This Compliance Code of Conduct (hereinafter referred to as "this Code") is established based on the Code of Conduct of Daiken Corporation and its group companies. This Code applies to all officers and employees, etc. (hereinafter referred to as “we”, including contract workers, contract employees, temporary workers and part-time workers) of Daiken Corporation and its group companies (hereinafter referred to as "Daiken"). As a member of the international community, we respect all human rights, comply with laws and social regulations, and act with high ethical based on corporate philosophy. Further, we will comply with this Code with the recognition that achieving these social responsibilities will lead to the enhancement of Daiken’s corporate value.
（1）Compliance with Laws and Corporate Ethics
We properly understand and comply with domestic and foreign laws and regulations that apply to our business activities, act with decency that does not violate corporate ethics and strive to earn the trust of society.
（2）Ensuring Transparency of Donations
We act appropriately and in accordance with relevant laws and company regulations when making donations to political or other groups. We always ensure transparency so as to avoid the appearance of having a cozy relationship with politicians or the bureacracy.
（3）Response to Anti-social Forces and Groups
We are always aware of maintaining compliance with laws and corporate ethics, and take a firm attitude towards anti-social forces and groups to avoid any form of relationship with them.
（4）Protection of the Environment
- In order to contribute to the realization of a sustainable society and protection of the global environment, we comply with relevant applicable laws, rules and regulations, we have establish ed the Daiken Group environment pol icy, and through our corporate activities we proactively address issues of global environmental conservation and consideration towards biodiversity.
- In order to expand manufacturing and products that consider the global environment, we have established Green Procurement Standards, under which we share issues concerning environmental conservation activities with our business partners and cooperate to protect the global environment.
（1）Response to Safety
We comply with relevant laws and regulations, and prioritize safety in all products and services. We will take prompt and appropriate action if we receive information about a safety issue.
（2）Improving Customer Satisfaction and Trust
We strive to provide products of excellent quality that satisfy our customers at reasonable prices in accordance with relevant laws and our corporate philosophy, and give due consideration to improving the quality of our products and services. We will respond promptly and in good faith to customer suggestions or requests regarding quality issues and strive to prevent recurrence.
（3）Sincere Sales Activities
We comply with relevant laws and regulations, and carry out sincere sales activities in accordance with sound trading rules.
（4）Appropriate Displays in Advertisements
We understand the meaning of and comply with consumer protection laws and regulations, strive to thoroughly explain the quality, performance and specifications of products and services in advertising and other sales activities, and do not make representations that differ from fact or may cause misunderstanding by customers.
（5）Management and Protection of Customer Information
We obtain the personal information of our customers appropriately, manage it strictly and prevent leaks and unauthorized use in accordance with laws and corporate regulations.
（1）Promotion of Free Competition
In order to promote fair and free market competition, we do not engage in acts that violate antitrust laws, such as cartels, bid rigging , maintaining resale prices or abuse of superior bargaining position.
（2）Appropriate Transactions with Suppliers
We comply with relevant laws and regulations such as the subcontracting law, execute appropriate contracts and conduct appropriate transactions.
（3）Prohibition of Infringement of Rights
We respect the rights of others and do not use any third-party intellectual property rights without permission or obtain or use other companies’ trade secrets by improper means.
（4）Gifts and Entertainment
We do not give or accept any entertainment or gifts that exceed societal norms.
We have established the Daiken CSR Procurement Standards as one of the means to provide products and services that meet the expectations of our customers and to realize a sustainable society in which people and the environment can coexist. We strictly comply with the standards and carry out procurement activities in cooperation with our business partners.
（6）Compliance in Overseas Business
- We comply with national, regional and international laws and rules, understand the social conditions in each country/region, and conduct business activities with due regard to local culture, customs and religion.
- We comply with the Foreign Exchange and Foreign Trade Act and other relevant domestic and foreign laws and regulations, and strictly comply with company regulations and procedures to properly conduct import and export transactions.
（1）Disclosure of Management Information
In accordance with relevant laws and regulations, we appropriately disclose our management policy, financial details, business activity status, etc. to shareholders and investors, strive to promote the understanding of our business activities and sincerely respond to opinions.
（2）Prohibition of Insider Trading
We do not trade stocks using undisclosed material facts concerning Daiken related companies or business partners, and we do not disclose such undisclosed material facts to third parties. We strictly adhere to the procedures stipulated in our company regulations when trading Daiken stocks to avoid the suspicion of insider trading.
（1）Respect for Human Rights and Prevention of Discrimination
Respect for Human Rights and Prevention of Discrimination We respect the human rights of each individual and will never commit any acts that are linked to discrimination on the grounds of sex, age, nationality, race, ethnicity, beliefs, religion, social status, disability, gender identity or sexual orientation.
（2）Prevention of Harassment
We receive continuous education on workplace harassment such as bullying and sexual harassment, and we continue to work to create a workplace where such acts are neither committed nor tolerated.
（3）Utilization of Internal Reporting
We do not ignore any harassment or other misconduct and will promptly and proactively report it to superiors or consult with and report to internal and external whistleblowing services . In addition, we will accomplish the protection of whistleblowers according to relevant laws and company regulations.
（4）Respect for Privacy, Protection of Personal Information
We respect the privacy of each individual. We use personal information that we acquire through our work in accordance with relevant laws and regulations and only for the purpose for which it was obtained , and we strictly manage it so that it is not leaked to third parties.
（5）Ensuring Workplace Safety and Hygiene
We comply with laws related to safety, health and disaster prevention, strive to prevent workplace accidents, and strive to ensure a safe, healthy and comfortable working environment.
（6）Ensuring a Comfortable Working Environment
We comply with labor laws and promote the creation of a workplace that builds relationships of trust, we evaluate each employee fairly and equitably, and strive to ensure a comfortable work environment that enables growth and self-fulfillment.
（1）Fair and Transparent Business Operations
We take responsibility for conducting fair and transparent business operations in accordance with relevant laws and regulations as well as company regulations and policies. We also carry out appropriate and transparent accounting and tax affairs and strive to establish effective internal controls.
（2）Confidential Information Management
- We recognize the importance of confidential information obtained through our business activities and strive to prevent leak s by strictly and appropriately managing such information in accordance with relevant laws and company regulations.
- We strictly adhere to company rules and regulations regarding security when using electronic devices to thoroughly prevent information leak s as well as unauthorized external access.
（3）Management and Proper Use of Corporate Property
We properly manage Daiken’s assets (both tangible and intangible) in accordance with relevant laws and company regulations, and do not use such for private or any other non business purposes.
We recognize that intellectual property rights are important company assets and strive to preserve such rights and make effective use of them.