Action Guidelines

1. Principles of Action

 Compliance with laws and regulations

We comply with laws and regulations, respect social codes, and work to conduct sensible corporate activities.

• We comply with the laws and regulations of Japan and other countries.
• We fully understand the corporate ethics we are expected to follow and act in a sensible manner as a member of society.

2. Relationship with Society

Contribution to society

We, as a corporate citizen, actively participate in social contribution activities and contribute to the development of society. We place importance on cooperation with communities, volunteer activities, and other social contribution activities and serve the functions expected of a corporate citizen.

Compliance with relevant laws and regulations

We comply with product and service related laws and regulations and perform procedures to meet approval and notification requirements.

Regulations on contributions/donations

• We make contributions or donations in accordance with the relevant laws and regulations as well as the proper method.
• Before making a contribution or donation, we obtain approval in accordance with the company’s rules.
• We do not make illegal contributions or donations. We also refrain from performing an act that may be misconceived as a cozy relationship with politics, the government, or a certain group and work to build sound and transparent relationships.

Severance of relationships with antisocial forces

• In order not to get involved in illegal or antisocial acts, we work to have a basic knowledge of laws, social common sense, and a sense of justice, and always act in a sensible manner.
• We stand firmly against antisocial forces and do not have any relationship with them. If we receive unreasonable requests from antisocial forces, we do not pay money to solve the problem.
• We do not exploit antisocial forces for the company’s or our own interests.
• We do not conduct any transactions with antisocial forces or business partners that have a relationship with antisocial forces.

Environmental preservation/protection

• In the research, development, manufacture, sale, and disposal of products, we always fully recognize the importance of environmental protection and work to make environment-friendly products in accordance with environment related conventions and laws and regulations. We work to generate less waste.
• We work to increase our awareness about the environment and actively participate in environmental protection activities such as the purchase of recycled products and paper resources saving by promoting paperless environments.

Compliance with import and export related laws and regulations

• In importing or exporting products, we perform the proper import or export clearance procedures in accordance with relevant laws and regulations.
• We do not import or export products prohibited from being imported or exported without obtaining the necessary approval.
• As for export transactions of cargos or technologies or provision of services regulated by relevant laws and regulations, we carefully examine whether to conduct those transactions in light of international situations and other factors and perform the necessary procedures in accordance with the relevant laws and regulations.

3. Relationship with Customers, Business Partners, and Competitors

Safety of products

• In the research, development, purchase, manufacture, storage, sale, and transport of products, we always pay attention to safety and fully understand and comply with the laws and regulations related to product safety.
• When we obtain information on product safety, we immediately verify the facts. If a problem is found, we report it to the relevant divisions and take the proper action.

 Compliance with the Anti-Monopoly Act

We fairly and freely compete with other companies and never perform acts that violate the Anti-Monopoly Act such as cartels, bid-rigging, and abuse of dominant bargaining positions under any circumstances.

Fair transactions with suppliers and compliance with the Subcontract Act

We conduct transactions with suppliers in a sensible and faithful manner and treat them fairly and equally.

• When selecting one from among two or more suppliers, we fairly compare and evaluate them in terms of quality, prices, delivery periods, capacity for technological development, stable supply, and other factors and decide which supplier is the most appropriate.
• Regardless of whether or not there is a positional influence on the selection or evaluation of suppliers, we do not exercise any influence that privileges a certain supplier.
• When we outsource the manufacturing of products to a business partner, we fully understand the Subcontract Act and make a contract and conduct transactions without performing any wrongful acts such as delays in payment.

Prevention of unfair competition

We do not use the trade secrets of other companies knowing that they have or may have been obtained by a dishonest means.

Entertainment/gift giving

• We do not provide entertainment or gifts to public servants or quasi-public servants.
• We provide entertainment or gifts to business partners only within the bounds of social common sense.
• We receive entertainment or gifts from customers or business partners only within the bounds of social common sense. If we are sent a gift that goes beyond the bounds of common sense, we do not receive it but send it back.

Proper advertisement

In conducting advertising campaigns, we do not transmit documents or information containing any expressions that defame or slander others or terms that may lead to social discrimination. In doing comparative advertising, we ensure that the information provided is supported by facts, complete and accurate at the time of comparison, and is not misleading.

4. Relationship with Stockholders and Investors

Disclosure of management information

We appropriately disclose our composition of finances, business activities, and other management information to stockholders and investors in a timely manner, clearly communicate the corporate philosophy and management policy to them, and sincerely accept opinions and criticism about such disclosed information from them.

Ban on insider trading

If we know inside information of our company or publicly traded business partners in conducting business, we do not sell or buy those companies’ stocks, bonds or other securities until such information is officially made public. We buy or sell our company’s stocks or stocks of publicly traded companies with which we do business in accordance with the company’s rules.

We never perform such insider trading, which is not permitted even if a mediator is involved or no personal profit is gained.

5. Relationship between Officers and Employees

Respect for human rights/ban on discrimination

We always work to maintain a sound work environment, respect our human rights, and do not perform any act that leads to discrimination.

• We do not practice any unreasonable discrimination based on birth, nationality, race, ethnic, belief, religion, gender, age, disabilities, hobby, or academic background.
• We do not force others to conduct operations by using violence, insulting, or defaming, slandering, intimidating, or threatening them nor perform any acts that violate human rights such as bullying.

Power harassment

We do not impair the human rights and dignity of others beyond the original scope of business by abusing the authority of management or other positional authorities.

 Sexual harassment

• We do not sexually harass others nor perform any acts that may be misconceived as sexual harassment.
• We do not speak or behave in a way that sexually discomforts others and thoroughly prevent others from performing such an act.

Privacy protection

We use the personal information of officers and employees and anyone outside the company known in conducting business only for business purposes and keep it under strict control to prevent it from being leaked to anyone outside the company.

Workplace safety and health

We give safety and health first priority, work to maintain a safe and hygienic work environment, and understand and comply with the laws and regulations related to work safety and health. If a work-related accident occurs, we minimize the accident, and immediately report it and perform other given procedures without fail in order to prevent similar accidents from occurring.

Compliance with labor laws

We comply with labor laws and work to maintain a pleasant and sound work environment.

• We manage working days and working hours so that they fall within the limits of the Labor Standards Act.
• We do not force employees to work too much or work excessive overtime or force work on them in any other ways.
• Officers and those in a management position always pay attention to the physical and mental health of their subordinates.

Fair treatment

We always pay attention so that officers and employees do not receive unreasonably differential treatment.

• Officers and those in a management position always work to fairly treat all divisions and employees from a company-wide perspective without acting in their own best interest. We work to carry out personnel affairs with importance placed on fairness and in a rational manner.
• All officers and employees try to be cooperative, be conscious of overall optimization, and avoid selfish behavior.

6. Relationship with the Company and the Company’s Assets

Compliance with the working regulations

Employees always comply with the working regulations.

• We do not perform any prohibited matters stipulated in the working regulations and the company’s related rules.
• We do not perform any fraudulent or dishonest act that runs counter to the working regulations and the company’s related rules.

Proper accounting

We keep accounting records and fill in slips correctly in accordance with the relevant laws and regulations and the company’s rules. We do not make false or fictitious entries nor build concealed assets.

Ban on conflict of interest

We do not get involved in activities that create a conflict of interest with the company.

• We do not perform any activities for competing companies or business partners that create a conflict of interest with the company regardless of the employment type or whether or not they are for a reward.
• We do not do business with our company as our business partner.

Ban on political/religious activities

We do not perform political or religious activities during working hours.

• We do not induce others to join a political group, conduct election campaign activities, or perform any other political activities during working hours.
• We do not induce others to join a religious group, impose religious beliefs, solicit for contributions, hand out brochures for proselyting, or perform any other religious activities during working hours.

Management of trade secrets

We manage trade secrets properly in accordance with the company’s rules and do not disclose or leak them to anyone outside the company without permission from the company.

• We keep the trade secrets of the company and other companies under strict control and do not leak them to anyone outside the company nor use them for other purposes than business purposes.
• When disclosing confidential information of the company to anyone outside the company, we conclude a nondisclosure agreement or take other measures to prevent unexpected leakage.
• We do not make fraudulent use of trade secrets of other companies nor use them for other purposes than the purposes permitted.
• We do not leak confidential information of the company or confidential information obtained from outside the company nor use it for any purposes even after retirement.

Proper use of the company’s assets

We make efficient use of the company’s assets, understand that they must be kept available, and treat them properly in a way to prevent them from being damaged or stolen regardless of whether they are tangible or intangible. We do not use the company’s assets or expenses for personal purposes.

Proper use of information systems

• We do not use the company’s information systems for personal purposes but use them only for business purposes.
• We keep IDs and passwords for the company’s information systems under strict control to prevent their leakage to anyone outside the company.
• We do not make fraudulent use of IDs or passwords of others nor break into the computer systems of others.

Protection of intellectual property rights

The company’s intellectual property rights are the company’s important assets, and we use them properly and work to protect the rights.

• We promptly apply for a patent for an invention derived from research and development or a manufacturing method and take other measures to protect the company’s intellectual property rights.
• We do not make unauthorized copies of computer software of others nor perform any other acts that infringe the intellectual property rights of others.
• We use the intellectual property rights of others only after concluding a proper contract and do not use them fraudulently.