Promoting Compliance

Everyone in the Group understands that maintaining relationships of trust with stakeholders is the foundation of our sustainable growth together with the communities that we serve. To reinforce this concept, we created a Group Corporate Philosophy, along with a Corporate Code of Conduct, designed for putting the spirit of our philosophy into practice. Moreover, an Internal Control and Compliance Committee chaired by the president executive officer strives to raise awareness of compliance so that all officers and employees obey all laws and regulations, as well as internal rules, social norms, and business ethics while performing their everyday work.

NS United Kaiun has established Helpline channels, both internally and externally that are available for direct reporting when officers or employees  are suspected of, or found to have committed, violations of laws or regulations, improper conduct, or acts that may give rise to such misconduct. All helpline channels accept reports on an anonymous basis. In line with the purpose of whistleblower protection, the Company guarantees that whistleblowers will not suffer any disadvantageous treatment as a result of making a report or consultation.

A total of three reporting channels have been established: one internal channel and two external channels, consisting of an external legal counsel channel and an independent third‑party  channel.

In order to lower the hurdle for use, NS United Kaiun conducted explanatory video‑based training on the Helpline channels in April 2025, and changed the name of the channels in April 2026.

In addition, personnel engaged in whistleblower response operations receive the necessary training, in accordance with the guidance under the Whistleblower Protection Act, to ensure appropriate handling of reports, including those related to whistleblowing and harassment.

Our Group aims to foster a workplace culture in which each employee can work with confidence and peace of mind.
As part of this effort, we conduct employee awareness survey on internal control and compliance. The feedback shared through these surveys is reported to the Executive Officers’ Meeting and made available on the internal intranet, and is utilized to consider and communicate measures to improve the working environment, enable employees to fully demonstrate their capabilities, and foster a culture in which employees feel comfortable seeking advice or raising concerns.

Guided by Japan’s Companies Act and Regulation for Enforcement of the Companies Act, the Board of Directors has established a basic internal controls policy, while also working to ensure the reliability of financial reports in accordance with the provisions of the Financial Instruments and Exchange Act.

Internal controls and compliance initiatives taken by corporations have been attracting an increasing amount of public attention. To effectively address these issues across the Company, we organize the Internal Control and Compliance Committee, appointing the president as the chairperson and each executive officer in charge of a business division as a committee member. Furthermore, every department established a system for autonomous internal controls, where they proactively identify local risks in daily operations and makes improvements to mitigate these risks.

We recognize that internal control activities help enhance the quality of our business management, and that financial reports which have high reliability give rise to trust in our Company by our stakeholders and from society. All the executives and employees of the Company will continue to work together to strengthen compliance, establish and implement an appropriate internal control system.

The NS United Kaiun Group has established this policy to ensure compliance with anti-corruption laws and regulations applicable to the countries and regions in which we conduct business activities and to practice behavior that our compatible with social ethics.

This policy was approved by the Board of Directors on January 31, 2023. Subsequent revisions or abolition of this policy will also be determined by approval of the Board of Directors.

Under our Group’s Code of Conduct, we are committed to complying with all applicable laws and regulations and to acting with integrity and a high level of ethical standards.

A Relationship with Stakeholders

• Refrain from offering excessive entertainment to business stakeholders that deviates from socially accepted idea and from giving and receiving goods because it is skeptical of illegal transactions.
• Do not offer any bribes or give unfair profits, or make an illegal offer and promises to civil servants.
• Do not borrow, use or give or receive money from others by taking advantage of your business position, or by improper or unfair means.

Through our Group Supplier Guidelines, we require our suppliers to support and comply with anti-corruption and anti-bribery practices.

Prevention of Corruption
Do not engage in any form of corruption, including bribery, the receipt of entertainment or gifts beyond what is socially acceptable or outside international norms, and insider trading.

With respect to the risks faced by the Company, including corruption-related risks, deliberations and decisions are carried out by the relevant departments or committees in accordance with the Risk Management Regulations. At the end of each fiscal year, the Internal Control and Compliance Committee—chaired by the President and comprising all Executive Officers as well as officers of major Group companies—reviews each risk item based on the Risk Item List, reports on and evaluates the status of risk management implementation, and reports the results to the Board of Directors.

NS United Kaiun Kaisha Group (“NSU Group”) hereby announces that we have joined the MaritimeAnti-Corruption Network (MACN*¹) as of October 7, 2024.　MACN is a global business network dedicated to working towards a corruption-free shipping industry through fair trade for the benefit of society as a whole. Established in 2011, the network has more than 200 members worldwide and works with stakeholders, including government officials, NGOs and civil society, to identify and mitigate the root causes of corruption in the shipping industry.

Through such participation, the Group engages in the collection of information on corruption-related issues and promotes education and awareness initiatives for relevant departments.

To date, we have not made any political contributions. However, in the event that we do make a political contribution, we will do so in light of our business performance, in compliance with the Political Funds Control Act, and in accordance with appropriate internal procedures.

We take measures to ensure executives and employees follow appropriate action and management guidelines to comply with the antitrust law, and implement a system to create and store records of details of contacts with other companies in the same industry depending on the nature of contact.

Starting in 2010, the year of the corporate merger, the Company has designated October as the month for raising compliance awareness and is engaged in several activities across the Group. The campaign aims to remind all executives and employees of the importance of this theme, implementing a range of activities to enhance their awareness as well as give them the knowledge and information needed to practice compliance.