The Nomura Group Code of Conduct serves as a guide for all employees to translate into actions the core values of entrepreneurial leadership, teamwork and integrity outlined in our Group Corporate Philosophy.

The Code represents our commitment to our clients and all stakeholders to adhere to the highest standards of ethics and integrity in our business activities.

Aiming to promote desirable conduct across the firm and reduce risks arising from inappropriate conduct, the Nomura Group Conduct Committee is the core in embedding the Code of Conduct and discussing on compliance and conduct risk management. The committee formulates conduct annual plans including initiatives as detailed below and deliberates on the revision of the Code. Progress on the annual plan is reported to the Executive Management Board and Board of Directors meetings, and revisions of the Code to the Board respectively. Regions, divisions and entities also formulate their own annual plans under the responsibility of relevant heads and implement measures to carry out their plans. We also manage risks by limiting inappropriate conduct through regulations and monitoring. To ensure effectiveness, we use the PDCA cycle to identify conduct that could adversely impact our clients and/or the market, assess risks, implement preventive measures, conduct monitoring, identify problems, and plan subsequent actions.

Employees' contributions to these efforts are reflected in their performance reviews, thereby providing additional motivation for them to be proactively involved.

Our business is built on the trust of our clients and all stakeholders. We regularly review our Code of Conduct to ensure it aligns with the expectations of society.

We are implementing various initiatives to ensure that our people clearly understand and abide by the Code of Conduct, and to foster the correct culture in the firm.

• Training for new hires, trainings by title and by themes
• Promotion of Nomura 5 YES and Code of Conduct apps on corporate mobile devices
• Intranet site to promote good conduct
• Entries and listing of outstanding conduct slogans

Generally provided in Japanese and English

All employees are responsible for reporting any suspected violations of laws and regulations, violations of the Nomura Group Code of Conduct, or suspicious accounting or auditing activities. Nomura Group companies in Japan and overseas have internal reporting systems (hotlines). We ensure our Group compliance system is effective by regularly reporting the status of its operations to the person responsible designated by the Board of Directors of Nomura Holdings. We are also working to raise awareness and promote the use of hotlines internally, and foster an organizational culture in which anyone can raise their voice when they feel something is wrong.