Makino Milling Machine Co., Ltd
Code of Conduct

March 1, 2022
(Revised Date)
Based on our “Promise of Performance”, we, the officers and employees of Makino, hereby
establish the following as our Code of Conduct. We will always keep in mind the spirit of theCode and promote good business activities that contribute to establishing a sustainable society.
1Compliance with Laws and Regulations
We comply with laws and regulations and internal regulations, and conduct sensible
corporate activities based on social norms.

2

Respect for Human Rights
2.1

Respect for Human RightsWe respect the human rights, society and culture of all individuals associated withour business activities.

2.2

Prohibition of Discrimination
We do not discriminate or allow discrimination against people involved in ourbusiness. We all have the right to be treated equally regardless of the race, ethnicity,gender, age, religion, beliefs, etc.

2.3

Prohibition of Forced Labor and Child Labor
We do not tolerate any human trafficking, slave labor, or any forced labor against thewill of the individual in our business. Also, in accordance with applicable laws andregulations, we will not hire nor permit to work children under the legal working age.
(Minimum working age is 15 years old, and 18 years old for hazardous work which
is likely to jeopardize health or safety.)3

Sensible Corporate Activities
3.1

Sincere Implementation of Agreements
We will fulfill our business contracts in good faith with a relationship of trust.

3.2

Fair Competition
We will maintain fair relationships with all our business partners and competitorsand comply with all relevant laws and regulations.

3.3

Prohibition of Improper Spending

Excessive or inappropriate gifts, entertainment, political contributions, donations,etc. are prohibited in our business. When providing or receiving entertainment andgifts from business partners, we will take great care to ensure that the range ofintention is appropriate.
3.4

Pursuit of Product Safety & Reliability
We will make every effort to ensure that our products are safe and of high quality. In
the event of a problem, we will respond promptly and provide the most suitable
solutions.

3.5

Appropriate Disclosure of Information
We are accurate and prompt in disclosing information about our business andcomply with all applicable laws, rules and regulations.

3.6

Import-Export Compliance Procedures
We will comply with national and regional import and export laws and regulations.

3.7Sound transactions with Subcontractors and Retailers
We outsource and purchase through fair and impartial transactions.
We will not engage in any unfair transactions using our superior position as anordering party.
We will select subcontractors and suppliers that comply with laws and regulations
and fulfill their social responsibilities based on corporate ethics, as well as reliablequality.

3.8

Use and Protection of Intellectual Property (IP)We recognize that our IP is an important corporate asset. We will ensure we properly
manage all such IP and comply with relevant laws, regulations and contractualcommitments.

3.9

Exclusion of Anti-Social Forces
We do not associate and do business with anti-social forces, organizations, andgroups that pose a threat to the social order and security of civil society.

3.10 Ensuring a Wholesome Working Environment
We prevent harassment and ensure a safe and agreeable working environment. We
also respect the right of employees to form and join labor unions and to bargaincollectively on their own initiative in accordance with applicable laws and regulations.
4

Environmental Protection
4.1

Environmental Concerns
We will comply with relevant laws and regulations concerning environmental
protection and carry out Environment-friendly business activities and raiseawareness for taking responsibility of a sustainable society.

5Internal Control
5.1

Misconduct & Prohibition of Conflicts of Interest
We shall comply with all laws, regulations and procedures, make a clear distinction
between public and private matters, and always act in the best interests of thecompany. We will not engage in any conduct that harms the company's assets orinterests by having relationships with business partners, customers, or competitorsthat may conflict with the company's interests.

5.2

Accuracy of Accounting and Financial Disclosure
We create accounting books and records accurately, conduct appropriate accounting
procedures in accordance with generally accepted accounting principles, anddisclose appropriate information in accordance with laws, regulations, and standards.

5.3

Trade Secret Protection
We protect not only our own trade secrets, but also the trade secrets of our businesspartners, in a way to prevent unauthorized use and leakage to third parties.

5.4

Prohibition of Insider Trading
We will not indulge in any form of insider trading.

5.5

Protection of Personal Information
We will strictly comply with Laws and regulations when handling PersonalInformation. The Company will use Personal Information only within the scope of
the purposes permitted for use of Personal Information. The Company willcontinuously take all measures necessary from technical and organizational point ofview to prevent unauthorized access to personal data, loss, destruction, falsificationand leakage. The Company will educate its officers and employees on proper
handling of personal data to prevent from alteration.

5.6

Internal Reporting System and Protection of Informant
In the case we witness any illegal or other problematic activities, we will report themto the appropriate division of the company for early correction. We established aninternal reporting system to ensure such reporting can be carried out appropriately,
and we protect the informant not to be treated disadvantageously.

5.7

Disciplinary Action
We will take appropriate disciplinary action in accordance with internal Rules ofEmployment and other rules against those who have violating the Code of Conduct
and/or committed illegal or problematic acts including fraudulent acts, conflict ofinterest or insider trading.