Every member engaged in procurement activities for the Nitto Group must ensure that their actions are consistent with corporate ethics and social common sense, and must observe the following action guideline to promote procurement activities that are fair and free of corruption.

1. A person who is engaged in procurement activities shall follow any and all laws and regulations related to procurement processes. If any person becomes aware of any fact indicating noncompliance with the law, such person must immediately report this to his/her supervisor and take appropriate action.
2. A person who is engaged in procurement activities shall not accept any kind of gifts from business partners, including summer and year-end gifts and presents from visitors. Similarly, he/she shall refuse any gifts offered as a gesture of courtesy, including gifts offered at times of celebration/condolence or gifts offered as a token of sympathy.
3. A person who is engaged in procurement activities shall not acquire unlisted shares of business partners or acquire shares based on insider information.
4. A person who is engaged in procurement activities shall not purchase products offered by business partners at a special discount, for his/her private use.
5. A person who is engaged in procurement activities shall not have any business partners pay for his/her transportation/hotel/meals on his/her visit to meet with such partners.
6. A person who is engaged in procurement activities shall not have any vested interest with partners in any form, including privately demanding payoffs from them.
7. A person who is engaged in procurement activities shall not accept any inappropriate entertainment from business partners or provide such entertainment to business partners.