YKK EMEA Group | Code of Business Conduct

YKK EMEA Group
Code of Business Conduct

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YKK PHILOSOPHY CYCLE OF GOODNESS“No one prospers unless he renders benefit to others.”
An enterprise is an important member of society, and as such, it must coexist with other elements of society.
Its value will be recognised by the benefits it shares with society.

Tadao Yoshida, YKK’s founder, carefully considered this need for mutual prosperity as he planned his businessendeavours. He determined that contributions to society could best be achieved by the continual creation ofvalue through innovative ideas and inventions. The resulting business expansion would bring prosperity toconsumers and trading partners, thus benefiting all society.

For example, if a more efficient machine can be developed, productivity will be enhanced; or, if the material
loss rate can be reduced, lower cost in the final product will be attained while making the best use of limited
resources.

Also, Tadao Yoshida felt strongly that the fruits of these innovative ideas must not be retained by any individual.
Instead, they should be distributed widely to society, thereby circulating the benefits. In this way, one canprosper while making a contribution to the enrichment of all humankind. Tadao Yoshida called this the Cycleof Goodness, and he made this idea his fundamental philosophy of business. We retain this concept as theongoing business philosophy of YKK.

2|PageYKK EMEA Group | Code of Business ConductYKK MANAGEMENT principle“YKK seeks corporate value of higher significance.”

Seeking corporate value of higher significance, means that YKK will pursue innovative quality in the sevenareas represented above.

In order to maintain our employees’, our customers’ and society’s trust, YKK Group will continue to enhancethe value of our products, technology and management. To make decisions in our business and management
activities, we rely on fairness as our guide.

Value Creation Backed by Technology
In order to provide new value that meets the needs of customers and society, YKK engages in manufacturingin which we apply ingenuity and inventiveness to all processes, from research and development tomanufacturing, sales, and after-sales service, as well as committing ourselves to pursuing quality and safety.

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YKK

Dear EMEA Group Employees:

As a global organization, YKK has established the YKK Group Gode of Conduct for our business which canapply across the world, ensuring that all our customers, wherever they are, can feel confident that YKKcompanies will maintain the high standards that we have set ourselves. YKK Corporation requires us to apply
these standards in all aspects of our work.

ln EMEA too, we want our customers to have the same confidence ln YKK brands that they have elsewhere.
Our customers want to know that they are dealing with a company with high ethical standards, that is respectedin the communities in which we operate and which produces a high quality, reliable product. ln this way, ourbusiness practices can contribute significantly to our customers'satisfaction.

For these reasons, I encourage you to familiarise yourself with this Code of Conduct that has been adapted tomeet the varied circumstances of our EMEA region. lts simple guidelines will help you make the decisions thatyou come across in the course of your work and will help us all focus on the globat principles that make YKKpart of the 'Cycle of Goodness' in our communities.

YKK Europe Ltd.
Managing Director
TakanoriYoshida

December2O2l

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YKK EMEA GROUP’S CODE OF BUSINESS CONDUCTIntroduction
The YKK Group is a global business, with employees in 73 countries/regions worldwide and the YKK EMEA
group, as one of the major regional business units in the YKK group, operates its business in 40 countries inthe Europe, Middle East and Africa region.

In order to offer our customers effective solutions, it is imperative that the YKK EMEA Group operates according
to high moral principles. This Code of Business Conduct (the Code) defines the ethical standards by which theYKK EMEA Group should conduct business.

This Code of Conduct also defines standards of social compliance as to how YKK treats and protects its
employees, its business partners, the environment and YKK’s cooperate social responsibility commitments.
This Code is an overview but is not intended to replace the laws and regulations that apply to each of us in our
various locations. Where a conflict exists, you must either apply the Code or local law - whichever sets thehighest standard of conduct. This Code does not purport to explain detailed rules concerning all the mattersaddressed in this Code, and individual internal rules, procedures and/or policies will be established, whereappropriate, by jurisdiction, YKK Group Company or office, which will complement this Code.

Observance of the Code is obligatory for all directors, officers and employees. Failure to observe the Codecould lead to disciplinary action, which could involve termination of your employment.

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1.

ComplianceYKK EMEA Group pledges to take whatever steps are necessary to fully comply with all applicable laws,
regulations, and all company policies and procedures.

YKK also commits to high standards of social compliance, ensuring that employees are treated fairly and work
under safe and supportive working conditions, that YKK’s business is compliant with environmental laws andregulations, that YKK is a socially responsible corporate citizen.

You must maintain the highest standards of integrity, and professionalism in your work for the YKK Group,
since any adverse behaviours may result in reputational risk or damage to the YKK Group.

YKK also commits to continuous improvements in labour standards across its organization, from themaintenance of safe and secure working environments for all employees, adherence to health and safety
regulation and respect for employment and workers’ rights. You must consider these commitments in yourwork for the YKK Group.

1.

Compliance with Laws and Regulations

You must take whatever steps are necessary to fully comply with all laws and regulations that apply to
conducting business activities. In the event that you are unsure as to whether any laws or regulations apply toyour conduct, you must consult with the local Compliance Officer designated for your region/country before
proceeding with any business activities.

2.

Compliance with Internal Rules and Policies

You must fully comply with related internal company rules, regulations, and policies when conducting businessactivities. In the event that you are unsure as to whether any internal company rules, regulations, or policies
apply to your conduct, you must consult with your local human resources department or the local Compliance
Officer designated for your region / country.

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2.

Company Property including Confidential Information

You must, in an ethical and efficient matter, utilise and protect YKK Group assets, including confidential
information, because you recognise that they are valuable to our business activities.

Confidential information is information, including proprietary information that you create, develop or use during
your employment (including sales and technological data) which is not generally known to the public about theYKK Group, its customers, business partners or employees.

Unauthorised access, use or distribution of confidential information is strictly prohibited and your obligations
continue even after you have left employment with the YKK Group. Similarly, you must not bring with you
proprietary confidential information which you have obtained from a previous employer.

You must comply with any applicable YKK Group policies or local law relating to confidential information. In
particular, you must follow the following guidelines:• Only access confidential information that you need and are authorised to view.
• Do not display or discuss confidential information in public places.
• Only communicate confidential information, to other YKK Group employees and authorised agents (e.g. legal
counsel or external auditors) who have a legitimate business reason to know the confidential information andwho have no duties or responsibilities which could lead to a conflict of interest.

You agree that you will use your best efforts to appropriately control company assets to prevent loss andunauthorised use.

You must comply with all applicable information security policies (including the “EMEA Technology Outflow
Prevention Guideline”, “EMEA Classified Information Management System” and the “EMEA IT Security Policy”)
and you should only use YKK Group assets, including telephone, computer networks and e-mail and remote
access capabilities in accordance with the rules of your local company.

When a stakeholder such as a customer requests YKK to disclose information, you should comply with internal
rules (including the “EMEA Classified Information Management System”), laws and regulations and obtain thenecessary approval, and once approved then disclose the information to the stakeholder in a fair, timely,
accurate and easy-to-understand manner, striving for constructive dialogue.

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3.

Privacy and Employee Confidentiality

The YKK EMEA Group pledges to comply with its data protection obligations. Access to personal data is strictly
limited to authorised employees who have a business reason for processing the data. Those with access topersonal data must only use it for the purpose for which it was collected and must adhere to high standards ofconfidentiality. Personal data must be accurate and kept up to date.

Personal data will be handled in accordance with laws and regulations and the “EMEA Data Protection Policy”
and procedures of your region/country (if any), and will not be held by the YKK EMEA Group for longer than isnecessary.

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4.

Harmony with the Environment and Sustainability

In September 1994, the YKK Group issued the “YKK Group Environmental Pledge”. Striving to be anenvironmentally friendly company, YKK EMEA Group pledges that it will address and promote harmony withthe environment as the highest priority of our business activities.

In April 2019, the YKK Group established its “Environmental Vision 2050” in response to the great need forenvironmental actions on a global scale. The “Vision” defines the long-term direction for environmental
initiatives that the entire Group must take in order to realize a higher level of environmental management.

As a response to climate change, YKK pursues energy conservation initiatives to reduce the amount of energy
we use in business activities and reduce greenhouse gas emissions by introducing renewable energy use.

As a manufacturing company, YKK also strives to develop and sell products intended to maintain a sustainable
use of resources, and to promote the efficient use of resources through new technology in manufacturing.

Furthermore, water is an important shared community resource. As a member of local communities, YKK
strives to optimise water uptake and drainage so that water can be used in sustainable manner.

In addition, through proper use, storage, and treatment of the chemical substances YKK uses, YKK seeks tominimise its impact on the natural environment and to conserve ecosystems.

You acknowledge the significance of environmental activities and the high priority in which they are regarded
within our business activities.

You must take whatever steps are necessary to comply with applicable environmental laws and regulations,as well as with all internal company rules and policies.

You must immediately report to your immediate supervisor or to the local Compliance Officer designated foryour region / country, any potential violation of applicable laws, regulations, or internal company rules andpolicies that you become aware of in the workplace.

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5.

Health and Safety

The YKK EMEA Group implements a variety of health and safety measures, including worker health and safety
management systems, at domestic and overseas sites from three perspectives—human resource
development, workplace development, and structural development—with the aims of eliminating industrial
accidents (achieving zero accidents) and creating workplace environments where employees can work safely
and with reassurance.

The YKK EMEA Group pledges that it will make the utmost effort to remove any items or practices in theworkplace, which are harmful or dangerous, and to maintain and increase the physical and mental well-beingof all employees. We pledge to use our best efforts to accomplish these goals, including by raising awarenessthrough training and other means.

The YKK EMEA Group implements thorough fire and disaster prevention measures, always giving first priority
to human life.

You must take whatever steps are necessary to comply with all applicable laws, regulations and internal
company rules and policies related to health and safety, and work to prevent the occurrence of workplace
accidents.

You must stop any work that becomes unsafe and only undertake tasks for which you are trained.

You must immediately report in accordance with your local reporting rules, or seek help from your local
Compliance Officer, any kind of potential harm, danger or defect you become aware of in the workplace. You
must never assume that someone else will report such a risk or concern.

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6.

Quality and Safety of ProductsEver since its founding, quality has been central to the YKK Group’s management, and all of its businessactivities, including through the YKK EMEA Group, revolve around the assurance of quality. Maintaining stable
and constant quality has become one of the key concerns for many of the global manufacturers, and in orderto support these companies, YKK has established “YFS” – “YKK Fastening Standards” – to provide productsof the same quality level, wherever and whenever they are manufactured. Each YKK production site conducts
various quality tests and reports the results to Japan HQ on a regular basis in order to maintain and assure a
consistent quality level.

The YKK EMEA Group highly values the trust that our customers have placed in our business, and pledges tocontinue providing products and services with the highest commitment to quality.

You must take whatever steps are necessary to comply with all applicable laws, regulations and internal
company rules and policies related to product safety.

You must immediately report in accordance with local reporting rules or seek help from your local Compliance
Officer, any potential danger or defect which could affect the safety of our products.

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7.

Human Rights and Employee Rights

The YKK EMEA Group respects the human rights, individuality and personality of all individuals in all ouroperations, in every country and region in which our operations reside.

You must respect the human rights of all individuals, and you must take whatever steps are necessary toeliminate any sort of violence, or other forms of intimidation in the workplace.

Child labour is prohibited. YKK will comply with all local laws and regulations with regards to minimum working
age and maximum working hours. If, despite all diligence in complying with law and regulation by YKK, any
underage worker is nevertheless discovered to be working directly or indirectly for YKK for whatever reason,
YKK will immediately upon discovery implement remedial action by ceasing further work by such underage
worker, and assisting in remedying the underage worker's circumstances by referring the matter to local
governmental social or child services for support and care.

The YKK EMEA Group also prohibits unlawful discrimination in its organisations (including, but not limited to,whether it be on the basis of sex, race, disability, medical status or condition) and YKK respects the rights of
employees to be treated equally and fairly, on the basis of their ability and qualification and not on personal
characteristics. YKK and employees are prohibited from questioning individuals’ medical status or condition(pregnancy, illness etc.).

The YKK EMEA Group respects the rights of employees, which include the freedom of association and theright to collective bargaining.

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8.

Relationship with Business Partners

The YKK EMEA Group will take whatever steps are necessary to ensure we conduct business transactions ina fair and equitable manner.

You must take whatever steps are necessary to fully comply with all applicable competition laws, and the“EMEA Competition Compliance Manual” established separately, which apply to all our business activities, inorder to continue to maintain fair and equitable dealings in the marketplace.

You must not undertake any personal activity that conflicts with the interests of YKK Group or its customers.
You are responsible for identifying and managing actual conflicts or the appearance of any conflicts and forbringing these to the attention of your supervisor.

You are prohibited from giving or accepting gifts, entertainment, free or subsidised travel or accommodation orother considerations of value unless they are in accordance with the “EMEA Anti Bribery Policy” Please notethat the giving or receiving of cash to or from business partners is never permitted under any circumstances.
You must refer to the “EMEA Anti Bribery Policy” for further details.

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9.

Relationship with Government Agencies

The YKK EMEA Group will take whatever steps are necessary to undertake lawful and appropriate conductand continue to develop fair and good faith relationships with all relevant government agencies.

You must take whatever steps are necessary to develop and maintain fair relationships with government
agencies.

You are prohibited from giving or accepting gifts, entertainment, travel, payments and other considerations ofvalue to or from an employee of any governmental agency unless they are in accordance with the “EMEA Anti
Bribery Policy”.

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10.

Workplace Dignity and Respect

The YKK Group’s diverse workforce is one of our greatest strengths. Bringing together and supporting
employees from different backgrounds, perspectives and cultures helps create a dynamic business thatreflects the range of customers we serve.

Therefore, the YKK EMEA Group is committed to providing equal opportunities for all its employees and job
applicants who will receive fair treatment regardless of personal traits, including but not limited to, age, race,
religion or belief, colour, nationality, ethnic or national origin, sex, gender reassignment, marital status ordisability. It is our aim that all relationships in the workplace are free from discrimination, bias and harassment.

You must ensure that you do not, by your own actions, behaviour or attitude, directly or indirectly discriminate
against job applicants or fellow employees. In some countries employees can be held personally liable for actsof discrimination they commit.

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Criminal Organizations

YKK has a zero tolerance to crime and criminal enterprises, crime syndicates, and other criminal organizations(anti-social groups), and are committed to preventing crime and ensuring that such criminal organizations are
not able to form relationships with any part of YKK. You must not have any relationship whatsoever with any
such criminal organizations and in the event that any crime by employees is discovered, relevant employees
will be subject to appropriate disciplinary action accordingly.

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12.

Proper use of Intellectual Property Rights

The YKK EMEA Group appropriately maintains and uses its own intellectual property rights, and continuously
undertakes the necessary management and improvements to prevent infringement of the intellectual property
rights of other companies.

You must inform the YKK Europe Ltd. Legal Department in the following cases.
You have an invention.

A third-party infringes/ is likely to infringe YKK’s intellectual property rights or uses/ is likely to use of
YKK group company name or other trade mark improperly.

Your company infringes/ is likely to infringe intellectual property rights of any third-party or uses/ islikely to use of the third-party's name.

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13. Proper Accounting and Tax Processing
The YKK EMEA Group has established internal rules and regulations related to accounting and taxation inaccordance with applicable laws, internal rules and industry standards.

YKK accounting and tax departments should carry out improvement activities based on the audit results ofexternal accounting audits and tax audits in accordance with the requirements of local law.

If your work is related to accounting and tax processing, you should accurately prepare your accounting
books and store them together with other important documents in preparation for external and internal
auditing. You must not create accounting books incorrectly or provide false information, even if it benefits thecompany you belong to.

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14.Raising Concerns and Reporting Misconduct
If you have genuine concerns regarding conduct - whether by another employee, a supervisor, customer,
consultant, agent, supplier, other third party or yourself - that may violate the law, regulations or company policy,
you will report the activity at the earliest practicable stage by contacting any of the following:•The appointed person under any applicable local disclosure/ escalation procedure or policy.
•Your immediate supervisor.
•Your local human resources representative.
•By using the “EMEA Whistleblowing Policy”.

By reporting your suspicions, in good faith, you are ensuring that the YKK Group is not exposed to any
unnecessary risks and that the YKK Group’s image is not tarnished.

It may sometimes be easier to ignore potential misconduct. However, your commitment to the integrity of theYKK Group means that any legal or ethical issues must never be ignored. Malpractice within the YKK Groupis taken very seriously and you will not be victimised or subjected to any detriment if you raise concerns ingood faith.

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Please speak to the local compliance officer in your region/country or YKK Europe Ltd. Legal Department if
you have any questions, queries or concerns about YKK EMEA Group Code of Business Conduct.
Please refer to the EMEA Bulletin Board for the list of the local compliance officers.

YKK Europe Ltd. Legal Department
Email: emeacompliance.yeu@ykk.com

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