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Third Party Opinion for Minebea Group CSR Report 2010

Senior Vice President Head of Corporate Social Responsibility Promotion Office Research and Design Department, Development Bank of Japan Inc. Keisuke Takegahara

Reading the Minebea Group's CSR Report

Your group's CSR Report is characterized by well-organized basic policies and extensive content. The "Five Principles" management policy, well established within the company, serves as the underlying foundation, and projects developed based on Minebea's CSR policies, code of conduct, and environmental policies are very clear and persuasive, not only to your employees but also to outside parties. The report is also easy to understand because the basic ideas are outlined by topic and discussed individually.

Each of your initiatives also shows an approach characteristic of your company's in many ways. In particular, the detailed grasp of materials flow, including at overseas locations, disclosure of CO2 and waste matter data, and the perspective on logistical measures, are typical of your company, which developed a global presence early on. I found it very interesting to read detailed examples of activities based on your idea of coexistence with global society by introducing the most advanced environmental technologies, such as erecting a cutting-edge energy-saving plant in Thailand and creating a closed waste water processing system in China.

On the other hand, among the weak points of your CSR Report is the lack of a strong scenario depicting how you will make your vision and policies a reality over the medium to long term. Since the report presents no medium- or long-term goals for CSR-based management, it is somewhat difficult to see the connection between your policies and individual initiatives. Given that each of your initiatives is excellent, this is regrettable. The lack of consistency, with references to both Minebea and the Minebea Group, in the report, also strengthens this impression. Compared to the Minebea Group Environmental Report up to last year, which described relatively clear directions in terms of medium- to long-term outlooks and the individual initiatives taken to work toward them, I assume that this is a temporary issue arising in the wake of the major shift to your CSR Report this year.

It is said that the true essence of CSR lies in each company committing itself at a level above and beyond compliance in the conduct of its mainstay business. Given that there are no uniform answers to the issues, many companies are very creative in establishing commitments. In this respect, as explained in President Kainuma's Top Commitment message, Minebea has a tradition of having been a pioneer in globalizing operations, and when establishing operations overseas, management has been based on your company's own independent standards surpassing locally specified regulations. The "manufacturing with sincerity" cultivated so far no doubt incorporates extensive experience and know-how in discussing CSR.

Your switch from a principally environment-centered report to a CSR report makes it likely that this type of tacit knowledge will be explained in concrete form from now on. For example, comments from locally hired senior management, and existing conditions with regard to measures (CSR procurement) concerning your supply chain and attention to biodiversity as part of that process, are topics that will attract the attention of many stakeholders, and it is not difficult to imagine that the company already has plentiful material for such reports. I eagerly look forward to the development of your CSR Report in the future.

(END)

Keisuke Takegahara

After graduation from the Faculty of Law, Hitotsubashi University, Mr. Takegahara joined the Japan Development Bank (now the Development Bank of Japan, Inc.). He holds his present post after residing in Germany Representative Office and posts within the bank's Research Department and Policy Planning Department and as section head of the Office for Corporate Social Responsibility of the Department for Public Sector Solutions. Mr. Takegahara is also a member of several councils, including the Expert Committee for a Virtuous Circle for Environment and Economy of the General Policy Subcommittee of the Central Environment Council, and the Japanese Ministry of the Environment's Deliberative Committee on Target Industries and Services in the Survey on Environment Business Market Size and Employment Size.

On Receiving a Third Party Opinion

Hidenori Kobayashi
General Manager
CSR Promotion Office
CSR Promotion Division

Thank you very much for your valuable comments.

We first issued the Minebea Group Environmental Report in fiscal 2003 and with the Minebea Group CSR Report we have adopted a new, improved format which consists of a management report and a social report in addition to an environmental report.

For this reason, as you pointed out, our management and social reports mainly describe and report current conditions and are inadequate as far as reporting on medium- and long-term goals is concerned. As for our environmental report, we have obtained ISO14001 certification for almost all of our manufacturing plants, and this report also mainly details the goals set and improvements made in accordance with the ISO management system. However, the report is not as thorough as it could be, from the viewpoint of the Group as a whole. This is also why our CSR Report contains references to both "Minebea" and "the Minebea Group".

Where our CSR promotion activities are concerned, following adoption this fiscal year of our Minebea Group CSR Basic Policy and the Minebea Group's CSR Implementation Principles, we will take your comments to heart for the next and subsequent business terms. Bearing in mind that, as you say, "the true essence of CSR lies in each company committing itself at a level above and beyond compliance", we will continue refining the Minebea Group's CSR by setting medium- and long-term objectives for various areas, including the environment, and by promoting CSR activities through application of the PDCA cycle.

We will also take steps to ensure that our CSR Report is easy to read and easy to understand, so that it can be helpful to all stakeholders in learning more about Minebea.

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