Code of Conduct for the Tokyo Sangyo Group

The officers and employees of the Tokyo Sangyo Group shall always act with sincerity, fairness and a high sense of ethics. The Tokyo Sangyo Group must strive to earn the trust of society and to develop sustainably while fulfilling our social contribution. Therefore, the officers and employees of the Tokyo Sangyo Group must comply with the Code of Conduct for the Tokyo Sangyo Group.

1. Compliance with Laws/Ordinances
   • （1）We shall act in accordance with social norms while complying with the laws/ordinances and regulations of Japan and overseas.
   • （2）We shall comply with the internal regulations and rules established by the company including this Code of Conduct.
2. Respect for Human Rights
   • （1）We shall respect the dignity and rights of all people. We shall not violate human rights.
   • （2）We shall respect the personality, individuality and diversity of all people. We shall not discriminate on the grounds of race, ethnicity, nationality, birthplace, creed, religion, gender, age, physical or mental disabilities, preferences, educational background or otherwise.
3. Realization of a Healthy Work Environment
   • （1）We shall strive to build relationships of trust between officers and employees and to put into practice good communication to promote the creation of an open and cheerful work environment.
   • （2）We shall comply with labor-related laws/ordinances and take into account the mental and physical health of employees while striving to ensure a safe and healthy working environment.
   • （3）We shall not engage in any form of harassment. That includes insulting remarks and words and deeds which apply pressure by using status or position in addition to sexual words and deeds which cause discomfort to others and slander and libel relating to pregnancy and childbirth.
   • （4）We shall not engage in personal activities unrelated to work such as political or religious activities in the workplace.
4. Appropriate Management of Information
   • （1）We shall properly collect and manage personal information. We shall not use personal information other than for the intended purpose or disclose it to third parties without undergoing the proper procedures such as obtaining the consent of the individual concerned.
   • （2）We shall appropriately manage the confidential information of our company and other companies. We shall not leak such information to third parties and we shall not use it unless there is a valid reason to do so.
   • （3）We shall appropriately prevent information leakages, theft and computer virus infections when using computers and software. At the same time, we shall strictly manage personal IDs and passwords.
5. Response to Insider Information
   • （1）If we learn of important undisclosed facts about our company or another company which would significantly affect investor decisions, we shall not disclose them to third parties except when necessary in the course of our duties.
   • （2）If we learn of important undisclosed facts about our company or another company which would significantly affect investor decisions, we shall not buy or sell the shares of the company concerned.
6. Response to Antisocial Forces
   • （1）We shall confront antisocial activities and forces with a resolute attitude and cut off any such relations.
   • （2）We shall not engage in any dealings with business partners who have a relationship with antisocial forces.
7. Fair and Transparent Dealings
   • （1）We shall understand and then comply with the relevant industry laws relating to our dealings.
   • （2）While complying with all trade-related laws/ordinances and international treaties, we shall undertake proper import and export procedures.
   • （3）We shall engage in common sense and fair dealings with our business partners based on respect for each other’s position and an equal relationship.
   • （4）We shall appropriately undertake procedures relating to the acquisition of approvals and the making of various notifications relating to our dealings without omission.
   • （5）We shall not provide unfair money/goods, benefits or other economic advantages to government workers or those in an equivalent position whether in Japan or overseas.
   • （6）When giving gifts or providing entertainment to our business partners, we shall do so within the scope of socially accepted norms. In addition, we shall not accept gifts or entertainment which exceed socially accepted norms from our business partners.
   • （7）We shall not request money/goods or special treatment from our business partners by using our position in our dealings.
   • （8）When engaging in dealings, we shall make choices with a comprehensive judgment taking into account quality, reliability and price. When entering into agreements with those with whom we have a relationship, friends or other interested parties, we must report that relationship to our superiors and receive appropriate instructions.
8. Appropriate Response as a Member of the Organization
   • （1）We shall not engage in acts which damage the interests of the company by using the position or authorities in the course of our duties or based on information learned in the course of our duties. Moreover, we shall not engage in activities which may harm the interests of our company without permission from the company and nor shall we become involved in such activities.
   • （2）We shall appropriately manage company assets. We shall appropriately handle company assets so that they do not become lost or damaged. We shall not use the assets or expenses of the company for personal purposes.
   • （3）We shall not infringe upon the intellectual property rights of others such as through the unauthorized copying of computer software.
   • （4）We shall appropriately perform account processing and undertake accounting procedures according to the relevant laws/ordinances, accounting standards, and internal regulations and rules to ensure reliable financial reporting. We shall perform accurate account processing without concealing facts and without performing false or fictitious processing.
   • （5）We shall not use the company’s information systems for purposes other than business.
9. Response to Social Contribution and Environmental Conservation
   • （1）We shall strive to conserve the environment by complying with environmental-related treaties, laws/ordinances and regulations.
   • （2）We recognize that addressing environmental issues is a challenge shared by all humankind. Recognizing that, we shall take measures against global warming and work to conserve and protect the environment while always taking into account the environment in our business activities.
   • （3）We shall aim for harmony with local communities and the international society as a good corporate citizen. We shall promote social contribution to realize a prosperous and livable society. We shall contribute to the realization of a sustainable society.