Nintendo Co., Ltd.

Modern Slavery Transparency Statement

This statement summarizes the policies of Nintendo (Nintendo Co., Ltd.

(Japan) and its main subsidiaries) and the actions we have taken
during the fiscal year ended March 31, 2024 (FY 2024*) to prevent
modern slavery, including slave labor, forced labor, child labor, prison
labor and human trafficking, in our business and supply chain.

Nintendo is a developer, manufacturer and seller of entertainment

products, based in Kyoto, Japan. Nintendo employs a “fabless”
production model for our main products, including gaming systems and
accessories, meaning we do not own the facilities that manufacture
those products. Thus, we establish policies and guidelines to prevent
modern slavery, and we work with our production partners to ensure
compliance.

1. Nintendo Business Overview

As a global company with the ultimate goal of “Putting Smiles on the Faces of
Everyone It Touches”, Nintendo realizes that consumer trust depends upon our
commitment to conduct business in a socially responsible and legally compliant
manner.

1-1 Policy
Nintendo supports and adheres to international human rights principles and
standards, such as the International Bill of Human Rights and the Guiding
Principles on Business and Human Rights, both from the United Nations, and
the Declaration on Fundamental Principles and Rights at Work, from the
International Labour Organization (ILO). Based on these principles and
standards, Nintendo has established the Nintendo Human Rights Policy. The
Policy was created through consultation with related internal departments and
external specialists. The Policy applies to everyone employed by Nintendo, and
it articulates Nintendo’s commitment to respecting human rights in accordance

Note: Starting with the 2024 statement, all references to fiscal years indicate the
*

year in which they end.

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with our corporate vision and codes of conduct. The Policy also extends to the
Nintendo supply chain, where we continuously engage with our business
partners to help ensure they are conducting socially responsible operations.

In addition, to ensure fulfillment of the Policy, Nintendo has established and

implemented region-specific internal codes of conduct to prevent modern
slavery within our business operations.

At Nintendo Co., Ltd. (Japan), we provide each employee with the Nintendo
Standards of Behavior, which constitute the policy for all actions at Nintendo.
These guidelines include both the Nintendo DNA and the Nintendo Code of
Conduct – basic rules our employees should uphold.

Our subsidiaries have implemented equivalent codes of conduct, which have

been adapted to the laws, regulations, and cultures of their respective countries
or territories, but which all seek to promote and protect the universal standards
of behavior expected by Nintendo.

1-2 Structure and Responsibility

At Nintendo Co., Ltd. (Japan), the Senior Director of the Human Resources
Department ensures that Nintendo employees in Japan receive training about,
and comply with, all relevant laws and regulations, the Nintendo Standards of
Behavior and human rights. Similarly, each of our subsidiaries has appointed a
department or person who is responsible for educating employees to ensure
compliance with laws and regulations, and the respective codes of conduct.

1-3 Due Diligence

When Nintendo hires employees, we take the following measures to reduce the
risk of modern slavery:

- We enter into written employment contracts with all employees.

- We use reputable employment agencies to hire temporary workers.
- We require each employment agency we use to provide the terms on which
workers will be engaged by them, including minimum wages to be paid,
before accepting employees from those agencies.
- We periodically review our terms with employment agencies and require all
agencies to confirm their compliance status with all related laws and

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 regulations.
- We have a procedure employees can use to report any legal violations or
suspected issues, including a violation of the Nintendo Standards of
Behavior or codes of conduct.

1-4 Training
At Nintendo, we conduct the following training to inform employees about
human rights topics.

All employees are notified of the Nintendo Human Rights Policy, which is
included in the codes of conduct and compliance manuals for each country. It is
also introduced to new employees of Nintendo Co., Ltd. (Japan), as part of their
training. Training on human rights is also conducted at our subsidiaries. For
example, at Nintendo of America Inc., employees receive annual training on our
Code of Business Conduct. Nintendo of America Inc. also conducts ongoing
training and education on human rights for employees engaged with our supply
chain and business partners. At Nintendo of Europe SE, all new employees
receive training on the Code of Conduct, which includes sections on protecting
human rights, compliance with the UK Modern Slavery Act and non-
discrimination and equal treatment. Refresher trainings on these subjects are
conducted periodically for all employees of Nintendo of Europe SE. Nintendo
Australia Pty Limited regularly implements training on the Australian Modern
Slavery Act for all employees involved in procurement.

2．Nintendo Supply Chain

Nintendo’s commitment to legal compliance and responsible manufacturing
applies throughout our supply chain. Nintendo requires our production partners
to adhere to our policies and guidelines prohibiting slave labor, forced labor,
child labor, prison labor and human trafficking in sourcing, manufacturing and
labor practices.

2-1 Policy
With our basic procurement policy, Nintendo is committed to complying with
laws, regulations, and social standards, as well as to advancing human rights
and global environmental considerations throughout all of our procurement
activities. We also work with our business partners to gain their understanding
of and cooperation with these policies. To facilitate these efforts, we have

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established the Nintendo CSR Procurement Guidelines and promote CSR
procurement activities. The division in charge of procurement created the
Nintendo CSR Procurement Guidelines (in Japanese, English and Chinese) to
further ensure that we fulfill our social responsibility throughout the supply
chain, with an emphasis on deepening mutual understanding and building trust
with our production partners. These Guidelines, created with the advice of
external specialists, adopt the standards of the Responsible Business Alliance
(RBA). They provide specific guidance based on relevant international laws,
regulations and standards that address topics such as human rights,
sustainability and ethical procurement, including the prohibition of forced labor,
respect for workers’ rights and occupational health and safety. Nintendo places
great importance on respect for human rights and includes this as the first item
in our Guidelines. We prohibit the use of forced labor, child labor, prison labor,
slave labor, human trafficking and other forms of involuntary labor in all parts
of our supply chain.

2-2 Due Diligence

Nintendo carries out supply chain due diligence in order to assess
environmental and human rights risks and work to reduce them. As part of
these efforts, to understand how CSR is being promoted by our production
partners, we ensure their awareness of the Nintendo CSR Procurement
Guidelines, confirm the state of CSR through written surveys, conduct
interviews and on-site visits to understand the current status, and follow up to
make improvements. In addition, in July 2024, Nintendo became a member of
the RBA, an industry alliance dedicated to advancing social responsibility in
global supply chains.

2-2-1 Confirmation by Written Survey

Nintendo conducts a written Business Status Survey and Factory Status Survey
once a year to confirm the level of CSR promotion at our production partners.

In the Business Status Survey, we verify business conditions and other items
such as the following. All first-tier suppliers respond to this survey.

 Compliance of first-tier suppliers with the Nintendo CSR Procurement

Guidelines

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 First-tier suppliers’ confirmation of second-tier supplier compliance with the
Nintendo CSR Procurement Guidelines or equivalent standards

The Factory Status Survey checks the status of CSR procurement of our
production partners at a factory level. The survey includes items related to
human rights, such as whether management and checks are implemented to
prevent forced labor, child labor and discrimination, as well as questions
covering working hours, wages, and health and safety topics including the
protection of pregnant and nursing workers and young workers. We also
confirm that there is an internal reporting mechanism that allows workers to file
complaints.

2-2-2 Interviews and On-site Visits to Understand Current Status

The division in charge of procurement at Nintendo conducts CSR Factory
Verifications of our production partners selected on the basis of their responses
to the Business Status Survey and Factory Status Survey, business criticality,
changes in the business environment and other such factors. To further
enhance the transparency of our CSR procurement, a third-party firm also
carries out audits of our main production partners selected based on the
business relationship status and other factors.

CSR Factory Verifications and third-party audits confirm the actual situation at
production sites with regard to the items covered in the CSR Procurement
Guidelines, such as the respect for human rights, labor contracts, prohibition of
discrimination, child labor and forced labor, compliance with legal wages,
management of working hours, and health and safety of worksites. During a
CSR Factory Verification, we hold video conferences with our production
partners after reviewing answers to a questionnaire provided in advance about
various CSR topics. Following this, as a general principle, we visit the sites
ourselves to confirm the situation directly. By checking the state of production
sites and dormitories, wages, working hours, and various other items via
sampling through the video conferences and on-site visits, we work to fully
understand the actual conditions at each production site.

CSR Factory Verifications go beyond understanding the situation at each site by

creating important opportunities to deepen mutual understanding about CSR
through dialogues with our production partners.

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During third-party audits, auditors review relevant documents and perform a
sampling check to verify wages, working hours and other items. Auditors also
confirm that the human rights of workers are being respected through
interviews with managers and workers employed at the production sites in their
native language and observation of production sites and dormitories.

2-2-3 Follow-Up for Improvement

We share the topics identified by the CSR Factory Verifications and third-party
audits with our production partners and request corrective actions based on the
follow-up guidelines for each item that needs to be improved. The corrective
actions taken are then confirmed by either visiting the site or through a video
conference.

For example, issues indicated by our CSR Factory Verifications and third-party
auditing have included occupational health and safety and labor issues.
Occupational health and safety issues included inadequate emergency and
evacuation exit signs, insufficient emergency lighting and fire extinguishers,
and fire alarm buttons installed in places that are difficult to access. From a
labor perspective, the reviews also noted long overtime. During our on-site
follow-up verifications, we have confirmed improvements that meet our
expectations to the fire extinguishers, emergency lighting and other
installations mentioned above. Also, in addition to checking via the follow-up
verification process, we are continuing to confirm the status of working hours
through other means of communication to ensure that the issue is properly
addressed. The responsible parties in our division in charge of procurement
make the final decision about whether to continue business with a production
partner based on the results of various written surveys, video conferences, CSR
Factory Verifications, and third-party audits carried out as part of our supply
chain due diligence. If serious CSR issues, such as those involving human rights
or the environment, are discovered, we will require that the issue or issues be
addressed, and the responsible parties at Nintendo may make the final decision
to cease business with a production partner if our requirements are not met. In
FY 2024, we did not identify any serious issues through our supply chain due
diligence efforts that would lead to ceasing business with a production partner.

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Nintendo’s Global Corporate Social Responsibility Commitment
Nintendo’s commitment to social responsibility extends beyond the
manufacturing and supply chain process. To find out more about our CSR
efforts, please read the CSR Information section of our corporate website:

Europe/Australia
[Link]

U.S.
[Link]

This Statement was reviewed and approved by the Board of Directors of

Nintendo Co., Ltd. (Japan) at its meeting held on August 30, 2024.

Issued: September 30, 2024

Shuntaro Furukawa
President and Representative Director
Nintendo Co., Ltd.