1■FraudTriangle
We shall understand that violation of compliance rules tends to occur when thethree factors of 1. Motivation/Pressure to do an illegal act, 2. Opportunity to do
an illegal act, and 3. Justiﬁcation of doing an illegal act, are in full. We shall try
to create a workplace free of compliance breaches by preventing formation of
this“Fraud Triangle”.

Ⅰ

Compliance with Laws and Social Norms;
Ethical Conduct1

Mandom Group’s ComplianceWe, as members of society, shall fully understand the laws, customs and all othersocial norms of our country and other countries in their meaning and intent; weshall strictly adhere to them with a spirit of compliance and always think and act
ethically with a high standard of social awareness and judgment.
The origin of Mandom Group’s compliance is OYAKUDACHI (MANDOM SPIRIT)
and Being honest with society (Corporate Philosophy).

In other words, our compliance is not a passive and defensive concept of“juststicking to the letter of the law.”Rather, our compliance is an active and positive
concept: we will obviously adhere to the law (minimum level of moral behavior) but
will also hold our own standards at a higher level for the attainment of“OYAKUDACHI for consumers”, ensuring consumers’safety and interests.
To be honest to the society, we shall always pursue compliance-driven business
management. We will never adopt dishonest means as a way of achieving success.
Therefore, for Mandom Group,(1) The ends never justify the means.
We shall not permit any line of thinking that condones the use of whatever
method for the achievement of business results.
(2) Moral behavior takes precedence over success. (Success is not as important as
upholding high moral standards.)
No matter how good the business results, we shall not recognize successachieved through immoral means (unjust methods).

1

Creating a Workplace Free of Compliance Breaches

Compliance with Laws and Social Norms; Ethical Conduct● ● ● ● ● ●2●Speciﬁc conduct①We shall endeavor to create openness in the workplace by encouraging close
communication.
②We shall check as necessary whether everything is in order in our daily
business and try to eliminate any intention of cover-up in the workplace.
③We shall conduct by fully understanding that just one violation of compliancewill result in a serious problem involving not only ourselves but also ourfamilies, colleagues, the company, and all stakeholders.

2■CreatingCorporate Culture based on the Broken Windows Theory
We fully recognize that in a corporate culture where small rule breaking goes
unpunished and where lack of distinction between private and corporate
matters goes unchecked, standards gradually lapse and incubate serious
compliance violation (Broken Windows Theory). Mandom Group’s corporate
managers shall lead the way in creating a corporate culture that does notcondone small rule breaking and non-distinction of private/corporate matters,
but a culture that upholds high ethical standards and alertness.
3■CreatingCorporate Culture based on Innate Weakness Theory
We fully recognize that“human beings are weak, and without evil intent, we
succumb to momentary weakness (give into temptation) depending on
circumstances (Innate Weakness Theory). We shall generate a corporate cultureof high ethical standards and alertness, where we shall try and eliminate thechances of colleagues succumbing to temptation and to follow up on eachother’s actions.
4■Eliminationof Concealment and Thoroughness of"Report, Communication, and Consultation"
To eliminate all acts of concealment which is obstructive to compliancemanagement, and to deal with risks quickly and properly, we shall create a
corporate culture where information sharing by Report, Communication andConsultation is fully practiced.

Compliance with Laws and Social Norms; Ethical Conduct2

Ⅱ

We shall engage in fair corporate activities fully complying with the legislations
relating to fair competition and trade including the Antitrust Law of each country
and each region.

●Speciﬁc conduct①We shall not make any arrangements with other companies in the same
industry (both domestic and overseas) that would restrict free competition
regarding price, production and sales volume, sales territory and sales timing.
②We shall not restrict our distribution companies regarding their selling price(resale price).
③We shall not unfairly restrict our distribution companies regarding their freebusiness activities such as handling of competitor products and having theirown sales and purchase channels.

Conduct from the View Pointof Stakeholders

1

Supply of Safe, Reliable and Attractive Products
and Services“Consumer-led Lifestyle Value Creation”is our basic motto. We shall develop andprovide, through“Challenge, Change, Innovation”, safe and reliable products andservices that are attractive for consumers.

●Speciﬁc conduct①We shall constantly pursue excellent products in functionality and usage aswell as high-quality services on the precondition of protection of safety andstability.
②In all types of experiments conducted for product quality assurance, our policy
is to eliminate all animal experiments and to develop alternative technologies
to animal experiments from the point of animal protection.
③In the event of quality problem arising with respect to our products andservices, we sha ll quickly a nd a ppropria t ely ta ke mea sures such a sinvestigating the facts and circumstances, adopting relief measures for the
injured party, disclosing information and adopting other measures to preventthe problem becoming more serious, investigating the cause, and adopting
measures to prevent recurrence.
④We shall conduct marketing with originality (products, brands, advertising,promotion, sales) and shall practice“OYAKUDACHI”for consumers.
⑤We shall aim to make products which give high satisfaction to consumers
through continuous research and pursuit of original technologies.
⑥We always oﬀer safe products that will win consumers’trust.
⑦We shall aim to expand our scope of“OYAKUDACHI”for consumers and torealize long-term mutual prosperity with our partners.
⑧We shall strictly adhere to legislations and regulations. To deepen consumers’
understanding about our products and services and their appropriate methodsof use, we shall endeavor to conduct appropriate and helpful product indication,
presenting information, and sincere communication.

3

Fair Competition and Trade● ● ● ● ● ●2

Conduct from the View Point of Stakeholders

3

Conduct in Purchasing and Sales●Speciﬁc conduct①In selecting our purchasing source and sales outlets, whether they are indomestic or overseas, we shall have an open-door policy and provide fairness ofbusiness opportunities. And following fair and rational criteria, we shall selectour partners transparently in both purchasing and sales.
②We shall set our business terms on an equal and fair footing with ourpurchasing and sales partners. Based on the principles of fairness, honesty andrespect for independence, we shall conduct fair and proper business
transactions, and conduct responsible supply.
③We shall fully comply with the Antitrust Law, including the following rules
regarding sales and marketing activities.
１）We shall use appropriate representations and descriptions regarding thequality of our products and services as well as our product standard inorder to avoid customer misunderstanding, by avoiding misrepresentation
through product claims (descriptions which mislead people to believe thatthe product is materially signiﬁcantly more favorable than competitor
products) and misrepresentation through advantage claims (descriptions
which mislead people to believe that the product is signiﬁcantly moreadvantageous than competitor products).
２）If oﬀering any free gifts to customers, it shall be within the conﬁnes oflaw (limits concerning maximum and total cost of the gifts)④We shall fully comply with the Antitrust Law, including the following rules
regarding purchasing activities.
１）We shall place our order with subcontractors supplying them withnecessary information such as time of delivery, subcontract price, andpayment due date.
２）We shall predetermine the payment due date to fall within the dateprescribed by law from the date of receipt of the product.

Conduct from the View Point of Stakeholders

4Adherence to Trade Control

6●Speciﬁc conduct①We shall ensure full understanding of and compliance with regulations
relating to foreign trade including all laws, regulations and international
treaties. This includes the Foreign Exchange and Foreign Trade Control Law
for ensuring international security, international navigation and shipping,safety of ports and harbors and the protection of wild animals.
②We shall grasp international situation, to fulﬁl the social responsibilities
expected as a global company, we shall not engage in any trade transactions
that would endanger international security and other above-mentioned ends.
③We shall construct a trade control system in order to engage in foreign tradethat properly complies with legislations and regulations and ensure its
rigorous operation.

5

5

7

Conduct from the View Point of Stakeholders

Handling of Intellectual Properties●Speciﬁc conduct①We shall recognize that our intellectual properties (patent right, utility modelright, design right, trademark right, copy right) are important company assets
and manage and handle them properly.
②We shall respect intellectual property of others and pay due attention so that
there is no violation of any intellectual property of others.
③When using the intellectual property of any other parties, we shall acquire theright to license its use from the right owner by means of appropriate
procedure or contract. We shall use others’intellectual property solely to theagreed limits and purposes.
④We shall take appropriate measures if any third party infringes any
intellectual property of the Mandom Group.

In dealing with companies and individuals with whom we come into contact on
business, we shall restrain ourselves from gift-giving and hospitality that exceed thelimits of ordinary common sense and internationally acceptable norms, and we shallrefrain from being on the receiving end of such acts. We shall also neither oﬀer nor
accept any form of bribe (including things which possibly may be construed asbribes). We shall maintain healthy relationships with politics and administration.

①When we either accept or oﬀer any hospitality, it shall be within ordinarycommon sense and social conventions.
②When we either accept or oﬀer any hospitality, we shall not deal with cash or
cash equivalents such as gift voucher.
③We shall not oﬀer any bribes to public servants (including those belonging toforeign governments) and any other person of equivalent position.
④We shall neither accept nor demand any bribes in return from othercompanies or individuals that hope to start or maintain business relationships
with our company.
⑤We shall not either oﬀer or indicate any bribes to other companies orindividuals with which hope to start or maintain business relationships.
⑥Regarding political activities, we shall not oﬀer any donations prohibited bylaw.

●Speciﬁc conduct①We shall handle our company assets (cash, securities, accounts receivable, rawmaterials, products, facilities, furniture, equipment, real estate and intellectual
property) properly in accordance with company rules. We shall also fully
respect the assets that belong to others.
②We shall use our company assets eﬃciently with due consideration of theircost-beneﬁt performance.
③We shall handle our company assets with suﬃcient care to protect them fromloss or damage.

Gifts and Reception●Speciﬁc conduct

Administration of Company Assets● ● ● ● ● ●4

8Administration of Information and Protection of
Personal Information●Speciﬁc conduct①We shall recognize the signiﬁcance of information and manage/handle itproperly.
②To avoid leakage of conﬁdential information, we shall apply the following
measures: storing information in locked places, setting passwords, strictly
controlling mobile devices, signing conﬁdentiality agreements, and conﬁrming
destination addresses to avoid wrong transmission.
③We shall obtain conﬁdential information of others in an appropriate way. We
shall use such information obtained only within the limits of use in accordancewith the contract etc. and manage it properly.
④We shall stay alert to cyberattacks such as external computer viruses infection.
⑤We shall manage personal information obtained from customers and supplierswith utmost care in order to prevent leaks.
⑥We shall use personal information obtained from customers and suppliers only
within the scope of the purposes they have agreed to. If they request us torevise or stop using their personal information, we shall take appropriate action.

Conduct from the View Point of Stakeholders

6Insider Trading●Speciﬁc conduct①We shall not engage in insider trading, the dealing in corporate shares either
directly or indirectly, using unpublished internal information that we acquireor may acquire through our work.
②In the event that we acquire unpublished internal information, we shall befully aware and be extremely careful that we shall be punished for violating
Laws and Regulations simply by conducting share transactions even if we do
not have intention to make proﬁt.
③In the event that we acquire unpublished internal information, we shall not
perform stock transactions without following prescribed procedures and weshall thoroughly manage internal information.
④We shall be fully aware of the fact that such a communication of internal
information may infringe on Laws and Regulations (It is illegal to engage in an
act of communication whose purpose may be deemed as causing others togain proﬁts or to avoid losses). We shall not communicate unpublished internal
information to others unless we are required for our duties.

10

Proper Processing of Accounting and Expense●Speciﬁc conduct①To ensure appropriate ﬁnancial reporting, we shall follow proper accounting
processing in accordance with stipulated rules.
②To ensure the accuracy of our ﬁnancial reporting, we shall create an
appropriate internal control system and operate the system strictly.
③We shall comply with applicable internal rules for expense processing (e.g.
correct billing) and we shall conduct necessary checks to prevent any
inappropriate or dishonest expense processing.

11

Restriction on Acts of Conﬂict of Interest/Competition●Speciﬁc conduct①We shall not commit the following acts that would come into conﬂict of interest
with Mandom Groups;
1) conducting a transaction such as sales or purchase, rental or lease, ﬁnancialtransaction, donation, etc. with himself/herself or a relative/friend, etc.
(including companies involving himself/herself or a relative/friend, etc.) as the
position of a Mandom Group’s director or employee.
2) undertaking to guarantee a debt for himself/herself or a relative/friend, etc.
(including companies involving him/herself or a relative/friend, etc.) as the
position of a Mandom Group’s director or employee.
②We shall not become involved in any business that is in competition with MandomGroup’
s business activities. Such non-involvement obviously refers to a director or
employee not personally engaging in competitive activities. Furthermore, he or
she shall not belong to a company that engages in competitive activities and nottake part in competitive business activity through other means.
③If we are obliged to conduct Conﬂict of Interest Transactions or to take part inbusiness that is in competition, we must take procedures designated by company.

7● ● ● ● ● ●9Conduct from the View Point of Stakeholders

Ⅲ

Conduct for Protecting
Global Environment
We shall be aware that activities to address environmental issues are common
issues for humanity, and shall take independent actions for these issues as essential
elements in a company’s existence and operations.

１．
Environmental Considerations in Products and Services
We continuously improve the eco-friendliness of commodities bybuilding a management system for evaluating environmentallyfriendly processes and their results in products and services.
２．
Promoting Measures toward a Carbon-Free Society
We promote measures to create a carbon-free society based on the
Paris Agreement, and eﬀorts to reduce greenhouse gas emissions
at all facilities.
３．
Protecting Biodiversity
We grasp the impact on biodiversity of each product throughout
its life cycle and carry out measures to protect biodiversity.
４．
Promoting a Recycling-Oriented Society
We carry out measures to achieve and maintain zero emissions by
fully recycling industrial waste.
５．
Our Duty as a Citizen
We shall execute to protect global environment in our daily assame as company life through careful use of resources, reductionof waste and use of recycled products.

Conduct for Protecting Global Environment8

①We shall resolutely confront antisocial forces or organizations that would
adversely impact on social order and safety. We shall clearly avoid involvementwith any antisocial forces or organizations and their activities.
②We shall not support the activities of antisocial forces or organizations nor
provide any beneﬁts to them.
③We shall conduct our businesses without using any inﬂuence of antisocial
forces or organizations.
④We shall not meet unreasonable demand made to us by antisocial forces ororganizations.
⑤When we exchange contracts concerning business transactions, we shallincorporate clauses requiring the elimination of anti-social forces.
⑥Concerning unsolicited books or magazines or seminar information, we shallreject and unsubscribe from such oﬀers.

Conduct in Relation toSociety
Cooperation and Integration with Local Communities●Speciﬁc conduct①We shall be aware that we are a member of the local community and we shallfully understand and respect local cultures and customs, acquire understanding
and trust in our corporate activities by participating in and cooperating with
community activities.
②We shall aim to conduct business activities with respect to the history, culture,values, and customs of each country and each region.
③In case of doing businesses in each country and each region, in addition tocompliance with international rules and local laws, we shall work together withlocal communities, companies and relevant institutions so that we can build
relationships of trust.

2

Social Contribution●Speciﬁc conduct①As a“good corporate citizen,”we shall oﬀer society the resources we have inan eﬀective way suitable to our means through our positive support andsponsorship of academic, cultural, and sports activities together with voluntary
activities. We shall endeavor to make active contributions to the healthy
development of society.
②In undertaking these activities to make our social contribution, we shall makeit our basic rule to conduct them within appropriate range by consideringsuﬃciently their public and social beneﬁts so that we can obtain the sympathyof a wide spectrum of stakeholders.

9

Non-involvement with Antisocial Forces●Speciﬁc conductⅣ1● ● ● ● ● ●3

Conduct in Relation to Society

4Communication with Society●Speciﬁc conduct①We are aware that mutual communication with a wide range of stakeholders is
not only a means for a company to fulﬁll its explanatory obligations but also ameans to enhance corporate value. We shall enhance corporate value by
having constructive communication frequently with stakeholders such associety, customers and business partners, not to mention shareholders.
②We shall earnestly listen the comments and requests made to us bystakeholders and reﬂect them in our business operations and management.
Meanwhile we shall make disclosure of corporate information positively,eﬀectively and fairly.
③When disclosing corporate information, we shall not only endeavor to actively
disclose information relating to management and ﬁnance such as ﬁnancial
statements, corporate philosophy, management policies, management plan andmanagement targets, but we shall endeavor to actively disclose information
relating to environmental and social aspects of our operations such asenvironmental activities and social contribution activities.
④When we use social media in communication, we shall be fully aware of thefact that social media is being accessed by various users all over the world. We
shall pay utmost attention so as not to invite misunderstanding or infringe
copyright, portrait rights or privacy.

Conduct in Relation to Society

10

Ⅴ

1

●Speciﬁc conduct

5①We shall respect the basic human rights of everybody.
②Under no circumstance shall we discriminate against anybody for theirnationality, race, ethnicity, religion, color of skin, age, sex, gender identity, sexual
orientation, health condition, physical disability or employment status. Should we
detect any discrimination, we shall not turn a blind eye.
③We shall not discriminate against anybody or anything on the grounds of
preconception or prejudice.
④We shall not force anybody to follow our own personal beliefs or preferences.

2
3●Speciﬁc conduct

Distinction between Public and Private Aﬀairs●Speciﬁc conduct①We shall never confuse our corporate and private positions and capacities. We
shall avoid conﬂicts of interest, avoiding interference of personal interest in theworkplace and of company status outside the workplace.
②We shall use the company PC and phone only within the scope necessary forbusiness.
③We shall refrain from making any solicitations at work relating to personalphilosophy/beliefs, or oﬀering any sale of private goods.

11 Conduct for Creating a Safe, Friendly and Decent Workplace●Speciﬁc conduct

Ban on Harassment●Speciﬁc conduct①We shall speak and act with consideration from other people’s point of view.
②We shall not engage in sexual harassment (any sexual acts that go against
somebody else’s will).
③We shall not engage in power harassment (any harassment using someadvantage of business position in and out of the oﬃce).
④We shall not engage in maternity harassment (any unfair treatment for
pregnancy or childbirth).
⑤We shall not engage in other harassment such as social harassment(infringements of privacy or nuisances involving social networks) and alcoholharassment(for example, forcing of participation in drinking parties, forcing of
drinking down a jug of beer in one go).
⑥Should we detect any harassment, we shall not turn a blind eye.

Ban on Child Labor and Forced Labor①We shall refrain absolutely from any use of child labor, the employment ofchildren who are under the minimum working age.
②We shall refrain absolutely from any use of forced labor, the illegal extraction oflabor by means of physical or psychological constraint.
③We shall comply with treaties and laws that prohibit child labor and forced labor.

Development of Working Conditions①We shall create working conditions which are conducive to work, taking into
account health and safety.
②We shall produce ways of working which develop individual capability andrespect diversity, personality and individuality so that we can enhance thepower of individual members to the strength of the entire team.
③Placing top priority on human life, we shall comply with laws and rules
concerning working conditions/industrial health and safety.
④We shall positively implement measures such as creating a safety-ﬁrst
environment and ensuring reasonable working hours.
⑤We shall actively participate in eﬀorts to maintain and promote health.
⑥If any accidents or other problems relating to our product occur, we shallpromptly respond to such a situation.

Conduct for Creating a Safe,
Friendly and Decent Workplace
Respect for Human Rights, Ban on Discriminatory
Treatment● ● ● ● ● ●4

6

Organizational Measures for Crisis Management●Speciﬁc conduct①We shall prepare to cope with crises such as actions taken by antisocial forces,
terrorism, cyberattacks, and natural disasters, by developing a crisis
management system in an organized manner.
②We shall recognize cybersecurity risks and take necessary measures againstthem.
③We shall recognize that we are facing growing risks of incidents and accidents
including terrorism. In this context, we shall collect necessary information andtake safety measures with the belief that what we need to do ﬁrst is to protect
ourselves.

Conduct for Creating a Safe, Friendly and Decent Workplace12We shall properly assess whether Mandom Group is upholding the Mandom Group
Code of Conduct and we shall build an internal system (internal control system) andstrictly manage it so that if any violation is detected, we could promptly address theviolation.

Ⅵ● ● ● ● ● ●5■Creation
and Operation of an Internal Control System

6■Dissemination

Act of the Mandom Group
Code of Conduct
We shall implement the Mandom Group Code of Conduct through eﬀorts as follows.
1■Understandingof Laws and Social Norms
We shall actively gather domestic and foreign information relating to laws and social
norms that are necessary to act up to the Mandom Group Code of Conduct. We shallendeavor to understand the information and carry out establishment, revision or
abolition of company rules and regulations as necessary.

We shall endeavor to create an environment by distributing booklets or by othermeans, where all board members and employees can easily refer to the MandomGroup Code of Conduct. We shall also oﬀer training and education so that everyone
can gain a thorough understanding of the Mandom Group Code of Conduct.

【Supplementary Rules】
To thoroughly implement compliance with this Code of Conduct, each Mandom Group
company, its directors and employees shall make ceaseless efforts.
Obligations for directors and employees to comply with this Code of Conduct shall be
provided in Mandom Group’s Ethical Conduct Promotion Rules.
If a director violates any of the Code of Conduct, such director shall be dealt with inaccordance with the Company Law and other pertinent legislation.
If an employee violates any of the Code of Conduct, such employee shall be dealt with inaccordance with the office regulations.

2■EthicalConduct
As members of society, we shall always cultivate our“hearts”that would equip us
with good judgment and social sense as well as ﬁrm ethical and moral values andprinciples. In the light of these, we shall look at our own conduct and we shall act
up to the Mandom Group Code of Conduct by conducting in good faith with
self-responsibility.
3■Strict
Handling of Compliance Violation
If we have factors to prevent compliance management, we must unite to eliminate
such factors thoroughly.
In undertaking our business conduct, should there be any suspicion that a violationof compliance has occurred, we shall report to and consult our line manager or
relevant company department, and take appropriate measures. We shall take strict
action against the violation.
4■Help
Line System
We shall establish Help Line System (information provider protection system) as
reporting contact oﬃce when we ﬁnd a violation of the Code of Conduct that would
harm the public interest as a Mandom Group (including acts suspected of violating),
and we shall operate it properly. In addition, we absolutely prohibit retaliation anddisadvantageous handling to legitimate information providers to reporting contact
oﬃce absolutely by internal regulations and will fully protect the legitimate
information provider.
13 Act of the Mandom Group Code of Conduct

Complimentary Close
The Mandom Group Code of Conduct is a booklet that summarizes what we should
keep in mind as we give material shape to the MANDOM MISSION. Therefore, wemust act with always having the mind that purpose, content and method to perform
our business are correspond to the Mandom Group Code of Conduct and the spirit inorder to perform our business smoothly. We need to act appropriately with consulting
our line manager or relevant company department in the event that there should be
any suspicion that our business correspond to the Mandom Group Code of Conduct.

I pledge to understand fully and comply with the contents of thisMandom Group Code of Conduct.
Department

Name

Supplementary Rules

14