Action Guidelines | Sustainability | DAIICHI KIGENSO KAGAKU KOGYO CO., LTD.

1. Fundamental Principles

We shall comply with all applicable laws and regulations, both domestic and international, as well as internal Company rules, including employment rules and policies, that apply to our business activities.
We shall respect internationally recognized guidelines, standards, and social norms.
We shall fully recognize the corporate ethics expected of the Company Group and act with integrity and sound judgment as responsible members of society.
We shall strive to create and maintain a healthy, safe, and respectful workplace where all employees can work comfortably and productively.

2. Relationship with Society and the Environment

Contribution to Society

We respect the cultures, customs, and traditions of the countries and regions in which we operate and contribute to social development and the realization of a sustainable society through its business activities.

We value social contribution activities, including cooperation with local communities and participation in volunteer activities.
We act with a strong sense of ethics and public responsibility as a responsible member of society.

Donations and Contributions

We make donations and contributions to support the healthy development of local and international communities, the promotion of culture, and socially beneficial activities. When making any donation or contribution, we shall comply with the laws, regulations, and standards of the countries and regions in which we operate and adhere to internationally recognized anti-corruption principles.*

We shall make donations and contributions only with prior approval in accordance with internal Company rules, including the Delegation of Authority.
We strictly refrain from any unlawful donations or contributions, as well as any conduct that could create, or appear to create, collusive relationships with political parties, public officials, governmental bodies, or other organizations. We are committed to maintaining sound, transparent, and fair relationships.

* International anti-corruption principles include, for example, the United Nations Convention against Corruption (UNCAC).

Zero Tolerance and Separation from Illegal and Unethical Organizations

We will not, under any circumstances, have any relationship with organizations or individuals involved in organized crime, terrorism, money laundering*, human trafficking, corruption, or those subject to international sanctions.
Even if we are faced with improper demands or unlawful pressure from such organizations or individuals, we will not seek to resolve the matter by providing money or any other benefit, and we will respond firmly and appropriately.

If we receive improper demands or unlawful pressure, or if we witness or become aware of such conduct, we shall immediately report it to the Company.
Before entering into any new business relationship, we shall conduct appropriate due diligence on the counterparty in accordance with internal Company rules and procedures.
We shall act with sound judgment and integrity to prevent any involvement in illegal or unethical activities.

* Money laundering: the illegal act of concealing the origin of assets obtained through criminal activity and making them appear legitimate.

Environmental Protection and Climate Action

We recognize the importance of environmental protection in all business activities and comply with internationally recognized environmental standards as well as applicable environmental laws and regulations in each country. Through the implementation of our environmental policy, we contribute to the realization of a sustainable society.

We strive to reduce environmental impacts throughout the entire lifecycle of our products and services.
We regard climate action as a material social priority and are committed to reducing greenhouse gas emissions.
In our daily operations, we practice energy and resource conservation, such as turning off unnecessary lighting, managing HVAC* settings appropriately, minimizing waste, promoting recycling, and advancing paperless practices.

* HVAC：Heating, Ventilation, and Air Conditioning

Compliance with Export and Import Laws and Regulations

When exporting or importing products, materials, or raw materials, we shall comply with all applicable domestic and international laws and regulations and ensure accurate customs procedures, as well as the timely filing of all required applications and notifications.

We shall verify whether any products, materials, or technologies are subject to economic sanctions or export and import controls, and shall not export or import such items without obtaining the necessary licenses, permits, or approvals.
For export transactions and the provision of services involving goods or technologies subject to regulatory controls, we shall carefully assess the permissibility of such transactions by taking into account international circumstances and security risks. Based on this assessment, we shall ensure that all required procedures are properly completed in compliance with applicable laws and regulations.

3. Relationships with Customers, Business Partners, and Competitors

Ensuring Product Safety

We place the highest priority on product safety at every stage of our business activities—including research, development, procurement, manufacturing, storage, sales, and transportation. We understand and comply with applicable laws and regulations in each country, as well as internationally recognized safety standards, and respond appropriately.

We comply with internal quality-related policies, procedures, and standards.
When we become aware of any information concerning product safety, we promptly verify the facts and take necessary actions in coordination with relevant departments.
We never falsify test results or quality data, and we always provide accurate and transparent information.

Fair Competition

We are committed to fair and free competition (in line with fair trade principles) and shall not, under any circumstances, engage in conduct that violates competition laws or internationally recognized fair trade principles, including cartels, bid rigging, price fixing, or abuse of a dominant position.

We shall not obtain the trade secrets, intellectual property, or other confidential information of other companies or third parties by improper or illegal means.
We shall not use information if there is any doubt or concern about how it was obtained.
We shall not exchange or discuss competitively sensitive information—such as prices, costs, margins, production or sales volumes, customers, territories, bidding plans, or future business strategies—with competitors.

Fair Dealing with Suppliers and Compliance with Laws and International Standards

In accordance with the Group's Procurement Policy, we conduct transactions with suppliers fairly and impartially, with sound judgment and integrity. We also respect internationally recognized standards* and promote responsible procurement practices.

We evaluate potential and existing suppliers comprehensively—considering quality, price, delivery lead time, technological capabilities, supply stability, and their efforts regarding human rights, environmental protection, and anti-corruption—and select the most appropriate business partners.
We shall not exercise undue influence that would provide favorable treatment to any particular supplier.
In subcontracted manufacturing or service arrangements, we comply with all applicable laws and regulations, including Japan’s Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors (the “Subcontract Act”), where applicable, as well as equivalent laws and regulations in other jurisdictions, and we prevent delayed payments and unfair contract terms.
In line with international guidelines*, we promote respect for human rights, environmental protection, and responsible mineral sourcing across our supply chain.

* International standards and guidelines include, for example:
・UN Guiding Principles on Business and Human Rights (UNGPs)
・UN Global Compact Ten Principles
・OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

Anti-Bribery and Proper Handling of Entertainment and Gifts

We do not offer money, gifts, entertainment, hospitality, or any other improper benefit to public officials, government-related persons, employees of international organizations, or individuals in equivalent positions.
All entertainment and gifts provided to business partners must comply with the laws and regulations of each country and with international anti-corruption standards.

Any necessary entertainment or gifts shall comply with internal Company rules such as the Delegation of Authority and shall receive prior approval.
When receiving entertainment or gifts from customers or business partners, we do not accept anything that exceeds socially appropriate norms. Any gift or benefit that is excessive or unreasonable must not be accepted and should be returned promptly.

Public Relations and Responsible Communications

We maintain trust with society and our stakeholders by providing information that is accurate, factual, and transparent.

We do not use false, misleading, defamatory, or discriminatory statements or language.
We respect intellectual property rights and do not infringe upon copyright, trademark, or design rights.
When disclosing corporate information or responding to crises, we provide timely, accurate, and transparent information.

4. Relations with Shareholders and Investors

Timely and Appropriate Disclosure and Assurance of Transparency

We disclose, in a timely and appropriate manner, accurate financial information and material non-financial information (including sustainability) to shareholders and investors.

We comply with applicable laws and disclosure standards in each jurisdiction.
We prevent misleading expressions and eliminate inaccuracies from our disclosures.
We communicate our corporate philosophy and policies clearly, and we take stakeholder views and criticism seriously by engaging in constructive dialogue.

Prohibition of Insider Trading and Information Management

We comply with applicable securities laws and regulations and implement internal policies to prevent insider trading and protect confidential information.

We do not trade the securities of any company while in possession of material non‑public information (MNPI), and we wait until such information has been publicly and broadly disseminated for a sufficient period.
We do not disclose or share MNPI with anyone—including family, friends, or other third parties—(no “tipping”), and we take care to avoid inadvertent disclosure.
When trading the Company’s shares, we follow internal rules and submit any required prior notifications.
Insider trading is prohibited even if there is no personal profit or if intermediaries are used; we never engage in such conduct.

5. Workplace Relations

Respect for Human Rights and Prohibition of Discrimination

We respect internationally recognized human rights standards* and comply with our Group’s Human Rights Policy.

We do not engage in any form of discrimination based on birth, nationality, race, ethnicity, creed, religion, sex, age, disability, sexual orientation, gender identity, educational background, or any other protected characteristic.
We do not engage in conduct that violates human dignity, including violence, threats, shouting or abusive language, defamation, bullying, or any other form of harassment or intimidation.
We respect diversity and work to foster an inclusive workplace where people recognize one another and collaborate.

*International human rights standards: the Universal Declaration of Human Rights; the UN Guiding Principles on Business and Human Rights.

Prevention of Harassment

We act with consideration for others and strive to maintain a comfortable, harassment‑free workplace.

We do not engage in any form of harassment, including power harassment (abusive conduct by those in a position of authority), sexual harassment, harassment related to pregnancy, childbirth, parenting or caregiving, discriminatory remarks or conduct, and online or digital harassment (including cyberbullying), as well as any other similar behavior.
If we witness or experience harassment, promptly consult with or report the matter to our manager or the designated internal contact point.
We strictly prohibit any adverse treatment or retaliation against anyone who raises a concern, seeks advice, reports in good faith, or truthfully shares facts about harassment.

Protection of Personal Data and Privacy

We comply with applicable laws and international standards, and implement our internal policies on personal data protection appropriately. (International standards include the OECD Privacy Guidelines and the EU General Data Protection Regulation (GDPR).)

We use the personal data and privacy‑related information of our officers and employees, as well as external stakeholders, only within the scope of legitimate business purposes and in an appropriate manner.
We strictly manage personal data in accordance with our internal policies and procedures, and protect it against unauthorized disclosure, loss, or misuse.
We do not use personal data for purposes beyond those specified without an appropriate legal basis (such as consent where required), and we handle only the minimum data necessary for the stated purpose.

Workplace Health, Safety and Well‑Being

We comply with international occupational health and safety (OHS) standards and applicable laws in each country, and we maintain a safe and hygienic workplace in accordance with our internal policies and procedures. We are committed not only to physical safety but also to mental health and the promotion of overall well‑being.

We conduct risk assessments on safety and hygiene and implement corrective and preventive measures to prevent accidents and incidents.
In the event of an accident or incident, we act to minimize harm and report promptly through the designated channels.
We complete company‑mandated medical examinations and stress checks as required, and we strive to maintain and improve our physical and mental health.

* International OHS standards include relevant ILO conventions and recommendations (e.g., ILO Convention No. 155 and No. 187)

Compliance with Labor Laws and Building a Supportive Workplace

We comply with international labor standards, the labor laws applicable at each place of work, and the Company’s employment rules, and we work to maintain a healthy, supportive, and comfortable workplace environment. We do not tolerate child labor or forced labor under any circumstances.

We comply with our internal policies on employment rules and standards of conduct, and we refrain from any prohibited acts or other behavior that disrupts workplace order.
We comply with our employment rules and related internal policies, and we submit required filings accurately and on time, including time and attendance reports.
We respect work–life balance and promote flexible working arrangements and the taking of paid leave and other legitimate time off.
Managers and supervisors pay continuous attention to their team members’ physical and mental health and provide appropriate support when needed.

* International labor standards include ILO conventions and recommendations, including the core labor standards.

Fair and Equitable Treatment and Workplace Culture

We ensure fair and equitable treatment without discrimination or unjustified disparities. Personnel decisions—including hiring, evaluation, and promotion—are based on capability, performance, and role fit, with transparency and consistency. Managers and HR professionals avoid conflicts of interest and personal bias, and act in the best interests of the organization as a whole.

We act with respect for one another and do not engage in behavior that creates discrimination or unjustified disparities.
We carry out our duties with integrity to ensure that our capability, performance, and role fit are evaluated accurately.
We refrain from behavior driven by personal gain or prejudice and prioritize cooperation and trust throughout the organization.

6. Relationship with Company Assets, Information, and Technology

Proper Accounting and Financial Reporting

We comply with all applicable laws, regulations, and internal policies in each country, and ensure timely and accurate financial reporting based on proper accounting practices.

We record all accounting books, records, and supporting documents accurately, completely, and in good faith.
We do not engage in any improper or fraudulent activities, including but not limited to the falsification or fabrication of records, recording of off‑the‑books assets or liabilities, earnings manipulation, or data falsification.

Prohibition of Conflicts of Interest

We shall not, without prior approval of the Company, engage in any conduct or transactions for our own benefit that may be detrimental to the interests of the Company.

We shall avoid any activities in which the interests of the Company conflict, or appear to conflict, with our personal interests.
We shall not engage in any activities for the benefit of competitors, business partners, or other third parties where such activities may harm or disadvantage the Company.
We shall not conduct business, directly or indirectly, as a business partner, contractor, or supplier of the Company.

Political and Religious Neutrality in the Workplace

We respect internationally recognized human rights standards and acknowledge each individual’s freedom of belief and religion. At the same time, we are committed to maintaining political and religious neutrality in the workplace and ensuring a respectful, inclusive, and productive workplace environment.

We shall not engage in political or religious activities in the workplace. This prohibition applies not only during working hours but also to the use of Company resources ——including but not limited to email systems, meeting rooms, communication tools, and IT systems—— for political or religious purposes.
We shall not engage in any conduct that may disrupt the workplace environment, including but not limited to political solicitation, election-related activities, recruitment for political or religious organizations, imposition of personal beliefs, requests for donations, or the distribution of pamphlets or similar materials.

Proper Management of Confidential Information and Information Assets

In compliance with applicable laws and regulations in each country and internal Company policies, we shall properly manage confidential information and information assets in accordance with the fundamental principles of information security. *

We shall use confidential information of the Company and of third parties solely for legitimate business purposes and shall not disclose, leak, or misuse such information without proper authorization.
When disclosing confidential information to external parties, we shall ensure that appropriate confidentiality agreements are in place and that reasonable measures are taken to prevent unauthorized or unintended disclosure.
Upon resignation or termination of employment, we shall comply with Company policies and shall not, after leaving the Company, retain, disclose, or use any confidential information of the Company or confidential information obtained from third parties.

* Fundamental Principles of Information Security:
・Confidentiality — protecting information from unauthorized disclosure
・Integrity — ensuring the accuracy and completeness of information
・Availability — ensuring information is accessible when needed

Proper Use and Protection of Company Assets

In compliance with applicable laws and regulations in each country and with the Company’s internal policies on asset management, we shall use Company assets, both tangible and intangible, efficiently and appropriately.

We shall maintain Company assets in a condition that ensures they remain available for legitimate business use.
We shall properly protect and manage Company assets in order to prevent loss, damage, theft, or misuse.
We shall not use Company assets or financial resources for personal purposes and shall not engage in any unauthorized removal, misappropriation, or embezzlement of Company property.

Proper Use of Information Systems and Ensuring Information Security

We shall comply with the Company’s internal policies and rules regarding information security and take appropriate measures to prevent security incidents.

We shall use the Company’s information systems—including networks, cloud services, mobile devices, and AI tools—solely for legitimate business purposes and shall not use them for personal purposes.
We shall strictly manage our IDs, passwords, and other authentication credentials and take all necessary precautions to prevent leakage, unauthorized disclosure, or misuse.
We shall not misuse or steal another person’s ID or password, nor shall we gain or attempt to gain unauthorized access to any information system.
We shall continuously enhance our information security awareness and act responsibly to prevent cyberattacks, malware infections, and other information security threats.

Protection and Proper Use of Intellectual Property

In compliance with applicable laws and regulations in each country, we shall protect and ensure the proper use of intellectual property, including patents, trademarks, copyrights, designs, and trade secrets.

Inventions created through research and development or manufacturing activities shall be promptly reported and appropriately protected through the acquisition of intellectual property rights.
We shall respect the intellectual property rights of third parties and shall enter into appropriate license agreements before using such intellectual property.
When using open-source software or AI-generated content, we shall comply with all applicable licenses, terms of use, and relevant laws and regulations.

Appropriate Use of Social Media

We shall comply with the Company’s internal policies regarding the use of social media and place the highest priority on protecting the trust, reputation, and information assets of the Company Group. Even when using social media for personal purposes, we shall act with a strong sense of social responsibility and shall not infringe upon the rights of the Company Group or any third party.

We shall not use social media for personal purposes during working hours without prior authorization.
We shall not repost, share, or otherwise use the Company Group’s products, logos, images, documents, or other materials without authorization.
We shall not make any statements or postings that represent, or could reasonably be perceived as representing, the Company Group without proper authorization.
We shall comply with the Company’s information security policies to ensure that no confidential information of the Company Group is disclosed through social media.