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Corporate Outline/Code of Conduct

Code of Conduct

With all of its board members and employees abiding by this Code of Conduct, the Shinano Kenshi Group is committed to living up to the trust placed on us by society.

I Human Rights and Labor

1.Prohibition of forced labor

We employ all people based only on their own free will. As well, we do not engage in forced labor, debtor’s labor, slave labor, or inhumane prison labor. We guarantee that all of our employees can leave his or her job by giving proper notification to the company and are not be obliged to provide us with his or her I.D. card, passport, or work permit.

2.Prohibition of inhumane treatment

We respect employees’ human rights and prohibit inhumane treatment, such as ill-treatment, bodily punishment, sexual harassment, and power harassment (harassment through overbearing acts or abusive language).

3.Prohibition of child labor

We do not employ children who fall short of minimum employment age requirements. Nor do we employ young workers in a way that can retard their development.

4.Prohibition of discrimination

We seek to realize fairness in terms of equal opportunity and equal treatment by eliminating discrimination in recruitment and employment.

5.Adequate wages

We observe the legal minimum wage as stipulated by wage-related laws and regulations, and we do not make unfair deductions as a means of wage cutting.

6.Working hours

In order to keep our employees’ total working hours within legal limits, we properly manage each employee’s number of working days and working hours, as well as their taking of weekly days-off and annual paid leave.

7.Employees’ rights to assembly

We respect our employees’ rights to assembly as a sound means of promoting labor-management consultation in the work environment, wage standards and other related matters.

II Safety and Hygiene

1.Machinery and equipment safety measures

To prevent the occurrence of accidents while at work, we take proper safety measures for and conduct proper maintenance of machinery, equipment, jigs, and tools.

2.Workplace safety

We evaluate risks concerning workplace safety and ensure such safety by means of appropriate process design, as well as by using pertinent technological and management measures.

3.Workplace hygiene

We examine the state of our workplaces with regards to risks from exposure to pests, hazardous chemicals, noise and offensive odors, the results of which are used in working out workplace hygiene criteria, providing protective equipment as necessary, and for promoting hygiene education for our employees.

4.Industrial accidents and diseases

We examine the state of industrial accidents at workplaces and work-induced diseases, and utilize the results to work out various countermeasures: such as the promotion of accident/disease reporting by employees; the classification and recording of industrial accidents and diseases; the provision of necessary medical care; the conducting of surveys on industrial accidents and diseases; the implementation of corrective measures to remove such causes; and the promotion of employees’ comeback to their workplaces after suffering from industrial accidents or diseases.

5.Responding to emergencies

To protect our employees’ lives and ensure their safety, we prepare measures against emergencies based on the likelihood of possible disasters and accidents, and make such measures known thoroughly among our employees at their workplaces. In the event an emergency occurs, we will make our best efforts to minimize its impacts and bring any damage back to normalcy as early as possible.

6.Consideration to jobs involving burdens to the body

For proper job management, we identify the types of jobs that involve heavy burdens to the body of employees. By supplying appropriate work-aid tools or by other means, we can help to keep these types of job from causing industrial accidents or work-induced diseases.

7.Safety and hygiene of employees’ living facilities

When it comes to facilities that support our employees at workplaces (such as dormitories, dining rooms, and restrooms), we properly secure the safety and hygiene of such living environments with respect to the supply of safe drinking water and fire preventive measures, the establishment of emergency evacuation routes, proper ventilation, and temperature management controls, and the proper management of personal belongings.

8.Employee health care

We offer periodical health examinations for all of our employees for the prevention and early detection of diseases.

III Environmental Initiatives

1. Development of environment-friendly products and services

We continue to strive to develop products and services designed to reduce negative impacts on the environment.

2.Management of chemicals contained in our products

We manage all of our products as to the content of designated chemical substances to ensure compliance with laws and regulations.

3.Management of chemicals used in manufacturing processes

When it comes to manufacturing processes using chemical substances that are designated by each host country, we exercise responsible management methods for such chemicals through proper storage, transfer, handling, reuse, and disposal, always in compliance with local laws and regulations.

4.Environmental management systems

At each one of our production sites, we establish and operate an environmental management system.

5.Minimizing impacts on the environment (regarding wastewater, sludge, and exhaust gas)

We make ongoing efforts to minimize the negative impacts of our operations on the environment by complying with each host country’s laws and regulations regarding wastewater, sludge, exhaust gas, and other pollutants. We also make further improvements as necessary based on our own in-house environmental criteria.

6.Environmental permits/administrative permits

Complying with each host country’s laws and regulations, we obtain permits and/or authorization from the local government whenever necessary and submit environmental management reports to the local government as required.

7.Initiatives toward reduction of negative impacts on the environment

In all aspects of our operations, we promote initiatives toward the reduction of our negative impacts on the environment through activities, such as the prevention of global warming, the effective utilization of energy and other resources, and the reduction of industrial waste.

IV Fair trade practices and business ethics

1.Prohibition of corruption and bribery

By maintaining sound and normal relationships with related politicians and public service personnel at all times, we never offer illegal political contributions or engage in bribery.

2. Prohibition from abusing positions of superiority

We never abuse our position of superiority as a purchaser or consignor to compel suppliers of commodities or services to accept unfair terms and conditions of business to their disadvantage, including delay in payment.

3.Prohibition of offering or receiving unjustifiable benefits

Vis-à-vis our business stakeholders, we never offer or receive unjustifiable benefits.

4.Prohibition of competition-restrictive conduct

Committed to fair, transparent, and unrestricted competition, we never perform acts that impede such competition. Vis-à-vis other companies in the industry, we never engage in collusion or behind-the-scenes agreements that restrict mutual free business activities with regards to terms and conditions of bidding, product prices, sales conditions, profits, market shares, and marketing territories. Furthermore, when choosing our suppliers, we offer fair opportunities to all interested suppliers.

5.Provision of accurate product/service information

We provide our consumers and industrial customers with highly reliable products and services while simultaneously providing them with accurate and up-to-date information on these products and services. We as well do not use improper product labeling that may mislead our customers in their product choice.

6.Respect for intellectual property rights

We respect intellectual property rights and perform proper management to ensure that we do not infringe on the intellectual property rights of other parties.

7.Exercising proper external trade management

When it comes to the import or export of technologies and commodities that are regulated, we perform proper export/import formalities by establishing a lawfully definite export/import management setup of our own.

8.Disclosure

We disclose, in a timely and appropriate manner, accurate corporate information regarding our company’s current state of business activities and business results.

9.Prevention and early detection of unlawful acts

We promote activities that prevent unlawful acts while also maintaining a system that enables early detection of and timely response to such acts.

V Product/Service Quality and Safety

1.Ensuring product/service quality and safety

We give full consideration to the quality and safety of our products or services to ensure that they meet the safety criteria required by each host country.

2.Quality management systems

At each one of our production sites, we establish and operate a quality management system.

VI Information Security

1.Defense against threats to our computer network

By taking measures to protect our computer network against threats, we ensure that both our company and other members of our computer network are not affected by such threats.

2.Preventing leakage of personal information

We properly manage and protect all personal information that has been obtained at our workplaces or through our business activities.

3.Preventing leakage of confidential information

We properly manage and protect all confidential information that has been obtained through our business activities.

VII Social Contributions

1.Contributing to local community and society at large

We promote interactions with both international and local communities and carry out our own activities that can contribute to the development of such interactions.