The Company implements business activities under the following four management policies:

1. The Company has a stable and continuous management body
2. The Company is a low fluidity and high-level group of excellent technical experts
3. The Company is an organization that can respond swiftly and precisely to customer needs that change drastically
4. The Company secures and maintains external channels for constantly introducing cutting-edge technology

We hereby establish the “Code of Business Conduct” as a starting point for solutions when tackling various problems that challenge the Company as we make concerted efforts to develop business by putting into practice these management policies, and to continue to be a corporate entity that is of value to society.

I, myself, will take the lead in setting the example so that all Company executives and employees adhere to the “Code of Business Conduct.” When a situation that violates the “Code of Business Conduct” occurs, I will disclose information inside and outside the Company in a swift and precise manner, and implement strict reprimands and strive to prevent reoccurrences after clarifying authority and responsibility.

1. Contribution to Society
The Company will constantly execute healthy management in order to contribute to the healthy development of society and public welfare through the business that the Company engages in.
In addition, the Company’s ability to be involved in the enhancement of social convenience through services and new technologies that the Company offers is a source of joy for all executives and employees alike, and the Company will continue high-quality development activities.

2. Compliance with Laws and Regulations
The Company will establish the “Compliance Manual” to familiarize all executives and employees on compliance with laws and regulations, which the Company considers as a primary matter in corporate activities.
Company executives and employees shall not only understand the wording of laws and regulations, but also the legislative intent and purpose, and shall constantly act in accordance with ethical judgment based on conscience.

3. Management of Information
The Company shall not leak to a third party any confidential information (including personal information) or information on the Company or other companies obtained through the course of business unless there is legitimate reason, such as approval by the party concerned or a request based on laws and regulations. Confidential information and such shall be strictly managed according to laws and regulations and in-house rules.

4. Protection of Intellectual Property
The Company rightly acknowledges intellectual property of third parties and respects their value.
Furthermore, the Company will not, under any circumstances, tolerate actions that attempt to violate the rights of third parties.

5. Compliance with Fair and Equitable Trading
The Company will practice sincere and fair trading. The Company will not conduct any of the following types of trading or actions, including doubtful actions, such as insider trading that gives preferential treatment to some shareholders and investors, trading that provides benefits to employees themselves, trading in which there is a conflict of interest between the Company or individual employee, or any other trading or action in which the relationship with the Company and the trading partner would be considered significantly unfair.

6. Disclosure
The Company will disclose to shareholders, investors and all other stakeholders in accordance with the IR Policy all important information concerning investment decisions in a fair, accurate and easily understandable manner at the adequate timing.

7. Isolation from Antisocial Forces
The Company will always take a resolute stance toward antisocial forces that threaten the safety of citizens. In addition, the Company will decisively confront any contact from antisocial forces.

8. Establishing a Good Corporate Climate
The Company will provide job duties that allow employees to grow and build a comfortable work environment based on the thinking that each employee is the biggest management asset of the Company. The Company will also respect the individuality and personality of respective employees and implement adequate evaluations and treatment according to job description and contributions to business performance.

9. Prohibition of Discrimination
The Company will not discriminate based on sex, ethnicity, nationality, religion, ideology, physical handicap or any other personal attribute.

10. Consideration for the Global Environment
As a global citizen, the Company duly considers environmental protection. The Company will establish and maintain a “work environment that is friendly to the environment and people” by harmonizing protection of the natural environment and the safety of employees.

I believe thorough implementation of compliance is one of the top-priority issues for the Company to conduct corporate activities according to management principles, respond to social expectations and fulfill its responsibilities.

I hereby stipulate the basic policy for all executives and employees to thoroughly implement compliance. In practicing this basic policy, the “Compliance Manual” that corresponds to the respective situations in executing specific business tasks will be prepared in an effort to foster the spirit of compliance in all executives and employees, and implement business activities that place compliance as the top priority.

1. We acknowledge the social responsibility and public mission of the Company’s operations, and will execute healthy corporate management and business conduct.
2. We will comply not only with the wording of laws and regulations but also with their legislative intent and purpose.
3. We will respect the individuality of all parties concerned business and otherwise, and contribute to the healthy development of the social economy.
4. We will take a resolute stance against antisocial forces.
5. We will strive to leave behind a richer and fairer society for future generations.

This Compliance Manual compiles matters that require attention regarding issues considered to be of particular importance in implementing the Company’s business.

Therefore, the Compliance Manual does not cover everything, but is an indication of the basic thinking. Please consult your immediate supervisor or the Compliance Team of the General Affairs Group of the Administrative Division on issues that are not directly indicated, or any complex issues that are difficult to resolve on your own.

It is important that we speak up when we have doubts about business practices or business procedures, etc. We must not hide from the problems we encounter.

We tend to forget to question things amidst our busy daily business, but what is important is maintaining a stance of always reviewing what we do, what we have done, and what we are about to do from a compliance perspective.

An attitude of leaving the responsibility up to others, rooted in the thinking that “This is not my problem. Someone else will probably resolve it.” or an irresponsible attitude in thinking that “You just do what others are doing and it is fine, because business is not just pretty words” may harm our Company, but will never make it better.

Let us strive to courageously comply with moral principles, and laws and regulations with courage, to create workplace worth working for and that we can be proud of.

I stress that the standards of judgment concerning complying with moral principles, and laws and regulations ultimately lies in your conscience and noble character. No matter how detailed we make the compliance manual or how much materials regarding laws and regulations we distribute, we cannot possibly cover everything or make everything understood.

As internationalization, informatization and deregulation progress, and in these modern times where speed is demanded in business, the greatest emphasis is on each individual having a mental attitude to adhere to the principles of the Compliance Manual and have a courageous conscience. It is important to make ethical judgments based on this conscience on the fundamentals of business.

“Ethical judgments based on conscience” refers to the act of questioning the appropriateness of your actions from a fair, third-party perspective, putting aside your personal interests or the interests of your workplace or business. If an action will not be condemned by anyone and is satisfactory in anyone’s eyes, that action can be considered to be non-problematic.

However, if you find a situation that is extremely complex and difficult to make a judgment on, please be sure to consult your immediate supervisor or the Compliance Team without delay.

Moreover, if you believe that the Company’s actions deviate or may potentially deviate from laws and regulations, articles of incorporation, in-house rules, the Compliance Manual, etc., please promptly report this fact.

Please consult and make inquiries to the Compliance Team and Internal Audit Office with a sense of security, as your privacy will be protected, and depending on the case, you will also be entitled to whistleblower protection.

If any type of reprisal is made in connection to such reporting, consulting or inquiry, we will immediately investigate the facts and address the issue.

We beseech you to be courageous and speak out concerning any problems when they occur. This is what will create a workplace that is comfortable for us to work in, and the best way for our Company to gain the confidence and high appraisal from society and the market.

Our aim is to build a fair workplace, healthy business relationships and to contribute to the development of society through our work. Our foundation is fair business, and our mission is to enrich society.

In the unfortunate event that violations of laws and regulations or rules are found, or we discover such through a subsequent internal audit, we will take strict measures including punitive dismissal based on work regulations, etc. after verifying the relevant facts.