1. Compliance with Laws

NH Foods Group will accurately understand applicable tax regulations in each countries, and make appropriate tax returns and payments in accordance with the regulations.

We will not use tax havens for the purpose of tax avoidance by way of business, etc. without legitimate business purpose or substance.

2. Tax Governance

Tax treatments of respective companies within the NH Foods Group will be done by the respective companies themselves. The Accounting & Finance Department of NH Foods, Inc., which has specialized knowledge, will strive to ensure that respective companies make appropriate tax returns, by reviewing relevant details of tax treatments as appropriate, determining the appropriateness and requesting to correct them as necessary.

Further, in order to improve our knowledge on tax treatments and to raise more awareness of tax compliance, we will carry out group trainings and information sharing as necessary for management personnel and those who work for preparing financial statements of respective companies within the NH Foods Group.

In preparing tax returns and tax payments, respective companies within the NH Foods Group will confirm the details of the tax returns using a checklist regarding tax treatments. Then, the Presidents of respective companies within the NH Foods Group and the respective directors/officers of NH Foods, Inc. who are in charge will make a final confirmation and report to the Accounting & Finance Department of NH Foods, Inc.

In addition, the Accounting & Finance Department of NH Foods, Inc. will periodically implement the on-site monitoring and confirm the status of tax treatments of respective companies within the NH Foods Group.

The details of these efforts will be reported to and shared with the director(s)/officer(s) in charge of the Accounting & Finance Department of NH Foods, Inc.

3. Minimization of Tax Risks

NH Foods Group will accurately understand tax regulations in each region and aim to minimize tax risks. If a transaction for which tax interpretation is unclear occurs, we will attempt to mitigate the uncertainty by carefully examining the reasonableness of the relevant tax treatments, and obtaining expert advice from professionals as necessary.

4. Transfer Pricing

For international transactions within the NH Foods Group, we will make an appropriate profit allocation considering arm’s length prices in compliance with the OECD Transfer Pricing Guidelines and tax regulations of respective countries.

Furthermore, we will fulfill our obligations to organize transfer pricing documentation in accordance with regulations on transfer pricing taxation in respective countries.

5. Relationships with Taxing Authorities

NH Foods Group shall maintain appropriate and cooperative relationships with tax authorities of each region in which we conduct business. And we will also inquire with relevant tax authorities in relevant regions for any unclear treatments as necessary and deal with them properly.

We will also respond to inquiries from tax authorities in good faith and strive to establish mutual trust with them.

6. Response to the Changes of Tax Environment

If there is a change of applicable tax regulations due to a change of our business activities, NH Foods Group will analyze the details of the changes appropriately and make a proper tax treatment. Further, we will strive to gather information and analyze the details of changes of tax regulations in each region as well, and make a proper tax treatments.

If there is a significant change to the tax environment, this tax policy will be reviewed as necessary to ensure that it leads to proper tax treatments at that time.

7. Ensuring Transparency

NH Foods Group will strive to ensure its transparency by disclosing this tax policy.

Established on June 10, 2020