Nichirei Group Code of Conduct

1. Compliance with Laws and Regulations Concerning Respect for Human Rights and Labor

The Nichirei Group respects human rights and never discriminates on the basis of race, color, gender, religion, political views, nationality, social position or national origin.
The Nichirei Group eliminates all forms of forced labor and child labor. Discriminatory language and behavior, violent acts, sexual harassment and power harassment at workplace are prohibited. The Nichirei Group complies with the legal standards concerning wages (including legal allowances) and working hours.

2. Environmental Protection

All people working for the Nichirei Group should comply with laws and regulations applicable to environmental protection and reduces environmental impact associated with our business activities, in order to realize a sustainable society. The Nichirei Group, as a group of companies with quality food products and a superb logistics network, will pass on the blessings of the Earth which is the source of our “food” and “health” to the next generation, recognize the impact of our business activities on biodiversity, and preserve biodiversity.

3. Compliance with Laws and Regulations and Internal Regulations

All people working for the Nichirei Group should, in compliance with all applicable laws and regulations and social norms of every country/region, ensure fair competition and carry out business activities faithfully, honestly and with a high standard of transparency.
The internal regulations of the Nichirei Group are the regulations that clarify the rules necessary for the organizational and effective management of each company of the Nichirei Group (the "Company"), and are indispensable for the governance and internal controls of the Company. Accordingly, all people working for the Nichirei Group should properly understand and comply with such internal regulations.

4. Management and Preservation of the Company's Property

All people working for the Nichirei Group should ensure that the Company's property is used in an effective and efficient manner.
When acquiring property, all people working for the Nichirei Group should give sufficient consideration at the planning stage so that no property goes to waste. In addition, proceedings consistent with the internal regulations should be taken, and the acquired property should be managed with due care to avoid being lost or stolen.
The Nichirei Group values intellectual property such as patents, designs, trademarks, trade secrets and copyrights, and protects them as its own property. In addition, the Nichirei Group respects the legitimate intellectual property rights of third parties and will not infringe upon or abuse them.

5. Prohibition on Personal Use of the Company's Property

All people working for the Nichirei Group should never mix the Company business with private affairs or use the Company's property for personal use, or use the Company's property such as its products and equipment for any purpose other than business.

6. Prohibition on Insider Trading

All people working for the Nichirei Group, when they come to know material facts of the Nichirei Group (undisclosed information that may affect investment decisions), should not purchase or sell Nichirei Corporation’s shares until such facts are publicized.
Transactions of shares of our business partners/clients/customers (collectively referred as “business partners’’) are also prohibited until material facts of such business partners (undisclosed information that may affect investment decisions) are publicized.

7.  Ensure the Reliability of Financial Information

For the sake of stakeholders, the Nichirei Group handles accounting transactions in an accurate and appropriate manner, and makes true and clear financial reports on the financial condition, operating results and cash flow.
For this purpose, books on which the financial reports are based, and documents that may affect the entries in those books, should always be accurate and complete, and no actions should be taken and no entries should be made that may cause fraud, dishonesty, mistakes or misunderstanding.

8. Management and Use of Information

All people working for the Nichirei Group should handle confidential information and personal information appropriately, and in compliance with the laws and regulations that prohibit illegal access to information systems and protect personal information, and carry out business activities accordingly.
In addition, confidential information, information assets (such as personal computers and mobile phones) and personal information should be handled in accordance with the regulations and guidelines of each company of the Nichirei Group concerning information security and the protection of personal information.

9. Prohibition of Personal Acts Conflicting with the Company’s Interests

All people working for the Nichirei Group assume responsibility for taking the best course of action for the Company's interests.
Neither should they receive personal benefits or grant benefits to third parties at the cost of the Company’s interests. Any acts that involve conflict of interests between the Company and its employee (such as competing transactions or self-dealing) should be reported beforehand to obtain the Company’s approval.

10. Prohibition on Unfair Benefits Given to/Received from Public Officers or Business Partners

All people working for the Nichirei Group should comply with laws and regulations applicable to relationships with public officers or any other equivalent persons ("Public Officers"), and should not provide bribes or other unjustifiable benefits to Public Officers.
Bribing foreign Public Officers is also subject to punishment depending on the applicable laws and regulations. Thus, all people working for the Nichirei Group should comply with laws and regulations applicable to foreign Public Officers, in the same way as we comply with laws and regulations applicable to Public Officers in our own country.
Receiving bribes, money or other personal interests from business partners, or providing the Company’s interest to business partners is also prohibited.
All people working for the Nichirei Group comply with applicable laws and regulations and rules of employment of each company and take necessary internal procedures when giving/receiving gifts or entertainment to/from Public Officers, business partners or other interested persons.

11. Prohibition on Involvement/Trade with Antisocial Forces

All people working for the Nichirei Group should not have any relationship with antisocial forces or groups that threaten public order and safety, and should reject unreasonable claims from such forces or groups and should not do business with them.

12. Compliance with/reporting of and Consultation on Code of Conduct

All people working for the Nichirei Group should report/consult with their superior or relevant department, promptly after they notice violation of laws and regulations, internal regulations or Code of Conduct.
If such reporting/consulting with the superior or relevant department is impossible, the internal whistleblowing system should be used.
The Nichirei Group prohibits any disadvantageous treatment of whistleblowers or people who ask for consultations.