Companies around the world are being required to comply with increasingly strict regulations in all regions. The Group's Compliance Committee has been established to maintain and promote awareness of compliance, and it deliberates and makes resolutions regarding the Group's annual compliance plan, policies for compliance-related activities, and other important compliance-related matters.
The Group's Compliance Committee convenes twice yearly and reports its agenda items to the outside directors and audit and supervisory board members by way of the Board of Directors.
The NYK Code of Conduct, which sets forth norms that officers and employees must follow in the course of their duties, is reviewed periodically to reflect changes in the business environment and social conditions. September has been designated a compliancestrengthening month in which comprehensive compliance checkups are conducted that allow employees to take the initiative in reviewing their conduct and work processes. As part of comprehensive compliance checkup activities, the Company raises employee^*1 awareness of compliance issues by conducting a compliance awareness survey and then providing feedback on the survey results via its internal bulletin board.

1. *1employees includes secondees from other companies, and temporary staff.

The NYK Group's Compliance System

• *Reports to a full-time audit and supervisory board member periodically and as required

Main Measures Aimed at Strengthening Compliance

1997	Established NYK Business Credo
1999	Established NYK Code of Conduct
2002	Established position of Chief Compliance Officer
2005	Established NYK Group Mission Statement
2006	Established Internal Control Committee
2008	Established Antitrust Law Task Force
2013	Established Executive Committee Overseeing Thorough Antitrust Law Compliance
2016	Introduced measures to prevent bribery of overseas public officials when establishing new business Revised the NYK Code of Conduct
2017	Implemented a written pledge of adherence to the NYK Code of Conduct
2020	Revised the company's internal rules related to compliance

The NYK Group recognizes its social responsibility to comply with the laws of all countries and to fulfill its obligation to pay taxes, and constantly strives to improve taxation compliance.
In recent years, various problems have arisen with companies seeking to evade paying taxes by taking advantage of differences between corporate activities, national tax regulations and international taxation. We believe international taxation frameworks, such as the OECD's Base Erosion and Profit Shifting (BEPS) project, are essential for securing taxation transparency, and we seek to comply with such international standards.

The Company provides several consultation services for employees to discuss concerns about or report workplace misconduct, harassment, and non-compliance activity, including the Yusen Chat Room providing connections to other employees and outside lawyers and a consultation line operated by outside contractors. The Yusen Chat Room is available to roughly 64 Group companies in Japan and provides connections to six personnel, including an outside lawyer, available specifically to listen to a wide range of compliance matters and provide consultation, reporting, and whistleblowing on the matters.
Every effort is made to ensure the person contacting the service incurs no adverse consequences and, if desired, the contact remains completely confidential with the objective that the information provided will help improve the work environment.

In the global shipping industry, which is subject to the principle of the freedom of shipping (free navigation in international waters and innocent passage in territorial waters), anyone is free to enter or leave the market, which means that it is easy for competition to intensify. To reduce the potential negative impacts from that, such as interruptions to the stable shipping network and reduced shipping and industry competitiveness in emerging countries, the industry has historically been exempted from the scope of antitrust laws under certain conditions.
With these legal protections diminishing in recent times, it has become common for shipping companies to cooperate through vessel sharing agreements and slot exchanges in order to fulfill infrastructure responsibilities, maintain and improve diverse navigation networks, and manage the frequencies of port calls. As such, companies in the industry encounter many opportunities to make contact with competitors.
Since September 2012, the NYK Group has been subject to investigation by overseas authorities for allegedly violating antitrust laws regarding the shipping of automobiles and other cargo. The Company and certain overseas Group companies are also subject to class action damage compensation suits in multiple regions.
We offer all our stakeholders a sincere apology for the concerns that we caused.
We implemented various measures including the president declaring thorough compliance with antitrust law, building and operating a control network spanning the entire Group in Japan and overseas, and educating and raising employee awareness through training and manuals on antitrust law and rules concerning contact with other companies in the same industry. Nevertheless, we solemnly accept the fact that this situation occurred and are constructing and initiating a system to ensure absolute compliance with antitrust laws while continuing to raise the awareness of all Group employees* and executive officers.

• *Includes company employees, personnel seconded from other companies, and temporary staff

In January 2014, the Company updated its basic policy and guidelines related to prohibiting bribery to reflect the Japan Unfair Competition Prevention Act (prohibiting the bribing of overseas public officials), the U.S. Foreign Corrupt Practices Act, and the U.K. Bribery Act 2010. Since fiscal 2015, the Company has conducted anti-bribery training for employees in Japan and overseas.
In addition, the Company has been a member of the Maritime Anti-Corruption Network (MACN) since fiscal 2015. MACN is a global network engaged in activities to prevent and eliminate corruption in order to realize fair trade across the entire maritime shipping industry while investigating the root causes of corruption. To reduce the incidence of corruption, MACN has established cooperative relationships with major stakeholders, such as government officials, government authorities, and international organizations.
In April 2016, the Company established a system to prevent the bribery of overseas public officials. When considering new businesses in high risk countries, our legal department screens candidate partners and agents for bribery issues and provides advice and checks, including establishing anti-bribery clauses when creating agreements.

Certification from anti-bribery business organization

The Group has received below certification from TRACE International, a globally recognized anti-bribery business organization and leading provider of third-party risk management solutions.

"TRACE has completed a TRACE certification due diligence review of Nippon Yusen Kabushiki Kaisha. Certification by TRACE signifies that Nippon Yusen Kabushiki Kaisha has completed internationally accepted due diligence procedures and has been forthcoming and cooperative during the review process. TRACE certification underscores Nippon Yusen Kabushiki Kaisha's commitment to transparency in international commercial transactions.

TRACE certification ID: TC3182-6961 (Valid through: 2023/1/15~2024/1/14)

More Information:

• TRACE International, Inc.

As part of its lobbying activities, NYK makes political contributions that comply with the political funds control law, are based on company performance, and are made in accordance with proper internal procedure.
Also, to remain socially responsible and expand business value, we carefully review our lobbying activities and make contributions at amounts considered acceptable.