Ⅰ General Rules

1. These principles are the foundation for the rules which the officers and employees of NEG Group must follow when they conduct business in accordance with “NEG GROUP CODE OF CONDUCT”.
2. These principles, by the resolution of the Board of Directors of respective NEG Group Companies, apply to all officers and employees of NEG Group, consisting of NEG and NEG subsidiaries, companies with more than 50% of their shares owned by NEG.
3. The establishment and revision of these principles are the duty of the NEG Compliance Committee. The Board of Directors of NEG will decide the appropriateness of the suggestions of the Committee. Each NEG Group company can revise the contents of the principles by giving prior notice to the NEG Compliance Committee so far as such revisions do not conflict with these principles.

Ⅱ Code of Conduct

1. The Customer First
   1. We make every effort to satisfy customers and provide superior products.
   2. When we design or manufacture products, we give the first priority to ensuring product safety. Moreover, we provide customers, by the most appropriate means, necessary information for the safe use of our products.
   3. We dutifully respond to the claims or requests from customers and make the best use of them to improve corporate activities.
   4. We challenge new technological innovations and contribute to the development of society by our devotion to creating products infused with the very best of human civilization, which grow together with the advance of civilization.
2. Getting the job done
   • We have the determination to see through the challenges we take on, without giving up halfway.
3. Broad Minds and Open Communication
   • We think beyond existing norms and encourage frank communication among all departments and generations.
4. High Ethical Standards
   1. 4－1　Fundamental Principles
      1. At all times we act with the consciousness of a member of NEG Group and obey a strong sense of morality, high ethics and social common sense.
      2. We comply with domestic and foreign laws and regulations, these principles, the company’s rules (which refers to internal rules, regulations, procedures, etc.; the same shall apply hereinafter) and conduct all corporate activities in conformity with fair business practices and public ethics.
   2. 4－2　Community Relations
      1. Donations and political contributions
         1. We make donations only after a full study of their need and appropriateness, following company’s rules to avoid allegations of bribery and the like, and every effort is made to avoid conflicts of interests concerning any shareholder.
         2. Regarding political contributions, elections and political activities, we comply with the laws, rules and regulations including Japanese Political Funds Control Law and the Public Offices Election Law.
      2. Antisocial forces, organizations
         1. We do not provide any money or other benefits to antisocial forces or organizations.
         2. We do not engage in any transaction with antisocial forces or organizations.
         3. We do not submit to blackmail, extortion or harassment by antisocial forces or organizations, nor do we accept monetary demand from such forces or organizations. If we have such request, we immediately inform the division responsible for General Affairs.
      3. Entertainment and gifts
         1. We conduct entertainment and the giving and receiving of gifts to and from interested parties including customers, suppliers, etc. within the scope of sound business practices and social common sense, and follow internal documentation procedures. We give no kickbacks or inappropriate rebates.
         2. With regard to civil servants or persons treated as civil servants, we do not enter into any activity that might be construed as bribery. Furthermore we do not enter into any act that might be deemed to be a gift for gaining unjustified business profit nor do we participate in any other acts that might be misunderstood.
   3. 4－3　Control of trade
      • When we export or import products, equipment or technology, we comply with the domestic and foreign regulations, such as Foreign Exchange, Foreign Trade Law as well as the company’s rule, regarding the control of commerce.
   4. 4－4　Fair and appropriate trade
      　We administer all transactions with all customers, suppliers and other persons fairly and in compliance with antitrust laws and other applicable domestic and foreign laws and regulations based on the principles of free competition. We also strive to fulfill our social responsibilities with respect to the environment, biodiversity, human rights, etc. throughout our supply chain.
      1. Relationship with competitors
         • We do not participate in activities, such as illegal agreements, cartels and so on that restrict fair and free competition. Furthermore, we do not attend any meeting or exchange any information which might be interpreted as participation in an illegal agreement or cartel. We also do not enter into any other questionable activities.
      2. Relationships with clients, agents, and others
         • In relation to clients, distributors, agents, and other parties, we do not engage in any unfair or unjustified activities, such as discriminatory treatment, instructions concerning resale-prices or unfair restriction of sales territories.
      3. Relationships with suppliers, contracts, and associated companies
         1. We maintain equal and fair relationships with suppliers of materials and the like, contractors of services, and subcontractors. All transactions with suppliers and subcontractors faithfully adhere to applicable domestic and foreign laws and regulations and contracts.
         2. During transactions with suppliers, contractors, and subcontractors, we do not use our purchasing power or any superior market position to unfairly depress prices, force the purchase of our products or services, nor do we conduct any other activities that might cause unreasonable disadvantage.
         3. In connection with purchasing or placing orders and so on, we do not seek private gains including the receipt of benefits or emoluments from suppliers.
   5. 4－5　Administration of corporate assets
      1. Administration and proper use of company assets
         • We use assets of the company or other companies (entities) in accordance with the rules and procedures of the company. Furthermore, we do not use assets for any purpose other than the business of the company.
      2. Information management
         1. We strictly control confidential information of the company. We do not disclose or divulge such confidential information in violation of the rules or procedures of the company, not only during our employment by the company but also after retirement. Furthermore, we do not use such confidential information for any purpose other than the business of the company.
         2. We do not improperly or unjustly use information about other companies (entities) that we come to know through our duties. We strictly control confidential information so as not to disclose or divulge it in violation of the rules or procedures of the company.
         3. We do not access or obtain confidential information of other companies (entities) by unlawful or improper means.
         4. We properly collect, record, manage, use and dispose of personal information according to domestic and foreign laws and the company’s rules.
      3. Protection of intellectual property rights
         1. We strive to acquire intellectual property rights when an employee makes an invention or originates a device for the benefit of the company.
         2. When we find that an intellectual property right of the company is infringed, we immediately inform the department in charge of intellectual properties of the company and strive to protect our rights.
         3. In the case that we assign or license our intellectual property right to other companies (entities), we follow the rules and procedures of the company, such as the approval request process or others.
         4. We respect intellectual property rights of other companies (entities) and do not intentionally infringe or unlawfully use them.
   
   
   6. 5. Consideration for the environment
      We are constantly aware of the need to be considerate of the environment, and strive to reduce our footprint.
      1. We comply with domestic and foreign laws and regulations and rules relating to environment, establish appropriate internal environmental rules and make every effort to obey them.
      2. We strive to reduce environmental loads in corporate activities and at every stage of the product life cycle, from procurement through to manufacture, transportation, sale, use, recycling, and disposal.
      3. By realizing world’s best manufacturing, we utilize natural resources and energy effectively and try for conservation of biological diversity and reduction of global warming gas emissions.
   
   
   7. 6. Contribution to society
      1. We produce profits by legitimate corporate activities and contribute to the development of society by fulfilling our role as a member of nation and a local society.
      2. When we do business in foreign countries, we respect the cultures and customs there.
      3. We actively support fostering of the next generation of local human resources.
   
   
   8. 7. Respect for human rights
      In every aspect of our corporate activities, we respect the fundamental human rights of all human beings.
      1. We do not engage in any activity that berates the dignity of individuals or discriminates on the basis of ethnic group, belief, gender, age, social status, family origin, nationality, race, religion or disability.
      2. We never tolerate child labor or forced labor.
      3. We comply with all laws and regulations and the company’s rules regarding working hours, holidays and vacations, wages, benefits and other working conditions.
      4. We strive to create a workplace environment under which everyone working at NEG Group respects each other’s diversity and can exercise and demonstrate his or her own ability.
      5. We comply with the laws and regulations and the company’s rules concerning health and safety, and put safety first in our operations.
      6. We do not perform an act to become workplace bullying, power harassment and sexual harassment.
   
   
   9. 8. Information Transfer
      • 8－1　Corporate disclosure
        • We disclose necessary information, including business situations and results, in a timely and appropriate manner.
      • 8－2　Prohibition against insider trading
        • We do not use privileged or undisclosed information about NEG Group or about customers and suppliers, and any third party which we know through our duties to engage in the buying and selling of stocks and other securities. In addition, we do not transmit the privileged or undisclosed information and do not leak it out to any person who is not connected with such information.
      • 8－3　Advertising and Publicity
        • In business advertisements, publicity and other corporate public relation activities, to avoid misunderstandings, we do not give misleading information about the quality, performance and specifications of our products or services. Furthermore, we require the same high standard of behavior from our distributors and agents.
      • 8－4　Use of Social Media
        • When using social media, we say and post something with an awareness of acting with integrity as a sensible member of society.

Ⅲ Compliance with these principles

1. Every officer and employee shall comply with these principles.
2. Officers and employees in managerial positions shall lead and supervise their subordinates so that they comply with these principles.
3. If any officer or employee violates these principles, he or she will be penalized under the rules of the company.

Ⅳ Operation system

1. Each department shall formulate its own internal regulations, rules and procedures in accordance with the Principles of Activities.
2. NEG Compliance Committee is in charge of the Principles of Activities. Any question about the principles shall be addressed to the Committee.

• Established on March 1, 2000
• Revised on February 1, 2006
• Revised on January 1, 2014
• Revised on December 1, 2015
• Revised on August 1, 2023