SAKATA INX Group Code of Conduct and Ethics

• With Society and Community
• With Shareholders, Customers and Suppliers
• With Employees
• Supplementary provisions

With Society and Community

Complying with laws and regulations

Complying with domestic and foreign laws and regulations is a matter of course, we will always keep in mind to conduct fair and honest corporate activities based on social norms and corporate ethics.

Regulations on act of endowment and political contributions

When political contributions and contributions to various organizations, etc. are made appropriately, all applicable laws and regulations must be complied, and its necessity and adequacy must be thoroughly considered.

Break off relations with Antisocial Groups

We will firmly maintain our stance against groups or individuals who pursue economic gains by using violence, power and fraudulent methods (“Antisocial Groups”) and unjust pressure. We will not give into unjust requests from Antisocial Groups and will exclude them.

Coexistence with community

We will coexist in harmony with the community whether in Japan or abroad, and respect its culture and customs. We will contribute to the community with activities as a good corporate citizen.

Environment preservation and protection

We acknowledge protecting the environment as an important business challenge. We will continue to propel corporate activities considering the environment.

Security export control

In order to comply with applicable export control related laws and regulations for all export transactions including domestic trade under the premise of export, we will gather information as much as possible on export destination country, application, end-user, etc., and thoroughly and appropriately manage all export transactions.

With Shareholders, Customers and Suppliers

Pride for our shareholders

Through sound corporate activities, we will provide pride for our shareholders by enhancing sustainable corporate values, appropriate and stable return on profit.

Disclosure of management information

We will adequately and timely disclose management information of the situation on corporate activities, etc. including our financial contents to heighten transparency in management.

Ban on insider trading

Acts to gain unjust profit by taking advantage of insider information on us, business partners, etc. acquired in the course of one’s duties etc. that inhibit the soundness and fairness in the securities market will not be conducted.

Maintaining and propelling fair and free competition

• We will enforce fair transaction based on free competition principle, which complies with all applicable competition related laws and regulations including but not limited to Japanese Antimonopoly Act and Unfair Competition Prevention Act among all business partners.
• We will not form cartels with others in the same trade and industry groups, which results in restriction of free competition in price, quantity, business partners, etc.
• We will not engage in unfair business methods through abuse of superior bargaining position, unreasonable restraint of handling competing goods that we sell, etc.

Fair transaction with suppliers

When selecting a supplier, we will decide the most suitable supplier by fairly and impartially comparing and evaluating the following conditions: quality, price, delivery time, stable capacity to supply, technological development capability, information power, etc.

Ban on unfair competition

• Third parties’ confidential information will not be obtained by unjust means, and will not be used to acquire unjust profit or cause damage to third parties for any reason.
• We will not libel and slander others in the same trade and their products, etc. by false or groundless information to damage their reputation and credibility in their business.

Entertainment and gifts

• We will comply with all applicable laws and regulations and will not offer entertainment and gifts beyond the bounds of socially accepted limits to public employees or any like persons.
• Entertainment and gifts can be given within the bounds of social common sense.

Ensuring safety

• We will ensure high level of safety when developing products and services, production, sales, etc.
• We will immediately confirm the facts on receipt of safety and quality information of products and services. If a problem were to be found, prompt and appropriate measures will be taken.

With Employees

Respect for human rights

• Unjust discrimination based on nationality, race, belief, religion, gender, physical disability and other reasons is not allowed.
• Acts of harassment such as sexual harassment that make the other person feel uncomfortable, forced labor through the use of violence, libel, slander and intimidation, bully, negative remarks on pregnancy, childbirth, maternity leave, family-care leave etc. are not allowed.

Creating a better healthy and safe workplace and working environment

• We will comply with our company rules on health and safety in operations, and promote to create a better.
• When disasters, etc. occur, damage must be minimized as much as possible. We must implement designated procedures in order to prevent reoccurrence.
• We will make efforts to consider the health of mind and body of our co-workers and subordinates and create a pleasant working environment for each other.

Ban on conflicts of interest with us

We will not engage in activities that have conflicts of interest with us such as selling products, providing service, etc. that competes with our business.

Management of information

• Confidential information must be recognized as our import asset and strictly controlled. Such information must not be leaked outside of us, and not be used for other than its designated purpose.
• When confidential information is disclosed to anyone outside of us, necessary measures must be taken such as non-disclosure agreement, etc.
• All confidential information must be handed to us when employees retire, and must not leak such information and cannot use it for any purpose even after he/she has retired.
• Personal information acquired in the course of one’s duties must not be used for purposes other than the original intent, and must be appropriately managed so that it is not leaked.

Appropriate use of corporate asset

Computer, production apparatus, equipment and other assets owned by us will be solely used for business purposes, and breakage, loss, theft, etc. must be prevented, and those assets must be appropriately used.

Protection of intellectual property rights

• The intellectual property rights owned by us are recognized as important assets of us. It must be used appropriately, and we must also work to protect its right.
• We will not conduct unauthorized copying of computer software, etc. and violate third-parties’ intellectual property rights.

Supplementary provisions

Handling of this code

• This Code applies to all officers and employees including person equivalent thereto of SAKATA INX Group.
• This code also applies mutatis mutandis to temporary staffs, part-time workers, etc, who are managed and supervised under SAKATA INX CORP.
• Appropriate measures must be taken with the spirit of this Code even for items that are not stipulated in this Code.

Amendment of this code

• This Code will be amended when necessary due to change in social conditions, etc.

Consultation and whistle-blow window for this Code

• When acts of violation or possible violation of this Code are found or conducted by oneself, this must be consulted with the immediate manager or must be reported to the whistle-blow system (if established). Consulter and whistle-blower will not suffer any unreasonable losses based on the fact of consultation and whistle-blowing.

Penalty

Those who violated this Code and overlooked violations of this Code will be severely punished under our working regulations, etc.