TRANSPARENCY

Transparency Policy on the Relationship between Corporate Activities and Medical Institutions

NSK has established the “Transparency Policy on the Relationship between Corporate Activities and Medical Institutions” as one of our corporate policies to disclose information on funds which are associated with our corporate activities and provided to medical institutions and medical personnel.

1）Background of the Policy

As a member company of the Japan Federation of Medical Devices Associations (JFMDA), the Company has complied with the “Code of Ethics,” the “Charter of Business Behavior,” and the “Promotion Code of the Medical Device Industry” set by JFMDA, as well as the regulations and spirit stated in the “Fair Competition Code of the Medical Devices Industry in Japan” set by the Japan Fair Trade Council of the Medical Devices Industry. Furthermore, keeping our motto since the foundation, which is to create products in a “robust, delicate, appropriate and affordable” manner, as our corporate philosophy, and in accordance with our internal regulations and employee behavior policies, we have carried out corporate activities that maintain high ethical standards.

In light of the above, with the goal of achieving a broad understanding of how we contribute to the development of the life sciences, including medicine and medical engineering, and promote corporate activities that ensure a higher standard of ethics, in compliance with the JFMDA’s “Transparency Guidelines for the Medical Device Industry and its Relationships with Medical Institutions and Other Organizations,” NSK publishes information about our corporate activities related to medical institutions and medical personnel.

2）Method of disclosure: The related information for FY2013 and subsequent years shall be disclosed at an appropriate and available time in the following fiscal year.

3）Timing of disclosure: The related information for FY2013 and subsequent years shall be disclosed at an appropriate and available time in the following fiscal year.

4）Target of disclosure

The contents of the information to be disclosed by the Company related to funds provided to medical institutions and other organizations shall be as specified in the “Transparency Guideline for the Relationship between Corporate Activities and Medical Institutions.”

A.Research and development expenses, etc.

Item	Disclosed content
Joint research expenses	Total annual amount
Commissioned research expenses	Total annual amount
Clinical trial expenses	Total annual amount
Post-marketing clinical trial expenses	Total annual amount
Failure/Infection case reporting expenses	Total annual amount
Post-marketing surveillance expenses	Total annual amount

B.Academic research grants

These include scholarship and general donations for the purpose of academic promotion and research grants in the field of clinical technologies, as well as donations to academic societies and other organizations to support the holding of meetings and expenses for co-sponsoring academic conferences.

Item	Disclosed content
Scholarship endowment	XX Department of XX University: XX cases, XX yen
General donations	XX University (XX Foundation): XX cases, XX yen
Donations to academic society	The XXth XX Academic Conference (XX Regional Meeting, XX Research Meeting): XX yen
Expenses for co-sponsoring academic conference	The XXth XX Academic Society Meeting XX Seminar: XX yen

C.Manuscript writing fees, etc.

These include fees paid for outsourcing services such as lectures, manuscript writing, and other consulting services to provide information on the proper use of the company’s medical devices.

Item	Disclosed content
Lecture gratuities	Total annual amount. The payee’s name, affiliation and title shall be specified individually.
Manuscript writing fees/supervision fees	Total annual amount. The payee’s name, affiliation and title shall be specified individually.
Consulting and other outsourcing fees	Total annual amount. The payee’s name, affiliation and title shall be specified individually.

D.Information provision-related expenses

Expenses of lectures and briefing sessions, etc. necessary for providing scientific information of the company’s medical devices to medical professionals shall be disclosed with the annual number of cases and total annual amount of each item below.

Item	Disclosed content
Lecture fees	Annual number of cases and total annual amount
Briefing fees	Annual number of cases and total annual amount
Medical/medical engineering literature provision expenses	Annual number of cases and total annual amount

E.Other expenses

These include the cost of hospitality and other expenses as a social ritual.

Item	Disclosed content
Hospitality Expenses	Total annual amount

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