1. Employees and executives must not make any improper solicitation that can be a cause of blame in society to a stakeholder directly or via a third party.

2. Employees and executives must not receive any illegal solicitation from stakeholders directly or through a third party, and must clearly indicate their intention to refuse it.

1. Directors, officers and employees must not acquire shares of any supplier in the name of themselves or their family/relative or make an investment or acquire an asset jointly with a stakeholder, through unfair use of their rank or position.

2. You must not practically own any supplier in the name of yourself or your family/relative.

3. You may not work as a director/officer/employee of a supplier by yourself or using the name of your family/relative, or practically perform a job of the supplier.

1. Falsification and tampering of documents and calculations
① You must not falsify or tamper any documents or calculations, whether intentionally or negligently.
② In particular, all accounting documents, including settlement of accounts, must be prepared fairly in accordance with tax laws and enterprise-accounting standards and reported to stakeholders, including shareholders.
③ All documents and calculations of certain types, which are recorded by directors, officers and employees and submitted to the Company, must be prepared accurately and honestly.
④ Where you falsify a document or calculation arbitrarily and consequently impose damage on the Company, you shall be subject to civil and criminal responsibilities.

2. False reports
(1) Where you make a false report in the course of your business and consequently disrupt the Company’s business or damage the Company, you are responsible for such damage.
(2) The provision under the preceding (1) shall also apply to where you make a false report by arbitrarily falsifying business information.

1. Definitions
“Illegal and unfair use of company assets” refers to any act of using the Company’s asset without permission and consequently wasting it or disrupting business, including:
(1) Use of tangible and intangible assets for unauthorized purpose.
① Act of using the Company’s tangible asset such as equipment without permission or taking it out of the Company for selling, etc. ② Act of using consumables for unauthorized or personal use.
③ Act of utilizing or illegally disclosing the Company’s intangible intellectual asset to be protected as confidential information, such as freight prices, for profits of yourself or someone else.
(2) Embezzlement and misuse of corporate funds (budgets and costs).
① Act of withdrawing and using the Company’s money without permission.

2. Basic principles
(1) The Company’s tangible and intangible assets and confidential information, etc., are its material assets, and thus must not be used for personal or non-business purposes, and directors, officers and employees are responsible to prepare for the loss, misuse or theft of such assets.
(2) The Company’s budgets and expenses are corporate funds and thus must be executed in a reasonable and efficient manner in accordance with their purpose and criteria. Corporate funds are limited resources for creating new profits and improving the value of the Company, and thus must be executed efficiently in accordance with fair and transparent procedures.

3. Prohibition on the use of tangible and intangible assets for unauthorized purposes
(1) You must not use the Company’s assets (human and material resources) for any non-business purpose or spend your business time on personal affairs, impeding business efficiency.
(2) The Company’s goods, including vehicles or computers, must be used only for business purpose, and must not be used for personal purpose. During your business hours, you should not do anything not directly related to business, such as excessive internet surfing, stock trading, chatting, and gaming.
(3) You must use the Company’s electronic communication network only for business or authorized purposes, and must not misuse it for indecent or commercial purposes (your or someone else’s sideline, business promotion, etc.) or take out any confidential information using the Company’s system.
(4) You must not do any act of gaining improper benefits, running business or working for someone else’s business by utilizing any information or knowledge you have acquired using your rank or position for your personal profits.
① You must ensure that neither you nor anyone else gains any improper benefits by using the Company’s internal information you came to know directly or indirectly in the course of your business.
(a) You must not do any act of providing the Company’s non-public information to someone else and getting paid for it or using such information in stock investments, etc., and as a result, gaining improper benefits.
(b) Even after you retire from the Company, you must not provide to someone else or use any intellectual property rights, information and technology, etc. you have obtained in the course of business for personal profits.
② You must not engage in any profit-making sideline or second employment that would affect your business without the Company’s permission.
(a) Without the Company’s permission, you must not engage in any sideline or secondary employment that would affect your business at the Company, or you must not establish and operate a separate business, for personal profits.
(b) You must not make a detour investment in any supplier of the Company using the name of yourself or your family/relative.
(c) Pyramid sales is strictly prohibited, and you must not force any director, officer or employee or stakeholder to buy such goods for the purpose of supporting such pyramid sales of yourself or your family/relative or acquaintance.

4. Embezzlement and misuse of corporate funds
(1) You must use any corporate fund for its prescribed purpose and must not embezzle and spend it or arbitrarily divert to other purposes.
(2) It is strictly prohibited to file a false invoice on any cost not incurred and withdraw the Company’s money.
(3) You must not report any cost spent for non-business purposes as the Company’s expense.
① You must not use expenses allocated for entertainment, meetings, department operation, business trip, etc., for personal entertainment or social activities.
② You must not use a company credit card for personal purposes.
(4) Investment budgets or regular expenses on purchase of materials, etc., must be allocated and executed reasonably in accordance with the Company’s business policy.

1. Directors, officers and employees must not make any remark or engage in any behavior that would damage sound colleague relationships, including physical, verbal and/or visual behaviors that would give a sense of unpleasantness or fear to others.

2. You must do your best to prevent any sexual harassment in the workplace.
For the purposes of this Policy, sexual harassment in the workplace (the “sexual harassment”) means an employer, superior or worker making the other party feel sexual humiliation or aversion through verbal or physical behavior of a sexual nature, sexual demand, utilizing his/her position or in relation with his/her duties, or expressing their intention to put the other party at a disadvantage on grounds of not complying with any verbal or physical behavior of a sexual nature, including:
(1) Making physical contact or touching specific body parts.
(2) Making a dirty joke or making a sexual remark (including mobile texting, SNS, phone call).
(3) Making a sexual comparison or evaluation about appearance.
(4) Forcing or conciliating for a sexual relationship.
(5) Forcing someone to sit next and making him/her pour drinks at a get-together, etc.
(6) Posting or showing pornographic photos, drawings, scribbles, publications, etc. (including online communication or smartphone, etc.)
(7) Any verbal or physical behavior deemed reasonable enough so as to cause sexual humiliation.

1. Protection of the Company’s information
(1) To protect the Company’s information, you must be fully aware of the Company’s security control policy.
(2) You must go through the official approval process before you disclose any of the Company’s trade secrets at a meeting, outside lecture or seminar or provide to any outside organization.
(3) You must not arbitrarily use the customer database, etc., for personal purposes without permission.
(4) Control of the Company’s material information must be in place to prevent it from leaking without permission, and to this end, proper security action must be taken.

2. Document control
All information must be recorded and reported accurately and honestly, and directors, officers and employees must record and retain all documents relating to decision making in accordance with the Company’s document control policy.

1. Where you request a public official to give a lecture, etc., and pay compensation to them, you must comply with the standard compensation amount.

2. Where you pay a compensation exceeding the amount under the preceding paragraph 1, you must report to the team in charge, and request the recipient to return the excess.

1. Employees and all related persons (agent, intermediary, etc.) performing their duties on behalf of the company shall not provide or promise to provide cash or anything else of value to foreign public officials or interested parties, and shall not make an improper solicitation. In addition, executives and employees and all related persons (agent, intermediary, etc.) performing their duties on behalf of the company shall not pay express charges improperly. (Express charges include payment of compensation for expedited handling or completion of routine government business such as visa issuance or customs clearance.)

2. All officials (agent, intermediary, etc.) performing their duties on behalf of employees and companies shall comply with domestic and foreign anti-corruption laws such as the Act On Combating Bribery Of Foreign Public Officials In International Business Transactions, the Foreign Corruption Practices Act, and the British Bribery Act, as well as relevant international agreements such as the OECD Anti-Bribery Convention and the United Nations Convention on Anti-Corruption.