Kuriyama Group
Code of Conduct

1.Basic principle

WE will understand the following basic principles with self-awareness as a citizen and of being a part of the corporation, and try to behave along the principles on a regular basis.

• 1.WE will comply with domestic and foreign laws and regulations, international treaties, this code of conduct and rules adopted by the corporation, and promote fair and sound business activities.
• 2.WE will respect human rights of all the people. WE will not take any discriminatory treatments based on race, color or gender and will not disregard individual dignity.
• 3.WE will respect and contribute to the development of cultures and customs of international and local communities.
• 4.WE will conserve the global environment and contribute to the creation of the sustainable society.
• 5.WE will strive to obtain customer satisfaction and trust by providing socially useful products and services with sufficient consideration of and attention to quality, safety and environment.
• 6.WE will compete fairly, transparently and freely in the market, and maintain sound and healthy relationship with politics and the administration of government, public communities, associations and organizations.
• 7.WE are committed to full, fair, accurate and timely disclosures of corporate information and promote the transparency of the business activities.
• 8.WE will ensure appropriate management of information assets including private information and customer data.
• 9.WE, as a member of Kuriyama group, will act in good faith, in a responsible manner, with self awareness and with integrity to continuously improve corporate ethic and culture.

2.Compliance with laws and regulations

• 1.WE are committed to conducting our businesses in accordance with laws, rules and regulations of countries and regions in which we do business. Under no circumstances should WE act or support that violate the laws or invite suspicions of violations.
• 2.WE will maintain sound and healthy relationship with politics and the administration of government and will not get involved with any individuals or organizations that disturb the social order or impede sound business activities.

3.Due consideration to the natural environment

In order to contribute to a global environmental preservation and zero-waste society, WE will comply with all applicable environmental legislation and regulations, and minimize environmental impacts made through life cycle of goods and products, which including manufacturing, logistics, use, reuse and disposal.

4.Respect of human rights

• 1.WE will respect basic human rights and dignity and never, in all aspects of business, take any actions such as harassment, insulting, verbal abuse and undue influence by taking advantage of business and professional positions.
• 2.WE will never take any discriminatory treatments based on nationality, race, color, gender, age, religion, creed, or physical or mental disabilities.
• 3.WE will never use any offensive terms, take discriminatory behavior, and commit a violent act or sexual harassment.

5.Protection of private information

WE will respect the privacy of all people and take all possible measures to ensure the appropriate treatment and protection of personal information in accordance with Personal Information Protection Law and all related rules.

6.Improvement of working environment

WE will respect each other and create a free, open and vibrant workplace so that each one of us can reach our maximum capability. And for that, WE will ensure a safe, clean and employee-friendly working environment.

7.Compliance with Antitrust laws

WE will conduct fair and sound business activities in accordance with antitrust and fair competition laws and regulations. WE will not make any actions of impeding fair and free competition such as collusion or cartel.

8.Prohibition of false or unfair advertising

WE will not give false indications or expressions about the quality, performance and specification of goods or services and that are misleading customers in advertising, publicity and other business activities. WE will not also give false or misleading indications or expressions about competitors or their products and services.

9.Respect of intellectual property

WE value the intellectual property rights of a third party such as patent, utility model right, design right and copyright and will avoid deliberate infringement or wrongful use of such rights.

10.Compliance with regulations and provisions for export and import trading

WE will observe Foreign Exchange and Foreign Trade Law and all applicable national and international regulations in exporting and importing of products, technologies and services.

11.Ban on unfair profit and policy of business gifts and entertainments

WE will refrain from any activities to gain personal profit unfairly by misusing our positions. Concerning offering business entertainments to customers and acceptance of gifts from business partners, WE will act in line with sound business and common practices.

12.Management of confidential corporate information

• 1.WE will maintain proper and strict control on information created and obtained through business activities in accordance with corporate rules and policies.
• 2.WE will handle confidential corporate information only for a business purpose, and will not use improperly or unfairly at any time, including following retirement.

13.Disciplinary measures

Employees that engage in intentional acts inconsistent with this Code are subject to disciplinary action up to and including discharge.

14.Administrations

• 1.Institution, modification and abolishment of this code must be approved by the board meeting of Kuriyama Holdings Corporation after the deliberation of the responsible department of compliance.
• 2.Monitoring of compliance of this code is managed by auditing by Kuriyama Holdings Corporation Audit Dept. and by reviewing by Administration Dept. and Management Strategy Office.
• 3.This code of conduct applies to each director, officer and employee of Kuriyama group companies by the resolution of their board meeting.
• 4.Kuriyama group companies may make revisions of this code within the scope of meaning and concept of the code. Any revisions must be reported to the responsible department of compliance of Kuriyama Holdings Corporation.