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ACCRETECH Group Code of Conduct

ACCRETECH Group Code of Conduct

【Corporate Philosophy】

We create the world's No.1 products and grow significantly with our partners and customers by integrating the excellent technology, wisdom, and information available in the world.

【MOTTO】

WIN-WIN RELATIONSHIPS CREATE THE WORLD'S NO.1 PRODUCTS

【Introduction】

Tokyo Seimitsu Co., Ltd. (here in after referred as “ACCRETECH”) has adopted the basic policy to build WIN-WIN relationships with its customers, shareholders, investors, employees, suppliers, governments, and other stakeholders and together achieve long-term sustainable growth. To this end, ACCRETECH shall do the right thing so that it is well accepted in communities in which it operates.

ACCRETECH Group (ACCRETECH, its subsidiaries and its affiliated companies) established this ACCRETECH Group Code of Conduct to provide a set of guiding principles which are to be observed by all directors, auditors and employees of ACCRETECH Group (collectively referred to as “ACCRETECH Officers and Employees”). ACCRETECH Group shall meet the highest ethical standards and establish transparency in management systems to promote compliance.

Through the promotion of education to all ACCRETECH Officers and Employees, ACCRETECH Group shall raise their awareness to observe this Code of Conduct. ACCRETECH Group shall make sincere efforts to obtain understanding and cooperation from all stakeholders in its compliance activities.

【Basic Principles】

ACCRETECH Group has the following basic principles for all stakeholders involved in its business activities such as customers, shareholders, investors, communities, societies, employees, suppliers, business partners, political organizations, and administrative bodies:

1.Customers

(1)

Always make efforts to satisfy customers, provide products and services of the highest quality in terms of function, reliability, safety, and environmental friendliness, as well as maintain and improve quality of products and services, to build long-term trusting relationships with customers.

(2)

Understand customers and strictly manage information obtained from them.

(3)

Offer accurate and sufficient information on ACCRETECH Group and its products and services to customers. Always try to respond to their requests sincerely.

2.Shareholders and Investors

(1)

Earn trust from shareholders and investors by establishment of basic internal control policies to ensure conducting of proper business operations and maintaining internal control systems.

(2)

Provide correct corporate information to shareholders and investors by making timely and accurate disclosure as well as enhancing transparency of the management.

(3)

Preserve the asset of the Company and prohibit ACCRETECH Officers and Employees from engaging in any act with conflict of interest (a clash between personal and professional interests) or insider trading so as not to hurt the interest of shareholders and investors.

3.Communities and Societies

(1)

Preserve the global and local environment as a “good corporate citizen” in communities and societies.

(2)

Comply with international rules and local laws in which it operates related to environmental protection, human rights, and national / international security.

(3)

Sever any relations with anti-social organizations or elements.

(4)

Actively participate in community activities to fulfill corporate social responsibilities.

4.Employees

(1)

Protect the workers’ rights of employees and establish a safe working environment.

(2)

Create an environment of mutual respect which is free from discrimination and harassment.

(3)

Establish a whistleblower system that allows employees to report any act against law or social norms and protect the rights of whistleblowers.

5.Suppliers and Business Partners

(1)

Enter and maintain relationships with suppliers and business partners based on fair and objective criteria to procure products/services for its business, contract business, or provide products/services to customers, avoid any act that could be seen as collusion or abuse of dominant position and maintain sound and transparent relationships.

(2)

Seek to obtain understanding and cooperation of suppliers and business partners with respect to this Code of Conduct.

(3)

Conduct corporate activities as a good citizen and engage in fair, transparent and free competition.

6.Political and Administrative Bodies

(1)

Keep sound, transparent and proper relations with political parties, political organizations, governments, government agencies, administrative bodies, public officers, and politicians (including candidates).

【Action Guidelines】

ACCRETECH Group shall require that all ACCRETECH Officers and Employees act consistently with the following guidelines in order to realize the basic principles for all stakeholders involved in its business activities.

Compliance Promotion System】

ACCRETECH Group establishes and operates a compliance promotion system as described below.

1.

ACCRETECH Group establishes the Compliance Committee at the Head Office of ACCRETECH to report and discuss compliance related issues. The Compliance Committee is chaired by the Representative Director of ACCRETECH.

2.

Major companies of ACCRETECH Group in Japan appoint members to sit on the Compliance Committee. The appointed members from each company shall be responsible for the implementation of this Code of Conduct in each company.

3.

Revision of this Code of Conduct shall require approval of the Board of Directors after reporting to and deliberation at the Compliance Committee.

4.

ACCRETECH Group shall provide its employees education and training on this Code of Conduct.

5.

In order to detect and solve problems as early as possible, ACCRETECH Group has a whistleblower system in place that allows ACCRETECH Officers and Employees to report any act against this Code of Conduct or other compliance rules and regulations, without going through their usual chain of command. The whistleblowers are to be protected and kept free from any disadvantages or unfavorable treatments.

6.

ACCRETECH Group shall severely punish ACCRETECH Officers and Employees who have violated this Code of Conduct or other compliance rules and regulations according to its working regulations and other rules.

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ACCRETECH Group Code of Conduct