Group Code of Conduct

The Group hereby sets forth “Group Code of Conduct” to signify the basic rules to be observed by all of its officers and employees in all activities they engage in toward realizing the Group’s Corporate Philosophy.

1. We Shall Comply with Laws and Regulations, and Act in a Responsible Manner in Line with the Social Norms

   (1) Compliance with Laws and Regulations

   －We shall comply with all laws and regulations applicable in the countries and regions in which we operate, international norms and internal rules, and shall act in a responsible manner in accordance with the social norms.

   (2) Prohibition of Any Involvement with Antisocial Forces

   －We shall have absolutely no relationship with any antisocial forces (all crime organizations, groups, and individuals).
   If we receive unreasonable demands from antisocial forces, we shall take a resolute attitude as an organization and provide no favors whatsoever to them.

2. We Shall Strive for Environmental Conservation and Seek Harmonious Coexistence with Society and Local Communities

   (1) Environmental Conservation

   －We shall continually seek to mitigate environmental load and strive for environmental conservation in order to contribute to realizing a sustainable society, guided by the concept of “minimum impact” to keep all impacts on the natural environment to the minimum at each stage from the procurement of raw materials to the manufacture of end products.

   (2) Harmonious Coexistence with Society and Local Communities

   －We shall seek harmonious coexistence with society and local communities through communication with local communities and social contribution activities.

3. We Shall Respect Human Rights and Strive to Secure a Safe, Hygienic and　Pleasant Workplace Environment

   (1) Appreciation of Diversity

   －We shall respect cultures, religions, and customs of countries and regions in which we operate, and shall strive to act by appreciating diversity in values.

   (2) Respect for Human Rights and Prohibition of Harassment

   －We shall respect human rights and shall refrain from any violation there of including, but not limited to, discrimination against anyone on the basis of race, color, creed, religion, gender, national origin, age, disability or other factors, forced labor and child labor. And we shall prohibit any kind of harassment.

   (3) Safety and Hygiene of Workplace

   －We shall give the highest priority to safety. We shall comply with laws and regulations as well as internal rules concerning labor safety and hygiene in order to prevent accidents and workplace injuries and shall also strive to secure a safe, hygienic and pleasant workplace environment.

4. We Shall Conduct Business with Integrity and Fairness

   (1) Safety of Products and Services

   －We shall build up the relationship of trust with our customers by providing products and services with excellent quality and safety.

   (2) Fair Advertising Activities

   －We shall not engage in false, misleading or defamation advertising.

   (3) Fair Competition

   －We shall comply with all laws and regulations concerning fair competition and transactions applicable in the countries and regions in which we conduct business and internal rules, and we shall never engage in any misconduct that stifles fair competition, such as bid-rigging and cartels.
   We shall not unilaterally change the terms and conditions of transactions by taking advantage of a superior bargaining position.

   (4) Prohibition of Bribery

   －We shall comply with laws and regulations and internal rules,etc., concerning the prevention of bribery, and shall not take any action that may be taken as bribery to government officials or those in positions equivalent to them.

   －We shall comply with relevant laws and regulations and internal rules regarding entertainment and gifts to officers and employees of customers and business partners, shall provide them to the extent deemed adequate by conventional wisdom, and shall not receive excessive entertainment or gifts beyond the scope of social courtesies.

   －We shall not engage in acts of providing favors to specific customers and business partners and in return receiving entertainment or gifts from them.

   (5) Stance toward Political Contributions and Donations

   －We shall maintain sound and fair relations with political office, administrative agency and related parties, including business partners, and we shall make political contributions and donations in an appropriate manner after thoroughly considering their necessity and propriety.

   (6) Timely and Appropriate Disclosure of Information

   －We shall disclose corporate information, including the Group’s management policy and financial information in a timely and appropriate manner in order to enhance management transparency and fulfill accountability to society.

   (7) Proper Accounting

   －We shall perform proper accounting in order to ensure the accuracy and credibility of financial information and accounting.

   (8) Prohibition of Insider Trading

   －We shall not sell or buy shares (insider trading) by taking advantage of undisclosed information that could give material influence on share prices (insider information). We shall not engage in acts that may induce insider trading by any third party, such as provision of information that may become insider information.

5. We Shall Appropriately Manage Corporate Assets and Information

   (1) Timely and Accurate Recording and Reporting of Information

   －We shall manage all business records and reports, including but not limited to accounting books and other financial records in a timely and accurate manner, and shall refrain from preparing or reporting false or misleading records.

   (2) Strict Management of Information

   －We shall strictly manage confidential information (including confidential information obtained from outside) without leaking, shall not disclose it without going through internal rules and other procedures, and shall refrain from making unauthorized or unfair use of it not only while employed but also after retirement.

   (3) Protection of Personal Information

   －We shall respect privacy of officers and employees of customers and business partners as well as of officers and employees of the Group, and shall handle the collection, utilization, provision, storage and disposal of personal information with the greatest care not to leak it.

   (4) Respect for Intellectual Property

   －We shall strive to appropriately utilize and secure our intellectual property rights, and shall respect intellectual property rights of others.

   －We shall not obtain trade secrets of others by fraudulent or unlawful means. We shall not make use of trade secrets of others that were obtained or suspected to have been obtained by fraudulent or unlawful means.

   (5) Protection of Corporate Assets

   －We shall efficiently utilize and protect our tangible and intangible assets and shall refrain from actions that prejudice their value by unauthorized use or private use.

   (6) Personal Conflicts of Interest

   －We shall refrain from acts that may bring loss to us for personal gains, including the use of our assets or expenses for personal purposes and the unauthorized use of the internal information system.