Human Rights Policy – Nichidenbo Corporation

To implement the protection of the human rights of employees and all stakeholders, Nitsuden Trading recognizes and adheres to the spirit of international human rights conventions and standards, including but not limited to the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights (ICESCR), the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), the Convention on the Rights of the Child (CRC), and the Convention on the Rights of Persons with Disabilities (CRPD). At the same time, with reference to the spirit of the Universal Declaration of Human Rights, the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, and relevant conventions of the International Labour Organization (ILO), the company has established a human rights policy to ensure the protection of human rights.

NDB Human Rights Policy

1.Human Rights Risk Identification and Assessment: Identify potential human rights risks arising from the company's business operations and supply chain, and assess their likelihood of occurrence and degree of impact.
2.Prevention, Mitigation, and Remediation Measures: Plan and implement corresponding risk mitigation and remediation measures for identified high-risk human rights issues.
3.Performance Tracking and Review: Regularly review the implementation status and effectiveness of each measure as a basis for continuous improvement.
4.Information Disclosure and Stakeholder Communication: Disclose human rights policies and implementation status through the official website, annual reports, or sustainability reports, and maintain communication with stakeholders.

In 2025, the company conducted a human rights due diligence assessment covering all employees. In addition to employees, the company also pays attention to supply chain human rights risk management. A Supplier Code of Conduct has been established,
covering requirements such as the prohibition of forced labor and child labor, anti-discrimination, reasonable working hours and wages, occupational safety and health, and ethical business practices. The relevant standards have been communicated to suppliers as an important basis for cooperation and ongoing business relationships.
If a supplier is found to be in violation of relevant human rights or labor standards, the company may require corrective action within a specified timeframe and, if necessary, terminate the cooperative relationship to reduce potential human rights risks in the supply chain.
At the current stage, the company manages supply chain human rights risks through the Supplier Code of Conduct and routine cooperation management mechanisms. In the future, based on business development and risk assessment results, the company will progressively evaluate the introduction of supplier human rights risk assessment or due diligence mechanisms to continuously strengthen sustainable supply chain management.
The material human rights issues identified for the current year are as follows:

Based on the results of the human rights due diligence, Nitsuden Trading plans and implements corresponding mitigation and remediation measures for the identified material human rights risk issues according to their likelihood of occurrence and degree of impact, in order to reduce potential adverse effects on employees and other stakeholders, and to continuously track and improve effectiveness.

Target Group

Material Risk Issues

Mitigation and Remediation Measures

Employees

Occupational Safety and Health

1.Conduct regular workplace safety inspections and risk assessments, with enhanced management and improvements for high-risk operations.
2.Plan and implement occupational safety and health education and training to enhance employees' awareness of operational safety and protective measures.
3.Promote employee health management programs, including health examinations, health consultations, and necessary health promotion activities.
4.In the event of an occupational accident, immediately initiate an incident investigation and improvement mechanism to prevent similar incidents from recurring, and provide necessary assistance and compensation in accordance with the law.

Employees

Wage and Working Hour Management

Employees

Prohibition of Discrimination and Prevention of Workplace Unlawful Infringement

1.Clearly establish regulations prohibiting discrimination, workplace bullying, and harassment, and incorporate them into the company's internal management systems.
2.Regularly conduct education and training on sexual harassment prevention, gender equality, and human rights to raise employee awareness.
3.Establish grievance and reporting mechanisms to ensure employees can raise concerns without fear of adverse treatment.
4.For verified cases of unlawful infringement, take appropriate disciplinary actions and improvement measures in accordance with company regulations.

Employees

Personal Data and Privacy Protection

1.Establish an information security management system and an incident reporting and response mechanism.
2.Develop clear management procedures and access controls for the collection, processing, and use of personal data.
3.Regularly conduct information security and personal data protection education and training to enhance employees' awareness of cybersecurity.
4.In the event of a suspected personal data breach, immediately initiate an investigation procedure and take remedial and corrective measures in accordance with the law.

Nitsuden Trading regularly reviews the high-risk human rights issues identified through the human rights due diligence assessment on an annual basis, and evaluates the effectiveness of each mitigation and remediation measure. The relevant implementation status is incorporated into internal management and sustainability governance mechanisms for continuous tracking, serving as a basis for future policy and measure improvements. Based on the aforementioned human rights risk identification results, the company continues to promote relevant mitigation measures through education and training, internal communication, and institutional management, and integrates them into daily operational management for effective implementation.

NDB Human Rights Policy

With reference to the Responsible Business Alliance Code of Conduct (RBA) and the OECD Due Diligence Guidance for Responsible Business Conduct, Nitsuden Trading has established a human rights due diligence process to regularly identify and manage human rights risks. The process is as follows:

1.Human Rights Risk Identification and Assessment: Identify potential human rights risks arising from the company's business operations and supply chain, and assess their likelihood of occurrence and degree of impact.
2.Prevention, Mitigation, and Remediation Measures: Plan and implement corresponding risk mitigation and remediation measures for identified high-risk human rights issues.
3.Performance Tracking and Review: Regularly review the implementation status and effectiveness of each measure as a basis for continuous improvement.
4.Information Disclosure and Stakeholder Communication: Disclose human rights policies and implementation status through the official website, annual reports, or sustainability reports, and maintain communication with stakeholders.

Scope of Human Rights Due Diligence and Material Issues
In 2025, the company conducted a human rights due diligence assessment covering all employees. In addition to employees, the company also pays attention to supply chain human rights risk management. A Supplier Code of Conduct has been established, covering requirements such as the prohibition of forced labor and child labor, anti-discrimination, reasonable working hours and wages, occupational safety and health, and ethical business practices. The relevant standards have been communicated to suppliers as an important basis for cooperation and ongoing business relationships.
If a supplier is found to be in violation of relevant human rights or labor standards, the company may require corrective action within a specified timeframe and, if necessary, terminate the cooperative relationship to reduce potential human rights risks in the supply chain
At the current stage, the company manages supply chain human rights risks through the Supplier Code of Conduct and routine cooperation management mechanisms. In the future, based on business development and risk assessment results, the company will progressively evaluate the introduction of supplier human rights risk assessment or due diligence mechanisms to continuously strengthen sustainable supply chain management.
The material human rights issues identified for the current year are as follows:

Mitigation and Remediation Measures
Based on the results of the human rights due diligence, Nitsuden Trading plans and implements corresponding mitigation and remediation measures for the identified material human rights risk issues according to their likelihood of occurrence and degree of impact, in order to reduce potential adverse effects on employees and other stakeholders, and to continuously track and improve effectiveness.

Target Group

Material Risk Issues

Mitigation and Remediation Measures

Employees

Occupational Safety and Health

1.Conduct regular workplace safety inspections and risk assessments, with enhanced management and improvements for high-risk operations.
2.Plan and implement occupational safety and health education and training to enhance employees' awareness of operational safety and protective measures.
3.Promote employee health management programs, including health examinations, health consultations, and necessary health promotion activities.
4.In the event of an occupational accident, immediately initiate an incident investigation and improvement mechanism to prevent similar incidents from recurring, and provide necessary assistance and compensation in accordance with the law.

Target Group

Material Risk Issues

Mitigation and Remediation Measures

Employees

Wage and Working Hour Management

Target Group

Material Risk Issues

Mitigation and Remediation Measures

Employees

Prohibition of Discrimination and Prevention of Workplace Unlawful Infringement

1.Clearly establish regulations prohibiting discrimination, workplace bullying, and harassment, and incorporate them into the company's internal management systems.
2.Regularly conduct education and training on sexual harassment prevention, gender equality, and human rights to raise employee awareness.
3.Establish grievance and reporting mechanisms to ensure employees can raise concerns without fear of adverse treatment.
4.For verified cases of unlawful infringement, take appropriate disciplinary actions and improvement measures in accordance with company regulations.

Target Group

Material Risk Issues

Mitigation and Remediation Measures

Employees

Personal Data and Privacy Protection

1.Establish an information security management system and an incident reporting and response mechanism.
2.Develop clear management procedures and access controls for the collection, processing, and use of personal data.
3.Regularly conduct information security and personal data protection education and training to enhance employees' awareness of cybersecurity.
4.In the event of a suspected personal data breach, immediately initiate an investigation procedure and take remedial and corrective measures in accordance with the law.

Tracking and Continuous Improvement
Nitsuden Trading regularly reviews the high-risk human rights issues identified through the human rights due diligence assessment on an annual basis, and evaluates the effectiveness of each mitigation and remediation measure. The relevant implementation status is incorporated into internal management and sustainability governance mechanisms for continuous tracking, serving as a basis for future policy and measure improvements. Based on the aforementioned human rights risk identification results, the company continues to promote relevant mitigation measures through education and training, internal communication, and institutional management, and integrates them into daily operational management for effective implementation.