Compliance

Standards of Behavior for Compliance

Basic Compliance Policies

• We will comply with laws, ordinances and regulations, and conduct transparent and fair corporate activities with a high standard of ethics.
• We will respect fundamental human rights and diversity and create workplace environments free from harassment or discrimination.
• We will maintain the quality and safety of our products and services and serve our customers appropriately.
• We will aim to realize a sustainable society and proactively address environmental problems through our business activities.

1.Quality and Safety of Products

• We will comply with all relevant laws, ordinances, regulations and in-house rules applicable to the quality and safety of our products.
• We will implement sufficient production control and quality control throughout all production processes, including those at producers to whom we outsource production.
• When any problem arises with respect to the quality of any of our products, we will promptly take remedial measures, such as recalling such products, with priority given to the prevention of any health hazards.

2.Export and Import and Security Export Control

• When we export or import any products or technologies, we will do so appropriately by complying with all applicable laws, ordinances, regulations, rules and procedures of the relevant country or region.
• When we export any products or technologies, we will comply with all applicable laws, ordinances, regulations, in-house rules and procedures relating to security export control and verify without fail that such products or technologies to be exported will never be used for any purpose obstructing the maintenance of international security.

3.Supply Chain

• We will require our business partners involved in the flow of our supply chain to comply with the various applicable laws, ordinances, regulations, and guidelines.
• We will select business partners capable of appropriately and stably supplying highly reliable products or services.

4.Environmental Preservation

• We will comply with all applicable laws, ordinances, regulations and in-house rules relating to the environment and conduct business activities that take into consideration the impact on the global environment, the environments of local communities, biodiversity, etc.
• We will work to reduce greenhouse gas emissions after voluntarily setting our own targets.
• We will strive to make sustainable and efficient use of resources, energy and materials and to reduce our environmental impact by appropriately disposing of waste.
• We will aim to provide products and services that contribute to a low-carbon society and recycling-based society.

5.Sales, Marketing and Information Transmission Activities

• In conducting our sales, marketing and information transmission activities, we will implement fair business activities in compliance with relevant laws, ordinances and regulations and our corporate ethics.

6.Public Relations Activities

• We will endeavor to communicate with society by disclosing information it requires in a timely, appropriate, and fair manner and by listening to its expectations and requests.
• We will transmit required information in an easily understandable form from the perspectives of our shareholders, investors, business partners, employees, consumers, etc., by conducting public relations activities in compliance with relevant laws, ordinances and regulations.

7.Illicit Provision of Benefits to Public Officials, Etc.

• We will never provide, offer or promise to provide any illicit benefits (such as money or commodities) to any public officials, deemed public officials or persons designated by any special law (hereinafter collectively referred to as “Public Officials, Etc.”). Furthermore, even if we are required to do so, we will resolutely refuse such requirement.
• We will never provide, offer or promise to provide any illicit benefits to any foreign Public Officials, etc., in violation of any applicable domestic or foreign laws, ordinances, regulations or the like relating to prevention of corrupt practices.

8.Political and Governmental Relationships

• We will build sound and transparent political and governmental relationships.
• We will never make any illicit payments of money, etc., to political parties, politicians, political organizations or the like, regardless of whose name is associated with the payment.

9.Contracts with Business Partners, Etc.

• When conducting transactions for outsourcing, contracting or the like, we will execute appropriate contracts that do not violate any laws, ordinances, regulations, or social norms in order to smoothly facilitate business and prevent impropriety and disputes stemming from bribery or other offenses.
• We will sincerely and faithfully fulfill all provisions of such executed contracts.

10.Donations

• When we make donations to business partners, external organizations or the like, we will ensure that such donations are not illegal, verify that they are genuine donations without demanding anything from the other parties in return and never use them as a means of illicitly inducing transactions.

11.Prohibition of Unfair Trade

• With regard to our relations with competitors, business partners, etc., we will conduct fair, lawful and transparent corporate activities in accordance with the rules set forth in the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade, the Act against Delay in Payment of Subcontract Proceeds Etc. to Subcontractors and other relevant laws.
• In conducting our business activities and other information-related activities, we will never provide illegal or illicit gifts, entertainment, kickbacks or the like to representatives of business partners. In addition, we will never accept illegal or illicit gifts, entertainment, kickbacks or the like from representatives of business partners.

12.Avoidance of Conflict of Interest

• We will appropriately handle situations in which the interests of the company conflict with the personal interests of directors or employees of the company in order to avoid unfairly prioritizing such personal interests.
• We will never engage in side businesses that conflict with the interests of the company.

13.Serving Shareholders and Investors

• We will disclose important corporate information timely, appropriately and fairly to shareholders and investors.
• We will strictly manage undisclosed important information until it is disclosed.

14.Exclusion of Anti-Social Forces

• We will never have relationships with anti-social forces that pose a threat to the order or safety of society, such as crime syndicates and “general meeting handlers” (corporate extortionists), and will resolutely confront them without succumbing to their illicit demands.

15.Respect for Human Rights

• We will develop appropriate working conditions and workplace environments and never utilize child labor or forced labor.
• We will never subject employees to discrimination, harassment, unjust treatment or the like based on race, nationality, ethnicity, sex, age, religion, creed, ideology, sexual orientation, educational background, disability, illness or the like.
• We will respect the human rights of our employees and create open, harassment-free workplace environments that are comfortable to work in.

16.Creation of Workplace Environments That Take into Consideration Compliance with Labor Laws, Ordinances and Regulations and Safety and Health

• We will comply with the Labor Standards Act, the Industrial Safety and Health Act and other labor laws, ordinances, regulations, and in-house rules.
• We will create workplace environments that consider the safety and health of our employees and are comfortable to work in and endeavor to prevent industrial accidents from happening and maintain or improve the health of employees.
• We understand the purpose of the Health Promotion Act and will promote preventive measures against passive smoking in workplaces, etc.
• We will comply with the regulations stipulated in the Employee Rules of Employment and create comfortable workplaces.

17.Prohibition of Illegal or Private Use of Company Assets

• We will utilize the assets, commodities and other properties of the company for business purposes only and never use them for illegal purposes or for the benefit of any individuals or third parties.
• We will effectively utilize the information systems and devices of the company and never use them for the benefit of any individuals or third parties.

18.Accuracy of Accounting Records and Compliance with Tax Laws

• In preparing, drawing up and keeping account records and documents to be submitted to government offices, we will accurately record our business activities.
• We will always recognize that the payment of taxes is an obligation of the Japanese people and comply with tax laws.

19.Handling of Intellectual Property Rights and Compliance with Rules for the Handling of Inventions

• We will respect the intellectual property rights of third parties with the same degree of respect as we pay to our own intellectual property rights and never infringe upon them.
• We will comply with the Rules for Employee Inventions (Rules for the Handling of Inventions) and promote research and development activities.

20.Information Security

• We will appropriately manage all information related to our business activities in accordance with all applicable laws, ordinances, regulations, and in-house rules.
• We will take preventive measures against threats on our computer networks and manage such threats appropriately to prevent any damage to our company and other companies.
• We will never illicitly acquire, use or disclose any confidential information of any other companies or third parties.
• We will never disclose within our company confidential information of third parties learned before joining our company or during periods of temporary assignments or the like to such third parties or use such information for our company.
• We will appropriately manage digitized confidential information with the same degree of care as we use for written confidential information.

21.Protection of Personal Information

• We recognize the importance of protecting personal information and will comply with all relevant laws, ordinances, regulations, and in-house rules and appropriately establish and operate a system to promote the protection of personal information, prevent its leakage, etc.
• We will take measures necessary and appropriate to protect personal information, including appropriate acquisition of it, notification and disclosure of purposes of use, prohibition of use for other purposes, safe management, education of employees, etc., restrictions on sharing with third parties and improvement, administration, etc., of procedures for responding to requests for disclosure, etc., of possessed personal data.

22.Insider Trading Regulations, Etc.

• We will comply with the insider trading regulations stipulated in the Financial Instruments and Exchange Act. If we learn of undisclosed important facts relating to the business, etc., of our company, our parent company, a subsidiary company, a business partner or the like in the course of performing our duties, etc., neither we nor the company shall trade any shares or the like of the related company unless such facts have already been disclosed through the prescribed procedure. In addition, directors will comply with the regulations regarding the trading of shares of companies by their directors stipulated in the Financial Instruments and Exchange Act.