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Compliance Manual

From the Foreword of the Compliance Manual
To all the peoole of the company

July 1,2008

The Compliance Manual outlines basic principles that must be observed by all our executives and employees without exception.
We aim to realize fair and adequate management and fulfill our social responsibilities.
As we have created the Company’s Compliance Manual, let us all pledge to proactively comply with the Compliance Manual as well as the laws, regulations and rules related to business operations. This should be done so that we can build an even more ethical corporate culture, with sincerity and equality, regardless of whether an executive or employee, and regardless of job title or duties.
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. We must not hide from the problems we encounter.
We tend to forget to question things amid 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; it will never make it better.
Let us strive to courageously comply with moral principles, and laws and regulations with courage, to create a 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 material 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, the 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 regard 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.