Third-Party Review

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We have edited CSR Report 2017 to serve as an easily understood and trustworthy report, on the basis of information disclosure policies. So that we may hear objective opinions with the aim of creating a better report, we requested a third-party review from Mr. Tomohiro Tokura of SGS Japan Inc.

Third-Party Review of CSR Report 2017

We have heard of your declaration once again towards accomplishing the CSR, and your signing of the UN Global Compact (UNGC) in relation to the four areas and ten principles: human rights, labor, environment, and anti-corruption. We have heard of your continuing CSR acts and commitment to the public regarding improved governance, response to individual and market demands, contribution to communities, and more. This can be viewed as a result of increased social concerns and company responsibilities. Work on increasing intra-company awareness of our signature of the UNGC will be carried out from now, while internal CSR training is ongoing and will be extended out to group companies in 2017. As well as basic training, we understand that you are also considering ongoing, follow-up training. We believe this will further increase company awareness of our social responsibilities and we look forward to hearing more on this.

As mentioned in a previous commentary, actions such as the “greeting campaign” along with our “po-ke-te-na-shi” system, and following the rules laid out by the health and safety committee, also serve as ways to continually disseminate information throughout the company. Furthermore, through continuous support for the “5s kaizen”, and various types of seminar, mutually beneficial relations can be set up with client companies. For a company that possess an open culture with good communications, this will not be simply a passing fad but will become part of the corporate culture. Also, a good communication leads to improvements in governance and compliance. Continuing with these actions demonstrates a positive attitude towards communication, and is a defining characteristic of NITTOKU. We look forward to further developments. Human Resources policy offers opportunities for employees to improve and grow, and has already had good results. In particular, the DNA (Dynamic New Approach) project gives employees the choice to suggest their own ideas, which may influence the direction of planned projects. For certain this approach encourages employee growth and is another defining characteristic of Nittoku. We very much look forward to hearing more on this.

The level of employment of the physically challenged is below the legally designated standard of 2 per cen. NGK Spark Plug Co, Ltd supports diversity, and through proactive efforts to increase awareness of this issue throughout the company, the figure was increased to 1.9 per cent in the fiscal year 2016. In the fiscal year 2017, a new group was set up to work on resolving this issue. To disclose this information in a written report increases trust in a company. The environmental report contains information pertaining to breaches and complaints, as well as how they are dealt with. We hope to continue receiving reports regarding ongoing issues.

With the recent prominence of SDG on the news, requests for information on the company’s social responsibilities, along with requests for disclosure, have been rapidly increasing. Questionnaires for organizations such as CDP (Carbon Disclosure Project) and DJSI (Dow Jones Sustainability Index) not only request disclosure of data regarding environment and sociability verified by a third-party, but cover many fields, such as water sources and forest sources. Not only the investors, but society itself have concerns about the way a company operates. While Nittoku has signed the UNGC, we hope to see a yet higher level of transparency along with increased accountability.

*This comment renders no judgment on whether the data presented in the report is accurately measured and calculated and is free from omissions, in accordance with standards for the preparation of environmental and other reports generally deemed to be fair and reasonable.

Mr. Tomohiro Tokura Verification Specialist Sustainability Service Division SGS Japan Inc.

2017 Regarding CSR’s Initiatives / In Response to Third-Party Suggestions

Thank you for your valuable advice concerning our initiatives. Since you have consistently been advising us on our initiatives for five years, we appreciate your suggestions as highly motivational.

To our stakeholders, who have high expectations of us, we have compiled the CSR report in line with our desire to “show our company as it is” even more than we did the year before. In addition, we have phrased it in simple vocabulary, and we treat all information as if it were new to the stakeholders, even though it may be obvious to ourselves.

The demands made on companies by our society are increasing year by year. In addition to responding with better results, we will work towards social approval through our business by contributing towards environmental and human rights issues.

We were selected by ESG-oriented investors as having reached their benchmark, and were highly acclaimed for our organization’s level of sustainability by the global investment research institution specializing in SRI. We will continue to make every effort to be a company which meets its customers’ expectations.

Masaya Futamura

General Manager, Risk Management Department, Corporate Strategy Group