Nomura Trading Group Basic Policy on Prevention of Bribery to Foreign Public Officials

Nomura Trading Co., Ltd. (hereinafter “we,” “our,” or “us”) hereby establishes and widely inform internally and externally of the Basic Policy on Prevention of Bribery to Foreign Public Officials (hereinafter this “Policy”) in order for the Nomura Trading Group^※1 including us to comply with the laws, regulations, and commercial practices in the countries where it carries out business activities and to fulfill its social responsibility as a global enterprise.

1. Scope

This policy applies to all executives and employees of the Group, including dispatched and seconded employees from other companies, and resident staff from subcontractors.
The Group also expects all our business partners, including suppliers, to support and comply with this policy.

2. Legal compliance

The Group does not commit any act of bribery that constitutes a crime of offering a bribe in any country where it carries out business activities or a crime of offering a bribe to a foreign public official under the Unfair Competition Prevention Act.

3. Responses to small facilitation payments (SFPs)^※2

(1) In principle, the Group does not make SFPs, concerning the possibility that SFPs encourage or help continue corrupt acts in each country.
※2 SFPs mean small-amount payments for smooth processing of normal administrative services.
(2) The Group will comply with the separately-provided detailed rules when it exceptionally makes one or more SFPs.

4. Mechanism to respond to concerns

As part of its internal reporting system, the Group has contact points to which its executives and employees can report concerns related to the prevention of bribery to foreign public officials. In each report, confidentiality and protection of personal information are ensured and the reporter is not disadvantageously treated for making the report.

5. Education and awareness-raising activities

The Group continuously provides appropriate education and training to our executives and employees to ensure that this policy is understood and effectively implemented.

6. Governance, audit, etc.

(1) The director in charge of our Risk Management Department is responsible for the implementation of this Policy in the Group. The director also makes proposals for establishing and revising detailed rules of this Policy to the extent necessary for this Policy.
(2) Our Internal Auditing Department continuously audits to check whether proper prevention of bribery to foreign public officials in compliance with this Policy is practiced.

7. Revision

This Policy is resolved by and revised as necessary by our Board of Directors. Each company of the Group follows our resolutions and revisions.

※1 The Group (or the Nomura Trading Group) means us and our consolidated subsidiary companies.

October 25, 2024
Hideaki Fujiwara, Representative Director
Nomura Trading Co., Ltd.