Meiden Group
Guidelines for Sustainable
Procurement

July 2022

Meidensha Corporation
Procurement GroupIntroduction
In recent years, the social environment surrounding corporations has been facing
major changes, such as the effects of climate change that has been accelerating since
the industrial revolution, digitalization brought about by technological innovations, anddiversification of people’s values and lifestyles.
Amid such social changes, we have newly depicted the social situation that
Meidensha is aiming for and established a vision of working to build a new society
through integrity toward the earth, society, and people and through the power of cocreation as the corporate form that we at the Meiden Group aspire to be.
In order to more specifically express that ideal form of the Meiden Group, weestablished the term “Sustainability Partner.” Sustainability Partner includes two roles
that the Meiden Group should carry out in order to realize people’s happiness and asustainable global environment.
The first role is a partner as a member of a society that will bring about a sustainable
Earth's environment. The other role indicates the role of a partner that provides
guidance for sustainability for the various stakeholders, such as employees,
shareholders, investors, and customers.
Providing roles as a Sustainability Partner that combines these two aspects toparties throughout the world through our business activities will lead to the realizationof the society for which we are aiming.
For materials procurement, we have presented a Basic Procurement Policy and a
Guidebook for the Promotion of Supply Chain CSR to transaction partners that are
Sustainability Partners, and we requested cooperation thus far as well; however, basedon recent international social demands, we have made significant revisions and newly
issued the Meiden Group Guidelines for Sustainable Procurement.
We ask that you please promote proactive and responsible corporate activities
throughout the entire supply chain by sufficiently understanding and complying withthese Meiden Group Guidelines for Sustainable Procurement and conducting thoroughinformation provision, management, and supervision for your related suppliers as well.
If a significant deviation from the Code of Conduct or Creation of a Management
System is recognized in a transaction partner, we take corrective measures, and if
improvements cannot be seen even after a grace period, or if a serious violation of alaw, ordinance, or ethics can be recognized, we follow a policy of stopping transactions.
In some cases, we may request disclosure concerning the state of activities attransaction partners. If such a request is made, we request that you please provide
cooperation.
July 2022i

Procurement Group, Meidensha Corporation*These guidelines were created by referring to the Responsible Business Conduct Guidelines (March
2020 edition) of the Japan Electronics and Information Technology Industries Association (JEITA).

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Table of Contents
1. The Meiden Group’s policies ............................................................................... 1
A. The Meiden Group’s company-wide policies ................................................... 1
A-1. The Meiden Group identity (corporate philosophy)................................... 1
A-2. The Meiden Group Corporate Code of Conduct ....................................... 1
A-3. The Meiden Group’s human rights policy ................................................. 2
A-4. The Meiden Group’s information disclosure policy ................................... 3
A-5. The Meiden Group’s environmental policy ............................................... 4
B. The Meiden Group’s procurement policies...................................................... 5
B-1. Basic procurement policy ......................................................................... 5
B-2. Green procurement policy ........................................................................ 5
B-3. Policy for responsible mineral procurement ............................................. 6
2. Code of Conduct for the Meiden Group’s procurement partners ......................... 7
Part 1: Code of Conduct ...................................................................................... 7
1. Compliance with laws and regulations, and respect for international norms 7
2. Human rights and labor ............................................................................... 7
3. Safety and health ......................................................................................... 8
4. The environment ........................................................................................ 10
5. Fair transactions and ethics ....................................................................... 11
6. Quality and safety ...................................................................................... 12
7. Information security.................................................................................... 13
8. Business continuity plans ........................................................................... 13
Part 2: Creation of a management system ........................................................ 15
A. Creation of a management system ............................................................ 15
B. Management of suppliers .......................................................................... 15
C. Appropriate export and import management ............................................. 15
D. Preparation of a mechanism for handling complaints ................................ 15
E. Disclosure of the state of initiatives ........................................................... 15
3. Revision history ................................................................................................. 16iii

1. The Meiden Group’s policies
A. The Meiden Group’s company-wide policies
A-1. The Meiden Group identity (corporate philosophy)
Corporate Mission: Illuminating a more affluent tomorrow
We continue to create value and technologies for the realization of a more
affluent and environmentally aware society.
Value Provision: For customer peace of mind and satisfaction
We offer complete environmental consideration and appropriate support for ourcustomers. From product design to commissioning, our highly skilled staff help
customers solve various issues and realize their dreams by providing high-quality,
socially responsible products and services.
*For information about our corporate philosophy, please refer to the site below.
https://www.meidensha.com/corporate/corp_03/index.html

A-2. The Meiden Group Corporate Code of Conduct
1. For realization of a sustainable society
We proactively and resolutely take on the challenges of creating new value
through integrity toward the earth, society, and people and through the power ofco-creation, and we contribute to the realization of a sustainable society.
2. Sincere and fair business activities
We sufficiently understand the laws, regulations, customs, and all other social
norms, as well as the spirit of such stipulations, of the countries and regions inwhich we conduct business activities, we comply with and respect such matters,
and we always act with highest levels of corporate ethics and social decency.
3. Respect for human rights
We understand and support the various international norms concerning humanrights and comply with the laws and regulations of each country and region andthereby respect all people’s human rights.
4. Realization of a workplace environment in which employees can exert theirabilities to the fullest extent
We support employees’ growth and promote creation of a workplace in which adiverse range of talented people can actively participate.
5. Environmental conservation
For the purpose of the realization of a sustainable society, we undertake
sustainability management and aim for corporate development for such tasks as
mitigation of climate change, adaptation to climate change, recycling of resources,
and conservation of biological diversity.
6. Cooperation with and contribution to society1As a member of the international society and as a member of the local society,
we respect the culture and customs of the international society and the local
society from a global perspective and promote business activities while striving forcooperation and harmony in the respective regions.
7. Management of information
We appropriately manage all of the information assets that we handle throughbusiness activities, and we protect those information assets from such threats as
disasters, accidents, and crimes.
8. Proper disclosure of information
We follow the rules of laws and regulations and disclose corporate information
appropriately and in a timely manner.
9. Risk management
We ascertain and assess all types of risks associated with business activities
and build a company-wide and cross-sectional system for appropriately controllingthose risks.
10. Responsibilities of top management
Top management is aware of the fact that realization of the spirit of this code of
conduct is top management’s role, and it conducts the maximum efforts so that
effective governance will be formulated within companies and in group companies
and so that business operations will be conducted based on this code of conduct.
If a situation that may be in violation of this code of conduct arises, top
management will take the lead in striving to resolve the problem and prevent
recurrences and will carry out its responsibilities.
*For information about the Corporate Code of Conduct, please refer to the site below.
https://www.meidensha.com/corporate/corp_03/corp_03_01/index.html

A-3. The Meiden Group’s human rights policy
1. Putting respect for human rights into practice
The Meiden Group respects the various international norms related to humanrights; understands that there is a possibility of having direct or indirect effects
through our business activities on the human rights of people related to our
research and development, materials procurement, manufacturing, use of
products and services, the value chain that includes disposal, and local society;and strives to prevent, mitigate, and avoid fostering of adverse effects on humanrights. If adverse effects on human rights arise in our business activities, we
handle them appropriately for the purpose of correction.
2. Scope of application of the Meiden Group’s Human Rights Policy
The Meiden Group’s Human Rights Policy applies to all of the board members
who work for the Meiden Group and to all employees, including semi-regular
employees, part-time workers, contract employees, and dispatched employees.
We also have all of our business partners and transaction partners understandand support this policy, we continuously ask them to adopt similar policies, and wethereby cooperate to promote respect for human rights.
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3. Continuous implementation of due diligence for human rights
By continuously implementing due diligence for human rights, we will regularly
assess adverse effects on human rights that arise in the Meiden Group’s businessactivities and identify notable human rights issues. We will also promote initiatives
to prevent and mitigate such adverse effects.
4. Relief and correction
If it becomes clear that adverse effects on human rights have been caused or
fostered because of the Meiden Group’s business activities, we implement theappropriate relief measures for the people who incurred those effects.
5. Dialogues and discussion with stakeholders
The Meiden Group conducts dialogs and discussions with related stakeholders
concerning human rights issues related to potential or apparent adverse effects
on human rights and thereby deepens initiatives for respect for human rights.
6. Information disclosure
The Meiden Group discloses our initiatives for respect for human rights and thestate of implementation of due diligence for human rights through our website andannual reports.
7. Cultivation and permeation of awareness about respect for human rights
The Meiden Group provides board members and all employees, including semiregular employees, part-time workers, contract employees, and dispatchedemployees, with the education and training that is necessary for practicing respectfor human rights, so that this policy will permeate and become established in all
corporate activities, and implements initiatives for activities for understanding andpermeation by transaction partners.
*For information about the human rights policy, please refer to the site below.
https://meidensha.disclosure.site/ja/themes/96

A-4. The Meiden Group’s information disclosure policy
1. Basic approach
To ensure that our corporate activities are transparent, and that stakeholders
such as our customers, our shareholders, investors, and local communities havea correct understanding of and confidence in our business, Meidensha (hereafter“the Company”) and its group (hereafter “Meiden Group”) disclose their corporate
overview at appropriate times in accordance with a pre-established set of rules.
To forge good relationships of trust with our shareholders and investors inparticular, we implement communication measures based on voluntary disclosureof information.
2. Criteria for information disclosure(1) We disclose information as promptly as possible in accordance with the
Financial Instruments and Exchange Law and other relevant laws andregulations (hereafter “Laws and Regulations”) and “Rules on Timely
Disclosure of Corporate Information by Issuers of Listed Securities”(hereafter “Timely Disclosure Rules”) set by the Tokyo Stock Exchange, etc.
With regard to information that cannot be disclosed for reasons of our
3business operation, we clarify why disclosure is not possible.
(2) Even when Laws and Regulations do not apply to particular information,
and/or the information does not meet the criteria for disclosure stated in theTimely Disclosure Rules, we actively and fairly disclose the information if it
may help our shareholders and investors gain a better understanding of theCompany and the Meiden Group.
3. How we disclose our information(1) We disclose information that meets the criteria for disclosure specified in theTimely Disclosure Rules, and information that is deemed to be helpful for ourshareholders and investors, via the timely disclosure information systemprovided by the Tokyo Stock Exchange.
(2) We actively disclose any information other than that stated above asnecessary depending on its content via press releases, briefing sessions,press conferences, and by other appropriate means if the information may
help us improve understanding of the Company.
(3) Information that has been disclosed based on (1) and (2) above is promptly
published on the Company’s website.
4. Silent period
To prevent any leakage of information about the Company’s account settlement,
and to ensure fairness, we observe a silent period between the account closing
date and the date of announcement of our financial results. During this period, we
do not make any comments or reply to any inquiries concerning the accountsettlement.
5. Prevention of insider trading
As soon as company overview is made public by any of the following means,the action of official announcement defined by the insider trading regulations iscompleted:(1) As soon as 12 hours have passed since the information is made available
to two or more news media(2) As soon as the information is published on the information disclosure systemprovided by the Tokyo Stock Exchange
6. About future forecasts (disclaimer)
Information that the Company discloses may include not only earnings forecasts
to be published in the Financial Result, but also descriptions about future outlooks,
including earnings forecasts, planning, and business strategies. In all cases,
except those concerning facts in the past, the descriptions are forecasts that theCompany has made based on information available at that time, and thus they
involve potential risks and uncertainty. Hence, please note that our actual
performance may differ significantly from the described future outlooks.

A-5. The Meiden Group’s environmental policy
1. Basic environmental philosophy
In the Meiden Group, we have the corporate philosophies of illuminating a more
affluent tomorrow and for customer peace of mind and satisfaction, and with theaim of realizing a sustainable society, we are undertaking ESG management and4aiming for corporate development with the tasks of mitigation of climate change,
adaptation to climate change, recycling of resources, and conservation of
biological diversity.
2. Environmental action guidelines(1) We promote the development of new products and new technologies thatcan contribute to the earth’s environment and will also assess the effects on
the environment throughout the entire life cycle from the procurement ofmaterials up to disposal and strive to develop and design environmentallyfriendly products.
(2) We reduce the environmental burdens associated with domestic and foreignbusiness activities and strive to reduce greenhouse gas emissions, promote
the 3Rs, and curtail discharges of hazardous substances.
(3) We obey laws and regulations related to the environment and otherrequirements and set voluntary standards and strive to prevent pollution andprotect the environment.
(4) We establish a system for ESG management, go through the PDCA cycle ofplanning (Plan), implementation and operation (Do), inspection and review(Check), and improvement (Act), make continuous improvements, and strive
to improve environmental performance.
(5) Through environmental education, we strive to deepen all employees’
understanding of ESG management and invigorate environmental
contribution activities.

B. The Meiden Group’s procurement policies
B-1. Basic procurement policy
In procurement transactions, the Meiden Group Corporate Code of Conduct willbe the basis for all actions.
Proactive promotion of responsible corporate actions(1) Together with our transaction partners, we realize a philosophy for our
procurement policy and build a sustainable supply chain.
(2) We promote environmentally friendly procurement activities and, together
with our transaction partners, we contribute to the conservation of the earth’s
environment.
(3) We exclude use of conflict minerals that serve as sources of funds for armed
forces that repeat inhumane actions, such as human trafficking, forced labor,child labor, and abuse.

B-2. Green procurement policy
In order to realize the Company’s basic environmental philosophy, we want topromote environmentally friendly procurement activities in materials procurement
as well based on the Green Procurement Standards, which were formulated asenvironmental action guidelines for use in the supply chain, and contribute toconservation of the earth’s environment together with our procurement partners.
(1) Creation of an environmental management system(2) Ascertainment of the amount of greenhouse gas emissions and reduction ofemissions(3) Creation of a system for management of chemical substances contained in
products(4) Promotion of resource recycling(5) Mitigation of water risks5(6) Consideration for biological diversity(7) Management of chemical substances*For information about green procurement, please refer to the site below.
https://www.meidensha.co.jp/procure/proc_02/index.html

B-3. Policy for responsible mineral procurement
In conflict areas and high-risk regions, we will conduct responsible procurement
activities in order to avoid procurement of parts and materials that include conflictminerals (tin, tantalum, tungsten, and gold) and minerals, such as cobalt, whichhave the possibility of being involved in the support of armed groups, child laboror other infringements of human rights, corrupt actions, and environmental
destruction.
We will ask our procurement partners to utilize internationally recognized tools,
such as the Conflict Minerals Reporting Template (CMRT) provided by the RMI(Responsible Minerals Initiative), conduct investigations related to the supply
chain, such as identification of minerals’ country of origin and refiners, and tosimultaneously conduct procurement from smelters that are compatible with the
RMAP (Responsible Minerals Assurance Process).
*For information about our policy for handling conflict minerals, please refer to thesite below.
https://www.meidensha.co.jp/procure/proc_09/index.html

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2. Code of Conduct for the Meiden Group’s
procurement partners
Part 1: Code of Conduct
1. Compliance with laws and regulations, and respect forinternational norms
It is necessary for your company to not only comply with applicable laws andregulations in your own country and the countries and regions in which you
conduct business but to also respect the international code of conduct.

2. Human rights and labor
It is necessary for your company to not only comply with related laws andregulations but to also refer to international human rights standards, including theILO Core Labor Standards, the Guiding Principles on Business and Human Rights
created by the United Nations, and the Guidelines for Multinational Enterprises
created by the Organization for Economic Co-operation and Development (OECD),
and to respect workers’ human rights.
(2-1) Prohibition of forced laborYour company must not use a work force that has been obtained by coercion,
constraint, inhumane prison labor, a slavery system, or human trafficking. Workthat is conducted in an exploitative manner under unfair treatment by using a
superior bargaining position will also not be permitted.
In addition, it is necessary for your company to not coerce any work and toprotect the right for workers to resign or end employment themselves.
(2-2) Prohibition of child labor, and consideration for young workers
Your company must not allow children younger than the minimum working age
to work. In addition, your company must not allow young workers who are under
18 years old to conduct dangerous work that has a possibility of harming theirhealth or safety, such as night shifts or overtime work.
(2-3) Consideration for work hours
Your company must not have workers conduct work in excess of the limit
stipulated under the laws and regulations of the region in which the workers work,
and it is necessary for your company to appropriately manage workers’ work hours
and days off based on the consideration of international standards.
(2-4) Appropriate wages and allowances
It is necessary for your company to comply with all laws and regulations that
apply to remuneration (including minimum wage, overtime pay, and legallyobligated allowances, and wage deductions) that will be paid to workers.
In addition, it is desirable to consider payment of wages at a level by which it ispossible to cover the items that are necessary for daily life (living wages).

7(2-5) Prohibition of inhumane handlingYour company must respect workers' human rights and must not conduct
inhumane handling, such as mental or physical abuse, coercion, or harassment,or actions that have a possibility of being such inhumane handling, of workers. In
addition, your company must clearly define a disciplinary policy and proceduresthat correspond to these requirements and convey that policy and those
procedures to workers.
(2-6) Prohibition of discrimination
In hiring and practical matters for hiring or employment, such as wages,
promotion, remuneration, and opportunities for education and training, yourcompany must not engage in discrimination or harassment based on race, skincolor, age, gender, sexual orientation, gender identity and gender expression,
ethnicity or nationality, existence or nonexistence of a disability, pregnancy,
religion, political party affiliation, union affiliation, existence or nonexistence ofmilitary service experience, protected genetic information, or existence ornonexistence of a spouse.
In addition, it is necessary to give consideration within an appropriate scope toworkers’ requests related to religious customs.
(2-7) Freedom of association, and collective bargaining rights
It is necessary for your company to respect workers’ rights to organize (right toform and participate in a labor union, conduct collective bargaining, and participate
in peaceful assembly) as a means of realizing discussions between labor andmanagement about the work environment and wage levels in compliance with local
laws and regulations.

3. Safety and health
It is necessary for your company to not only obey related laws and regulations
but to also keep in mind and follow the ILO’s safety and health guidelines andstipulate safety and health policies and objectives and the people responsible forthose matters, minimize workers’ injuries and physical and mental illnesses
associated with work, and implement initiatives to prepare a safe and healthy work
environment.
(3-1) Occupational safety
It is necessary for your company to identify and assess the risks for occupationalsafety and to ensure safety by using appropriate designs and technological andmanagement means.
Reasonable consideration for pregnant women and mothers who are in anursing period is particularly necessary.
(3-2) Preparation for times of emergency
It is necessary for your company to prepare for emergency situations, such as
disasters and accidents that will harm the safety of people’s lives or bodies,
identify such situations, including the possibility of occurrence, create action
procedures for times of emergency measures that will minimize damage toworkers and property, install the necessary equipment, and provide education andtraining so that the relevant actions will be taken in times of disaster.
8(3-3) Occupational accidents and occupational illnesses
It is necessary for your company to identify, assess, record, and report thesituation of occupational accidents and occupational illnesses and implement theappropriate countermeasures and corrective measures.
(3-4) Industrial health
It is necessary for your company to identify and assess the risks of workers
being exposed to harmful biological, chemical, or physical effects in the workplaceand conduct appropriate management.
(3-5) Consideration for work that has physical burdens
It is necessary for your company to identify and assess work that has physicalburdens and to appropriately conduct management so that such work will not leadto occupational accidents or occupational illnesses.
(3-6) Safety measures for machinery and equipment
It is necessary for your company to conduct assessment of whether or not there
are safety-related risks for machinery and equipment that workers use for theirduties and implement appropriate safety measures.
(3-7) Safety and health for facilities
It is necessary for your company to appropriately ensure safety and health forfacilities (dormitories, cafeterias, and restrooms) that are provided for workers’
daily lives. In dormitories, it is necessary to ensure appropriate emergency exits
for times of emergency.
(3-8) Communication for safety and health
It is necessary for your company to provide, by using language and methods
that workers can understand, education and training about appropriate safety andhealth information concerning various duty-related dangers for which there is apossibility that workers will suffer. In addition, a mechanism for providing feedbackof workers’ opinions related to safety is necessary.
(3-9) Health management for workers
It is necessary for your company to conduct appropriate health management for
all employees.

94. The environment
It is necessary for your company to proactively implement initiatives for global
environmental problems of the depletion of resources, climate change, andenvironmental pollution and give consideration to local environmental problems
by taking care to ensure the health and safety of the people of related regions. For
information about the Meiden Group’s ways of thinking about environmental
policies, please also read A-5 “The Meiden Group’s environmental policy.”(4-1) Environmental permission and reports
It is necessary for your company to follow the laws and regulations of thelocation of business, obtain the permission and approval that is necessary forbusiness, and conduct registration and reports.
(4-2) Energy consumption, and reduction of greenhouse gas emissions
It is necessary for your company to strive to improve energy efficiency andconduct continuous reduction activities for amounts of energy consumption andfor amounts of greenhouse gas emissions throughout the entire life cycle.
(4-3) Discharge into the atmosphere
It is necessary for your company to comply with related laws and regulations
and implement appropriate measures for curtailing the discharge of harmful
substances into the atmosphere.
(4-4) Management of water
It is necessary for your company to comply with laws and regulations, monitor
water sources, use, and discharge of water that is used, and save water.
For all kinds of wastewater, it is necessary to present its characteristics asnecessary and to conduct monitoring, control, and treatment before conducting
discharge or disposal. In addition, it is necessary to identify sources of pollutionthat have a possibility of causing occurrence of water pollution and to conduct
appropriate management.
(4-5) Effective utilization of resources, and management of waste
It is necessary for your company to comply with laws and regulations andconduct appropriate management, and thereby promote reduction, reuse, andrecycling, strive for effective utilization of resources, and minimize generation ofwaste.
(4-6) Management of chemical substances
It is necessary for your company to comply with laws and regulations, identify,
indicate, and manage chemical substances and other substances that will create
danger to people’s bodies or the environment, and conduct management so thatsafe handling, movement, saving, use, recycling/reuse, and disposal will be
reliably conducted.
(4-7) Management of chemical substances contained in products
It is necessary for your company to comply with customer demands and with alllaws and regulations that will be applied in relation to prohibition of use or
restriction of specific substances that are included in products.
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5. Fair transactions and ethics
It is necessary for your company to not only comply with laws and regulations,but to also conduct business activities based on a high-level sense of ethics. It isnecessary for top management itself to serve as a model, for all employees toperform business with a high sense of ethics, and for your company to obtain all
stakeholders’ trust.
(5-1) Prevention of corruption
Your company must comply with each country’s and each region’s laws forpreventing corrupt actions and must not conduct any type of bribery, corruption,
blackmail, or embezzlement.
(5-2) Prohibition of giving and receiving inappropriate profits
Your company must not provide or accept promises, offers, or permission asmeans for obtaining bribes or other unjust or inappropriate profits. For information
about the Meiden Group’s ways of thinking about prevention of corruption, pleasealso read the Guidelines for the Prevention of Bribery.
*The Meiden Group’s Guidelines for Prevention of Bribery
https://meidensha.disclosure.site/ja/themes/104(5-3) Prevention of money laundering
It is necessary for your company to prepare initiatives and internal control forthe purpose of preventing involvement in criminal actions, such as corruption
through money laundering, accounting fraud, or provision of funds for terrorism.
(5-4) Appropriate information disclosure
It is necessary for your company to follow applicable laws and regulations andthe industry’s customary practices to disclose information related to labor, safety,
health, environmental activities, business activities, organizational structure,
financial situation, and business performance. Falsification of records ordisclosure of false information will not be allowed.
(5-5) Respect for intellectual property
It is necessary for your company to respect intellectual property rights and to
conduct transfers of technology or knowhow in a form in which intellectual property
is protected. It is also necessary to protect the intellectual property of third parties
such as customers and suppliers.
(5-6) Fair performance of business
It is necessary for your company to comply with the competition laws of eachcountry and region and conduct fair business, competition, and advertisement,
and unfair transactions and actions, such as abuse of a superior bargaining
position are prohibited.
It is also necessary to block all relationships with antisocial forces or groups thatcause threats to the order or safety of civil society and to strive to not allow antisocial forces to obtain unjust profits.

11(5-7) Protection of whistleblowers
It is necessary for your company to protect the anonymity of whistleblowers andconfidentiality concerning information related to reports and to eliminate retaliation
against whistleblowers.
(5-8) Responsible mineral procurement
It is necessary for your company to follow the OECD Due Diligence Guidance
to confirm whether or not tantalum, tin, tungsten, gold, and minerals, such ascobalt and mica that are included in the products that your company is
manufacturing will cause, or are helping, serious human rights infringement,
environmental destruction, corruption, or disputes in conflict areas or high-risk
regions. For information about the Meiden Group’s ways of thinking about
responsible mineral procurement, please also read B-3 “Policy for responsible
mineral procurement.”

6. Quality and safety
It is necessary for your company to ensure the safety and quality of the products
and services that are provided and provide accurate information.
Inaccurate information related to safety and quality of products and services has
a possibility of having an enormous effect, through the supply chain, on not only
customers but also on the various stakeholders.
For that reason, it is necessary to create and operate a quality management
system and thereby conduct continuous improvement while going through the
PDCA (Plan, Do, Check, Act) cycle and ensure the safety and quality of products
and services.
(6-1) Ensuring products’ safety
It is necessary for your company to conduct designing, manufacturing, andselling by which it is possible to ensure sufficient product safety and for products
to fulfill the safety standards stipulated by the laws and regulations of each country
and region, as well as to carry out your responsibilities as a supplier.
In other words, when conducting product design, it is necessary to use designthat makes it possible to ensure sufficient product safety and conduct sales byconsidering responsibilities as a manufacturer. In addition, in relation to productsafety, compliance with laws and regulations is of course necessary, and it is also
necessary to consider the safety that should ordinarily be possessed.
For ensuring products’ safety, management of traceability (the history ofmaterials, parts, and processes), and prompt handling aimed at problem
resolution are useful.
When a change has arisen from the content that was agreed upon for amanufacturing process for the 4Ms (Man, Machine, Material, and Method) or otherwritten purchase specifications, please make a report in advance.
(6-2) Quality management
It is necessary for your company to not only comply with all applicable laws andregulations in relation to the quality of products and services but to also comply
with your company’s own quality standards and customer requirements. In orderto do so, it is necessary to create an appropriate mechanism and a management
system.
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(6-3) Provision of accurate product and service information
In relation to products and services, it is necessary for your company to provide
information that is accurate and that will not cause misunderstandings, tocustomers and consumers. In other words, it is necessary to provide accurate
information that will not cause misunderstandings in relation to products andservices. False information and information that has been manipulated must not
be provided.
When an impropriety, such as provision of false or manipulated information, isdiscovered, credibility as a corporation will be lost, an enormous amount ofverification work will be required, and even continued existence as a corporation
will be endangered.
Accurate information refers to things such as those below, for example.
− Content related to specifications, quality, and methods of handling related to
products and services is accurate. (Expressions that differ from the facts will
not be used, or customers’ misunderstandings will not be caused.)− Information about substances contained in materials and parts that are usedin products is accurate.

7. Information security
It is necessary for your company to prevent leaks of confidential information andpersonal information and to strive to strengthen information security.
(7-1) Defense against cyber attacks
It is necessary for your company to take defensive measures against threats
from cyberattacks and conduct management so that damage will not arise for yourown company and other parties.
(7-2) Protection of personal information
For all personal information about parties, such as suppliers, customers,
consumers, and employees, it is necessary for your company to comply withrelated laws and regulations and conduct appropriate management and protection.
(7-3) Prevention of leaks of confidential information
It is necessary for your company to thoroughly conduct management so thatnone of the confidential information of not only your company but also that whichis received from customers and third parties will be dishonestly obtained, used,disclosed, or leaked.

8. Business continuity plans
In order for your company to carry out its supply responsibilities in cases inwhich your company or a supplier for your company encounters an emergency
situation because of a large-scale natural disaster, a massive fire, an epidemic, or
terrorism, it is necessary for your company to conduct preparations so that it will
be possible to resume production activities as soon as possible.
(8-1) Formulation and preparation of business continuity plans
It is necessary for your company to identify and assess risks that will inhibit
business continuity and to formulate business continuity plans (BCP) thatsummarize careful examination of effects on business, precautionary measures13

that are necessary for the medium and long term, and initiatives for thoseprecautionary measures.

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Part 2: Creation of a management system
A. Creation of a management system
In order to realize compliance with Part 1: Code of Conduct, it is necessary foryour company to create a management system and strive for continuous
improvement through appropriate operation of that management system. In
addition, in order for all workers to implement your company’s policies, processes,
and improvement targets and fulfill the requirements of applicable laws andregulations, it is necessary for them to regularly undergo education and training
programs.

B. Management of suppliers
It is necessary for your company to convey the requirements of Part 1: Code of
Conduct to suppliers and to create a process for monitoring suppliers’ compliancewith standards.

C. Appropriate export and import management
It is necessary for your company to comply with the laws and regulations of eachcountry and region and to thoroughly conduct confirmation, under a clear andspecific management system, of whether or not technologies and products thatwill be exported or imported are subject to regulation and about whether or notcountries or regions for export or import are subject to trade regulation.

D. Preparation of a mechanism for handling complaints
In order to prevent improper actions at your company and in the supply chain
and to make relief from infringement of human rights possible, it is necessary foryour company to create a complaint-handling mechanism that can be used bystakeholders, including workers and suppliers, and to implement appropriate
corrective measures. Measures must also be implemented so that whistleblowers
will not incur disadvantages.

E. Disclosure of the state of initiatives
It is necessary for your company to create documents and records about
initiatives for these guidelines and to conduct information disclosure based onrelated laws, regulations, and international standards.

(End)

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3. Revision history
No.
1

Month and yearof revision
October 2010

2
3

January 2014
July 2022

History
Creation of the first edition of the Meiden Group Guidebook for
Promotion of Supply Chain CSR
New addition of items of “IV. Fair transactions and ethics”− Change of the title to Meiden Group Guidelines for Sustainable
Procurement− Established based on the Meiden Group’s company-wide policies
and procurement policy and by referring to laws, regulations,standards, and guidelines that are widely recognized throughout theworld

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