FUKOKU Group
Compliance
Guidebook
FUKOKU Co., Ltd.

Table of contents
About FUKOKU Group Compliance Guidebook

Message from the President
FUKOKU Group Compliance Initiatives
Basic Policy on Sustainability
FUKOKU Group Employee Code of Conduct
１．A safe and healthy working environment
２．Respect for human rights and diversity
３．Harmony with the global environment
４．Adhering to customer contracts
５．Compliance with import and export laws and regulations
６．Prohibition of conflicts of interest
７．Appropriate management of confidential and personal information
８．Protection of intellectual property
９．Fair competition
１０．Honest transactions and prohibiting bribery

About FUKOKU Group Compliance Guidebook
Message from the President
Since our founding in 1953, FUKOKU has practiced its corporate philosophy of “Contributing to people’s happinessthrough the creation of new value” under the rallying cry of “Yes, We Do! (Let’s Take on New Challenges
Together!).” In April 2007, we compiled our Guidelines for Corporate Behavior to help us act in a manner
appropriate to a global company. These guidelines have been revised as the FUKOKU Group Employee Code of
Conduct, and we are now issuing a Compliance Guidebook to guide the actions of each employee.
You may feel that the content of this guidebook should be self-evident to any businessperson or adult member ofsociety, but for FUKOKU to be able to continue its business while receiving the trust and empathy of society, it is ofutmost importance for each and every employee to contribute to people’s happiness by actually doing all of those
things that should be “obvious,” and to do so continuously and consistently.
No matter how good a company’s product may be, if its employees act in a way that runs contrary to the
expectations of society, the company will not be trusted. We have been charged with upholding public trust in ourcompany, and if each employee could draw upon these guidelines as the foundation of their actions, then we would
be able to build up that trust.
The environment surrounding companies is changing year by year. Corporate activities are becoming increasingly
globalized, and the personalities and values of people working within companies are diversifying. We must hold not
only our action guidelines but also our actions up to the demands and expectations of society, adapting anddeveloping them to keep pace with the changing times.
Each of you should read this guidebook carefully and familiarize yourselves with its contents. If you are unsure
about your actions, talk to your supervisor, your specialized department, or the company’s consultation service.
Your voices are important to the company, and the company respects the human rights of every single one of you.
Through the actions of each of us, we can build a company in which all employees can feel the joy of contributing topeople’s happiness and take pride in working for FUKOKU. Let us work together toward that goal.
FUKOKU Co., Ltd.
President & CEO Takashi Ogawa

About FUKOKU Group Compliance Guidebook
FUKOKU Group Compliance Initiatives（1/2）
Compliance“Compliance” is sometimes defined as the “observance of laws and regulations,” but it is actually broader thanmerely observing laws, regulations and internal company rules (such as employment regulations). One can also
think of it as observing social norms and meeting the demands of society. Both as an employee of the FUKOKUGroup and as an individual human being, it is important to be aware of social norms, including morals and manners,
and to act accordingly.

The Risks of Compliance Violations◇ Compliance violations cause serious damage and loss to the company.
◇ Violations of laws and regulations can result in legal penalties for the company and its employees, including finesand prison sentences if a criminal case develops. In some cases, harm to customers and suppliers can lead tolawsuits and the payment of high sums in compensation.
◇ Being seen by society as a “compliance violator” has several negative impacts on a company, including theworsening of its image, the loss of public trust, falling share prices, and reduced business performance.

About FUKOKU Group Compliance Guidebook
FUKOKU Group Compliance Initiatives（2/2）
FUKOKU Group Compliance Guidebook
This guidebook covers the most important compliance topics and is based on both the FUKOKU Group Basic Policy
on Sustainability, which places great importance on compliance, and the FUKOKU Group Employee Code of Conduct.
Each and every employee of the FUKOKU Group is encouraged to read, think about, and deepen his or her
understanding of this guidebook.
-- Are there any words that you continue to use or actions that you continue to carry out even though you know
they are bad?
-- Do you turn a blind eye to problems you have noticed?

Basic Policy on Sustainability

FUKOKU Group
Employee Code of Conduct

FUKOKU Group
Compliance Guidebook

About FUKOKU Group Compliance Guidebook
Basic Policy on Sustainability
The FUKOKU Group considers it a top management priority to contribute to the creation of a sustainable world byaddressing the various issues facing the environment and society. Based on the following three pillars, the Groupwill realize its corporate philosophy of “challenging to create new value and contributing to a future full of dreams.”（１）Environmental considerations and compliance
We will value the environment and offer high-quality, long-lasting, energy-saving, and resource-conserving
products and services. Our business activities will emphasize compliance, including compliance with the laws andregulations of each country we operate in, consideration for human rights, respect for the traditions and culturesof all nations, assurance of diversity, fair and healthy working conditions, and the protection of personal
information.

（２）Building mutual trust with stakeholders
We aim to become a trusted company. To this end, we will strive to disclose accurate and clear information.
Furthermore, we will ascertain the expectations and demands of our customers, business partners, employees,
shareholders, local communities, and other stakeholders through interactive dialogue, and work to fulfill these
expectations and demands.
（３）Fostering a corporate culture that promotes sustainability
Under the leadership of our top management, we will continue to educate and enlighten all Group employees onsustainability while marshaling the wisdom of each and every employee to take on the challenge of creating newvalue.
May 2022
FUKOKU Co., Ltd.
President & CEO Takashi Ogawa

About FUKOKU Group Compliance Guidebook
FUKOKU Group Employee Code of Conduct（1/2）
１．Supplying safe and high-quality products
１） We will comply with applicable laws and safety regulations when we develop and manufacture our products.

２） We will supply safe and high-quality products in accordance with customers’ needs.
３） We will rapidly take corrective actions and measures to prevent recurrence whenever a problem occurs.

２．Conducting sales and other corporate activities fairly and transparently
１） We will establish a relationship of mutual trust with our customers, suppliers and other business partners.
２） We will conduct transactions fairly in accordance with applicable laws and regulations such as antitrust laws.
３） We will not be engaged in any acts of bribery. We will not give and/or receive any business entertainment, gifts, or anything
beyond socially accepted common sense.

３．Prompt disclosure and communication of corporate information
１） We will promptly and actively disclose our corporate information to shareholders and investors to enhance transparency ofmanagement.
２） We will promptly disclose the necessary corporate information to other stakeholders.
３） We will collect and manage the latest and most accurate information.

４．Creating a cheerful, safe and pleasant work environment.
１） We will respect the individuality of every associate and promote everybody’s creativity.

２） We will strongly prohibit discrimination and harassment.
３） We will comply with labor laws and regulations; our objective is to keep proper employee management as well as health and safety.
４） We will develop our personnel system with fair evaluations and treatments, creating an open and energetic corporate culture
based on this system.
５） We will extend the above to our overseas operating sites and business partners, which may have different laws and/or social
conditions.

About FUKOKU Group Compliance Guidebook

FUKOKU Group Employee Code of Conduct（2/2）
５．Taking actions for environmental protection
１） We will comply with environmental protection laws and regulations and prevent environmental pollution.
２） We will actively commit to carrying out business activities with a low environmental impact.

６．Protection of intellectual property rights and confidentiality
１） We will execute an adequate preliminary survey to avoid infringement of a third parties’ intellectual property rights.
２） We acknowledge the company’s management of confidential information from sales, engineering (including know-how andprocesses), and other areas, and our obligation to keep them in a strictly controlled condition.

７．Contributions to society１） Our company’s objective is to coexist with and grow together with society.
２） We will actively engage in positive activities to contribute to our community.
３） We will properly perform our duty to pay taxes as a responsible taxpayer.
４） We will not have any relation with any antisocial organizations and will take a firm stand against them.

８．Considerations for international business activities
１） We will import and export in accordance with applicable laws and regulations and under appropriate procedures.
２） We will comply with local laws and regulations and respect local culture when we conduct operations overseas.

９．Developing a compliance system
１） We will develop a compliance system to ensure that corporate activities be conducted in accordance with this code of conduct.
２） We will promptly report a violation of this Code of Conduct to the corresponding consultation contact as soon as we identify theviolation. We fully understand that retaliatory measures to the whistleblowers who report violations are prohibited and will protect
them.

1.

A safe and healthy working environment（1/2）
Preventing workplace accidents and ensuring employees health and safety
in the workplace.

We strive to eliminate occupational accidents and create a comfortable workplace where
people can work safely and healthily. Each and every employee will maintain a highawareness and knowledge of health and safety while ensuring that the rules of their work
are being followed.
We also aim to reduce stress factors in the workplace and create a workplace environment inwhich each employee is free from excessive job-related anxiety and worry.
Essential Points●We will ensure the management of health and safety in the workplace and health and safety education.
●We will understand internal rules (such as work processes) and comply with established processes,
procedures, and standards.
●We will ensure that any work requiring legal qualifications is performed by qualified personnel.
●We will report minor incidents immediately, making improvements and taking countermeasures to prevent
accidents to oneself and coworkers.
●We will treat something as “disordered” if it is “different from how things normally work,” and torespond accordingly. For example, if a machine makes unusual sounds, smells, does not work, and so on,take the three actions of a) stopping the machine, b) calling a supervisor, and c) waiting for instructions.
●We will strive to eliminate overwork and achieve a work-life balance for employees.
●Alcohol or drugs that could affect safety will not be consumed prior to work.

1. A safe and healthy working environment（2/2）
Inappropriate Cases◇An employee disabled safety devices in order to speed up work.
◇Injuries occurred because the prescribed protective equipment (protective goggles, cut-resistant gloves,etc.) was not used.
◇People were working in forced, unnatural postures or in dangerous positions.
◇Items were piled up in an unstable way.

2.

Respect for human rights and diversity（1/3）
We respect the human rights of all people, do not discriminate on the basis of gender,
nationality, or other factors, and treat people fairly.

（１）Respect for human rights and diversity
We respect the human rights of all people and value the diversity of our employees, treatingeach other with respect.
We aim to eradicate discrimination on the basis of gender, nationality, culture, religion, physicaldisability, and other characteristics. We evaluate each individual and allocate positions
according to each employee's ability and performance.
Essential Points●We are careful not to accept anything bearing any relationship to child labor, human trafficking, or forcedlabor in any form.
●We respect the diversity of our employees and strive to create a workplace where each employee candemonstrate his or her abilities.
●In hiring, evaluation, and work allocation, we will not make unfair evaluations based on the personalvalues and prejudices of evaluators that have nothing to do with ability, performance, or aptitude.

2. Respect for human rights and diversity（2/3）（２）Preventing harassment
We will never engage in harassment.
We will always speak and act with respect, not only to those within the company, but to all
those with whom we interact through our work.
※By “harassment” we primarily refer to aggressive pressure and bullying. It is an unjustified infringement of
personal dignity and a violation of human rights.
※The appropriate supervision of work does not constitute harassment.
However, when work supervision becomes overbearing or aggressive in language or behavior, it may go
beyond the scope of supervision.

Essential Points●We acknowledge the reality that many of those who are guilty of harassment are unaware that their own
words and actions constitute harassment.
●We understand that viewpoints such as “if I don't yell, they won't improve,” “they deserved it for
doing things wrong,” and “everybody does it” are not justifications for words and actions that
constitute harassment.
●We should stay in constant communication with each other, not treat others with indifference, andproactively approach each other when we see someone in need of help.

2. Respect for human rights and diversity（3/3）
Inappropriate Cases◇Giving different work assignments and employment conditions, etc. based on race, religion, nationality,
gender.
◇Loudly reprimanding someone in front of everyone for a minor mistake.
◇Criticizing someone in a way that put them down as a human being.
◇Making fun of someone on the topic of sex and sexuality.
◇Persistently asking about family and private matters, asking questions such as “Why aren't you
married?”◇Assigning quotas that were impossible to achieve.
◇Deliberately not assigning someone any work.

3.

Harmony with the global environment（1/2）
Each of us will act to protect the planet from environmental destruction.

Harmony with the environment is essential to contribute to people's well-being.
In addition to complying with environmental laws and regulations, we will take responsibility
for the entire process of product development, raw material procurement, manufacturing,sales, and disposal, and actively engage in environmental conservation with the aim ofminimizing environmental impact and promoting environmental contribution activities.
Essential Points●Energy Conservation
We are working to manage and reduce our energy use to ensure energy is used without waste and to
reduce our CO2 emissions.
●Water Resources
We are working to manage and reduce our water use (tap water, groundwater, industrial water) toensure it is used without waste.
●Chemical Management
We are striving to manage our use of chemicals to ensure they are used without waste and to reduce thequantities used.
●3R (Reduce, Reuse, Recycle)
We are engaged in the separation and recycling of industrial waste products. We are also working to curb
the generation of industrial waste.
●Pollution Prevention
To prevent air and water pollution, foul odors, and other forms of pollution, we will take responsible
measures to prevent pollution throughout the entire process from the development of our products tothe procurement of raw materials, manufacturing, sales, and disposal.

3. Harmony with the global environment（2/2）
More specifically...
◇Reducing quantities of materials used by making our products smaller and lighter. Extending the service
life of our products.
◇Disposing wastewater in strict compliance with laws, regulations, and standards and re-using waterused in production.
◇Promoting paperless operations.
◇Reducing Volatile Organic Compounds (VOC) emissions through measures to prevent volatilization ofadhesives and paints.
◇Conducting thorough voluntary inspections to prevent leaks of chlorofluorocarbons(CFCs).
◇Promoting the reuse of pallets, shipping cartons, etc. used for transportation.

4.

Adhering to customer contracts
We do not make changes to designs or processes without customer approval.

We are obliged to produce and deliver products based on the contracts we enter into withour customers.
Any design or process change made without the customer's approval is considered a breachof contract for failing to fulfill its obligations. We will never engage in any practices that could
damage the quality or credibility of the company.
Essential Points●When making changes to designs or processes, we will not only follow our internal procedures, but also
refer to the customer's criteria and request the customer's permission to make said changes.
●If the customer has no criteria, we will determine whether a request is required based on our internal
criteria (in particular, judgments will be made based on the internal criteria that address the contract,acknowledgment, and trust with the customer).

Inappropriate Cases◇Changing the materials, source of materials, or production location of the materials without obtaining
prior approval from the customer.
◇Fearing delivery deadlines would not be met due to increased orders, production was carried out at
another factory that had not yet been approved.
◇When initiating a new product, Production Part Approval Process (PPAP) data was created for adifferent product type or production process and submitted to the customer.
◇When submitting PPAP, past data was appropriated.
◇Molds were renewed without first obtaining customer approval.
◇Although the product did not conform to the performance evaluation standards required by thecustomer, a false inspection certificate was prepared and delivered, claiming that it conformed to thesame standards.

5.

Compliance with import and export laws
and regulations（1/3）
We will follow correct declaration and labeling procedures at customs clearance.

We will comply with all applicable laws and regulations when importing or exporting.
In particular, from the perspective of maintaining international peace and security, we will
maintain a firm understanding of and comply with arms export controls regulating the exportof arms and goods or technology usable for military purposes. From the perspective ofapplying customs policies, etc., we will likewise maintain a firm understanding of and comply
with rules of origin.
Furthermore, we will work to ensure that our products bear no relation to conflict minerals intheir procurement, import, and export.
※“Arms export controls” refer to the rules regulating the export of weaponry for the maintenance ofinternational peace and security.
※“Rules of origin” refer to rules for determining the origin (country) of a product.
※Conflict minerals are four types of minerals – gold, tantalum, tin, and tungsten – produced in the Democratic
Republic of Congo and neighboring areas that may be a source of funding for armed groups that haveperpetrated serious human rights abuses.

5.

Compliance with import and export laws
and regulations（2/3）

Essential Points（1/2）（１）Arms export controls●We will not take out of the country any goods, technology, etc. (※) regulated by the Foreign Exchange
and Foreign Trade Act or other applicable domestic or foreign laws and regulations without obtaining anexport license. Even when dealing with unrestricted cargo, we will not do business with countries orcompanies that are subject to restrictions.
※This includes materials that can be converted to military use and machine tools that can be numericallycontrolled.
●When carrying work-related products, materials, jigs and tools, etc. as hang luggage on overseas businesstrips, we will be sure to consult with logistics management departments in advance.
●Export regulations vary from country to country (e.g., U.S. export control regulations) and are subject toconstant change, so we will check with the relevant authorities as we proceed.
（２）Rules of origin●We will not engage in any act that falsifies the conditions of the rules of origin in order to obtain
preferential tax rates under economic partnership agreements and free trade agreements.
●We will always provide sufficient information on the origin of the goods to the customs authorities of thepartner country who will determine the application of the preferential tax rate, and we will do so before

applicable deadlines.
●When changing the price or raw materials for products to be exported, we will check whether theconditions of the rules of origin in the articles and annexes of the respective agreements still apply after
such changes.

5.

Compliance with import and export laws
and regulations（3/3）

Essential Points（2/2）（３）Conflict minerals●We will investigate suppliers and other parties to ensure that our products do not contain conflictminerals. We will not procure parts or materials that may contribute to human rights abuses.

Inappropriate Cases（１）Arms export controls◇The parts we purchased were not classified as restricted cargo but became restricted cargo due tomodifications. However, we exported the products without realizing it.
◇We shipped items by EMS, DHL, or other international courier services without checking the trade control
regulations of the partner country.
◇We purchased equipment for use in the company through an overseas internet auction without checking
import regulations.
（２）Rules of origin◇The risk of additional and penalty taxes was incurred because the original certificate of origin was usedeven though the manufacturing plant was moved overseas and a preferential tax rate was applied.
◇We used the original certificate of origin for exports and received preferential tax rates, even though therules of origin were no longer satisfied due to having changed the materials to reduce costs and loweringtransaction prices.
（３）Conflict minerals◇We purchased materials knowing that they contained gold, tantalum, tin, and tungsten, and did not
check whether they constituted conflict minerals or not.

6.

Prohibition of conflicts of interest（1/2）
We will not engage in any conduct that conflicts with the interests ofthe company, such as seeking personal gain or using the company's assets orinformation (conflicts of interest).

（１）Conflicts of interest
In addition to clearly distinguishing between work duties and private activities, we will neverengage in any conduct that would compromise the interests of the company for their own ora third party's benefit.
Essential Points●We will not take advantage of our work positions to benefit ourselves or a third party.
●Company property (product inventory, production facilities, information systems, furniture, etc.) shall be
used appropriately for business purposes and shall not be used for personal purposes.
●We will not download files containing confidential information for private purposes.

Inappropriate Cases◇An employee used company equipment, company cars, cell phones, computers, and copy machines, etc.
for personal purposes.
◇ An employee padded the bills for transportation and other expenses for business trips and invoiced thecompany for the expenses.
◇ An employee subcontracted a manufacturer run by a relative to produce parts under conditions thatdeviated from what would be considered rational.

6. Prohibition of conflicts of interest（2/2）（２）Insider trading“Insider trading” refers to the buying and selling of publicly listed stocks based on
undisclosed information available only to insiders. It is not only a conflict of interest, but also a
serious crime that can result in criminal penalties. Such inside information must never be
provided to third parties, including family members.
Essential Points●If an employee becomes aware of a material fact about a company or another company, he or she mustnot buy or sell shares or other securities of that company before the information is publicly announced.
●If an employee becomes aware of undisclosed material facts about the company or other companies, heor she must not communicate such facts to family, friends or third parties.

Inappropriate Cases◇An employee learned of a business tie-up with another company before it was announced andpurchased shares in anticipation of a rise in the share price.
◇An employee learned some inside information about the company's performance for the current fiscal
year and told a friend, “You should sell your shares while you still can because there will be a disclosure
about the company's performance next week.”

7.

Appropriate management of confidential andpersonal information（1/2）
Confidential information must be managed properly and must not be used for purposes
other than those previously specified. In order to protect privacy, personal informationmust be properly managed in accordance with laws.

Confidential information belonging to the company and disclosed to the company by othercompanies must be properly managed. It must not be used for any purposes other thanthose previously specified. Furthermore, confidential information must not be disclosed tothird parties, nor to anyone other than company employees and executives who have been
given authorized access to such information.
We will take every precaution in handling personal information, given that personal
information is subject to legal protection.
Essential Points●Handling confidential information①Confidential information shall be managed properly in accordance with internal company regulations andagreements with other companies concerning confidential information.
②Both during and after our employment with the company, we must not divulge or use for private
purposes any confidential information obtained during our employment.
●The protection of personal information①We will comply with each country's laws on the protection and use of personal information, as well aswith internal company regulations.
②When personal information is obtained, the person concerned must be notified of the purposes of its use.
③The personal information must not be used for any purposes other than those notified to the person
concerned.
④The provision of personal information to third parties is subject to the laws of each country and internal
company regulations.

7.

Appropriate management of confidential andpersonal information（2/2）

More specifically...
◇Confidential information such as diagrams received from business partners shall be strictly managed inaccordance with confidentiality agreements concluded with the suppliers.
◇Files containing confidential or personal information must not be stored on a local network that can beaccessed from anywhere.
◇Documents containing confidential or personal information must not be left unattended on a desk.
◇Personal information such as telephone numbers and addresses must not be disclosed without theconsent of the individual concerned, even within the workplace.
◇Matters involving confidential company information may not be discussed in public places such as inside
trains, buses, and restaurants. In addition, such information must not be made available to third parties,
such as by being posted to social media.
◇When taking computers outside the company for business purposes only, security measures must be
taken, as well as measures to prevent the computers from being lost or stolen.

8.

Protection of intellectual property（1/2）
We recognize that intellectual property is a company asset and must be protected
appropriately.

Intellectual property rights such as patent rights (inventions), utility model rights (plans),
design rights (designs), copyrights (written works), and trademark rights (product and service
names) are becoming increasingly important as a source of competitiveness.
We recognize that intellectual property is an important asset of the company, and we willprotect it appropriately, taking sufficient care not to infringe on the intellectual property rights
of other companies.
Essential Points●We will promptly report to the company any inventions created during our work and endeavor to protect
and exercise the rights of such inventions.
●Technical information must not be disclosed prior to the filing of a patent application.
●Whenever we intend to manufacture or sell a new product, we will thoroughly check in advance to ensurethat we do not infringe on the intellectual property rights of others.
●Unlike patents, copyrights are protected without the need for an application. Therefore, when drafting
documentation, we will not quote the works of others without approval from the source.
●If we become aware of any infringement or threatened infringement of our intellectual property rights byother companies, we will promptly report it to the intellectual property department.
●Computer and other software shall be used appropriately in accordance with the license agreement.
●The copyrights of all documents, files, reports, etc. obtained or created in the course of work belong to thecompany and will not be released to outside parties without the company's permission.

8. Protection of intellectual property（2/2）
Inappropriate Cases◇The company applied for a patent based on technical information obtained from a customer, claiming
the invention as its own.
◇When preparing presentation materials for external use, text and diagrams were copied from anothercompany's website.
◇New product or technical information was announced externally before a patent application was filed.
◇Articles about the company were copied without the copyright holder's permission and distributed
internally and to business partners.
◇Computer software was used, copied, or installed without obtaining a license or exceeding the scopeof the license.

9.

Fair competition（1/2）
We will vigorously engage in corporate activities while complying with competition laws
and based on free and fair competition.

We will comply with competition laws and other laws and regulations and engage in faircompetition with our competitors.
We will not form cartels with other companies in the same industry, nor will we engage in any
activities that unfairly restrict competition.
※Competition is essential for the development of the company, but it must be fair. Competition laws exist
around the world to prevent unfair behavior with the goal of maintaining and promoting a state of fairand free competition. Violations can result in serious penalties not only for the company, but also for theindividuals involved.
Essential Points（1/2）（１）Compliance with competition laws
●We will not engage in so-called cartels in which multiple companies collude to set common prices andproduction volumes. Such decisions should be made independently by each company.
●We will avoid activities that could raise suspicion of cartel-like behavior, such as having dinner meetings
with other companies in the same industry.
※If there are meetings where contact with other companies in the same industry is unavoidable, be sure tofollow the company rules.
●We will consider cartels to be illegal not only within home country but in all countries.
●We will remain fully aware that fines (sanctions) for violations of competition laws can be so severe thatthey can bankrupt companies. We also recognize that individual perpetrators may be liable to criminal andcivil prosecution.

9. Fair competition（2/2）
Essential Points（2/2）（2）Prohibition of unfair competition●We will not obtain confidential information of competitors by unfair means or use information that may

have been obtained by unfair means.
●We will not display misleading documentation or data to deceive customers about the origin, quality,
contents, or manufacturing method of our products.

Inappropriate Cases（１）Compliance with competition laws
◇We colluded with competitors to set and raise product prices together.
◇To prevent a drop in contract prices, companies within the same industry colluded to take turns taking
orders from each other and jointly bid for the contract.
◇We met with a competitor to exchange information regarding a competing product.

◇We ran into a competitor by chance and answered carelessly when asked about the status ofa price increase or reduction being negotiated with a customer.
（２）Prohibition of unfair competition◇We illegitimately obtained confidential information consisting of design drawings from employeesof another company and used the designs to manufacture the products.
◇We falsely labeled products manufactured overseas as “Made in Japan.”◇We discredited a competitor or its product with unfounded accusations.

10.

Honest transactions and prohibiting bribery（1/2）
We neither offer nor accept bribes.
We do not exchange entertainment or gifts with suppliers or clients beyond accepted
common sense.

We will not give, offer, promise, or accept, either directly or indirectly, any bribe to any numberof people. Entertainment and gifts shall be provided in accordance with the laws of eachcountry and internal company regulations. We will not offer or accept excessive
entertainment or expensive gifts that could influence professional judgment.
※If payment of some form is necessary to avoid harm to life, body, or liberty (for example through assault, threats, orconfinement), personal safety should take the highest priority.

Essential Points●We will not give, offer, promise, or accept, either directly or indirectly, any bribe to any number of people,
including, but not limited to, public officials.
※Bribe is money or goods given for an improper purpose, such as to obtain an arrangement for one's
own benefit, and bribery is the giving and receiving of a bribe. In recent years, laws and regulations
concerning bribery have been tightened worldwide, and investigations are becoming stricter. In somecountries, it is considered a crime to offer benefits to executives and employees of private companies.
●“Payments to grease the wheels,”(Facilitation Payment) which are small payments to public officials
to expedite official procedures, are no exceptions. They are also bribes and will not be tolerated.
●When making donations, contributions, and the like, we will comply with the laws of each country and ourinternal regulations.
●When giving gifts or entertainment to customers or business partners, we will follow company rules andprocedures.

10. Honest transactions and prohibiting bribery（2/2）
Inappropriate Cases◇To ensure a smooth approvals process for the permits and licenses required by our business, we took
the public official in charge of permits and licenses out for food and drinks and asked him to take ourcase into consideration.
◇A supplier offered to deliver a product at a price significantly higher than the market price, for which we
received a rebate.
◇A certain amount of money was given in cash to local consultants affiliated with the company overseas
for the cost of obtaining the necessary permits and licenses.
◇We received a computer and a personal service account from a service vendor who was one of thecandidates to become a partner.

Issue：Compliance Committee
Supervision
Human Resources Dept.／Internal Audit Dept.

Cooperation
FUKOKU Group Each company
First edition
September 28, 2022