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October 27, 2021
Kunimitsu Sato

The Company conducts 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 a 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 and an individual employee, or any other trading or action in which the relationship with the Company and the trading partner would be considered significantly unfair.


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 appropriate time.

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.Respect for Diversity

The Company will respect diversity in terms of culture, nationality, race, ethnicity, language, religion, values, gender, age, gender identity, sexual orientation, and disability, and aim to create a healthy and dynamic workplace.

10.Promotion of Health Management

In order to ensure the sustainability of our business and to enhance our enterprise value, the Company will promote health management to maintain and improve the health of our employees.

11.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.