In this Group, September of each year has been designated a compliance strengthening month in which comprehensive compliance checkups are promoted with the goal of getting the officers and staff, etc. to take the initiative in reviewing their conduct and work processes. As one of the activities, we have established "Compliance Day," a town hall meeting where the Chief Compliance Officer delivers his/her opinions on compliance and lawyers provide compliance training, which is broadcast live to the company and Group companies.
In addition, we are reaffirming the commitment of each staff/employee to the NYK Code of Conduct and conducting a compliance awareness survey. The results of the awareness survey are submitted back to the company to further raise compliance awareness.
We have confirmed that 2,108 of our officers and staff (including individuals dispatched or sent from other companies) have pledged to follow the 2023 NYK Code of Conduct, and have received pledge responses from 100% of them. The 2023 Compliance Awareness Survey was administered to 2,107 respondents for a response rate of 92.26%.

We continuously provide various types of compliance education and training to ensure that all employees, including those at Group companies, are further aware of compliance and are familiarized with the knowledge and information necessary to practice compliance.
In 2023, we continued to provide compliance training based on our Code of Conduct as part of ESG training for newly hired employees of our company and our Group companies. We also provide detailed education and training by employee level, such as training in competition law/antitrust law, anti-bribery law, economic sanctions, and compliance when employees are posted overseas, and management training in directors' duties and responsibilities and compliance when employees are transferred to Group companies.
In September of each year, which is Compliance Strengthening Month, the company conducts compliance training for all employees of the company and its domestic Group companies in a hybrid face-to-face and online format to promote compliance awareness throughout the Group. We are also expanding our education and training opportunities by introducing new workshop-style training programs that incorporate an interactive format.
For our executives and managements, we provide training aimed at preventing the recurrence of corporate misconduct, using past cases as teaching materials. This training is a future-oriented Institutional Memory training program that compiles past cases as organizational knowledge and utilizes it as organizational learning for future management, with the aim of learning for the future.
We are also strengthening our training programs for specific high-risk business departments, including individualized competition law/antitrust law training and anti-bribery training for ship operators.
For overseas Group companies, we provide ongoing education and training programs, led by local attorneys, on competition law/antitrust law, anti-bribery law, economic sanctions, compliance training, and other topics based on regional characteristics. In 2023, 2,027 employees underwent training in 23 countries.
In addition, we offer e-learning programs for domestic and overseas Group companies. The program is offered in Japanese, English, and Chinese languages on the themes of competition law/antitrust law, anti-bribery law, economic sanctions, and compliance, with 8,415 participants in 2023 for a target audience participation rate of 95.8%.

The Group companies (Japan) provide several consultation services for employees to discuss concerns about or report workplace misconduct, harassment, and non-compliance. Such services include the Yusen Chat Room which allows employees to contact external lawyers, and internal hotline, harassment-related consultation desk, and a consultation desk which is operated by outside contractors. The Yusen Chat Room is available to employees of roughly 66 Group companies in Japan and provides access to six personnel, including an external lawyer, who are available to listen to a wide range of compliance matters and provide consultation and facilitate whistleblowing on said matters.
The Japan Helpline is available to employees, etc.* of the NYK Group, as well as staff and retired employees (within one year of retirement).
Every effort is made by the department conducting the investigation of the company to ensure personnel contacting the Whistleblower Consultation Desk suffer no adverse treatment and, if desired, the identity of the person contacting the service is kept completely confidential, based on the objective that the information provided will help improve the work environment.

• *Employees, etc.: Employees (including fixed-term employees, seconded employees, employees converted to permanent employment, and temporary dispatched employees) and persons directly or indirectly engaged in the execution of their duties at each business location (including persons indirectly engaged in the execution of their duties based on outsourcing or contracting agreements)

At overseas Group companies, regional management offices in each region have established whistleblower desks operated by outside vendors, which are available to employees, etc. of overseas Group companies.

The dedicated desk for competition law and anti-bribery laws accepts reports and provides consultation on antitrust and other competition law and bribery matters. It is available to employees, staff, and retirees (within one year of retirement) of the Company and its domestic and overseas Group companies.

(3) Standard processing time (excluding Saturdays, Sundays and national holidays) Average number of days from the date of receipt of the report by the Whistleblower Consultation Desk until the completion of the investigation and feedback of the results to the informant: 80 days.
Since the processing time varies depending on the nature of the report and the busyness of the department handling the investigation, actual cases may be completed in a few days or may take more than a year.

Since September 2012, the NYK Group had been under investigation by several competition authorities for alleged violations of antitrust laws (including overseas ones) in connection with the shipping of automobiles and other cargo.
Furthermore, the Company and certain overseas Group companies are also subject to class action damage compensation suits in multiple regions. Taking this situation seriously, we are building a system and promoting activities to reemphasize compliance with the antitrust laws to raise the awareness of each and every executive officer and employee* in the Group.

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

In April 2016, the NYK Group established an anti-bribery system for foreign public officials. In this system, When the launch of a new business in a high-risk country is being considered, in addition to screening partner and agency candidates for bribery-related problems, the legal departments confirm relevant matters and provide suggestions regarding incorporation of clauses related to the prohibition of bribery when concluding contracts.