CSR

Established April 2008
Nanan Seiko Co., Ltd.

<Introduction>

In order to realize its management philosophy, Nanan Seiko Co., Ltd. has been promoting the thorough implementation and strengthening of “trust-based management.” We define our CSR as “realization of the management philosophy” = “practice of trust-based management.”
　Nanan Seiko Co., Ltd. believes that the foundation of trust-based management lies in continuing to be a company trusted by all business partners and contributing to the creation of a better society while growing together with society.
　To practice trust-based management, we have established an “Employee Code of Conduct” as a concrete set of behavioral guidelines and ensure its thorough implementation through employee education and training.

　While it goes without saying that continuing to provide products that satisfy customers and benefit society is the most important factor in building corporate trust, Nanan Seiko Co., Ltd. cannot manufacture its products alone, and they can only be delivered to the market with the cooperation of its business partners.
Therefore, trust-based management must be practiced together with all business partners. We ask for your understanding and cooperation with these basic policies of Nanan Seiko Co., Ltd., and, based on the “Nanan Seiko Co., Ltd. Code of Conduct,” we will strive for continuous improvement in our initiatives.

The “Nanan Seiko Co., Ltd. Code of Conduct” sets forth standards to ensure that our business environment is safe, that employees are respected and treated with dignity, and that environmental considerations are incorporated into the manufacturing process.
We understand that, in all aspects of our business activities, we must comply with the laws, regulations, and rules of the countries in which we operate. Furthermore, we go beyond legal compliance and engage in advanced social and environmental initiatives based on international standards.

We respect the human rights of our employees and treat them with dignity in line with the expectations of the international community.
The labor standards are as follows.

1) Voluntary Employment
We do not use forced labor, debt bondage, slavery, or involuntary prison labor. All work is voluntary, and employees are guaranteed the right to leave employment freely with reasonable notice. As a condition of employment, we do not require employees to surrender government-issued identification, passports, or work permits.
2) Child Labor
We do not use child labor at any stage of manufacturing. A “child” refers to a person under the age of 15 who is employed. However, legitimate workplace training programs (such as apprenticeships and internships) conducted in accordance with applicable laws and regulations are permitted. Employees under the age of 18 are not assigned to hazardous work. In addition, where necessary for educational purposes, restrictions are placed on night work.
3) Working Hours
Research in the manufacturing industry shows a correlation between worker fatigue and decreased productivity, increased turnover, and a higher incidence of injuries and accidents. We do not require employees to work beyond the legally prescribed number of working days per year. We also comply with laws and regulations regarding working hours and overtime. Employees are provided with at least one day off per week.
4) Minimum Wages
Wages paid to employees comply with all applicable wage-related laws, including minimum wage, overtime pay, and statutory benefits. Disciplinary wage deductions are implemented in accordance with applicable domestic laws. Details of wage payments are communicated to employees promptly and without delay through pay slips or equivalent documents.
5) Inhumane Treatment
We do not engage in harsh or inhumane treatment of employees, including sexual harassment or abuse, corporal punishment, mental or physical coercion, or verbal abuse, nor do we threaten such treatment.
6) Discrimination
We eliminate harassment and unlawful discrimination from the workplace. We do not discriminate against applicants or employees in hiring or employment practices, including promotion, compensation, and access to training, based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, marital status, or any other similar factors. We also do not conduct medical examinations on employees or applicants that may be used for discriminatory purposes.
7) Freedom of Association
Free communication between management and employees regarding working conditions is effective in addressing workplace environment and compensation issues. We respect employees’ rights to freely form and join labor unions, to choose whether or not to participate, and to serve as or participate in workers’ representatives in accordance with applicable laws. We provide an environment in which employees can openly express their views on working conditions to management without fear of retaliation, intimidation, or harassment.

We recognize that creating a safe and healthy workplace environment improves product and service quality, manufacturing consistency, and employee morale.

1) Workplace Safety
Risks to workplace safety, including electricity and other energy sources, fire, vehicles, and falling objects, are managed through appropriate design and engineering or administrative controls, such as preventive measures and workplace safety procedures (lockout/tagout). If these measures cannot adequately control risks, appropriate personal protective equipment is provided to employees. Employees are not subject to disciplinary action for raising safety concerns.
2) Emergency Preparedness
We establish systems to identify, evaluate, and analyze potential emergency situations and scenarios. We establish systems to identify, evaluate, and analyze potential emergency situations and scenarios.
Emergency reporting, employee notification, evacuation procedures, evacuation drills, appropriate fire detection systems, fire suppression equipment, suitable evacuation facilities, and recovery plans.
3) Occupational Injuries and Illnesses
We establish and operate procedures and systems to identify, report, and manage occupational injuries and illnesses.
These include the following initiatives. a) Encouraging employee reporting, b) Classification and recording of injuries and illnesses, c) Provision of necessary medical treatment, d) Investigation of incidents and implementation of corrective actions to eliminate causes, e) Support for employees returning to work.
4) Industrial Hygiene
When employees are exposed to chemical substances, biological agents, or substances that cause physical changes, such conditions are identified, evaluated, and properly controlled. If hazardous substances cannot be adequately controlled through engineering or administrative measures, appropriate personal protective equipment is provided to employees.
5) Physically Demanding Work
When employees engage in physically demanding tasks such as manual material handling, prolonged standing, or highly repetitive or forceful assembly work, such conditions are identified, evaluated, and managed.
6) Machinery Safety Measures
Safety measures such as safety devices, interlocks, and protective barriers are implemented for machinery and equipment used by employees, and proper maintenance is carried out.
7) Dormitories and Cafeterias
Employees are provided with clean toilet facilities, drinking water, and hygienic food preparation and storage facilities. Dormitory facilities provided by the Company are clean and safe, equipped with emergency exits and appropriate air conditioning and ventilation systems, and ensure adequate personal space.

We recognize that sufficient consideration for the environment is essential in manufacturing products at an international level, and we strive to minimize adverse impacts on society, the environment, and natural resources arising from our manufacturing processes, while ensuring the health and safety of people.

1) Environmental Permits and Reporting
We carry out all necessary applications, notifications, and reporting required by environmental laws and regulations and obtain the necessary permits. We maintain compliance with applicable regulations through up-to-date operational management.
2) Pollution Prevention and Resource Conservation
All emissions, including wastewater, waste, and energy-related outputs, are reduced and minimized through process improvements and the substitution, recycling, and reuse of raw materials.
3) Hazardous Substances
We identify chemical substances and other materials that may pose a risk of environmental pollution and manage them to ensure safe handling, transportation, storage, reuse, and disposal.
4) Wastewater and Waste
Industrial wastewater is treated and properly managed to meet discharge standards before being released. Waste generated from operations is appropriately classified, stored, and managed before being treated or entrusted to external disposal services.
5) Air Pollution
Emissions such as volatile organic compounds (VOC), aerosols, corrosive substances, particulate matter, ozone-depleting substances such as fluorocarbons, and SOx, NOx, and soot emitted from stacks are identified, controlled, and properly monitored.
6) Regulations on Substances in Products
We comply with all applicable laws and regulations regarding the prohibition or restriction of specific substances, including those related to labeling for recycling and disposal. We also adopt and comply with processes that meet customer-specific restrictions and lists of hazardous substances.

Note) For environmental protection items requiring particularly detailed compliance, we adhere to the provisions set forth in the “Seiko Epson Green Procurement Standards for Production Materials.”

The management system must be designed to ensure (a) compliance with laws, regulations, and customer requirements related to business and products, (b) compliance with this Code, and (c) identification and mitigation of operational risks related to this Code. In addition, such management systems must be continuously improved.

1) Corporate Commitment
We confirm our responsibility to society and the environment and declare our commitment to compliance with this Code and continuous improvement.
2) Management Accountability and Responsibility
We clearly define responsible personnel within the Company to ensure the operation and regular review of the management system.
3) Laws and Customer Requirements
We identify, monitor, and appropriately understand applicable laws, regulations, and customer requirements.
4) Risk Assessment and Risk Management
We establish processes to identify risks related to environmental, health and safety, and labor practices associated with business activities, evaluate the relative significance of each risk, and implement appropriate procedures and physical controls to manage identified risks and ensure legal compliance.
5) Objectives, Implementation Plans, and Measurement
We establish and promote implementation plans that include documented standards, objectives, targets, and periodic performance evaluations.
6) Training
We provide education and training to management and employees to implement policies, procedures, and improvement objectives.
7) Communication
We provide clear and accurate information on performance, initiatives, and expectations to employees, business partners, and customers.
8) Employee Feedback and Participation
We assess employees’ understanding of the areas covered by this Code and obtain their feedback on these initiatives to promote continuous improvement.
9) Audits and Evaluations
We conduct periodic self-evaluations to ensure compliance with applicable laws, this Code, and contractual requirements related to social and environmental responsibility.
10) Corrective Actions
We promptly correct any deficiencies identified through internal or external evaluations, inspections, investigations, or reviews.
11) Documentation and Records
We maintain records and documentation of compliance with laws and requirements, ensuring appropriate confidentiality of personal information.

To fulfill our social responsibilities and succeed in the marketplace, we maintain the highest standards of ethical conduct, including the following.

1) Integrity in Business
The highest standards of integrity are required in all business transactions. All forms of corruption, extortion, and embezzlement are prohibited. Contracts will be terminated immediately, and legal action will be taken as necessary.
2) Improper Benefits
We do not offer or accept gifts or entertainment for the purpose of obtaining improper benefits, such as bribery.
3) Disclosure of Information
Information regarding business activities, structure, financial condition, and performance is disclosed in accordance with applicable laws and industry practices.
4) Intellectual Property Rights
We respect intellectual property rights, and the transfer of technology and know-how is carried out in a manner that protects such rights.
5) Fair Business, Advertising, and Competition
We conduct fair business, advertising, and competition.
6) Protection of Whistleblowers
We protect the confidentiality of whistleblowers in relation to reports from business partners and employees.
7) Community Contribution
We engage in activities that contribute to the development of society and the economy.

1) Export Control
We establish a clear management system and carry out appropriate export procedures for technologies and goods subject to export regulations under applicable laws and regulations.
Technologies and goods subject to such regulations include components, products, technologies, equipment, and software that are regulated for export under laws based on international agreements (such as the Wassenaar Arrangement). Where export procedures require approval from relevant authorities, such procedures will be followed.
2) Information Security
Confidential information received from customers or other parties (such as business and technical information), as well as personal information of customers, other parties, and our employees, is handled in compliance with applicable laws and regulations and in accordance with contractual agreements, and is properly protected and managed as trade secrets against internal and external threats, including risks to confidentiality (leakage), availability (loss of access), and integrity (tampering).
When using IT systems, we implement technical safeguards against threats on computer systems and networks (such as unauthorized access and viruses) and manage them to prevent any damage from affecting our company or others.
3) Product Safety
When we are responsible for product design, we ensure that products comply with safety standards established by applicable laws and regulations in each country.
Product design is carried out to ensure sufficient safety, and products are marketed with due consideration of the responsibilities of a manufacturer.
In addition to legal compliance, we also consider the level of safety ordinarily expected.
To ensure product safety, we maintain traceability (such as records of materials, components, and processes) and respond promptly to any issues.
4) Use of Trademarks and Company Names
When it becomes necessary to use trademarks or company names owned by business partners, we submit a written request to the relevant partner. We ensure that such trademarks or company names are not used in advertising or publicly disclosed without prior approval from the business partner.
5) Management of Borrowed Assets
When using assets owned by business partners for production, we comply with contractual terms and applicable laws and regulations. We also ensure proper management so that such assets can always operate normally. We respond promptly to requests from business partners, such as submission of custody certificates, inventory inspections, and on-site inspections of usage conditions.