1. System for ensuring that the execution of the duties of the directors and the employees of the Company and its Subsidiaries complies with laws and regulations and the Articles of Incorporation and is performed efficiently

1) The Company shall, under the Group Management Principle and the Code of Conduct, comply with laws and regulations and the Articles of Incorporation as well as firmly maintain the policy of not committing any illicit or antisocial act, and shall be devoted to fair interfirm competition as a public institution of society.
2) The Company shall, as a holding company, advance the Group management and enhance corporate governance through improving/operating/establishing the internal control systems for the whole Group, formulating the management strategies for the whole Group, conducting internal audits of the Group, monitoring Subsidiaries, and financing in a consolidated way.
3) The Company shall, under the Group Accounting Basic Rules, strive for swift, accurate and fair disclosure as well as continuously achieve accountability to its shareholders and investors, and shall increase the transparency of corporate information.
4) The Company shall establish the division for internal audit of the Group and conduct audits on the internal control systems of each Group company under the Group Internal Audit Rules.
5) The Company shall, under the Group Internal Reporting Rules, set up a whistle blowing system for protecting whistleblowers to receive reports or provide consultation concerning any act in contravention of corporate ethics, and make efforts to detect misconduct at an early stage and to rectify such misconduct immediately as well as strictly ensure legal compliance.
6) The Company shall establish the systems for the appropriate and efficient execution of the duties under official authority and decision-making rules based on the Board of Directors Rules, the Organization Rules and other internal regulations.

2. System for retaining and managing the information concerning the execution of the duties of the directors of the Company and reporting to the Company on matters concerning the execution of the duties of the directors and employees of its Subsidiaries

1) The Company shall properly record, retain, manage and maintain the minutes of the meeting of the Board of Directors, documents of request circular for approval and other information concerning the execution of the duties under laws and regulations and the internal regulations such as the Board of Directors Rules, the Group Document Management Rules and the Group Information Security Management Rules.
2) The Company shall receive reports on matters concerning the execution of the duties of the directors and employees of its Subsidiaries under the Group Management Rules, the Group Proposal and Approval Rules, and other Rules pertaining to the Company Group.
3) The directors and the auditors of the Company may directly inspect and copy the information concerning the execution of the duties that are electromagnetically recorded, retained, managed and maintained by each division of the Company.
4) Upon the request of the directors and the auditors of the Company, the concerned division of the Company shall promptly submit the requested information and documents for inspection.

3. Rules and other systems for the management of risk of loss of the Company and its Subsidiaries

1) The Company shall, under the Group Risk and Crisis Management Rules, identify and evaluate the overall risk of the Group at the Group Risk Management Committee and improve systems for the risk management cycle of the Group.
2) The Company and its Subsidiaries shall, under the risk management cycle, voluntarily and independently manage each risk related to corporate activities according to the type and characteristics of any risk, and discuss responses to any significant matter after reporting to the Board of Directors of the Holding Company.
3) The Company shall, under the Group Risk and Crisis Management Rules, take prompt and appropriate action at the outbreak of a business continuity crisis such as disaster, accident or incident.

4. System for ensuring the suitability of the operations of Nichirei Group in addition to the systems listed in above 1 to 3

1) The Company shall, as a holding company, plan, decide and perform Group strategies, appropriately allocate business resources, implement monitoring and risk management for the whole Group, and fulfill the responsibility of a publicly traded company to attain the mission and vision of the Group.
2) To enhance the social responsibility function of the Group, the Company as the Holding Company shall organize:
i) Corporate staff division to develop, decide, and carry out Group strategies, and provide support and guidance for the appropriate distribution of management resources and the realization of Subsidiaries' strategies;
ii) Internal audit division to monitor the Company and Subsidiaries to point out problems and provide guidance for improvement; and
iii) R&D division and QA division from the Group perspective.
3) Subsidiaries shall organize necessary functions such as planning, development, production, sales, and administration to improve the environmental adaptation to respond promptly to market requests under the executive authority of the respective Representative Directors and Presidents based on the missions and visions expected and required by the Company.
4) The transactions between the Company and its Subsidiaries in the Group shall be conducted appropriately according to relevant accounting principles, tax laws and other norms.

5. Basic policy for the elimination of antisocial forces and the system for ensuring compliance with such policy

The Company shall strongly recognize corporate social responsibility and will under no circumstances tolerate submission to and/or a close relationship with antisocial forces posing a threat to the order and security of civic society. The Company shall take a firm position against such forces.

6. Matters concerning any employee requested by the auditors to assist them, matters concerning the independence of such employees from the directors, and matters concerning the ensuring of effectiveness of directions from the auditors to such employees

1) The Company shall establish the division for internal audit of the Group and improve the systems to enable the auditors to conduct audits more effectively and efficiently, including holding regular liaison meetings between the auditors and the division.
2) The Company shall assign specialized staff upon the request of the Board of Auditors. The personnel matters thereof shall be determined after discussion between the directors and the auditors paying attention to their independence from the directors and ensuring the effectiveness of directions from the auditors to them.

7. Systems of reporting to the auditors

1) In the event that the directors and/or the employees become aware of any material violation of laws or the Articles of Incorporation, any fact of an illicit act, or any fact likely to cause considerable damage to the Company concerning the execution of duties, they shall promptly report such information to the auditors.
2) The directors and/or the employees shall promptly report to the auditors any decisions significantly affecting the business and the organization, and the implementation status and the result of the internal audits.
3) The directors, auditors, and the employees of Subsidiaries aware of a fact which may have a material effect on the Group's internal controls as well as those reported to by them shall promptly report such information to the auditors.
4) The Company and its Subsidiaries shall protect those who reported to the auditors from unfair treatment on the grounds that they made such report.

8. Other systems for ensuring the effective audit by the auditors

1) The Representative Directors shall improve the systems to fully achieve the auditing function of the auditors concerning the execution of operations, including setting up opportunities for the Board of Auditors to regularly report on its performance of the execution of operations apart from the written report thereof to the Board of Directors.
2) The Board of Directors shall ensure the presence of the auditors at any meetings for operational purposes which are important in ensuring the suitability of the operations.
3) The Company shall, when requested by the relevant auditors, accept advance payments or reimbursement of expenses arising related to their execution of duties as auditors as soon as possible unless it is specially unreasonable.