The pursuit of profits is an inseparable part of a company's normal business activities aimed at realizing ideas and goals. Nonetheless, a business should never deviate from appropriate behavior because of escalating competition and violate social norms in seeking profits. NJC has adopted a policy on business conduct in full recognition of our social roles and responsibilities and is practicing this conduct in order to realize our ideas and goals as a company that grows with society as a basis for our existence. Here following is presented the specific rules of NJC's compliance (Code of Conduct).

Article 1 Basic Thinking

All directors and employees of NJC must think and act in full recognition of the company's social responsibilities knowing that their individual observance of pertinent laws and regulations concerning all aspects of business activities and their compliance with social ethics are indispensable to sound business growth.

(1) Promotion of sound business activities

1 Always be aware of oneself as a businessperson and aim for continued stable growth and development.
2 Perform activities fairly and appropriately in observance of laws, regulations, ordinances, etc.
3 Observe normal social rules and business practices with a strong sense of ethics and morals.

(2) Mutual understanding and social contributions

1 Practice social contribution activities in the local community.
2 Develop a corporate atmosphere that values social contribution through activities for the local area.
3 Respect cultures and customs worldwide.

(3) Considerations for the global environment

1 Research and develop environmental-friendly products.
2 Work to prevent pollution and conserve energy.
3 Undertake recycling to maintain and improve the environment.

(4) Relationship to antisocial influences

1 Do nothing that aids antisocial influences.
2 Adamantly refuse to purchase illegal products from or donate to antisocial influences.

(5) Considerations for shareholders and investors

1 Strive to maintain and improve business performance and stably pay dividends on a long-term basis.
2 Provide business information in a timely appropriate manner in compliance with the Securities and Exchange Law and other pertinent laws.

Article 2 Our Employees

NJC must build systems where each individual employee can fulfill one's roles and responsibilities in business activities, live and work with a sense of usefulness, and must support that each individual employee sufficiently demonstrate one's abilities both on the job and in one's life, and grow as a human being.

(1) Expectations placed on employees

1 Act respectful of laws, regulations, etc.
2 Act consciously of one's position as a member of society and the company.
3 Think and act for others.

(2) Respect for basic human rights

1 Respect human rights and eliminate all discrimination.
2 Respect the privacy of others.

(3) Providing a workplace environment where is it is easy to work

1 Provide appropriate deployments and fair opportunities that allow employees the chance of self-realization.
2 Make fair personnel evaluations based on respect for the personalities and individuality of employees.
3 Pay careful attention to ensure employee safety and create workplace environments where is it is easy to work.

Article 3 Fair Business Practices

In all business activities, NJC must act fairly and impartially in compliance with laws, regulations and international rules (global standards), and take every measure conceivable to understand and honor future events.

(1) Observance of the Antitrust Act

1 Do not engage in any acts of collusion, cartelling or that otherwise restrict free business activity.
2 Do not commit any unlawful acts that take advantage of superior business position.
3 Do not make inappropriate indications, resort to sensational advertising, and provide exaggerated premiums or gifts, etc.

(2) Observance of export laws and regulations

1 Confirm prior to exporting or importing products the export laws and regulations (business configuration, legalities, etc.) of Japan and other country.
2 Make prudent decisions based on the advice of experts if and when NJC products possibly conflict with export laws and regulations.

(3) Considerations for entertainment, gifts, etc.

1 Do not act in anyway that runs counter to normal business practices.
2 Do not entertain or provide gifts to public officials.

Article 4 Protection and Appropriate Disclosure of Company Information

Each and every employee must pay careful attention to information as a corporate asset on the understanding that leaking company information -- including customer information and samples that employees come in contact with on a daily basis through business activities, technical information or data on compositions and so forth, as well as information (intellectual property) created by the employees themselves -- to the outside can cause serious tangible and intangible damage to the company and customers. Also, information must be released in a timely appropriate manner and in full compliance with pertinent laws and regulations.

(1) Handling of corporate secrets

1 Carefully manage confidential information according to internal rules, to prevent leaks to the outside.
2 Do not obtain information by illegal means in violation of laws, regulations and social norms.
3 Observe laws, regulations and internal rules on information disclosures.

(2) Handling of insider information

1 Do not spread insider information for personal benefit.
2 Do not provide insider information to third parties.

(3) Handling of intellectual property rights

1 Complete formalities for newly created intellectual property without delay as instructed by internal rules.
2 Appropriately protect and effectively utilize intellectual property rights.
3 Respect the intellectual property rights of others without committing intentional infringement or unlawful use.