Nikkiso Group Global Code of Conduct

IGeneral Provisions
This Nikkiso Group Global Code of Conduct (the “GCC”) shall set internal standards of the highest
level with respect to compliance. The GCC provides the basic rules that we must observe to enable
us to follow our conscience and to contribute to society as corporate citizens.

IIBasic Policy
We will obey the laws, regulations, our articles of incorporation, the social norms and the GCC(“laws/GCC”) in all of our business and other activities. In the event we detect a potential violation
within the scope of the laws/GCC we will not condone such conduct, but will take the necessary
action to deal with it.

III Scope
The GCC applies to Nikkiso Co., Ltd, (“Nikkiso”) and its group of companies (meaning thecompanies in which Nikkiso holds, directly or indirectly, a majority of outstanding voting shares orequity, or companies that Nikkiso substantially controls; collectively the “Nikkiso Group”), andtheir officers and employees (including the members of the board of directors, auditors, directors,executive officers, corporate advisors, and employees (including non-regular employees, seconded
personnel, part-time employees, temporary workers, and dispatched workers).
IV Code of Conduct
1. Fair and honest business activities(1) Free competition• We will not enter into an agreement with any third party that interferes with the market
mechanisms, including price fixing, dividing territories, and restricting the supply ofproducts.
• We will not take advantage of our position in a transaction to force unreasonable terms andconditions on our business partners.
(2) Fair transactions• We will select our business partners based on price, quality, delivery term, and otherobjective criteria in the procurement of products and services.
• We will endeavor to maintain and improve mutual understanding and trusting relationships
with our customers and business partners from a long-term perspective.

(3) Quality and safety of products and services• We will provide products and services with high quality and safety.
• We will confirm the facts promptly and take appropriate action, in the event the quality orsafety of our products and services is brought into question.
(4) Gift-giving and entertainment• We will not offer entertainment or gifts to employees who are in public service, such as
government employees and local authorities, and foreign public service personnel.
• We will not offer the entertainment or gifts to our customers or business partners (including
potential customers or business partners) beyond the range acceptable in terms of the law,customary practice, or business courtesy; we will not receive entertainment or gifts beyond
that range.
(5) Export control• We will observe the export control laws and regulations of each country (including the USExport Administration Regulations) in the exporting of goods and their related
technologies, and prevent any unlawful action.
• We will not participate in exports that may obstruct the maintenance of international peaceand security.
(6) Disclosure and dissemination of corporate information• We will disclose corporate information according to the requirements of the law, value
dialogues with our stakeholders, and strengthen two-way communication with society.
• We will endeavor to disseminate accurate corporate information while giving consideration
to the need for confidentiality.
(7) Prohibition of insider trading• We will not disclose the insider information of the Nikkiso Group or other companies that
we come to know during the course of our work to any persons other than those who needto know for the purpose of business, and will control such information in a proper manner.
• We will not purchase or sell shares of Nikkiso or other companies using the insider
information pertaining to these companies.
(8) Tax Compliance Efforts
・ We will maintain and improve our tax compliance efforts and fulfill our social
responsibilities by, among other things, paying all taxes in accordance with the law andregulation of each country and region in which we operate, and by implementing
appropriate tax risk management controls. The details of the tax standard of conduct are
specified separately in the "Nikkiso Group Global Tax Standard of Conduct".
2. Protection of corporate assets and management of information(1) Corporate assets• We will make efficient use of the assets of the Nikkiso Group for our business activities
while protecting them against loss, theft, and destruction.
• We will not use any assets of the Nikkiso Group for any purpose other than our business.
(2) Conflicts of interest• We will carry out our business activities by making judgments that are in the best interestsof the Nikkiso Group.
• We will not engage in any act that is, or may be, in conflict with the interests of the Nikkiso
Group.
(3) Intellectual property• We will promote research and development activities through the protection andapplication of the intellectual property rights of the Nikkiso Group.
• We will not make unauthorized use of or infringe upon the intellectual property rights of athird party.
(4) Records and reporting• We will prepare records and reports regarding business activities, including accounting andfinance, accurately and in a timely manner.
• We will not intentionally prepare false records or misleading reports.
(5) Confidential information• We will not disclose or disseminate any information provided by our customers or business
partners, or any confidential information of the Nikkiso Group, without due and properauthorization.
• We will use such information only to the extent our business requires it.
(6) Personal information• We will respect the individual right to privacy.
• We will prevent leakage, loss, or damage of privacy and personal information by taking

appropriate security measures.
3. Respect for human rights and harmony with environment(1) Respect for human rights• We will respect the rights of individuals, and will not force anyone to work against his/her
will or employ child labor.
• We will not treat any person unfairly on the basis of race, nationality, religion, creed, gender,gender orientation, age, or disability in recruitment, employment, and promotion.
(2) Soundness of workplace• We will encourage each other to improve the safety of the workplace and productivity.
• We will not commit any act that could create hostile human relationships, such as
discriminatory behavior, sexual harassment, and power harassment.
(3) Conservation of environment• We will promote the development, production, and sale of technologies and products thatwill contribute to the conservation of the environment.
• We will work to prevent global warming, to ensure the cyclic use of resources, and toprotect the ecosystem.
(Established on October 5, 2015)(Amended on December 4, 2017)- END -