Anti- Slavery and Human Trafficking Statement for FY2025

This document is a statement by Noritsu Koki Co., Ltd. disclosing its commitment
to preventing forced labor and human trafficking in the Group’s operations and
supply chain in accordance with Section 54 of the UK Modern Slavery Act 2015.

1. About the Noritsu Koki Group

Structure and Business Overview

The Noritsu Koki Group (the “Group”) has 15 consolidated companies and 1,344 employees (as of December 31, 2025), mainly in the parts/materials business and the audio equipment/peripherals, which both utilize globally advanced technologies. This statement is issued by Noritsu Koki Co., Ltd. (the “Company”) on behalf of its consolidated company AlphaTheta EMEA Limited (European subsidiary of AlphaTheta Corporation, one of the core companies of the Group) which is a reporting entity under the UK Modern Slavery Act 2015 (the Act).

For more information about the business of our Group, please visit our website.

Supply Chain

This statement describes the supply chain of products supplied by the Group. Products supplied by the Group are manufactured at plants operated by consolidated subsidiaries and at plants operated by contract manufacturers (EMS providers, ODMs). AlphaTheta EMEA Limited imports and sells DJ, music production and audio equipment to individual and corporate customers in Europe, including the UK. This equipment is made in contract manufacturing plants located primarily in China and Southeast Asia. The Group has established long-term collaborative relationships with these contract manufacturing plants, which are required to comply with the Noritsu Koki Group Procurement Policy.

Corporate Philosophy

In its corporate philosophy, the Company’s mission is “Prosperity for society and people” and its vision is to be “A corporate group that continues producing ‘No. 1/Only 1’ businesses.” The Company aims to realize this mission and vision by implementing its values – “Understand the needs of the age and think one step ahead,” “Pursue products and services that enrich lives,” and “Respect the potential for growth and innovation and support a spirit of challenge.”

2. Policies Related to Preventing Slavery and Human Trafficking

Noritsu Koki Group Human Rights Policy

In July 2022, the Group disclosed the Noritsu Koki Group Human Rights Policy (revised in Nov 2023), which was approved by the Board of Directors. The policy is based on international human rights standards, including the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and its follow-up, the Guiding Principles on Business and Human Rights, and the Children’s Rights and Business Principles. This Policy states that the Group will not tolerate any form of slavery and human trafficking and expects all of the Group board members, employees as well as its suppliers and other business partners to comply with the Policy. To fulfill its responsibility to respect human rights, the Group is committed to developing and continuously implementing a framework of human rights due diligence to avoid causing or fomenting negative human rights impacts in its value chain.

Noritsu Koki Group Code of Conduct

The Group has established the Noritsu Koki Group Code of Conduct to clarify its basic management approach and expected standards of conduct for corporate executives and employees. The Code of Conduct is based on the basic policy of compliance with all applicable laws and regulations in each country and region where the Group operates, and consists of the following six items: (1) Legal Compliance, (2) Social Contribution, (3) Working Environment, (4) Information Management, (5) Ethical Behavior, and (6) Delivering Safe and High-Quality Products and Services.

Noritsu Koki Group Procurement Policy

The Group has established the Noritsu Koki Group Procurement Policy, which clearly states its commitment to promoting sustainable procurement including consideration for human rights and the environment, as well as legal compliance. With the aim of further propelling its procurement activities based on the policy, the Group established the Noritsu Koki Group Procurement Guidelines which stipulate specific standards and approaches of behavior the Group expects its business partners to comply with and apply to their business operations. In establishing these guidelines, the Group has referred to the Code of Conduct of Responsible Business Alliance (RBA) and the Responsible Business Conduct Guidelines of Japan Electronics and Information Technology Industries Association (JEITA). The guidelines consist of eight sections: Labor, Health and Safety, Environment, Ethics, Quality and Safety, Information Management, Business Continuity Plan, and Management System. AlphaTheta EMEA Limited, a reporting entity under the Act has established an AntiSlavery and Human Trafficking Policy which states that AlphaTheta EMEA Limited will not tolerate any form of slavery and human trafficking and expects all of its business partners who works for, or on behalf of, AlphaTheta EMEA Limited anywhere in the world to adhere to the same standards and report any concerns to AlphaTheta EMEA Limited.

3. Efforts to Prevent Slavery and Human Trafficking

Human Rights Due Diligence

Since 2023, we have conducted human rights due diligence at the Groupwide level to ensure efforts to respect human rights are effective, in line with the Noritsu Koki Group Human Rights Policy. Human rights due diligence is the responsibility of the Sustainability Promotion Office of Noritsu Koki, which implements initiatives in collaboration with the Personnel & General Affairs Department and the procurement departments of Group companies. In 2025, we conducted further investigation on the prioritized risks (risks with high severity and relevance to the Group’s business) based on the human rights risk map and implemented necessary measures. The human rights risk map was created in 2023, as the first phase of human rights due diligence assessing human rights risks related to the Group’s businesses.This year, we also conducted human rights risk assessments at our additional sites; identified areas of concern, and implemented necessary measures to address them.

Risk Assessment and Monitoring

To respect human rights and eliminate slavery and human trafficking from the Group’s entire supply chain, we believe the business partners must also share our values and policies on respect for human rights. In 2025, with the aim of further propelling our procurement activities based on the policy, we publicly launched the Noritsu Koki Group Procurement Guidelines which set clear expectations of our business partners to mitigate ethical, environmental, labor and human rights risks including instances of slavery and human trafficking. Following the publication of these guidelines, we communicated them to our business partners as well as requested them to complete the self-assessment questionnaire (hereinafter referred to as SAQ) to confirm their compliance status and identify risks. We have worked with an independent third-party organization in evaluating results of the SAQ as well as conducting open-source research, and in consulting measures for risks or issues identified. Additionally, for our new business partners, we have established a system to communicate the guidelines and obtain commitments from them, as well as to confirm their compliance status using the SAQ, as part of the due diligence process before starting transactions. We also continue to conduct supply chain audits of contract manufacturers through its quality audit mechanism, which overlaps with some areas of the Group Procurement Policy and the Guidelines.

Effectiveness of Actions

As noted above, the Group conducts risk assessments, raises awareness of policies and the guidelines among its business partners and carries out quality audits of contract manufacturers annually. By monitoring the number and results of audits, we verify the effectiveness of measures to prevent human rights violations. Our efforts to address sustainability issues, including human rights issues such as slavery and human trafficking, are reported annually to the Sustainability Promotion Committee and the Board of Directors.

Education and Training

In 2022, we formulated and published the Noritsu Koki Group Human Rights Policy (revised in Nov 2023) and conducted human rights training for all the Group’s executives and employees to raise awareness of the policy and embed it across the organization. In 2025, we carried out human rights training for all corporate executives and employees to raise their awareness of the policy. Additionally, we invited human rights specialist and held a seminar on “Business and Human Rights.” It was held in a hybrid style combining in-person and online participation, and it helped deepening the understanding of human rights among our executives and employees. Human rights training will be conducted annually for all corporate executives and employees. AlphaTheta EMEA Limited has also invested in educating staff to recognize the risks of modern slavery and human trafficking through mandatory training and staff are encouraged to identify and report any potential breaches of the AlphaTheta EMEA Limited Anti-Slavery and Human Trafficking Policy.

Remediation

The Group operates an internal reporting system covering the entire Group to rapidly detect and prevent risks and issues in corporate activities. Each Group company also operates its own whistleblowing hotline that accepts reports on actions that violate, or could potentially violate, the Noritsu Koki Group Code of Conduct, including legal violations, human rights issues and corruption. In 2025, the Group established and started operating a grievance hotline available for its external stakeholders, including workers of its business partners, local residents of its business locations, etc. who are or may be negatively affected (e.g., actual or suspected violations of the procurement guidelines such as violations of laws and regulations, human rights violations) by its business operations and supply chain. The grievance hotline ensures legitimate and equitable response by accepting reports regarding the negative impacts of our business operations and supply chain through a third-party law firm. After receiving a report, we will promptly investigate the case and work to remedy any violations of the Noritsu Koki Group Procurement Guidelines (this includes requesting our business partner for the corrective action).

4. Looking Forward

“Creating inclusive workplaces where diversity is respected and all employees can thrive and contribute with a future-oriented mindset” is one of the Group’s materiality issues. As a specific measure focused on respect for human rights, the Group is “respecting diversity and promoting more flexible ways of working.” In 2026, we will continue our efforts to raise human rights awareness across the organization and implement human rights training to cultivate an open corporate culture that respects diverse values and prevents human rights violations, including slavery and human trafficking. Additionally, we will work to make sure that the Noritsu Koki Group Procurement Guidelines are communicated to and agreed by our new business partners and conduct risk assessments using the SAQ before starting businesses. At the same time, for our existing business partners, we will confirm their compliance status using the SAQ and other means on a regular basis. If issues are identified, we will request the relevant business partner take corrective action to address the issue. Through these efforts, we are confident in our ability to identify and address any human rights risks within our supply chains, including slavery and human trafficking, and to implement appropriate measures to prevent, mitigate and eliminate such practices.

This statement was approved by a director delegated by the Company Board of Directors.

Representative Director and CEO-2025
March 2026
Representative Director and CEO
Ryukichi Iwakiri