Objectives

Being aware that each of us is a constituent member of the business enterprise having a characteristic of a social and public institution, we hereby adopt this Code as our moral standard and code of conduct.

Basic Thoughts

We can continue to operate the business only if customers support us and society trusts us.

We keep this in mind and have pride in having as our principle the lawfulness and sincerity that reflects the spirit in which the Company was founded.

Guidelines of Ethical Conduct

We observe applicable domestic and foreign laws with regard for the underlying spirit of such laws and also “behave with integrity as a company and an individual” in order to continue to be fair and sincere to society.  More specifically, we:

1. 1.develop and keep fair relationships with customers, shareholders, parties transacting business with us and all other interested parties;
2. 2.eliminate any relationship with any antisocial force that poses a threat to public order or safety;
3. 3.widely and fairly disclose the Company information and, at the same time, strictly control nonpublic information;
4. 4.respect intellectual property rights in the world and not engage in illegal use of these rights;
5. 5.draw a line between official matters and private matters and not make use of official or business position for personal interest;
6. 6.perform official duties faithfully, keep conscious of our role as a good citizen and a member of a responsible business enterprise, and not deviate from social ethics and morals;
7. 7.respect our frank and openhearted communication environment and make an effort to maintain a sound and effective system of internal checks and balances;
8. 8.respect the differences in culture and customs from those in Japan when engaging in business outside Japan and make an effort for mutual understanding;
9. 9.respect and observe Quality Assurance Code, Environmental Code and other internal rules and regulations; and
10. 10.for the purpose of employee evaluation, give priority to their loyalty to the matters provided in the Code of Ethics.

Management personnel should take the lead in observing this Code of Ethics and make it well known to people within the Company.  If any breach of this Code occurs, Management should investigate the reasons therefore, make efforts to avoid recurrence of such breach and fulfill the responsibility of prompt disclosure of relevant information and explanations for such incidences.

The Code of Ethics, which sets forth our ethics and action guidelines, upholds the principle to “behave with integrity as a company and an individual.” To ensure that business activities adhere to laws and regulations, the Ethics Subcommittee, an organization in which external attorneys participate and which is directly controlled by the President, is held once every two months. The Ethics Subcommittee plans and manages programs seeking thorough compliance through enhancement of staff education and training, and makes final decisions on compliance with various business issues. An officer responsible for risk management reports the detailed activities of the Subcommittee to the Board of Directors.
To deal with doubtful matters on compliance in the Group, the Company has established an internal reporting system which allows executives and employees of the Group to directly inform the Ethics Subcommittee of such matters. The liaison contacts, which may be used by each domestic Group company, have been set both inside and outside the Company, and a system is in place which ensures that Audit & Supervisory Board Members are informed at the same time. The Company also receives information from external sources such as business partners.

The Ethics Subcommittee was established based on the Code of Ethics and the Ethical Action Standards for the purpose of raising the level of ethical behavior of the Company and the Group companies, and is convened six times a year.