Tsuzuki Group Code of Conduct
Each company of the Tsuzuki Group will, as part of compliance, strictly comply with laws, social norms, employment regulations, and various company regulations; strive to conduct fair actions with social common sense; and carry out the company's social responsibilities. Each company will also aim for the company's further sound development and herein establish the Tsuzuki Group Code of Conduct.
[I. General provisions]
1. Purpose of establishment
This Code is to stipulate basic matters that should be complied with in carrying out daily business operations.
2. Scope of application
This Code applies to all board members and employees (company employees, trial-period employees, non-regular employees, and temporary employees) of each of the companies of the Tsuzuki Group. It also applies correspondingly to people conducting work under a dispatch contract.
3. Basic principles
（1）Laws, social norms, employment regulations, and various company regulations shall be complied with, and actions that violate social ethics shall not be conducted.
（2）Fundamental human rights shall be respected, and actions that harm an individual's dignity shall not be conducted.
（3）Impartial and fair relationships shall be maintained with all parties that have an interest in each company of the Tsuzuki Group.
（4）Actions that run counter to the fair profits of each company of the Tsuzuki Group, or actions that damage the credibility or honor of each company of the Tsuzuki Group, shall not be conducted.
（5）Awareness as a member of society shall always be maintained, and actions shall be conducted with a sense of social decency.
（6）A safe and pleasant workplace environment that is easy to work in shall be secured.
4. Responsibility for complying with the Code
The matters stipulated in this Code shall be performed with sincerity.
[II. Relationships with society]
1. Political donations and endowment acts
For political donations and endowment acts, sufficient consideration shall be given to their necessity and appropriateness, and they shall be made in compliance with related laws.
2. Prohibition of involvement in antisocial acts
A resolute stance shall be taken against antisocial forces or groups that threaten social order or safety, and all relations with them shall be refused. In addition, acts that facilitate the activities of such forces or groups shall not be conducted.
3. Environmental preservation
Consideration for the environment shall always be kept in mind, and active efforts shall be made to preserve the environment.
4. Social contributions
Activities to contribute to society shall be actively conducted through business.
[III. Relationships with customers, business partners, and competitors]
1. Quality, reliability, and safety in relation to products and services
Attempts shall always be made to improve customers' levels of satisfaction, sufficient consideration shall be given to the quality and safety of products and services provided by each company of the Tsuzuki Group, and efforts shall be made to maintain customers' trust.
2. Fair transactions
（1）Fair transactions that comply with laws related to the Anti-Monopoly Act, etc., shall be made, under the principle of fair competition.
（2）Relationships with customers, business partners, and competitors shall always be transparent and fair, and honest transactions shall be made according to social ethics.
3. Relationships with business partners
（1）Interaction with business partners shall always be from an equal and fair position, and honest transactions shall be made according to related laws and contracts.
（2）Personal profit, such as receiving profits or advantages, shall not be pursued in relation to duties.
4. Business entertainment and gift giving
（1）Giving and receiving business entertainment or gift items to or from customers or business partners shall not deviate from sound business practices or social common sense.
（2）Bribery actions of course shall not be made to government employees, and business entertainment or gift items shall not be provided to government employees.
5. Advertising and publicity
In advertising, publicity, and other business activities, indications or expressions that are different from facts concerning the quality, performance, or specifications of products or services of a company of the Tsuzuki Group or indications or expressions that might cause misunderstandings by customers shall not be used.
[IV. Relationships with shareholders and investors]
1. Disclosure of company information
In accordance with related laws, company information such as management matters or the state of business activities shall be disclosed in a timely and appropriate manner.
2. Prohibition of insider trading
Transactions related to negotiable securities, such as buying or selling shares, shall not be made by using undisclosed important information of a company of the Tsuzuki Group or a business partner that was learned in a position for a job or duties or in a relationship with a business partner. In addition, such information shall not be used to give profits to a third party or to receive profits from a third party.
[V. Management of company property and information]
1. Appropriate use of company property
The property of each company of the Tsuzuki Group shall not be used for a purpose other than the purposes of its business operations.
2. Handling of confidential information
（1）The confidential information of each company of the Tsuzuki Group shall be strictly managed in accordance with the separately stipulated "Tsuzuki Information Security Policy" and shall not be divulged or fraudulently or wrongfully used.
（2）Information of a customer or business partner that was learned through duties shall not be used for other than a legitimate purpose and shall be strictly managed so that it will not be disclosed or divulged without going through the prescribed procedures.
（3）Confidential information of a customer, business partner, or competitor shall not be obtained by a fraudulent method.
3. Protection of intellectual property rights
（1）Efforts shall be made to maintain and secure the intellectual property rights (patent rights, copyrights, utility model rights, design rights, trademark rights, or other rights protected by related laws) of each company of the Tsuzuki Group.
（2）The intellectual property rights of other companies shall be respected and shall not be infringed or used fraudulently.
[VI. Operation system]
1. Operation system
（1） Establishment, revision, or abolition of this Code shall undergo deliberation by a separately stipulated Committee for Managing Risks and Compliance and shall become effective upon approval of the board of directors of Tsuzuki Denki.
（2）This Code shall be managed by the Compliance and Risks Managing Department of Tsuzuki Denki, and the Committee for Managing Risks and Compliance shall give each related department advice and proposals concerning implementation of the matters stipulated in this Code.
（3）Employees that have violated this Code shall be subject to disciplinary action in accordance with the employment regulations of each company of the Tsuzuki Group.
（4）Detailed regulations for this Code will be stipulated separately as necessary.
2. Office for inquiries
The office for inquiries related to the provisions of this Code will be the Compliance and Risks Managing Department of Tsuzuki Denki.
This Code shall take effect on September 27, 2004.
Partial revision shall take effect on April 1, 2007.
Partial revision shall take effect on April 1, 2016.