Responsibility to Customers, Suppliers, and Competitors

We provide safe, high-quality products and services that earn the satisfaction and trust of our customers.

• We incorporate the latest technologies and develop products and services from the customer’s perspective, striving to provide high-quality products and services. To that end, we continuously pursue self-improvement and endeavor to acquire advanced expertise and technical knowledge.
• We provide appropriate information to ensure that customers can use our products safely and correctly.
• We respond sincerely and promptly to customer inquiries and requests.

We conduct our business activities in compliance with laws, regulations, and commercial ethics, based on the principles of free and fair competition.

• In conducting business activities, we comply with all applicable industry laws and regulations, including obtaining necessary permits and licenses and making required filings.
• We comply with laws and regulations concerning the prohibition of monopolization, fair competition, and fair trade.
• We conduct purchasing and procurement activities in a fair and equitable manner and do not engage in conduct that could be perceived as collusion or that imposes unjust burdens on suppliers.
• With the aim of enhancing added value throughout the supply chain and achieving mutual prosperity between large enterprises and small and medium-sized enterprises, we have formulated and published a “Declaration of Partnership Building”

We appropriately and strictly control and manage our own and others’ confidential information, personal information, and intellectual property rights.

• Confidential information (including know-how and customer information) of the Company and third parties, as well as customers’ personal information obtained in the course of business, shall be strictly controlled and managed during and after employment and shall not be used improperly or disclosed to third parties. We do not obtain confidential or personal information of business partners or others through improper means.
• We protect and strictly manage the Company’s intellectual property rights, such as patents and trademarks, and do not infringe upon the intellectual property rights of others.

With respect to entertainment and gifts, we do not engage in conduct that deviates from accepted social norms.

• We avoid excessive gifts or entertainment to business partners and do not accept excessive entertainment or gifts that exceed customary social courtesies.

Responsibility to Shareholders, Investors, and Financial Institutions

We disclose corporate information accurately and in a timely manner in accordance with applicable laws and regulations.

• Accounting information is processed and recorded properly and accurately in accordance with applicable laws, accounting principles, and standards, and business performance is disclosed in a timely and appropriate manner. We strengthen our internal control systems by ensuring proper accounting treatment and conducting effective internal audits.
• Through investor relations (IR) activities and other means, we proactively provide corporate information, including management policies and business activities, in a fair manner so that shareholders, investors, and financial institutions can make informed correct decisions.

In accordance with applicable laws and Company regulations, we strictly control and manage internal corporate information (insider information) and do not use it improperly.

• If we obtain material non-public information about the Company or other companies that could influence investment decisions in securities markets, we will not use such information for the financial benefit of the Company or individuals, nor engage in any conduct that undermines the soundness or fairness of the securities markets.

Company Responsibility to Directors, Employees, and Other Persons in an Employment Relationship with the Company and Responsibility of these

The Company respects the fundamental human rights and diversity of its employees and ensures a comfortable and inclusive working environment.

• We do not discriminate on the basis of race, gender, nationality, religion, beliefs, physical disability, age, or any other protected characteristic, and we prevent sexual harassment and any other form of harassment in the workplace.
• We comply with applicable labor laws and regulations, including the Labor Standards Act and the Industrial Safety and Health Act of Japan, maintain sound labor-management relations, and ensure workplace safety and health.
• Employees’ personal information is not used for purposes other than business operations. Such information is strictly controlled and managed in accordance with applicable laws and regulations and is not disclosed to unauthorized persons.

We do not engage in conduct that conflicts with the interests of the Company and do not mix personal and business matters.

• We comply with the Company’s Work Rules and other internal regulations and do not abuse the authority granted to us.
• We appropriately manage and use the Company’s tangible and intangible assets and do not use them for personal purposes.
• We do not engage in other employment without the Company’s approval.
• As responsible members of society, we act with dignity and moderation, maintain workplace order, and refrain from making statements also outside of the Company that would damage prestige and creditability of the Company.

Responsibility to Politics, Government, and Society

We comply with applicable international treaties and the laws and regulations of the countries and regions in which we operate.

• We comply with laws and regulations governing the export of products and technologies related to the manufacture or use of weapons of mass destruction, such as nuclear, biological, and chemical weapons, as well as conventional weapons.
• With respect to import and export transactions, we comply with the laws and regulations of Japan and other relevant countries, including export and import control laws and customs laws.
• We respect the local cultures and customs of the countries and regions in which we conduct business.

We maintain transparent and sound relationships with political and governmental authorities.

• We do not provide entertainment or gifts to public officials.
• We do not make improper political contributions to politicians or political organizations in violation of applicable laws and regulations.

We take a firm stance against antisocial forces or organizations and provide no benefits to them.

• We have no relationships whatsoever with antisocial forces or organizations.
• We counter unreasonable demands or threats from antisocial forces or organizations in cooperation with the police and do not compromise with such entities.

We proactively and positively engage in efforts to conserve the global environment.

• We comply with treaties, laws, agreements, and international standards relating to environmental protection and strive for efficient use and recycling of resources and energy.
• We develop and provide equipment and products that reduce environmental load.

To prevent human rights abuses associated with armed conflict, we support the intent of U.S. legislation concerning conflict minerals (tantalum, tin, tungsten, and gold).

• We actively participate in investigations based on U.S. financial regulatory reform laws (including the Dodd-Frank Wall Street Reform and Consumer Protection Act) to procure minerals that do not benefit armed groups responsible for human rights abuses.
• If it is discovered that our products contain minerals associated with armed groups in conflict-affected or high-risk areas, we will immediately suspend such transactions.

Prohibition of Personal Conduct Contrary to the Company’s Interests

We do not engage in any conduct, or any conduct that may appear to engage in such conduct, that harms or may harm the Company or its business partners for the purpose of obtaining personal gain.

• We do not use our position within the Company for purposes other than Company business. For example, we do not request colleagues or subordinates to cooperate in political, religious, or commercial activities, nor do we provide personal favors or seek personal gain for the benefit of third parties.
• Without prior approval from the Company, we do not engage in business activities that compete with the Company’s transactions, become officers or employees of competing companies, support the sales activities of competitors, or mediate or participate in transactions between the Company and our family members, relatives, or friends.

Prohibition of Personal Use of the Company’s Tangible and Intangible Assets

We do not use assets lent or provided by the Company for business purposes for personal use.

• We handle Company property (including office automation equipment such as personal computers, office supplies, promotional items such as planners, and other items) with care and economy and do not use them for personal purposes or remove them from Company premises without permission.
• We clearly distinguish between business and personal expenses and do not misappropriate Company funds for personal purposes.
• We refrain from using telephones, e-mail, internet, or computer software for purposes unrelated to business and do not install new software without the Company’s permission.

Compliance with Confidentiality Obligations and Proper Information Control & Management

Non-public information, confidential information, and personal information of the Company and external parties obtained in the course of business shall be handled and managed appropriately in accordance with internal regulations and shall not be disclosed to others without the permission of the Company’s information management officer. Such information shall not be used for personal purposes or for unfair purposes such as insider trading. We respect intellectual property rights and do not infringe them.

• Information shall be obtained by legitimate means, managed and stored appropriately in accordance with applicable laws and internal regulations, and completely disposed of when no longer necessary. We exercise due care to prevent accidental leakage, maintain organized documents, and store them securely in locked cabinets or other secure locations.
• Outside the Company, we do not discuss Company business or personnel matters in public places such as public transportation or restaurants and exercise due caution to prevent information leakage, even in conversations with family members.
• We do not use obtained information for improper investment activities or to gain personal benefit.
• When disclosing Company information to the media, analysts, or other external parties, we consult with the General Affairs Department or the department in charge of investor relations and follow their instructions.

Maintenance of Workplace Order

We maintain workplace order by complying with the Work Rules and internal regulations and perform our duties faithfully and responsibly.

• Through “reporting, communication, and consultation,” we strive for mutual understanding and work to create an open and dynamic workplace.
• We value cooperation and teamwork and refrain from selfish conduct.
• We respect each other’s human rights and dignity and do not engage in any form of discrimination, sexual harassment, or any other harassments.
• We strive to ensure safety and hygiene, prevent accidents and disasters, and proactively promote a sound working environment.

Response to Violations of the Code of Conduct​

Employees who violate this “Code of Conduct,” the Company’s Work Rules, or related instructions and notices may be subject to disciplinary action in proportion to the extent of the damage caused or the risk posed to the Company’s corporate value. In the case of serious violations that significantly impair the Company’s corporate value, the Group may take legal action to recover damages.

If a director personally violates this “Code of Conduct,” he or she may be subject to penalties under the laws and regulations of Japan or, where applicable, the laws and regulations of the relevant foreign country, and may be liable for compensation for damages under applicable corporate or commercial laws.

Establishment of the Corporate Ethics Committee and “Helpline”

In order to improve and promote corporate conduct based on this “Code of Conduct,” we have established a Corporate Ethics Committee and a “Helpline.”
We also accept consultations and reports from business partners regarding violations of laws or corporate ethics obligations by the Company.