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Company Response

27 May 2024

Author:
NDK

Nihon Dempa Kogyo response

Regarding report that our products were in weapons used by the Russian military in the

report "CHALLENGES OF EXPORT CONTROLS ENFORCEMENT: How Russia

Continues to Import Components for Its Military Production" published by KSE

Institute on January 11, 2024, we will respond to you below.

Our group conducts business activities based on the founding philosophy of

"Contributing to the prosperity of society and world peace through our service to

customers." In accordance with this philosophy, our group does not permit transactions

to countries or regions subject to sanctions or export controls, including Russia, or

transactions for weapons or military purposes. This is based on our internal policy,

which we have established and operates. Therefore, there is no evidence that the

product was approved for sale to the Russian military. Furthermore, since March 2022,

we have suspended all business activities, including export, sales, and technical support

to Russia, and this policy continues today.

Our group has established and operates an internal management system to ensure

compliance with sanctions and export control laws in each business region, such as

Japan and the United States. We do not permit sales, direct or indirect, to end users

who may have military use. This policy also strongly requests our group's overseas sales

agents to comply with the above policy and cooperate in preventing bypass exports

when selling our products. However, there continues to be concern about the risk of

circumventing sanctions and export regulations against Russia at secondary and

tertiary resale destinations. Therefore, in addition to complying with laws and

regulations, we plan to further strengthen these efforts in the future.

Timeline