ALMEDIO
Supply Chain CSR
Code of Conduct

1st Edition

May, 2016
ALMEDIO Supply Chain CSR Code of Conduct （1st Edition）

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Introduction

In order to enhance our corporate value and to achieve sustainable development, we are conducting
appropriate business activities in accordance with the "Almedio Charter of Corporate Conduct". This is inaccordance with the basic principles of corporate governance, such as ensuring soundness and transparencyof management, and we are working to fulfill our corporate social responsibility.

Under global business development, we are sought to implement transparent and unbiased supply chain
management together with our suppliers, whom we ask to procure raw materials, resources and parts and/or
to produce goods. Therefore, we have established the "Almedio supply chain CSR Code of Conduct"(hereafter “the Code”) to fulfill the social responsibility properly.

The Code is based on “the EICC Code of Conduct” (ver. 5.1) set forth by EICC®（Electronic Industry
Citizenship Coalition: a CSR alliance）, the international Electronic industry association.
We shall actively fulfill the social responsibility through the supply chain by implementing CSR activities withrespect to the EICC Code of Conduct.

The Code is made up of five (5) sections as below.
Sections A, B and C outline standards for Labor, Health and Safety, and the Environment, respectively.
Section D adds standards relating to business ethics; Section E outlines the elements of an acceptablesystem to manage conformity with the Code.

Section A: Labor
Section B: Health and Safety
Section C: Environment
Section D: Ethics
Section E: Management System*EICC® is a registered trademark of Electronic Industry Citizenship Coalition Incorporated.

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A．LABOR
ALMEDIO committed to uphold the human rights of workers, and to treat them with dignity and respect as
understood by the international community. This applies to all workers including temporary, migrant, student,
contract, direct employees, and any other type of worker. The recognized standards, as set out in the annex,
were used as references in preparing the Code and may be a useful source of additional information.

The labor standards are:1）

Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or
trafficking of persons shall not be used. This includes transporting, harboring, recruiting, transferring or
receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There
shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to
unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process,workers must be provided with a written employment agreement in their native language that contains a
description of terms and conditions of employment prior to the worker departing from his or her countryof origin. All work must be voluntary and workers shall be free to leave work at any time or terminate
their employment. Employers and agents may not hold or otherwise destroy, conceal, confiscate or denyaccess by employees to their identity or immigration documents, such as government-issued
identification, passports or work permits, unless such holdings are required by law. Workers shall not be
required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If
any such fees are found to have been paid by workers, such fees shall be repaid to the worker.

2）Young Workers
Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under
the age of 15, or under the age for completing compulsory education, or under the minimum age for
employment in the country, whichever is greatest. The use of legitimate workplace learning programs,
which comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers)
shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.
ALMEDIO shall ensure proper management of student workers through proper maintenance of student
records, rigorous due diligence of educational partners, and protection of students’ rights in accordancewith applicable law and regulations. ALMEDIO shall provide appropriate support and training to all student
workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be
at least the same wage rate as other entry-level workers performing equal or similar tasks.

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A．LABOR (con’t.)
3）Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnover andincreased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, aworkweek should not be more than 60 hours per week, including overtime, except in emergency or unusual
situations. Workers shall be allowed at least one day off every seven days.

4）

Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating tominimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers
shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages
as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with atimely and understandable wage statement that includes sufficient information to verify accuratecompensation for work performed. All use of temporary, dispatch and outsourced labor will be within thelimits of the local law.

5）

Humane Treatment
There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporalpunishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any
such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly
defined and communicated to workers.

6）

Non-Discrimination
ALMEDIO should be committed to a workforce free of harassment and unlawful discrimination. Companies
shall not engage in discrimination based on race, color, age, gender, sexual orientation, gender identityand expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union
membership, covered veteran status, protected genetic information or marital status in hiring andemployment practices such as wages, promotions, rewards, and access to training. Workers shall be
provided with reasonable accommodation for religious practices. In addition, workers or potential workers
should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

7）

Freedom of Association
In conformance with local law, ALMEDIO shall respect the right of all workers to form and join tradeunions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect
the right of workers to refrain from such activities. Workers and/or their representatives shall be able toopenly communicate and share ideas and concerns with management regarding working conditions andmanagement practices without fear of discrimination, reprisal, intimidation or harassment.

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B．HEALTH and SAFETY
ALMEDIO recognize that in addition to minimizing the incidence of work-related injury and illness, a safe andhealthy work environment enhances the quality of products and services, consistency of production and worker
retention and morale. ALMEDIO also recognize that ongoing worker input and education is essential to identifying
and solving health and safety issues in the workplace.

Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety and Healthwere used as references in preparing the Code and may be a useful source of additional information.

The health and safety standards are:1）

Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, andfall hazards) are to be controlled through proper design, engineering and administrative controls,
preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety
training. Where hazards cannot be adequately controlled by these means, workers are to be provided
with appropriate, well-maintained, personal protective equipment and educational materials about risks
to them associated with these hazards. Workers shall be encouraged to raise safety concerns.

2）Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimized
by implementing emergency plans and response procedures including: emergency reporting, employee
notification and evacuation procedures, worker training and drills, appropriate fire detection andsuppression equipment, adequate exit facilities and recovery plans. Such plans and procedures shallfocus on minimizing harm to life, the environment and property.

3）

Occupational Injury and Illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury andillness including provisions to: encourage worker reporting; classify and record injury and illness cases;
provide necessary medical treatment; investigate cases and implement corrective actions to eliminate
their causes; and facilitate return of workers to work.

4）

Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled.
Engineering or administrative controls must be used to control overexposures. When hazards cannot beadequately controlled by such means, worker health is to be protected by appropriate personal protective
equipment programs.

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B．HEALTH and SAFETY (con’t.)
5）Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling andheavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be
identified, evaluated and controlled.

6）

Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks andbarriers are to be provided and properly maintained where machinery presents an injury hazard to workers.

7）

Sanitation, Food, and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary foodpreparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor agent
are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water
for bathing and showering, adequate heat and ventilation, and reasonable personal space alongwith reasonable entry and exit privileges.

8）

Health and Safety Communication
ALMEDIO shall provide workers with appropriate workplace health and safety training in their primarylanguage. Health and safety related information shall be clearly posted in the facility.

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C. ENVIRONMENTAL
ALMEDIO recognize that environmental responsibility is integral to producing world clss products. In
manufacturing operations, adverse effects on the community, environment and natural resources are to beminimized while safeguarding the health and safety of the public. Recognized management systems such as ISO
14001 and the Eco Management and Audit System (EMAS) were used as references in preparing the Code andmay be a useful source of additional information.

The environmental standards are:1）

Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to beobtained, maintained and kept current and their operational and reporting requirements are to be followed.

2）

Pollution Prevention and Resource Reduction
The use of resources and generation of waste of all types, including water and energy, are to be reduced
or eliminated at the source or by practices such as modifying production, maintenance and facility
processes, materials substitution, conservation, recycling and re-using materials.

3）

Hazardous Substances
Chemicals and other materials posing a hazard if released to the environment are to be identified andmanaged to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

4）

Wastewater and Solid Waste
ALMEDIO shall implement a systematic approach to identify, manage, reduce, and responsibly dispose ofor recycle solid waste (non-hazardous). Wastewater generated from operations, industrial processes andsanitation facilities are to be characterized, monitored, controlled and treated as required prior todischarge or disposal. In addition, measures should be implemented to reduce generation of wastewater.
ALMEDIO shall conduct routine monitoring of the performance of its wastewater treatment systems.

5）

Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals
and combustion by-products generated from operations are to be characterized, routinely monitored,
controlled and treated as required prior to discharge. ALMEDIO shall conduct routine monitoring of theperformance of its air emission control systems.

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C. ENVIRONMENTAL(con’t.)
6）

Materials Restrictions
ALMEDIO to adhere to all applicable laws, regulations and customer requirements regarding prohibition
or restriction of specific substances in products and manufacturing, including labeling for recycling anddisposal.

7）

Storm Water Management
ALMEDIO shall implement a systematic approach to prevent contamination of storm water runoff.
ALMEDIO shall prevent illegal discharges and spills from entering storm drains.

8）

Energy Consumption and Greenhouse Gas Emissions
Energy consumption and greenhouse gas emissions are to be tracked and documented, at the facility
and/or corporate level. ALMEDIO to look for cost effective methods to improve energy efficiency and tominimize their energy consumption and greenhouse gas emissions.

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D．ETHICS
To meet social responsibilities and to achieve success in the marketplace, ALMEDIO and their agents are to
uphold the highest standards of ethics including:

1）

Business Integrity
The highest standards of integrity are to be upheld in all business interactions. ALMEDIO shall have azero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.
All business dealings should be transparently performed and accurately reflected on Participant’sbusiness books and records. Monitoring and enforcement procedures shall be implemented toensurecompliance with anti-corruption laws.

2）

No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised, offered,authorized, given or accepted. This prohibition covers promising, offering, authorizing, giving or
accepting anything of value, either directly or indirectly through a third party, in order to obtain or
retain business, direct business to any person, or otherwise gain an improper advantage.

3）

Disclosure of Information
Information regarding participant labor, health and safety, environmental practices, business activities,
structure, financial situation and performance is to be disclosed in accordance with applicableregulations and prevailing industry practices. Falsification of records or misrepresentation of conditions
or practices in the supply chain are unacceptable.

4）Intellectual Property
Intellectual property rights are to be respected; transfer of technology and knowhow is to be done in amanner that protects intellectual property rights; and, customer information is to be safeguarded.

5）

Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld.
Appropriate means to safeguard customer information must be available.

6）

Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity and protection of supplier and employee
whistleblowers1 are to be maintained, unless prohibited by law. ALMEDIO should have a communicatedprocess for their personnel to be able to raise any concerns without fear of retaliation.

1

Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, orby a public official or official body.
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D．ETHICS (con’t.)
7）

Responsible Sourcing of Minerals
ALMEDIO shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the
products they manufacture does not directly or indirectly finance or benefit armed groups that areperpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining
country. ALMEDIO shall exercise due diligence on the source and chain of custody of these minerals
and make their due diligence measures available to customers upon customer request.

8）

Privacy
ALMEDIO to commit to protecting the reasonable privacy expectations of personal information of
everyone they do business with, including suppliers, customers, consumers and employees. ALMEDIO
to comply with privacy and information security laws and regulatory requirements when personal
information is collected, stored, processed, transmitted, and shared.

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E．MANAGEMENT SYSTEMSALMEDIO shall adopt or establish a management system whose scope is related to the content of this Code.
The management system shall be designed to ensure: (a) compliance with applicable laws, regulations andcustomer requirements related to the participant’s operations and products; (b) conformance with this Code;and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual
improvement.

The management system should contain the following elements:

1）

Company Commitment
A corporate social and environmental responsibility policy statements affirming Participant’scommitment to compliance and continual improvement, endorsed by executive management and posted
in the facility in the local language.

2）

Management Accountability and Responsibility
The Participant clearly identifies senior executive and company representative[s] responsible for
ensuring implementation of the management systems and associated programs. Senior management
reviews the status of the management system on a regular basis.

3）

Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements,
including the requirements of this Code.

4）

Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety 2 and labor practice andethics risks associated with Participant’s operations. Determination of the relative significance foreach risk and implementation of appropriate procedural and physical controls to control the identified
risks and ensure regulatory compliance.

5）

Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Participant’s socialand environmental performance, including a periodic assessment of Participant’s performance inachieving those objectives.

2

Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage
facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria andworker housing/dormitories.
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E．MANAGEMENT SYSTEMS (con’t.)
6）

Training
Programs for training managers and workers to implement Participant’s policies, procedures andimprovement objectives and to meet applicable legal and regulatory requirements.

7）

Communication
A process for communicating clear and accurate information about Participant’s policies, practices,
expectations and performance to workers, suppliers and customers.

8）

Worker Feedback and Participation
Ongoing processes to assess employees’ understanding of and obtain feedback on practices andconditions covered by this Code and to foster continuous improvement.

9）

Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of theCode and customer contractual requirements related to social and environmental responsibility.

10） Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments,
inspections, investigations and reviews.

11） Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity
to company requirements along with appropriate confidentiality to protect privacy.

12） Supplier Responsibility
A process to communicate Code requirements to suppliers and to monitor supplier compliance to the
Code.

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REFERENCES
The following standards were used in preparing this Code and may be a useful source of additional
information. The following standards may or may not be endorsed by each Participant.
Dodd-Frank Wall Street Reform and Consumer Protection Act
http://www.sec.gov/about/laws/wallstreetreform-cpa.pdf
Eco Management & Audit Systemwww.quality.co.uk/emas.htm
Ethical Trading Initiativewww.ethicaltrade.org/
ILO Code of Practice in Safety and Healthwww.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf
ILO International Labor Standards
www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm
ISO 14001 www.iso.org
National Fire Protection Associationwww.nfpa.org/catalog/home/AboutNFPA/index.asp
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from ConflictAffected and High Risk Areas http://www.oecd.org/corporate/mne/mining.htm
OECD Guidelines for Multinational Enterpriseswww.oecd.org/mne/
OHSAS 18001 http://www.bsigroup.com/en-GB/ohsas-18001-occupational-health-and-safety/
Universal Declaration of Human Rightswww.un.org/Overview/rights.html
United Nations Convention Against Corruptionhttps://www.unodc.org/unodc/en/treaties/CAC/
United Nations Global Compactwww.unglobalcompact.org
United States Federal Acquisition Regulationwww.acquisition.gov/far/
SA 8000 http://www.sa-intl.org/index.cfm?fuseaction=Page.ViewPage&PageID=937
Social Accountability International (SAI) www.sa-intl.org

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