Guidelines for Corporate Behavior

1. Compliance

(Compliance with social norms)
- As a corporate citizen, we will act in accordance with the highest ethical standards and in a manner that is consistent with the expectations of the general public.
(Compliance with laws)
- We will ensure that our understanding of domestic and international laws and regulations, as well as the amendments to these, is accurate and up to date, and will then apply this knowledge appropriately.
- We will comply with all legal requirements regarding reporting and notification to the relevant administrative agencies.
(Compliance with internal regulations)
- We will ensure that we have a proper understanding of internal regulations and that we are kept informed of any revisions.
- We will ensure that all reporting and notification procedures as outlined in our internal regulations are carried out.

2. Information Management

(Compliance with confidentiality obligations)
- We will not divulge confidential information to third parties or use it inappropriately without permission, whether during employment or after retirement.
- It is prohibited to divulge to third parties or misuse for improper purposes any non-public information about customers, business partners, etc. that has been obtained in the course of duties without permission, whether during employment or after retirement.
- Information about individuals such as shareholders, customers, officers and employees, etc. must not be disclosed without the consent of the individual concerned, unless there is a legal requirement or legitimate business need to do so.
(Respect for intellectual property rights)
- We will respect the intellectual property rights of third parties. This encompasses, but is not limited to, patent rights, utility model rights, design rights, and copyrights.
- Confidential information held by third parties shall not be acquired or used in an improper manner.
(Security management)
- Facilities and fixtures will be appropriately managed by locking and using passwords.

3. Communication

(Relationship with customers)
- We will promptly incorporate customer feedback into our work processes.
- We will endeavor to provide proposals that take into account safety, quality, delivery times, and costs to the greatest extent possible in response to customer requests.
- We will not offer customers any economic benefits, such as money, gifts, or entertainment, that exceed socially accepted norms.
- We shall not provide gifts or entertainment to public officials that are prohibited.
(Relationship with business partners)
- We will strive to be transparent and fair in our interactions with business partners, aiming to establish a foundation of trust as reliable business partners.
- We will comply with all relevant laws and regulations, including the Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors, and similar laws and regulations in other countries.
- We will not receive from business partners any economic benefits, such as money, gifts, or entertainment, that exceed socially accepted norms.
(Relationship with shareholders)
- We will provide shareholders with appropriate information in a timely manner, with their interests in mind.
- We will fulfill our duties with the highest ethical standards and a sense of responsibility.
- We will strive to strengthen our financial position and corporate governance for long-term stable growth and development.
(Relationship with society)
- We will maintain fair, clear, highly transparent, sound, and normal relationships with all stakeholders to ensure trust and confidence in our business practices.
- We will collaborate with local communities to facilitate their progress and development through fostering close interaction.
- We recognize that our business activities have a significant impact on the environment and are committed to proactively addressing these challenges.
- We will sever all ties with any antisocial forces or groups that pose a threat to the stability and security of our society, and will not engage in any activities that encourage such activities. Furthermore, should any issues arise with such forces or groups, we will address them in a resolute manner as a company.

Guidelines for Employee Behavior

4. Human Rights

（(Prohibition of discrimination)
- We respect human rights and do not discriminate on the basis of birth, nationality, creed, religion, gender, race, ethnicity, age, intellectual or physical disability, medical history, hobbies, educational background, or social status.
- We do not use words or expressions that could be considered discriminatory or that could be misinterpreted.
- We endeavor to foster a culture of respect and harmony with diverse cultures and customs.
(Prohibition of harassment)
- Do not engage in sexual harassment or make sexually suggestive comments that may cause discomfort to the other person. Furthermore, avoid any actions or behaviors that could be misconstrued as such. - Do not use language or make demands that are violent, unreasonable, or unattainable. Furthermore, avoid any actions or behaviors that could be misconstrued as such.

5. Strict Separation Between Company and Private Matters and Prohibition of Conflict of Interest, etc.

(Strict separation between public and private matters)
- Maintain a clear distinction between your professional and personal roles. Personal interests should not be brought into the workplace, and company positions should not be applied to personal matters.
(Prohibition of conflict of interest)
- Company property must not be used for personal gain.
- Company assets and expenses must not be used in a manner that is contrary to the company’s interests.
- Documents and information must be managed appropriately and protected from any leakage.
(Prohibition of insider trading)
- Employees and officers in a position to obtain knowledge of important company matters shall not trade in the company’s shares for personal gain before the information is made public.
- Officers and employees who have gained knowledge of significant customer or business partner matters in the course of their duties shall not trade in the shares of those companies for personal gain before the information is made public.

6. Reporting, Consultation, and Disciplinary Action

(Response to detection of misconduct, etc.)
- If an officer or employee becomes aware of any form of misconduct or an act that may be considered misconduct, they are expected to first issue a caution to the individual in question. If this is not possible, the matter should be immediately brought to the attention of their superior. However, if the situation does not improve, the matter should be reported and referred to the General Affairs Section without delay. No action should be taken to turn a blind eye to or cover up the misconduct of other officers or employees.
- Officers and employees shall cooperate fully with any and all investigations into alleged misconduct. In the event that misconduct is confirmed, the individual(s) responsible and their supervisor(s) will be subject to disciplinary action in accordance with the company’s Rules of Employment.
- The company will maintain the confidentiality of officers and employees who report or consult about misconduct, cooperate with investigations, and guarantee that they will not be treated disadvantageously.

Guidelines for Management Behavior

7. Guidance and Supervision

（(Thorough instruction of the Guidelines)
- It is the responsibility of officers and employees in management positions to uphold the spirit of these Guidelines. It is their duty to provide guidance and supervision to ensure that these Guidelines are faithfully implemented.
- Officers and employees in management positions will request that our affiliated companies and business partners, to whom we dispatch employees to work on-site, comply with these Guidelines.

8. Responsibilities

（(Responsibilities of top management)
- In the event of a serious violation of the law or of these Guidelines, the top management will assume responsibility for resolving the problem, including investigating the cause and preventing a recurrence.
- Top management will fulfill their accountability to disclose information to society in a timely and accurate manner and will take disciplinary action, including against themselves, if necessary.