a negative impact through its customers or related parties, the group will work to remedy it through discussion and corrective actions.
• The Nitto Group will conduct appropriate training of officers and employees to ensure that this policy is effectively executed.

Hideo Takasaki
President & CEO
Nitto Denko Corporation

*1 The Nitto Group aims to continue its status as a company that highly values human rights. Toward this end, the full Group will promote and carry out activities necessary to make respect for human rights a matter of course in all business conducted, as based on our Corporate Philosophy.
*2 The process of identification, prevention, and reduction of negative impacts on human rights, and of taking responsibility for the handling of such impacts.

If there is any contradiction between the Japanese and translated versions of the Policy, then the Japanese version shall take precedence.

Nitto Group Policy on the Handling of Conflict Minerals*1

Minerals produced in the Democratic Republic of the Congo (DRC) and neighboring African countries are in widespread use by industries around the world. Armed insurgents who receive funds and profit from this mining, directly or indirectly, are said to be heavily involved in internal strife accompanied by serious human rights violations in this region.
Under these circumstances, the U.S. Securities and Exchange Commission (SEC) reached a decision in August 2012 to make it mandatory for all concerned firms listed on the stock market in the United States to disclose information on their procurement of specified minerals (the "conflict minerals" in Note 1), beginning in 2014. Studies to this end are already widening throughout corporate supply chains, and specification of smelters in the distribution process is considered particularly important.

• In response to this trend, the Nitto Group has adopted the policy of not using any conflict minerals*1 that are sources of funds for armed insurgents in the DRC and neighboring countries. 
• The Nitto Group shall strive to make on-going specifications of smelters in order to avoid use of conflict minerals. 
• The Nitto Group shall respond with integrity to inquiries related to conflict minerals from customers, and provide all information it has on the subject.

Notes
(*1) The term "conflict minerals" refers to those quantities of tantalum (Ta), tungsten (W), tin (Sn), and gold (Au) which are produced in the DRC and neighboring countries and are thought to be sources of funding for armed insurgents perpetrating serious human rights violations.

The process of confirmation to this end shall be implemented in conformance with the rules of the SEC and in accordance with requests from the Responsible Business Alliance (RBA) or other customer industry groups.

Protection of Human Rights in the Supply Chain

The CSR Procurement Survey and CSR Procurement Supplier’s Evaluation Checklist for the suppliers of the Nitto Group contain questions concerning the protection of human rights.
By using the results of these as a reference, we ensure that there are no human rights violations with child labor or forced labor within, or even outside of, the Group.