TSUBAKI NAKASHIMA
SUPPLIER CODE OF CONDUCTTable of Contents
Driving Integrity In Business Dealings........................................................................

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Antitrust and Competition Laws ................................................................................

2

Anti-Corruption and Anti-Bribery Laws......................................................................

3Gifts and Entertainment ............................................................................................

3Sanctions and Export Control Laws..........................................................................

3

Sourcing Materials from Areas of Conflict.................................................................

3

Driving Integrity Within Our Workplace ...................................................................

3

Respect for Labor Standards and Human Rights .....................................................

3

Diversity and Inclusion..............................................................................................

7

Health and Safety .....................................................................................................

4

Environmental Responsibility....................................................................................

4

Driving Integrity Through Our Actions.....................................................................

5

Conflicts of Interest...................................................................................................

5

Protection of Information and Intellectual Property ...................................................

5

Driving Integrity With Good Communication ........................................................

5

Reporting Concerns and Non-Retaliation ...............................................................

5

Conflict with Other Requirements ...........................................................................

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Our Supplier Code of Conduct provides the framework for success in dealing with Tsubaki
Nakashima, including its single entities and plants (from now on: Tsubaki Nakashima), or with any
sub-supplier you do business with when serving Tsubaki Nakashima.
It forms an integral part of our overall contractual relationship with you, and it is important that you
understand and abide by it.
Driving Integrity In Business Dealings
At Tsubaki Nakashima, we set high ethical standards for ourselves and our suppliers. Tsubaki
Nakashima’s suppliers, vendors, consultants, independent contractors, agents, or any other third
party engaged to carry out any action on our behalf (“suppliers”) must always act with integrity byobeying the letter and spirit of laws, regulations, standards (together, “laws”) and Tsubaki
Nakashima policies that apply to them, wherever they do business.
They should, in turn, also require that their suppliers abide by the requirements of this Code.
The requirements of this Code are in addition to the requirements set out in any agreement or otherset of terms and conditions that apply to your relationship with Tsubaki Nakashima.
While the laws that apply to our suppliers are numerous and vary by jurisdiction, some importantprinciples that must be followed include:
Antitrust and Competition Laws
We compete vigorously while respecting free and fair competition. We expect the same of oursuppliers. Suppliers must comply with all applicable antitrust and competition laws and cannot
engage in any act that improperly reduces competition. Examples of such prohibited acts include
agreeing with competitors to fix prices, set discounts or terms of sale, limit production, divide
markets, allocate customers, coordinate bidding activities, boycott customers and suppliers, fix
employee compensation, or refrain from hiring each other’s employees. In some jurisdictions, themere exchange of sensitive commercial information is illegal.
Read Tsubaki Nakashima’s Code of Business Ethics.
✓ Suppliers should know the laws that apply to them and follow the letter and spirit of suchlaws✓ Suppliers must not collude with competitors to limit competition✓ Suppliers are strictly prohibited from offering bribes to government officials✓ Suppliers must not violate sanctions and export control laws
✓ Suppliers must cooperate with Tsubaki Nakashima in identifying the source of certain
minerals used
Tsubaki Nakashima’s suppliers must always act with integrity by obeying the letter and spirit of laws
and Tsubaki Nakashima policies that apply to them, wherever they do business.
To report suspected violations of Tsubaki Nakashima’s Supplier Code of Conduct, please contact
your Tsubaki Nakashima reference or write to Ombudsman@tsubaki-nakashima.com

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Anti-Corruption and Anti-Bribery Laws
Our suppliers must follow all applicable laws that prohibit the giving of anything of value to any
person or entity to obtain an improper business advantage, as well as laws that require keeping
accurate books and records.
Suppliers must follow anti-corruption and anti-bribery laws in all cases and must be particularly
cautious when interacting with government officials.
Regardless of the specific laws or established business practices of any jurisdiction in which we or
our suppliers operate, Tsubaki Nakashima prohibits the making of “facilitation payments” or “greasepayments” (i.e. payments involving small sums to low-level government officials to obtain routine
services to which a person or company would otherwise be legally entitled.
Gifts and Entertainment
Any gift or entertainment offered to a Tsubaki Nakashima employee to induce or unduly influencea business decision (e.g. awarding business to the supplier, offering favorable terms) is strictly
prohibited. If you wish to provide a Tsubaki Nakashima employee with a gift or entertainment, it
must be reasonable, given only occasionally, and of modest value.
In turn, we prohibit Tsubaki Nakashima employees from soliciting gifts and entertainment fromsuppliers. If you are solicited by a Tsubaki Nakashima employee for a gift or entertainment, you
should report it promptly.
Sanctions and Export Control Laws
We expect our suppliers to comply with all applicable export control laws, as well as laws thatprohibit or restrict business relationships with sanctioned countries, entities, persons, or industry
sectors.
Sourcing Materials from Areas of Conflict
As a public company, we are required by law to track and disclose our use of minerals such as gold,tin, tungsten, and tantalum originating in several designated countries.
When requested, our suppliers are required to provide data in the form we request, regarding theiruse of such minerals in their products. Furthermore, suppliers may be required to request similar
information of their suppliers to establish the origin of such minerals, and to provide their findings
to us.
Driving Integrity Within Our Workplace
Fairness, inclusivity, safety, and sustainability are values we hold dear at Tsubaki Nakashima andwhich we strive to achieve in our operations. We expect the same of our suppliers.
Respect for Labor Standards and Human Rights
Tsubaki Nakashima is committed to complying with all applicable labor, employment, and humanrights laws, and we demand the same commitment from our suppliers. Our suppliers must therefore
follow local laws on minimum wages, benefits, overtime, work hours, and working conditions.
3Our suppliers are never permitted to use forced or compulsory labor. Suppliers are also prohibitedfrom using underage labor, as defined by local labor law, unless it is part of a government-approved
training or apprenticeship program that clearly benefits the participants. Suppliers should also
respect employee freedom of association and choice with respect to the issue of unions or works
council affiliation, consistent with local laws.
Tsubaki Nakashima is committed to complying with all applicable human rights laws, and we
demand the same commitment from our suppliers.
• Suppliers must respect the rights of their employees. They must avoid the use of forced and childlabor.
• Suppliers are expected to prohibit workplace harassment as well as improper discrimination.
• Suppliers must maintain a safe and healthy workplace for their employees.
We expect suppliers to follow environmental laws and to regularly monitor their environmentalimpact.
Diversity and Inclusion
We believe that diversity is a source of strength. That is why we expect our suppliers to prohibit
workplace harassment and discrimination based on sex, race, ethnic background, religion, disability,
or any other personal characteristic protected by law.
Health and Safety
Our suppliers are required to comply with all applicable health and safety laws. This includes theduty to maintain a safe and healthy workplace with access to personal protective equipment for
employees and to have a procedure for dealing with injuries that require medical treatment.
Environmental Responsibility
We are committed to environmental responsibility. We expect our suppliers to meet or exceed
applicable environmental laws, and to be committed to minimizing the impact of their operations
on the environment. Suppliers should also seek to regularly evaluate and monitor the impact of
their business activities on the environment, manage and reduce the use of energy and otherresources, minimize waste and emissions, recycle materials at every stage of the product life cycle,
store hazardous and combustible materials in a safe and legal manner, and reduce environmental
impact through design and innovation.
We encourage certification to ISO 14001 environmental standards or any successor standards, andencourage our suppliers to develop a plan to achieve such certification status. Similarly, weencourage our suppliers to minimize their water and energy consumption. Materials from oursuppliers are required to be REACH (Registration, Evaluation, Authorization and Restriction ofChemicals) compliant.
Read Tsubaki Nakashima’s Health, Safety and Environmental Policy.

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Driving Integrity Through Our Actions
Our employees are required to demonstrate their integrity each day through their actions. They arealso required to speak up if they become aware of a situation in which someone may have failed tolive up to our ethical standards. Our suppliers are required to do the same if they learn of a violationof this Code.
Conflicts of Interest
To ensure that relationships with our business partners are based on integrity and sound businessjudgment, we require our employees to promptly disclose conflicts of interest. Similarly, we expect
any supplier to inform us promptly if it has a family or close personal relationship with the Tsubaki
Nakashima employee making or influencing a business decision that may benefit the supplier.
Protection of Information and Intellectual Property
As a supplier, Tsubaki Nakashima or its business partners may provide or give you access tointellectual property or confidential or personal information (“Information”). You acknowledge thatyou will maintain and enforce appropriate safety and physical security procedures with respect tothe access and maintenance of such Information that are at least equal to industry standards forsuch types of Information; and which provide reasonably appropriate technical and organizationalsafeguards against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure
or access of Information.
Additionally, you will never sell such information, never disclose it without Tsubaki Nakashima’s
consent, ensure you use Information only for the purposes of your provision of products and/orservices to Tsubaki Nakashima, and promptly return or destroy such information at the end of ourrelationship (or when it is no longer needed).
If you become aware that confidential or personal information of Tsubaki Nakashima’s, its
employees, or business partners has been disclosed. or that Tsubaki Nakashima’s intellectual
property rights have been violated; you must notify your primary Tsubaki Nakashima point ofcontact immediately.
Driving Integrity With Good Communication
As a supplier to Tsubaki Nakashima, we ask that you uphold the values of honesty and integrity
embedded in this Code. We note that violating certain elements of this Code is a violation of the law
in the jurisdictions in which we operate. Tsubaki Nakashima does not tolerate any violations of thelaw by its suppliers.
Reporting Concerns and Non-Retaliation
We require you to take steps and ensure your employees understand this Code and comply with its
requirements.
We expect our suppliers, and their employees, to speak up promptly if they learn of a violation of
the law or this Code (while working for Tsubaki Nakashima), either by the supplier itself or by
Tsubaki Nakashima employees.
5You can always make the report to the Tsubaki Nakashima employee who is your primary contact,or the Tsubaki Nakashima’s Ombudsman.
Reports to them can be made anonymously in most countries.
Depending on the circumstances, Tsubaki Nakashima may take a range of actions to remediate afailure by a supplier to comply with this Code, for example by suspending business with the supplier
until corrective measures have been implemented or by terminating the relationship with thesupplier.
Conflict with Other Requirements
If any requirement in this document conflicts with the requirements of the Tsubaki Nakashima
Global Supply Chain Requirements or any other requirements of Tsubaki Nakashima suppliers (e.g.
under any agreement in place between you and Tsubaki Nakashima), the requirements of thisdocument shall prevail.
• Employees of suppliers must be familiar with this Code and comply with its terms.
• Suppliers must speak up if they learn of a violation of this Code or the law.
• Suppliers are prohibited from retaliating against any employee who raises a good-faith complianceconcern.

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