Corporate Code of Conduct

Statement

The Takachiho Koheki Group recognizes that consistently fulfilling its social responsibility as a corporate citizen links to enhancing corporate value. We have therefore established the following Corporate Code of Conduct to complement our existing Corporate Philosophy, Corporate Vision, and CSR Charter. In all our business activities, we, as a Group not only comply with laws and regulations but also act in good faith based on a strong ethical perspective, adhering to this Code of Conduct.

The Code applies to all officers and employees, including contract employees and dispatched employees (hereinafter referred to as “we”).

1. Basic Approach

With an awareness of our roles as both individuals and corporate citizens, each of us strives to understand the fundamental principles outlined below, keeping them in mind in our daily work and acting with integrity.

  1. We comply not only with domestic laws and regulations but also with international rules, local laws and the other relevant rules. Additionally, we conduct our business activities with respect for the history, culture, customs, and other characteristics of each country and region around the world.
  2. As responsible members of society, we avoid getting caught in the industry logic and instead act with integrity, guided by our common sense as a good citizen. Moreover, we comply with the Company’s regulations and maintain a clear distinction between personal and professional matters, always striving to speak and act responsibly, constantly aware that we represent the Company.
  3. When increasing sales or profits conflicts with ethically correct actions, we prioritize ethical conduct. Additionally, we refrain from engaging in acts that pursue personal or third-party interests at the expense of the legitimate interests of the Company.
  4. We all aim to enhance customer satisfaction and tackle challenges to deliver high quality work with creativity.
  5. We maintain sound, fair, impartial and transparent relationships with all of the Company’s stakeholders and conduct business dealings with integrity and fairness.
  6. We comply with applicable laws and regulations regarding corporate information, including details of management, financial status and business activities. Furthermore, we enhance the transparency of our business activities by consistently ensuring fairness and accuracy and disclosing information in a timely and appropriate manner.
  7. We respect each individual’s unique personality, values and character and create workplaces that emphasize autonomy and creativity.

2. Legal Compliance

  1. We refrain under any circumstances from actions that violate laws and regulations or could raise suspicions of illegality. Furthermore, we do not instruct others to engage in unlawful or potentially suspicious activities.
  2. When it is unclear which laws and regulations to follow or what actions are required to ensure the proper conduct of our duties, we act based on sound judgment and generally accepted standards.

3. Protection of the Natural Environment

To protect the global environment and contribute to the creation of a sustainable society, we comply with applicable laws and regulations. Additionally, we work to minimize the environmental impact of products and components throughout their lifecycle, from procurement to disposal, by carefully considering their effects on the natural environment.

4. Compliance with Antitrust and Related Laws

  1. We are committed to ensuring fair business dealings with all partners, based on the principle of free competition and in compliance with antitrust, subcontractor and other related laws and regulations.
  2. We do not enter into any agreements with competitors intended to restrict competition. Additionally, before signing any agreement that could potentially limit competition with a competitor, we ensure its content is reviewed in advance by our legal department to confirm compliance with antitrust and other laws.

5. Prohibition of Unfair Advertising

In publicity, advertising, and other sales activities, we avoid making any false or misleading representations about the quality, performance, or specifications of our products and services as well as our competitors and their products and services.

6. Respect for Third-Party Intellectual Property Rights

We respect third-party intellectual property rights, including patent rights, utility model rights, design rights, trademark rights, copyright and services, and refrain from intentional infringements or unauthorized use.

7. Comprehensive Management of Import and Export Controls

We conduct all import and export transactions related to our products, component, technologies and services in compliance with the Foreign Exchange and Foreign Trade Act, which aims to maintain international peace and security, as well as applicable laws and regulations in accordance with proper procedures stipulated in internal rules and regulations.

8. Policy on Anti-Social Forces

We adopt a resolute stance against anti-social forces and organizations that threaten public order and safety, refusing all unjust or illegal demands.

9. Prohibition Against Bribery of Public Servants and Similar Activities

We refrain from offering bribes, financial contributions, entertainment, or engaging in other improper economic benefits to public servants, politicians, their staff, and similar individuals.

10. Donations

When making donations, we carefully consider their necessity and appropriateness in compliance with relevant laws and regulations.

11. Prohibition of Illicit Gains, Policy on Entertaining, Bribery, etc.

We do not use our positions to obtain improper personal benefits. Furthermore, when providing or receiving entertainment or gifts in business relationships, we adhere to internal rules and regulations and act in line with sound business practice and societal norms.

12. Prohibition of Insider Trading

We do not trade the Company’s shares or other securities, including those of other companies, using material non-public information obtained during our work. Furthermore, we do not use such information to confer benefits or advantage to third parties.

13. Creation of a Supportive Workplace Environment

We strive to provide an environment where every employee can fully realize their potential and work with enthusiasm, guided by fundamental principles of the Code of Conduct. To achieve this, we ensure a safe, efficient, and supportive workplace environment.

14. Respect for Basic Human Rights and Prohibition of Discrimination

We respect the basic human rights of every individual and do not discriminate based on religion, belief, nationality, gender, disability, age, or any other personal attribute. Furthermore, we refrain from discriminatory speech or actions, violence, sexual harassment, or any other behavior that undermines the dignity of individuals.

15. Respect for Privacy and Prohibition of Leaking Personal Information

  1. We respect the privacy of employees, customers, and others, taking the utmost care to prevent any violation of their privacy.
  2. We do not disclose personnel data to external parties. Furthermore, employees handling information on personnel in the course of their duties take great care in managing it.

16. Management of Trade Secrets

  1. We manage information created or acquired in the course of our work appropriately and rigorously in line with the level of importance specified in internal rules and regulations.
  2. We use trade secrets solely for the purpose of conducting the Company’s business and refrain from improper or unauthorized use, both during and after our tenure with the Company.

17. Prohibition of Unauthorized Access and Handling of Third-Party Trade Secrets

  1. We refrain from unauthorized accessing of information designated as confidential.
  2. When handling third-party trade secrets disclosed to us under contractual agreements, we strictly adhere to the purposes and conditions stipulated in the contract.
  3. We do not use information about customers, individuals, or others acquired in the course of our work for unauthorized purposes and we manage such information rigorously in compliance with internal rules and regulations to prevent its disclosure or leakage.

18. Protection of Corporate Assets

We manage the Company assets appropriately in accordance with established rules and do not divert them for personal use or other unauthorized purposes unrelated to business activities.

19. Disciplinary Action

Any acts that violate the CSR Charter or the Corporate Code of Conduct are subject to disciplinary action and compensation for damages in accordance with our employment regulations.

20. Administration of the Code

  1. Decisions on the formulation and revision of this Code are made by the Board of Directors of Takachiho Koheki Co., Ltd., following deliberation by the department responsible for CSR.
  2. Compliance with the Code is audited by the internal audit division of Takachiho Koheki Co., Ltd., and verified by the Administrative Department.
  3. This Code applies to the officers and employees of each Takachiho Koheki Group company upon its adoption by the respective company’s Board of Directors.
  4. Each Takachiho Koheki Group company may make changes to its Code based on a resolution of its Board of Directors, provided that such changes do not conflict with the provisions of this Code. In such cases, the changes must be reported to the department responsible for CSR at the Company’s headquarters.