TOMOEGAWA

Sustainable Procurement
Guidelines

Enacted: January 1, 2024

TOMOEGAWA CORPORATION-1-

INDEX
Introduction
Structure and Positioning of these Guidelines
Tomoegawa’s Basic Sustainability Policy････････････

4････････････

4････････････

4

Basic Procurement Policy････････････

5

Sustainable Procurement Standards
1. Legal Compliance and Respect for Internationally Recognized Standards････････････

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2. Human Rights and Labor････････････

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2-1 Prohibition of Forced Labor････････････

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2-2 Prohibition of Child Labor and Respect for the Rights of Young Workers････････････

6

2-3 Consideration of Working Hours････････････

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2-4 Appropriate Wages and Allowance････････････

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2-5 Prohibition of Inhumane Treatment････････････

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2-6 Prohibition of Discrimination････････････

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2-7 Freedom of Association and Right to Collective Bargaining････････････

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3-1 Occupational Safety････････････

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3-2 Emergency Preparedness････････････

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3-3 Occupational Injury and Illness････････････

9

3-4 Industrial Hygiene････････････

10

3-5 Consideration of Physically Demanding Work････････････

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3-6 Machine Safeguarding････････････

10

3-7 Health and Safety at Facilities････････････

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3-8 Health and Safety Communication････････････

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3-9 Worker Health Management････････････

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12････････････

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4-2 Reducing Energy Consumption and Greenhouse Gas Emissions ････････････

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4-3 Air Emissions････････････

12

4-4 Water Management････････････

13

4-5 Efficient Use of Resources and Waste Disposal････････････

13

4-6 Chemical Substance Management････････････

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3. Health and Safety

4. Environment
4-1 Environmental Permits and Reports-2-4-7 Managing Chemical Substances Contained in Products (Tomoegawa Green Procurement)････････････

14････････････

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5. Fair Business and Ethics････････････

15

5-1 Preventing Corruption････････････

15

5-2 Prohibiting Provision and Acceptance of Inappropriate Benefits ････････････

15

5-3 Appropriate Disclosure of Information････････････

15

5-4 Respecting Intellectual Property････････････

16

5-5 Fair Business Practices････････････

16

5-6 Protecting Whistleblowers････････････

16

5-7 Responsible Minerals Procurement････････････

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6. Quality and Safety････････････

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6-1 Product Safety････････････

17

6-2 Quality Management････････････

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6-3 Providing Accurate Information on Products and Services････････････

17････････････

18

7-1 Defense from Cyber Attacks････････････

18

7-2 Protecting Personal Information････････････

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7-3 Preventing Leakage of Confidential Information････････････

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19････････････

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9. Establishing a Management System････････････

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9-1 Establishing a Management System････････････

20

9-2 Management of Suppliers････････････

21

9-3 Proper Import and Export Controls････････････

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9-4 Establishing Grievance Mechanisms････････････

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4-8 Natural Resources and Biological Diversity

7. Information Security

8. Business Continuity Planning
8-1 Developing and Preparing a Business Continuity Plan

Revision History-3-

Introduction
Tomoegawa Corporation aims to contribute to the sustainable growth of society. To this end, we
promote sustainable procurement activities, whereby corporate social responsibility (CSR) activities
are extended throughout the entire supply chain in cooperation with our suppliers and contractors.

Structure and Positioning of these Guidelines
These Guidelines consist of the Basic Procurement Policy and the Sustainable Procurement
Standards, based on the ideas of Tomoegawa’s Basic Sustainability Policy. These Guidelines areapplied to the procurement activities of Tomoegawa Corporation when we procure any goods orservices necessary for our business activities by means of purchasing, leasing, or otherwise.
Therefore, the Guidelines shall not only be applied to the procurement activities of procurement
departments, but also to all departments of Tomoegawa Corporation. The Guidelines, however, do
not apply to the procurement of funds (financing).
Furthermore, these guidelines are also matters that we, as a company, request our suppliers to follow,
on the basis of internationally recognized standards and the laws of respective countries, and mattersthat are mutually required of companies by society.
We ask our suppliers to fully understand these guidelines and to implement their contents, andrequest your understanding and cooperation toward the further strengthening of Tomoegawa’s
sustainable procurement activities.

Tomoegawa’s Basic Sustainability Policy
Tomoegawa Corporation has continued to, and will continue to contribute to the realization of asustainable “better world (society, environment, and governance)”, through “maximizing profit by wayof customer satisfaction through the launch of new products and new technology” on the basis of our
founding principles of “integrity”, “social contribution”, and “pioneering spirit”.
1. Initiatives toward Social Issues
By creating new value through products that confront social issues, we strive toward theimprovement of corporate values, and solutions to social issues through business.
2. Initiatives toward Environmental Issues
We strive toward conservation of the global environment through measures such aschanging our business portfolio via the contraction of the energy-intensive paper
manufacturing business, offering environmentally-conscious products, and reducing CO₂
emissions.
3. Initiatives toward Respecting Human Rights and Maximizing the Value of Human Talent
We respect human rights and diversity through the entire supply chain, and strive to maintaina workplace environment where everyone can work with ease and pride, and a system for
nurturing human talent.

-4-Basic Procurement Policy
In order for Tomoegawa Corporation to be trusted and selected by all our stakeholders, first andforemost by our customers and suppliers, we fulfill our corporate social responsibilities within our
procurement activities.
• We fairly and impartially enter into communication with all suppliers and contractors.
• We comply with domestic and overseas laws and regulations, and conduct fair business
transactions based on corporate ethics.
• We strictly control all information obtained through procurement activities.
• We work to conserve the environment and reduce our environmental impact.
• We pursue quality, cost, and delivery in order to meet the needs of the market.
• We work to foster mutual cooperation and build relationships of trust with suppliers and contractors.
• We promote sustainable procurement throughout the entire supply chain.
*The Sustainable Procurement Standards were compiled as a restructured version of the
Responsible Business Conduct Guidelines (March 2023) issued by JEITA (Japan Electronics andInformation Technology Industries Association).

Sustainable Procurement Standards
1． Legal Compliance and Respect for Internationally RecognizedStandards
In addition to strict compliance with the laws and regulations of Japan andthe countries in which we conduct business, we also respect internationallyrecognized standards.
In recent years, respective countries have enacted and enforced various laws, regulations andpolicies in relation to the environment, human rights, corruption, and other issues. It is crucial tounderstand and comply with these laws. Some laws and regulations apply not only domestically,
but also in other regions, which necessitates caution. In addition, in line with the globalization of
the supply chain and the market, we are required to comply with laws and regulations and respect
international recognized standards throughout the supply chain, not only within our company.
“Internationally recognized standards” refers to expectations for socially responsible businesspractices, guided by customary international law, generally-accepted principles of internationallaw, and universally or near-universally accepted intergovernmental agreements (including
conventions and treaties).
This corresponds to documents such as, for example, the “Guiding Principles on Business andHuman Rights” and the “Sustainable Development Goals (SDGs)” of the United Nations, the“Guidelines for Multinational Enterprises” of the OECD (Organization for Economic Co-operation
and Development), and the “Tripartite Declaration of Principles Concerning Multinational
Enterprises and Social Policy” (MNE Declaration) of the ILO (International Labour Organization).

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In addition to compliance with the relevant laws and regulations, we refer tointernational human rights standards, including the ILO’s Core Labor Standards(CLS), and respect the human rights of workers.

2-1 Prohibition of Forced Labor
Any use of labor that is obtained through forced or bonded labor, inhumane
prison labor, slavery, or human trafficking, is prohibited. Furthermore, noform of employment can be forced, and we respect the right of workers toretire or terminate their own employment.
“Forced labor” refers to labor provided by a person or persons against their own will
(involuntarily), under the threat of penalty.
It is prohibited to transport, harbor, recruit, transfer, or receive persons by means of threat,
coercion, abduction or fraud. In addition, the act of making workers pay fees in order to work isalso considered to be forced labor. Furthermore, the act of carrying out forced labor by converting
such fees into debt is also prohibited.

2-2 Prohibition of Child Labor and Respect for the Rights of Young
Workers
We do not employ or allow work by children who are under the minimum
working age governed by local laws and regulations. Furthermore, we do
not allow young workers under the age of 18 to perform hazardous workthat may jeopardize their health or safety.
“Child labor” refers to any activities or duties that damage the intellectual, physical, social, or
moral development of a young person due to the nature or conditions of execution of such work;or work that makes school attendance impossible, forces the child to leave school, or otherwise
disrupts the child’s educational opportunities or healthy development by requiring dual
engagement in work as well as study.
Child labor is prohibited in all situations by the ILO and the laws of respective countries. Within
the category of child labor, the “Worst Forms of Child Labor” require urgent and immediate action.
These are defined in ILO Convention No. 182 (1999) as the following four types of work.
・Slavery, or any similar practices
・The use of children in prostitution, the creation of pornography, or obscene performances, oras an intermediary of the above; or to provide any of the above
・The use of children in illegal activities, particularly manufacturing or trafficking of illegal drugs,
or as an intermediary of the above; or to provide any of the above
・Work of a nature that harms, or may harm, the health, safety or morals of a child, or work thatis carried out under circumstances that risk the occurrence of any of the above“Hazardous work” refers to the following.
・Work that exposes children to physical, psychological or sexual abuse
・Work carried out underground, underwater, at dangerous heights or in confined spaces
・Work that uses dangerous machinery, equipment or tools, or that involves the manual-6-

handling or transport of heavy loads
・Work carried out in unhealthy environments (for example, exposing children to hazardous
substances, agents or processes, or to temperatures, noise levels, or vibrations that may
damage their health)・Work carried out under particularly difficult conditions such as working for long hours or during
the night, or work where the child is unreasonably confined to the premises of the employer

2-3 Consideration of Working Hours
Workers must not be allowed to work in excess of the limits provided for in
local laws and regulations. Furthermore, we appropriately manage workers’
working hours and days off in consideration of international standards.
We appropriately assign working hours, days off, and leave, on the basis of each country’s
laws and regulations. In addition, we also take international standards into consideration. For
example, ILO Conventions (No. 14, No. 106) provide for the granting of a minimum of one day off(at least 24 hours) every seven days. The RBA (Responsible Business Alliance), an internationalorganization for corporate social responsibility in the electronics industry, stipulates maximum
working hours, including overtime, of 60 hours per week.
“Appropriate management” refers to the following.
・Ensuring that the number of prescribed working days per year does not exceed the legal limit
・Ensuring that the number of working hours per week, including overtime, (excluding disasters,other unavoidable emergencies or unusual situations) does not exceed the legal limit
・Granting the right to annual paid leave, maternity leave, and childcare leave provided for inlaws and regulations
・Granting the right to break times provided for in laws and regulations
・Conducting physical and mental health examinations to protect the health of workers.

2-4 Appropriate Wages and Allowance
We comply with all laws and regulations that apply to remuneration paid toworkers (including minimum wages, overtime wages, and legally obligatedallowances and payroll deductions). In addition, we take into account the levelof wage that is required to support workers’ daily living needs (living wage).
“Minimum wage” refers to the lowest level of wage stipulated in the wage-related legislation of
the country of employment. Employers must pay workers an amount equal to or greater than theminimum wage. Furthermore, as a voluntary corporate initiative, employers are expected to giveconsideration to a “living wage” as the amount of money estimated to be needed to maintain abasic standard of living, separately to the statutory minimum wage.

2-5 Prohibition of Inhumane Treatment
We respect the human rights of workers. Workers must not be subject toinhumane treatment such as emotional or physical abuse, coercion,harassment, or any actions that may result in the above.

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In addition to establishing disciplinary policies and response procedures, in order to ascertain
the facts of any inhumane treatment, it is vital to introduce and consistently operate an internal
whistleblowing system (grievance mechanism), and to widely publicize the existence of thissystem among workers.
“Emotional abuse” refers to the infliction of mental or emotional harm through acts ofpsychological violence toward another person such as, for example, the use of inhumane speechor harassment, silent treatment, or verbal attacks on the other party’s self-esteem. “Physicalabuse” refers to violence or work carried out in a brutal environment.

2-6 Prohibition of Discrimination
Acts of discrimination and harassment are prohibited. Furthermore, we arecareful to consider appropriate boundaries with regard to requests fromworkers relating to religious customs.
Any acts of potential discrimination with regard to wages, promotions, remuneration, education,
recruitment, or employment practices, made on the basis of race, skin color, age, sex, sexual
orientation, gender identity or gender expression, ethnicity or nationality, disability, pregnancy,
religion, affiliated political party or political views, union membership or non-membership, military
service record, protected genetic information, or marital status, are prohibited. Furthermore, anyloss of equal opportunities or fair treatment that results from procedures such as health checks
or pregnancy tests is also act of discrimination.

2-7 Freedom of Association and Right to Collective Bargaining
We respect workers’ rights to organize, as a means of implementing labormanagement discussions related to the working environment, wage levels,and other issues, in compliance with local laws and regulations.
In addition to respecting the right of all workers to form or join a labor union of their choice, theright of workers to refrain from participating in such activities must also be respected. Furthermore,workers or their representatives must be able to voluntarily engage in collective bargaining withmanagement, with the aim of honest communication regarding their opinions and concerns about
working conditions and management practices, without fear of discrimination, retaliation, threats,or harassment.

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3． Health and Safety
In addition to compliance with the relevant laws and regulations, we pay
attention to the ILO’s health and safety guidelines. Furthermore, it is necessary tominimize the occurrence of injuries and physical or mental illness among workers
during their work duties by taking initiatives to maintain a safe and sanitary
working environment.

3-1 Occupational Safety
We identify and evaluate risks to occupational safety, and ensure safety
through appropriate planning, technology, and management methods. In
particular, we give appropriate consideration to the safety of pregnant
women and nursing mothers.
It is necessary to identify safety hazards in the workplace and their risk of occurrence, andimplement safety measures toward workers. Examples of safety hazards in the workplace include
contact with chemical substances, electricity or other energy sources, fire, vehicular accidents,and fall hazards.
In addition, it is vital to protect pregnant women and nursing mothers from hazardous
conditions and to provide reasonable accommodations for their safety.

3-2 Emergency Preparedness
We prepare for emergency situations, such as disasters or accidents that
could cause loss of life or physical safety, and identify such situations
including potential occurrences. We establish action procedures to follow
in times of emergency in order to minimize damage to workers and property,
install necessary equipment, and carry out training and drills to ensure thatsuch actions are correctly followed during disasters.
“Emergency planning” refers to, for example, emergency reporting, communication to workers,
clarifying evacuation procedures, installing evacuation equipment, ensuring easily identifiable
exits without obstruction, providing appropriate exit facilities, storing medical supplies for
emergency use, installing fire detection systems, installing fire extinguishers, fire shutters, andsprinklers, securing external communication methods, and maintaining recovery plans. It is also
necessary to disseminate emergency plans within the workplace. This involves, for example,
providing emergency training (including evacuation drills) to workers, and placing or posting
information on emergency procedures in an easily accessible location in the workplace.

3-3 Occupational Injury and Illness
We identify, assess, record and report the conditions of workers who suffer
occupational injury or occupational illness, and take appropriate
countermeasures.
When a worker suffers occupational injury or occupational illness, we are required to record thesituation, provide any necessary treatment, investigate injuries, identify and eliminate causes andimplement preventative measures, and to take all proper corrective steps including monitoring-9-and reporting. In addition, provisions to facilitate the worker’s return to the workplace are also
required, as well as reporting on the implementation of such provisions.

3-4 Industrial Hygiene
We identify, assess, and appropriately control the risk of workers’ exposure
to hazardous biological, chemical, or physical substances in the workplace.
The risk of hazard must be eliminated, or controlled, through appropriate planning, engineeringand operational management. In cases where hazards cannot be managed appropriately bytaking such steps, workers must be provided with appropriate PPE (personal protective
equipment) that is properly maintained and managed, and must use the said PPE correctly.

3-5 Consideration of Physically Demanding Work
We identify and assess physically demanding work tasks, and appropriately
manage such tasks so that they do not result in occupational injury or
occupational illness.
“Physically demanding work” refers not only to load-bearing tasks such as the manual handlingof raw materials or manual transportation of heaving loads, but also includes physicallydemanding assembly work, repetitive or consecutive tasks over a long period such as data entry,
and other tasks that involve maintaining an unnatural posture for long periods of time.

3-6 Machine Safeguarding
We assess the safety risks of machinery used by workers during their duties,
and implement appropriate safety measures.
“Appropriate safety measures” refers to management for the purpose of preventing theoccurrence of accidents and health hazards during work. This includes, for example, employing
safety mechanisms such as fail-safe, fool-proof, interlock and tag-out, installing safety devices
and safety barriers, and implementing regular inspections and maintenance of machinery.

3-7

Health and Safety at Facilities

We appropriately ensure health and safety at facilities provided for workers’
daily living (dormitories, cafeterias, toilets, etc.). In addition, we ensure that
there are appropriate emergency exits at dormitories.
In order to ensure health and safety, in addition to maintaining the cleanliness and hygiene offacilities, the following points must also be considered.
・Drinking water: Water quality testing that conforms with laws and regulations; Safe drinking
water (water servers, etc.)
・Hygienic meal provision: Appropriate clothing and health checks for food preparation staff,
pest control, temperature control of foodstuffs, certification of cafeteria operators
・Toilets: Sufficient number of clean toilet facilities in relation to worker numbers; provision of
toilet paper, etc.

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・Dormitories: Fire control, emergency evacuation routes (exits), secure storage facilities for
personal belongings (provide lockers with keys), sufficient room size (minimum of 3.3m 2
per person), ventilation, temperature control, appropriate lighting, etc.

3-8 Health and Safety Communication
We provide appropriate health and safety information, training, and drills in
relation to various hazards that workers may potentially be exposed to, using
languages and methods that workers can understand. In addition, we establish
a mechanism that allows workers to give feedback and opinions related tosafety.
It is necessary to provide appropriate information, training and drills on workplace health andsafety, in relation to workplace hazards that workers may be exposed to (including, but not limited
to, mechanical, electrical, chemical, fire, and physical hazards).
Health and safety information must be clearly displayed within the facilities, or placed in alocation identifiable and accessible by workers, and must be provided in languages that workers
can understand.
Training and drills must be provided to all workers before commencing work, and at regularperiods thereafter. In addition, workers are encouraged to raise any safety concerns, and training
and drills shall include topics such as the correct use of PPE (personal protective equipment),
emergency countermeasures, safe operation of machinery, and preparations before entering
hazardous environments.

3-9 Worker Health Management
We provide appropriate health management toward all workers.
“Appropriate health management” refers to conducting health checks at the level stipulated bylaws and regulations, as a minimum, and to aim toward prevention and early detection of illness
among workers. In addition, ample consideration must be given to care of mental health andprevention of damage to health through overwork.

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4． Environment
Corporations are required to proactively tackle global environmental issues
such as exhaustion of natural resources, climate change, and environmental
pollution, in addition to paying attention to localized environmental issues in theirregions of involvement, with consideration for maintaining the health and safetyof the local community.

4-1 Environmental Permits and Reports
We are required to obtain permits and approval necessary for business
operations and to comply with registration and reporting requirements, inaccordance with the laws and regulations that apply in the location of business.
In Japan, laws such as the Waste Disposal Act, the Act on the Rational Use of Energy, and the
Air Pollution Control Act obligate us to appoint managers with specific qualifications stipulated bylaws and regulations. In addition, depending on the chemical substances used in business, wemay be obligated to appoint a manager responsible for control of poisonous and deleterious
substances, control of designated chemical substances, or control of hazardous substances. In
some cases, depending on business type or factory location, we may also be required to obtainenvironmental impact assessments or government approval for facilities that handle hazardous
substances.

4-2 Reducing Energy Consumption and Greenhouse Gas Emissions
We are required to work toward improving energy efficiency, and to takecontinuous initiatives to reduce energy consumption and greenhouse gas
emissions.
“Improving energy efficiency” refers to minimizing energy consumption, the related Scope 1(greenhouse gases directly emitted by a company) and Scope 2 (greenhouse gases indirectly
emitted by using electricity, heat, or steam provided by another company) greenhouse gas (GHG)
emissions. We are required to track and document energy consumption and GHG emissions at
each facility or business office.

4-3 Air Emissions
We comply with relevant laws and regulations, and implement appropriate
measures in order to reduce emissions of hazardous substances to theatmosphere.
Hazardous substances emitted to the atmosphere include volatile organic compounds,
aerosols, corrosives, particulates, ozone-depleting substances, and byproducts of combustion.
We are required to make efforts to analyze and monitor these substances prior to emission, andonly allow emission after conducting necessary control and treatment based on the results of suchanalysis and monitoring. Countermeasures include regular monitoring of the handling of emitted
substances and the performance of treatment systems.

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4-4 Water Management
We comply with laws and regulations, monitor the source, usage, and discharge ofwater used, and practice water-saving. We also monitor, control, and process all
wastewater before discharge or disposal, labelling water characteristics whennecessary. Furthermore, we identify and appropriately manage potential sources ofpollution that may lead to water contamination.
In water management, we are required to monitor water sources, usage, and discharge, andconserve water and control channels of contamination.
Controlling channels of contamination includes ensuring that site water channels are free fromcontamination and are protected from contamination (e.g. no stagnant water or fat deposits in thevicinity of storm drain pipes) and that emergency response equipment is correctly installed (e.g.
shutoff valves and stopcocks must be installed to prevent outflow or leakage of clean water orsewage, including pollutants, due to factory accidents or natural disasters; street inlets or storage
reservoirs installed to contain leaks or overflows are not considered sufficient).

4-5 Efficient Use of Resources and Waste Disposal
By complying with laws and regulations and implementing appropriate
management, we promote the 3Rs (reduce, reuse, and recycle), plan
towards efficient use of resources, and keep generation of waste to aminimum.
We are required to identify and manage waste even when disposing of waste not identified ashazardous, to implement a systematic approach for responsible disposal or recycling, and work
towards reducing waste. It is also necessary to implement measures for disposing of substances
according to the laws and regulations of the location of business, and to ensure that natural
resources are not wasted by minimizing their disposal. Measures to achieve this include changing
production equipment at the source, using alternative materials, and reusing and recycling
resources. We also establish voluntary targets in order to comply with laws and regulations.
“Natural resources” refers to water, fossil fuels, minerals, virgin forest, the products of virgin forest,etc. The prevention of environmental pollution leads to conservation of natural resources, and isclosely related to the sustainability of the planet.

4-6 Chemical Substance Management
We comply with laws and regulations to identify, label, and control chemicaland other substances that are hazardous to humans or the environment,
and manage accordingly to ensure the safe handling, transport, storage,use, recycling, reuse, and disposal of such substances.
Within Japan, we are required to manage substances on the basis of the Chemical Substances
Control Law, the Poisonous and Deleterious Substances Control Law, the Industrial Health and
Safety Act, the Fire Services Act, and the PRTR (Pollutant Release and Transfer Register).
Additionally, careful management of chemical substances during the manufacturing process isalso necessary.

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4-7 Managing Chemical Substances Contained in Products (Tomoegawa
Green Procurement)
We comply with all laws, regulations, and relevant Tomoegawa Group
standards that apply to the prohibition and restriction of specificsubstances contained in products.
We follow the relevant Tomoegawa Group standards in relation to substances contained in
products, in addition to the laws and regulations of products’ countries of origin and destination.
Since producers of end products must also bear responsibility for the components included in end
products, upstream companies in the supply chain are required to provide the necessary
information to downstream companies. For details, please refer to the “Tomoegawa Green
Procurement Standards”.

4-8 Natural Resources and Biological Diversity
During procurement of raw materials, we avoid or minimize impact on
biological diversity, and work toward the sustainable use of natural
resources.
When using natural resources such as those derived from forests, oceans, or living creatures,
we must avoid the use of resources that have been illegally extracted, cultivated, or traded. In
addition, we are also expected to give consideration to resource conservation when using raw
materials, including from the perspective of controlling deforestation and forest degradation.
Furthermore, due to the potential for business activities to affect various organisms and theirhabitats, we are also expected to mitigate any adverse impacts. When there is a possibility thatrare plants or animals are being used, steps such as checking the raw materials, their origin, andthe existence of relevant regulations and resource conservation measures can be considered tomitigate the impact on biological diversity.

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5． Fair Busisness and Ethics
In addition to legal compliance, we conduct our business activities on the basisof high ethical standards.

5-1 Preventing Corruption
All forms of bribery, corruption, blackmail, and embezzlement are prohibited.
We maintain a policy of absolute prohibition of acts of bribery, excessive gifts or entertainment,
blackmail, and embezzlement, and require continuous compliance. Continuous compliancemeans not only the establishment of such policies, but also requires appropriate education andtraining of employees as well as continuous and thorough policy implementation.

5-2 Prohibiting Provision and Acceptance of Inappropriate Benefits
It is prohibited to provide or accept bribes or any other promises, offers, or
permissions as a means to obtain unfair or inappropriate benefits.
It is prohibited to directly or indirectly provide or receive items of value (money, goods, orservices), or to promise or offer to do so, in order to secure business or to obtain inappropriate
benefits. We are required to clarify and monitor our policies and procedures for compliance withlaws and regulations related to corruption prevention.

5-3 Appropriate Disclosure of Information
We disclose information related to labor, health and safety, environmental
activities, business activities, our organizational structure, financial situationand performance in accordance with applicable laws and regulations andindustry practices. We do not allow the falsification of records or the disclosureof false information.
We are required to proactively provide and disclose information to stakeholders. Information
provided and disclosed to stakeholders includes the details of business activities, financial
situation and performance, ESG (environmental, social, and governance) information, risk andincident information (such as damage caused by large-scale disasters, adverse impacts on theenvironment or society, or discovery of significant violations of law, etc.), and information
regarding the supply chain. Timely disclosure of information on major risks and notifying
customers are also examples of proactively providing information. With regard to such information,acts such as falsification of records, misrepresentation of information, or disclosure of false
information are not permitted.

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5-4 Respecting Intellectual Property
We respect intellectual property rights. The transfer of technology and knowledge
must be carried out in a form that protects intellectual property. In addition, we also
protect the intellectual property of customers, suppliers, and other third parties.
The protection of intellectual property applies not only to our own company, but includes thatof customers, suppliers, and other third parties.
“Intellectual property” includes trade secrets and technical know-how in addition to intellectual
property rights. “Intellectual property rights” are rights stipulated by laws and regulations, andinclude patent rights, utility model rights, design rights, trademark rights, and copyrights.

5-5 Fair Business Practices
We carry out fair business, fair competition, and fair advertising.
We comply with laws and regulations regarding fair business practices, including faircompetition and subcontracting laws, and must not engage in illegal acts such as cartel
agreements to restrict competition, unfair business practices, or misleading representations. In
addition, we are required to eliminate any forces that threaten the order or safety of civic life, andto comply with laws, ordinances and all other societal norms. When presenting products orservices in catalogs or other advertising, we do not make factually incorrect statements or otherwords that mislead consumers and customers. Furthermore, we must take care to ensure that nocontent that slanders or infringes the rights of other companies or individuals is included inadvertising materials.

5-6 Protecting Whistleblowers
We are required to protect the confidentiality of reported information and theanonymity of whistleblowers, and eliminate acts of retaliation against whistleblowers.
“Disadvantageous treatment” refers to harassment and other acts that damage the working
environment, and changes to working conditions such as unfair performance evaluation,
remuneration, dismissal, or reassignment.

5-7 Responsible Minerals Procurement
We check that the minerals contained in our manufactured products are in no way
connected or complicit in serious violations of human rights, environmental
destruction, corruption, or conflict, in conflict-affected regions and high-risk areas.
“Due diligence” in relation to responsible minerals procurement refers to establishing policies,
communicating expectations to suppliers (and incorporating such expectations in contracts where
possible), identifying and assessing risks in the supply chain, and establishing and implementing
strategies to tackle identified risks. The OECD’s “Due Diligence Guidance for Responsible Supply
Chains of Minerals from Conflict-Affected and High-Risk Areas” is an internationally-recognizeddocument regarding due diligence in responsible minerals procurement.

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6． Quality and Safety
We ensure the safety and quality of our products and services, and provide
accurate information on safety and quality.

6-1 Product Safety
We ensure that our products meet safety standards provided for in the laws
and regulations of respective countries, and fulfill our responsibilities as
suppliers by ensuring sufficient product safety in design, manufacturing,and sales.
We are required to ensure adequate product safety in the product design process, and to
consider our responsibility as a manufacturer in the sale of products. We must also consider thesafety that the product should ordinarily provide, in addition to legal compliance. Within Japan,
product safety is governed by laws such as the Electrical Appliances and Material Safety Act, theConsumer Products Safety Act, and the Household Goods Quality Labeling Act, and safety
standards are defined in the detailed regulations of domestic laws and in the Japanese Industrial
Standards (JIS). Furthermore, overseas safety standards include the UL, BSI, and CSA standards.
Effective measures for ensuring product safety include management of traceability (history ofmaterials, components, and processes, etc.) and swift responses toward problem resolution.

6-2 Quality Management
We are required to comply with in-house quality standards and the
Tomoegawa Group’s quality requirements, in addition to compliance withall laws and regulations that apply to the quality of products and services.
It is necessary to establish appropriate frameworks and management systems for complying
with in-house quality standards and the Tomoegawa Group’s quality requirements, in addition tocompliance with local laws and regulations that apply to the quality of products and services.

6-3 Providing Accurate Information on Products and Services
The information we provide on products and services is accurate, and will
not lead to misunderstanding.
It is necessary to provide information to customers and consumers that is accurate and does
not lead to any misunderstandings. We must not provide false information or information that has
been misrepresented.

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7． Information Security
We prevent leakage of confidential information or personal information, andimplement reinforcement of information security.

7-1 Defense from Cyber Attacks
We establish defensive measures to counteract cyber attacks and otherthreats, and manage our systems to prevent harm occurring to ourselves orto third parties.
We are required to prevent trouble caused by cyber attacks, such as leakage or manipulationof information, or the crashing of information systems. Attackers may be able to expand theirtarget of attack using the customer and client information they obtain, which means that the scopeof damage from cyber attacks will not be limited to ourselves. Due to the ongoing broadening ofdevice categories subject to cyber attacks, from conventional computers and servers to industrial
systems and IoT (Internet of Things) devices, countermeasures must also be implemented forsuch devices. It is vital to establish a plan for prompt recovery in the event of a cyberattack.
Measures should include, for example, backing up important data, and duplicating servers anddata centers.

7-2 Protecting Personal Information
We comply with relevant laws and regulations and appropriately manageand protect all personal information, including that of our suppliers,
customers, consumers, and employees.
We are required to comply with the laws and regulations of each country and carefully handle
all personal information, including that of our suppliers, customers, consumers and employees.
Personal information must only be collected, stored, modified, transferred, shared or otherwise
processed within the extent necessary to achieve the specified purpose of use.

7-3 Preventing Leakage of Confidential Information
We appropriately manage and protect not only our own confidential
information, but also confidential information received from customers andother third parties.
It is necessary to establish an appropriate framework and management system for managing
confidential information received from third parties, as well as our own. This includes setting
information management levels, in addition to worker education and training.
“Confidential information”, in general, refers to information disclosed in documents that havebeen agreed to be confidential, or information disclosed orally with a verbal notification that the
information is confidential.

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8． Business Continuity Planning
Companies must make preparations to ensure swift resumption of production
activity if the company or a contractor is affected by a disaster, such as a largescale natural disaster, in order to fulfill the company’s supply responsibilities.

8-1 Developing and Preparing a Business Continuity Plan
We identify and assess risks that could impede business continuity, andformulate a Business Continuity Plan (BCP) that includes a detailed
examination of the impact on the business, necessary preparatory
countermeasures in the mid-to-long term, and the current status of suchinitiatives.
Risks that could impede business continuity include large-scale natural disasters (such as
earthquakes, tsunamis, floods, heavy rainfall, heavy snowfall, and tornadoes) and accompanying
power outages, water stoppages, disruption to transportation, accidents (such as fires or
explosions), the spread of epidemic or infectious diseases, and terrorism or riots.
Preparatory countermeasures include local recovery strategies for how to protect, mitigate, andrecover the various elements at each production base from anticipated damage. It is vital to plan
to secure alternative means of production, with the assumption that recovery from damage will
be a prolonged process.
We are also required to formulate a manual for the swift resumption of business, in accordancewith the details stated in the BCP, in the event that business is actually disrupted, and to provide
continuous training and drills to employees so that they can respond during actual disasters.

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9． Establishing a Management System
We aim to establish a management system in order to ensure correct compliancewith these Guidelines.

9-1 Establishing a Management System
The following cautions apply to the establishment of a management system.
・Do we comply with laws, regulations, and client requirements related to ourbusiness and products?
・Are our actions consistent with the contents of these Guidelines?
・Do we identify and mitigate risks in relation to the contents of these
Guidelines?
・Can we anticipate continuous improvements through the above actions?
A “management system” refers to establishing a framework for continuous improvements
through the Plan-Do-Check-Action (PDCA) cycle in relation to policy compliance, implementation
systems, corrective actions, and stakeholder engagement. Specifically, it includes corporate
commitment, management accountability and responsibility, legal requirements and customer
requirements, risk identification and management, improvement targets, education and training,communication, worker feedback, participation and grievance filing, assessment and audit ofidentified risks, corrective action processes, documentation and records.
The OECD’s “Due Diligence Guidance for Responsible Business Conduct” (RBC) is a set ofdue diligence guidelines in relation to all corporate conduct. The following six processes areindicated in this guidance.
・Incorporate RBC in corporate policies and management systems
・Identify actual and potential adverse impacts on RBC issues
・Terminate, prevent and mitigate adverse impacts
・Track and assess implementation and results
・Communicate how impacts are addressed
・When appropriate, give summaries of how corrections are implemented“Due diligence” is a process that corporations should carry out in order to identify, prevent,mitigate and fulfill accountability for how they address actual and potential adverse impacts inbusiness operations, their supply chain, and other business relationships. Effective due diligenceshould be supported by efforts to incorporate responsible business conduct (RBC) in corporate
policies and management systems, and aims to correct any adverse impacts that are caused by,
or facilitated by the corporation.

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9-2 Management of Suppliers
We communicate the requirements of these Guidelines to our suppliers. In
addition, we aim to establish processes for monitoring the status of
suppliers’ compliance with these requirements.
Corporations are required to assume the same level of accountability for corporate social
responsibility (CSR) within their supply chain as in-house CSR. Therefore, it is necessary tocommunicate the requirements of these Guidelines to suppliers, monitor their status ofcompliance, and encourage improvements.

9-3 Proper Import and Export Controls
We maintain a clear management system for the import and export oftechnologies and goods regulated by local laws and regulations, and carryout appropriate import and export procedures.
We are required to understand and comply with various national laws and regulations related
to importing and exporting. “Technologies and goods regulated by laws and regulations” refers togoods, products, technologies, equipment, and software subject to import and export controls inlaws and regulations based on international agreements (such as the Wassenaar Arrangement).
In addition, in some cases we may be required to carry out procedures including obtaining
permission from the competent authorities regarding importing and exporting.

9-4 Establishing Grievance Mechanisms
In order to prevent violation of these Guidelines within our company andour supply chain, we establish grievance mechanisms that can be used bystakeholders, including workers and suppliers.
In order to comply with these Guidelines, in addition to due diligence, it is important to establish
grievance mechanisms in which reports from stakeholders, including workers and suppliers, canbe received, responded to and rectified, and victims can be helped, and also to facilitate acontinuous process of addressing such issues. In cases where it is difficult to establish an inhouse mechanism, an alternative method is to participate in a collective grievance mechanism.
Engagement and dialog with stakeholders, including whistleblowers, is fundamental to dealing
with grievances. In order for a grievance mechanism to function effectively, it is useful to promote
understanding among stakeholders who may become whistleblowers, to conduct awarenesssurveys to confirm the level of understanding, and to participate in continuous improvement
through advice and suggestions from concerned parties and specialists. “Grievance mechanism”
refers to a framework that enables concerned parties to report acts that are suspected of violatingthese Guidelines, and to promote corrective actions. During the grievance process,whistleblowers must not be subject to disadvantageous treatment.

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Revision History
Edition No.

Date of Enactment / Date of Revision

1st Edition

January 1, 2024

Contents / Reason

Newly enacted- 22 -