JAL Group Supplier Code of Conduct
Active date: 16JUL19

The JAL Group (“we”) is firmly committed to maintaining flight safety, the basis of our existence, as an
infrastructure that supports society. We endeavor to be a corporate group that provides unparalleledproducts and services to customers and fulfills responsibilities as a corporate citizen in order to increase
corporate value and contribute to the betterment of society, as declared in the JAL Group Corporate
Policy.
Under this Corporate Policy, the JAL Group has established this Code of Conduct to promote theestablishment of sound supply chains in order to achieve the Sustainable Development Goals*, on the
major premise of securing safety based on a shared awareness that safe operations is maintained throughjoint efforts with our suppliers so that our customers may use our flights with peace of mind.
The JAL Group requests its suppliers to not only understand and comply with this Code of Conduct but
also establish good partnerships based on mutual trust regarding the principles outlined herein andpromote sustainable and responsible purchasing activities.
*Sustainable Development Goals, or SDGs:
17 goals to be solved by the international community by 2030 to realize a sustainable society.

＜Requests to our suppliers＞
Suppliers of the JAL Group are requested to comply with the following matters.

1．Quality Assurance
1-1

Ensure product & service quality and safety

Ensure product & service quality and safety through quality management systems or a third-party
certification system. Provide accurate information on products and services.
【Commentary】Daily quality enhancement efforts are necessary in order to provide product and service
quality and safety of high standards. Specifically, steadily implement the PDCA cycle and conduct quality
control based on international standards such as ISO9000.

1-2

Respond appropriately to accidents or distribution of defective products and services

Establish systems to disclose information, report to relevant authorities, recall products, enforce
measures toward suppliers, etc. in case of an accident or defective products.
【Commentary】In case defective products and services cause bodily harm to customers, etc. or damage
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their property, or such concerns are raised, provide accurate information, quickly set up a recall system,
etc. in order to solve the problem with top priority. Also, establish a system to proactively prevent recall.

2．Human Rights and Labor
2-1

Respecting human rights and eliminate discrimination

Do not discriminate on the basis of gender, age, national or regional origin, race, ethnicity, religion,social status, disability, sexual orientation, gender identity or other attributes.
【Commentary】Make every effort to create workplaces that are free of harassment and unlawful
discrimination. Discrimination in employment conditions such as wages, promotion, remuneration on thebasis of the following is prohibited; race, color, age, gender, sexual orientation, gender identity disorderand sexual expression, ethnicity or national or regional origin, disability, pregnancy, religion, politicalconviction, union member, military experience, protected genetic information, marital status, etc.

2-2Freedom of association

Respect fundamental labor rights including freedom of association, workers’ rights to organize andcollective bargaining rights。
【Commentary】Respect fundamental labor rights including freedom of association, workers’ right toorganize and collective bargaining rights according to local laws. Give consideration to employees toexchange frank opinions on working conditions and management practices with management without fearof discrimination, retaliation, threats, etc.

2-3

Control long work hours

Manage work hours of employees appropriately to ensure work hours do not exceed limits stipulated
by local laws.
【Commentary】Work hours must not exceed limits established by applicable local laws. As a general rule,the number of working days a year must stay within statutory limits and the number of working hours aweek (including overtime) must not exceed statuary limits.

2-4

Wages

Pay wages and salaries to employees in compliance with all related laws including the minimum wage,
overtime and statutory benefits.
【Commentary】Remuneration paid to employees must comply with all related laws including the2minimum wage, overtime and statutory benefits. Comply with applicable local laws and pay overtime at ahigher wage rate than normal hourly rate.

2-5Prohibiting forced labor and child labor

Do not use forced labor in any form or employ workers who do not reach the minimum work age.
【Commentary】Effectively eliminate forced labor by guaranteeing that all work is voluntary and that
employees are free to leave the company at any time. To effectively eliminate child labor, do not employ
children who are 15 or the mandatory education completion age or the minimum employment age ofthe country, whichever is the oldest, according to regulations of the ILO (International Labor
Organization). Furthermore, do not assign workers under 18 (young workers) to jobs where they are
exposed to health and safety hazards including night shift and overtime.

2-6

Prohibiting inhumane treatment

Do not imposed physical or mental cruelty, all types of harassment and inhuman treatment thatdamages personal dignity.
【Commentary】Apparent or fear of degrading, inhumane treatment toward employees such as sexual
harassment, power harassment, sexual abuse, corporal punishment, psychological or physical repression,and verbal abuse is prohibited. When taking disciplinary action, etc. against these acts, clarify the policy
and procedures and inform employees in advance.

2-7

Preventing involvement (participation) of human rights violations

Give sufficient consideration to prevent involvement (promotion) of human rights violations ofconsumers, residents of regional communities and all stakeholders through the company’s businessactivities.
【Commentary】In case related persons of a company’s business violate human rights, the company will
be regarded as having had “indirect” involvement (participation). As participation in human rights
violations must be taken into account, pay attention to the impact of not only your products and services
but also decision-making and business activities on human rights.

2-8

Respect for the lives of indigenous people and local communities

When conducting business in habitation areas of indigenous peoples or minority ethnic groups, giveconsideration to their rights by respecting their unique culture and history.
【Commentary】As vulnerable indigenous peoples or ethnic minorities may be impacted by business3

activities in various ways, respect their culture and practices by paying attention to habitation areas
specified by local laws and regulations and international standards such as international laws.

2-9

Respect for foreign and immigrant workers

Foreign and immigrant workers shall be treated in the same way as workers of your own country andprovided transparent employment conditions, good work conditions and life conditions.
【Commentary】Ensure that foreign or immigrant workers (including technical interns) are not treateddifferently from workers of your own country on the basis of nationality, etc. and that immigrant workers
are not illegally employed.

2-10

Creating work environments

Respect traditions and customs of countries and regions where the company operates, respect religious
traditions and customs of employees, and take care not to obstruct such traditions and customs throughuniform employment regulations, etc.
【Commentary】Respect and give consideration to the cultures and practices of countries and regions
where the company operates. In particular, give consideration to a certain extent to allow employees toobserve religious practices.

3．Safety and Sanitation of Work Environment
3-1

Proactively prevent accidents and disasters and minimize damage

Proactively prevent accidents and disasters, minimize damage and create workplaces where employees
can work with peace of mind.
【Commentary】The company has the responsibility to comply with applicable local laws and protect thesafety and health of their employees. Employees have the responsibility to observe necessary matters toprevent occupational accidents and cooperate with occupational accident preventive measures
implemented by the company.

3-2

Occupational healthAppropriately manage chemical, biological and physical factors in the work environment that arepotentially harmful to employee health.
【Commentary】Companies have the responsibility to comply with applicable local laws, identify, assess
and manage exposure of employees to chemical, biological and physical factors, take steps to reduce4excess exposure, and if it is difficult to control dangerous factors through such steps, protect employee
health through appropriate protective equipment, etc.

3-3

Healthcare management of employees

Prevent occupational accidents and illness by providing and maintaining safe and sound work
environments.
【Commentary】Take necessary steps to prevent occupational accidents and illness, pay attention to heavy
physical work and conduct healthcare management to maintain employee health. Comply with allapplicable laws concerning the work environment and keep the workplace clean and sanitary. Especially,
provide and maintain clean toilets, safe drinking water and a hygienic meal environment.

4．Global environment
4-1

Establish and operate environmental management systems

Establish, operate and continuously improve environmental management systems.
【Commentary】To implement voluntary environmental preservation initiatives in management, establish
environmental policies and targets and a framework of systems, procedures, etc. in factories and businessoffices for pursuing the targets, which are called environmental management systems (international
standard ISO14001). To conduct continuous environmental activities, establish and operate environmental
management systems.

4-2

Reducing greenhouse gas emissions

Establish and pursue voluntary greenhouse gas emission reduction targets to respond to climatechange.
【Commentary】Make every effort to pursue cost-efficient methods to minimize greenhouse gases directly
emitted by burning fossil fuel in business activities and indirectly emitted by purchasing electricity, such as
improving energy efficiency and using alternative fuels.

4-3

Sustainable, efficient use of resources (energy, water, raw materials, etc.)

Set voluntary targets to save resources and save energy, and continuously strive to use resources andenergy effectively.
【Commentary】To effectively use resources (energy, water, raw materials, etc.), take steps to check facility

5and company levels and improve efficiency.

4-4Managing and reducing sewage, sludge and exhaust

Prevent pollution by monitoring, controlling and reducing emission of sewage, sludge and exhaust, etc.
【Commentary】Establish voluntary targets to reduce impacts on the environment equivalent to or above
standards under law, prevent pollution, monitor and control sewage, sludge and exhaust, etc. and reduce
emissions.

4-5

Identify, manage, reduce and responsibly dispose of recycle waste

Establish and pursue voluntary waste reduction targets.
【Commentary】Take systematical approaches to identify, manage, reduce and responsibly dispose or
recycle wastes (excluding hazardous substances).

4-6 Manage chemical substances and hazardous substances specified by laws andregulations, etc. for the production process and contained in products and services.
Appropriately manage chemical substances and hazardous substances and appropriately report togovernment agencies.
【Commentary】Comply with applicable local laws and manage chemical substances contained in products,
identify the volume of chemical substances handled and report, etc. to government agencies. Also,
document procedures for safe storage, usage and disposable of hazardous substances and manage
chemical substances.

4-7

Initiatives for biodiversity

Consider direct and indirect impacts of operations on the ecosystem and take steps for the conservationand sustainable use of biodiversity.
【Commentary】Recognizing that rich and diverse ecosystems are the basis of business, take steps toprevent damage, taking into account impacts of operations on the ecosystem.

5．Business Management
5-1

Comply with laws and statutory and regulatory requirements

Operate business in compliance with laws of countries and regions where the company operates, and all6other related statutory and regulatory requirements.
【Commentary】Comply with laws of countries and regions where the company operates and all related
statutory and regulatory requirements, including the establishment of appropriate export and importmanagement systems and procedures. To reinforce compliance, policies and systems, establish andenforce action guidelines, and frameworks such as the whistle blower system and education programs.

5-2

Fair business transactions

Conduct fair, transparent, free competition and appropriate transactions. Impeding practices areprohibited.
【Commentary】Fair, free, lawful competition through transparent processes is indispensable in domestic
and international businesses for markets to function properly. Comply with competition laws of eachcountry.
Abuse of a dominant bargaining position that is detrimental to business partners is prohibited.
【Commentary】Transactions with business partners must be honest and fair based on agreements, etc.
Abuse of a dominant bargaining position to arbitrarily decide favorable terms and conditions or to makeunfavorable demands on business partners is prohibited.
When there is a conflict of interest between an employee and the company, it is prohibited to damage
the interests of the company to enjoy personal gain.
【Commentary】 In case the interests of the company and an employee contravene (conflict of interest),
the interests and purpose of the company must be prioritized. Using one’s position in the company toenjoy personal gain is prohibited. Behavior that impedes fair operations or objective judgment isprohibited.
Buying and selling of equities, etc. by related persons, etc. of listed companies based on confidential
information those people had privileged access to is prohibited.
【Commentary】Buying and selling equities, etc. as a result of having access to confidential informationthat could impact share prices is called insider trading and is prohibited. Leaking important non-public
information about a company or advise others to buy or sell equities, etc. for their benefit is also
prohibited.

5-3

Preventing bribery and corruption

Giving or accepting bribes of any form is prohibited. Giving and accepting entertainment, gifts or cash tocustomers, suppliers and other business partners in excess of common sense is prohibited.
【Commentary】Do not give, accept, promise, request or approve to give bribes or other means to gain
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inappropriate benefits. This includes promises, requests, approvals, giving or receiving of value, direct orindirect, through a third person to acquire, maintain or transfer business or to gain other inappropriate
benefits. To comply with anticorruption laws, open a hot line for whistle blowers.

5-4

Elimination of relations with antisocial forces

Any and all relations with antisocial forces that pose a threat to the order and safety of civil society anddisrupt economic activities is strictly prohibited.
【Commentary】Make every effort to eliminate any and all relations with antisocial forces. Resolutely
refuse threatening demands for unlawful economic benefits due to complaints about our service, etc. The
organization shall deal with such demands without leaving employees isolated to deal with the matter
alone.

5-5

Protection of intellectual property

Protect and pay attention to intellectual property in possession or belonging to the company to prevent
infringement by a third party.
【Commentary】Protect and pay attention to intellectual property in possession or belonging to thecompany to prevent infringement by a third party. Illegal acquisition and misuse of intellectual property
such as patent rights, utility model rights, design rights or trademark rights of third parties including
customers and suppliers or infringement of rights such as illegal copying of software and books is
prohibited.

5-6

Protect and prevent the leakage of personal information and confidential information

Properly manage, protect and prevent the leakage of personal information and confidential informationof the company, business partners, customers and third parties.
【Commentary】Make every effort to properly manage, protect and prevent the leakage of personal
information and confidential information of the company, business partners and customers and third
parties. To execute this, take steps to provide protection against computer network threats and manage
information to ensure that there is no damage to the company, business partners, customers and third
parties.

6．Expansion to Suppliers
6-1

Expansion to suppliers

8Establish a policy to achieve sustainable procurement through the company and supply chains anddisseminate and penetrate the policy inside and outside the company to achieve the principles set out inthis Code of Conduct.
【Commentary】Request business partners to comply with the principles set out in this Code of Conduct
as well as the company. It has the same meaning as the JAL Group requesting its business partners tocomply with this Code of Conduct that it established. Therefore, establish a CSR procurement policy topractice sustainable procurement activities, disseminate the policy inside and outside the company andensure that your business partners observe the policy.

6-2

Initiatives for conflict metals

Prevent the purchase and use of conflict metals, inspect and check suppliers according to businessconditions of the company.
【Commentary】Establish a policy to reasonably secure that tantalum, tin, tungsten and gold contained in
products manufactured by the company do not directly or indirectly benefit or fund armed groups thatcommit serious human rights violations in the Democratic Republic of the Congo and neighboring
countries. Perform due diligence on the source and distribution of metals and disclose the means tocustomers at their request.

7．Contribution to Regions and Society
7-1

Contributing to regions and society

Carry out activities to reduce health, safety, sanitation, etc. hazards in regional communities andresidents caused by the company’s business activities. At the same time, contribute to the developmentof regional communities through your business.
【Commentary】Carry out activities to reduce health, safety. sanitation, etc. hazards in regional
communities caused by the production process or your products and services. At the same time,
contribute to the development of regional communities while maintaining harmonious coexistence
through job creation, capacity building, sales promotion of local products and services, development of
suppliers, volunteer activities by employees, etc.

8．Establishment of Internal Promotion Systems
8-1

Establish promotion systems

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Establish risk management and PDCA cycle implementation systems in related fields and items toenforce this Code of Conduct.
【Commentary】Specifically, establish promotion systems including the ① establishment of a policy for
CSR initiatives, ②appointment of a management system oversight officer, ③ establishment of systems
to respond to local laws and regulations, international laws and customer requests, ④ identification andmanagement of risks, ⑤establishment of targets, ⑥establishment of a training program,⑦dissemination to employees and suppliers, etc. ⑧improvements based on requests from employees,⑨implementation of audits and assessment and corrective measures.

8-2

Establish an internal controls system

Establish a management system or framework to secure business effectiveness and efficiency as acompany, credibility of financial reports, compliance with laws concerning business activities, securityof assets.
【Commentary】To establish an organizational structure to comply with applicable local laws and achievesound business management, build a management system or framework to secure business effectivenessand business efficiency as a company, credibility of financial reports, compliance with laws, etc.
concerning business activities and security of assets.

8-3

Preparedness in case of emergency disasters

Develop a Business Continuity Plan (BCP), presuming possible conditions and events in an emergency.
【Commentary】Be prepared for unforeseen circumstances by identifying possible emergencies andappraising effects of damage, etc. in advance. In addition, establish measures and procedures to minimize
damage to life, the environment and assets and build systems to assure business continuity even in acontingency.

8-4

Establish a whistle blower system

Establish a whistle blower system for employees to safely report or consult compliance problems orhuman rights and labor rights violations inflicted upon them.
【Commentary】Establish a whistle blower system for employees to raise concerns or suspicion ofcompliance problems such as violation of laws and regulations or illegal behavior in company operations
or human rights or labor rights violations inflicted upon them to a dedicated department or an external
contact. Retaliation to the employee who reported or consulted is prohibited.

8-5

Information disclosure
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Actively disclose information and fulfill accountability to stakeholders even if disclosure is notmandatory under laws and regulations, etc.
【Commentary】Respond to requests for transparency or accountability of business operations by societyor stakeholders, actively communicate and disclose information (financial, non-financial information)
inside and outside the company, and fulfill accountability.

＜Communication＞
Make this Code of Conduct accessible by any employee in the company’s business offices in the local
language, disseminate and ensure compliance. We would appreciate your cooperation.

＜Verification of efforts of suppliers＞
To check efforts of suppliers, we may contact external organizations and ask them to answer ourquestions.

＜For inquiries＞
If you should have any questions, etc., please inquire with groups in the Procurement Division of Japan
Airlines, the distributor of this Code of Conduct, or the department below.
Japan Airlines Co., Ltd., Procurement Divisione-mail : purchasing＠jal.com
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