TMR-CSR-G1007-06-E

Guidelines for Responsible Business Conduct
in Supply Chains（Ver.6）

Enactment：March 26, 2007
Revisions ：June 23, 2023（Ver.６）

TMR-CSR-G1007-06-E

1. To Our Trading Partners
The mission (Raison d’être) of the Tamura Group (a corporate group comprised of Tamura Corporationand its subsidiaries, hereinafter referred to as the “Tamura Group”) is for “The Tamura Group supplies an
original range of products and services, highly regarded in the global electronics market, to satisfy the
evolving needs of customers, employees and shareholders supporting the Group’s growth.” The Tamura
Group conducts its business operations based on the following five visions (fundamental management
principles).
Tamura Group Vision
1. The management of the Tamura Group is based on businesses related to
the requirements of the global electronics industry.
2. The business of the Tamura Group is based on technologies that support
rapidly diversifying customer needs, with a special focus on high market
value.
3. The Tamura Group evaluates its employees with fairness and highly rates
excellent performance and exceptional productivity.
4. The Tamura Group is a responsible member of the global community andrespects the laws and customs of the countries in which it conducts
business activities.
5. The Tamura Group strives to protect the global environment, conserve
natural resources and promote recycling.
However, for the Tamura Group to fulfill its social responsibilities and develop its business activities in goodfaith, it is also vital that not only the members of the Tamura Group, but also all our trading partners
understand and share our vision, and that the Tamura Group’s purchasing activities receive the support of our
trading partners.
Here, we request that our trading partners abide by the Guidelines for Responsible Business Conduct in
Supply Chains that we have put forth, and hope that our trading partners will then encourage their suppliers
upstream to implement these guidelines.
Note that, going forward, the Tamura Group will preferentially deal with trading partners who makeproactive efforts for responsible business conduct.

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2. Fundamental Purchasing Principles
The Tamura Group, as a global company that promotes materials procurement from a worldwide perspective,
seeks to attain mutual profit creation with companies that demonstrate an understanding of the Tamura
Group Vision and with which a continuing partnership can be established.

Tamura Group Fundamental Purchasing Principles(1) With regard to quality, the Tamura Group will trade with corporations that have a keen awareness of“putting quality first”, understand the Tamura Group’s quality control principles, and have establishedquality management procedures.
(2) With regard to the environment, the Tamura Group will trade with corporations that are fully aware ofworldwide trends in environment preservation, abide by the Tamura Group Green Procurement
Standards and take the lead in initiatives that consider the environment.
(3) The Tamura Group will trade with corporations that constantly make proactive improvements andreforms in accordance with market demand.
(4) The Tamura Group will trade with specialized manufacturers that have a uniqueness not found in othercorporations.
(5) The Tamura Group will promote the simplification of trade routes.
(6) The Tamura Group will trade with corporations that are proactive in providing opinions, proposals andinformation, and conduct their activities with enthusiasm.
(7) The Tamura Group will trade with corporations that consider human resources as a company asset, arepassionate about employee education and training, and strive to improve the corporation on the whole.

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3. Regarding the Application of these Guidelines(1) Submission of Self-Evaluation Sheet and Agreement Form
As a rule, we request that our trading partners submit the self-evaluation sheet regarding the actual stateof their efforts to follow these guidelines once a year. In addition, if a significant change to the content
described in the submitted self-evaluation sheet occurs, we request that our trading partners submit
another self-evaluation sheet at that time. Regarding the agreement form, we request this to be submitted
when commencing continuous transactions with the Tamura Group.
(2) Initiatives for Improvement
Based on the results of the submitted self-evaluation sheet, we might request a trading partner for theircooperation to improve the situation.

4. Other Matters
These guidelines are revised as necessary depending on changes in the social situation, new knowledge, andother factors.
In addition, if there is a strong request from a stakeholder to ascertain the status of initiatives for anindividual theme related to responsible business conduct, we might separately request cooperation to act inaddition to submitting a self-evaluation sheet.

These guidelines and the self-evaluation sheet comply with the Responsible Business Conduct Guidelines
issued by the Japan Electronics and Information Technology Industries Association (JEITA).

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Guidelines for Responsible Business Conduct in Supply Chains / Contents
Section 1 : Code of Conduct
1. Respecting the Laws and Internationally
Recognized Standards ·························· 6

5. Fair Trading and Ethics ····················· 8(5-1) Preventing Corruption ················· 8(5-2) Prohibiting Inappropriate Provision
and Improper Benefit ·················· 8(5-3) Fair Information Disclosure ·········· 8(5-4) Respecting Intellectual Property ··· 8(5-5) Conducting Fair Business ············· 8(5-6) Protecting Whistleblowers ············ 9(5-7) Responsible Minerals Procurement················································· 9

2. Human Rights and Labor ·················· 6(2-1) Prohibiting Forced Labor ·············· 6(2-2) Prohibiting Child Labor andRespecting the Rights of Young
Workers ······································ 6(2-3) Decent Working Hours ·················· 6(2-4) Adequate Wages and Allowances ···· 6(2-5) Prohibiting Inhumane Treatment ··· 6(2-6) Prohibiting Discrimination ············ 6(2-7) Freedom of Association and Right toCollective Bargaining ··················· 6

6. Quality and Safety ···························· 9(6-1) Ensuring Product Safety ·············· 9(6-2) Quality Management ··················· 9(6-3) Providing Accurate Information on
Products and Services ·················· 9

3. Health and Safety ···························· 7(3-1) Occupational Safety ······················ 7(3-2) Emergency Preparedness ·············· 7(3-3) Occupational Injury and Illness ····· 7(3-4) Industrial Hygiene ······················· 7(3-5) Physically Demanding Work ·········· 7(3-6) Machine Safeguarding ·················· 7(3-7) Health and Safety at Facilities ······ 7(3-8) Health and Safety Communication · 7(3-9) Worker Health Management ·········· 7

7. Information Security ························· 9(7-1) Defense from Cyber Attacks ·········· 9(7-2) Protecting Personal Information···· 9(7-3) Preventing Leak of Confidential
Information ································ 9
8. Business Continuity Planning ············ 9(8-1) Developing and Preparing a
Business Continuity Plan ············· 9

4. Environment ··································· 7(4-1) Environmental Permits andReports ······································· 7(4-2) Reducing Energy Consumption andGreenhouse Gas Emissions ··········· 8(4-3) Air Emissions ······························ 8(4-4) Water Management ······················ 8(4-5) Effective Utilization of Resources
and Waste Management ················ 8(4-6) Chemical Substance Management ·· 8(4-7) Managing the Chemical Substances
Contained in Products ·················· 8

Section 2 : Establishing a Management
SystemA. Establishing a Management System····················································· 10
B. Supplier Management. ····················· 10
C. Proper Import/Export Control ··········· 10
D. Establishing a Grievance Mechanism····················································· 10
E. Disclosing the Activities ··················· 104TMR-CSR-G1007-06-E

Annex
Section 1 : Description of Code of Conduct
1. Respecting the Laws and International
Standards ·······································115. Fair Trading and Ethics ···················· 23(5-1) Preventing Corruption ················ 23(5-2) Prohibiting Inappropriate Provision
and Improper Benefit·················· 23(5-3) Fair Information Disclosure ········· 24(5-4) Respecting Intellectual Property ·· 24(5-5) Conducting Fair Business ············ 24(5-6) Protecting Whistleblowers ··········· 24(5-7) Responsible Minerals Procurement················································ 25

2. Human Rights and Labor ·················11(2-1) Prohibiting Forced Labor ············ 11(2-2) Prohibiting Child Labor andRespecting the Rights of Young
Workers ···································· 12(2-3) Decent Working Hours ················ 14(2-4) Adequate Wages and Allowances ·· 15(2-5) Prohibiting Inhumane Treatment · 16(2-6) Prohibiting Discrimination ·········· 16(2-7) Freedom of Association and Right toCollective Bargaining ················· 17

6. Quality and Safety ··························· 25(6-1) Ensuring Product Safety ············· 25(6-2) Quality Management ·················· 26(6-3) Providing Accurate Information on
Products and Services ················· 26

3. Health and Safety ·························· 18(3-1) Occupational Safety ···················· 18(3-2) Emergency Preparedness ············ 19(3-3) Occupational Injury and Illness ··· 19(3-4) Industrial Hygiene ····················· 20(3-5) Physically Demanding Work ········ 20(3-6) Machine Safeguarding ················ 20(3-7) Health and Safety at Facilities ···· 20(3-8) Health and Safety Communication················································ 21(3-9) Worker Health Management ········ 21

7. Information Security ························ 26(7-1) Defense from Cyber Attacks ········· 26(7-2) Protecting Personal Information··· 26(7-3) Preventing Leak of Confidential
Information ······························· 27
8. Business Continuity Planning ··········· 27(8-1) Developing and Preparing a
Business Continuity Plan ············ 27
Section 2 : Description of Establishing aManagement System
A. Establishing a Management System····················································· 28
B. Supplier Management ······················ 29
C. Proper Import/Export Control ··········· 30
D. Establishing a Grievance
Mechanism ···································· 30
E. Disclosing the Activities ··················· 31

4. Environment ································· 21(4-1) Environmental Permits andReports ····································· 21(4-2) Reducing Energy Consumption andGreenhouse Gas Emissions ········· 22(4-3) Air Emissions ···························· 22(4-4) Water Management ···················· 22(4-5) Effective Utilization of Resources
and Waste Management ·············· 22(4-6) Chemical Substance Management 23(4-7) Managing the Chemical Substances
Contained in Products ················ 23

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Section 1
Code of Conduct
１ Respecting the Laws and Internationally Recognized Standards
Companies must respect internationally recognized standards in addition to complying withthe laws and regulations of their home country as well as countries and regions where they
conduct business.
２ Human Rights and Labor
Companies must respect the rights of workers in line with international human rights
standards including the ILO core labor standards in addition to complying with relevant laws
and regulations.
（2-1） Prohibiting Forced Labor
Companies must not use labor obtained by forced, bonded, exploitative prison labor, slavery, or
human trafficking. Companies also must not force to work, and must keep the right of workers
to terminate employment.
（2-2） Prohibiting Child Labor and Respecting the Rights of Young Workers
Companies must not allow children who are under the minimum age for employment.
Furthermore, companies must also not allow young workers under the age of 18 to performhazardous work that is likely to jeopardize their health or safety, including night work or
overtime.
（2-3） Decent Working Hours
Companies must not allow workers to work exceeding the maximum working hours set by local
laws and regulations, and appropriately manage working hours and days off in consideration ofinternationally recognized standards.
（2-4） Adequate Wages and Allowances
Companies must comply with all applicable laws and regulations regarding payments of work
(including minimum wage, overtime payments, and allowances and deductions required by law).
Furthermore, it is expected that companies pay wages at a level that allows workers to support
their basic needs (a living wage).
（2-5） Prohibiting Inhumane Treatment
Companies must respect the human rights of workers and must not treat workers in a mannerthat is or may be construed inhumane, including physical and psychological abuse, coercion, or
harassment. Companies must also provide workers with individually secured accommodations
for storing their personal and valuable items, and a reasonable personal space along withreasonable entry and exit privilege.
（2-6） Prohibiting Discrimination
Companies must not engage in discrimination or harassment. Companies must also consider
requests from workers regarding religious practices where appropriate.
（2-7） Freedom of Association and Right to Collective Bargaining
In conformance with local laws and regulations, companies shall respect the right to collective
bargaining of workers and openly communicate with workers for improving working
environments and wage conditions.

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３ Health and Safety
In addition to complying with relevant laws and regulations, Companies must takeconsideration of standards such as ILO health and safety guidelines to minimize injury andillness in the workplace and maintain a safe and healthy working conditions.
（3-1） Occupational Safety
Companies must identify and assess risks regarding occupational safety and maintain safety
through proper design, engineering and administrative controls. Taking reasonable steps mustalso be taken to protect pregnant women and nursing mothers.
（3-2） Emergency Preparedness
Companies must identify the possibility of emergency situations by such as natural disasters or
accidents that may adversely affect human life or safety, establish procedures in case of
emergency to minimize harm to workers and property, install the required equipment, andconduct training and drills so that the required responses can be taken in case of emergency.
（3-3） Occupational Injury and Illness
Companies must identify, assess, record, and report the status of occupational injury andillness, and implement appropriate countermeasures and corrective actions.
（3-4） Industrial Hygiene
Companies must identify, assess, and appropriately control the risk of workers being exposed tohazardous biological, chemical, or physical agents in the workplace.
（3-5） Physically Demanding Work
Companies must identify and assess worker exposure to the hazards of physically demanding
tasks and appropriately control such work so that it does not lead to occupational injury andillness.
（3-6） Machine Safeguarding
Companies must evaluate the machinery used by workers for safety hazards and provide
appropriate safeguarding.
（3-7） Health and Safety at Facilities
Companies must appropriately maintain the health and safety of facilities and accommodations
provided to workers (such as dormitories, cafeterias, and toilets). Dormitories also requireappropriate emergency egress to be provided.
（3-8） Health and Safety Communication
Companies must provide training on appropriate health and safety information regarding
various workplace hazards that workers are exposed to in the workplace in languages andmethods that the workers can understand. A system that enables workers to provide feedbackon safety is also required.
（3-9） Worker Health Management
Companies must conduct appropriate health management for all employees.
４ Environment
Companies must actively address environmental problems such as resource depletion, climatechange, and pollution, as well as address regional environmental problems considering thehealth and safety of its relevant local community.
（4-1） Environmental Permits and Reports
Companies must obtain the permits and approvals required for conducting business as well as
register and report according to local laws and regulations.

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TMR-CSR-G1007-06-E（4-2） Reducing Energy Consumption and Greenhouse Gas Emissions
Companies must address energy efficiency and make continuous efforts for reducing
greenhouse gas emissions and energy consumption. For that reason, we will actively use
renewable energy.
（4-3） Air Emissions
Companies must comply with relevant laws and regulations and implement appropriate
measures for reducing the emission of hazardous substances to the atmosphere.
（4-4） Water Management
Companies must comply with laws and regulations, monitor the source, usage, and discharge ofwater used, and save water. All wastewater must be tested as required, and monitored,
controlled, and processed before discharge or disposal. Sources of pollution that may cause
water pollution must also be identified and appropriately managed.
（4-5） Effective Utilization of Resources and Waste Management
Companies must comply with laws and regulations and implement appropriate management inorder to promote the 3Rs (reduce, reuse, and recycle), ensure the effective utilization of
resources, and minimize waste.
（4-6） Chemical Substance Management
Companies must comply with laws and regulations to identify, label, and manage chemical andother substances posing hazard to humans or the environment, and conduct management toensure safe handling, transport, storage, use, recycling, reuse, or disposal of such substances.
（4-7） Managing the Chemical Substances Contained in ProductsCompanies must comply with all laws, regulations, and customer requests applicable to theprohibition and restriction of specific substances contained in products.
５ Fair Trading and Ethics
Companies must conduct business activities based on high ethical standards in addition tocompliance with the law.
（5-1） Preventing Corruption
Companies must not be involved in bribery, corruption, blackmail, or embezzlement in any
form.
（5-2） Prohibiting Inappropriate Provision and Improper Benefit
Companies must not provide or accept any promises, propositions, or approvals as a means ofobtaining bribes or any other illicit or inappropriate benefit.
（5-3） Fair Information Disclosure
Companies must disclose information regarding labor, health and safety, environmental
activities, business activities, organizational structure, financial situation, and performanceaccording to applicable laws and regulations and industry practices. Falsification of records or
the disclosure of false information is not allowed.
（5-4） Respecting Intellectual Property
Companies must respect intellectual property rights and the transfer of technology andexpertise must be performed in a manner where intellectual property is protected. Companies
must also protect the intellectual property of third parties such as customers and suppliers.
（5-5） Conducting Fair BusinessCompanies must engage in fair business, competition, and advertising.

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TMR-CSR-G1007-06-E（5-6） Protecting Whistleblowers
Companies must protect the confidentiality of information regarding whistleblowing and theanonymity of whistleblowers, and avoid retaliations towards whistleblowers.
（5-7） Responsible Minerals Procurement
Companies must exercise due diligence to ensure that the minerals such as tantalum, tin,tungsten, and gold contained in its products manufactured do not cause or contribute to serious
human rights abuses, environmental destruction, corruption, or disputes in Conflict-Affected
and High-Risk Areas.
６ Quality and Safety
Companies must ensure the safety and quality and provide correct and accurate information on
provided products and services.
（6-1） Ensuring Product Safety
Companies must fulfill their responsibility as a supplier by ensuring that products meet safety
standards stipulated by national laws and conduct design, manufacturing, and sales to ensure
adequate product safety.
（6-2） Quality Management
Companies must comply with their own quality standards and customer requirements inaddition to all laws and regulations applicable to the quality of products and services.
（6-3） Providing Accurate Information on Products and Services
Companies must provide correct and accurate information on products and services that will
not cause misunderstandings.
７ Information Security
Companies must prevent leaks of confidential information and personal information, andenhance information security.
（7-1） Defense from Cyber Attacks
Companies must implement protective measures against threats such as cyber attacks andconduct management to prevent damage to the company and others.
（7-2） Protecting Personal Information
Companies must comply with relevant laws and regulations and appropriately manage andprotect all personal information of suppliers, customers, consumers, and employees.
（7-3） Preventing Leak of Confidential Information
Companies must appropriately manage and protect the confidential information not only of
their own but also received including from customers and third parties.
８ Business Continuity Planning
Companies must make preparations to ensure that they can quickly resume business activities
in order to fulfill their responsibility of supply in the event that the company or a business
partner becomes a victim of such as a large-scale natural disaster.
（8-1） Developing and Preparing a Business Continuity Plan
Companies must identify and assess risks to business continuity, examine their impact on thebusiness, and establish preparatory measures required in the medium to long term and abusiness continuity plan (BCP) that indicates the status of those initiatives.

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Section 2
Establishing a Management System
Ａ Establishing a Management System
Companies must establish a management system in order to comply with the code of conduct in
Section 1.
Ｂ Supplier Management
Companies must establish a process for communicating the requirements of the code of conduct
in Section 1 to suppliers and monitoring supplier compliance.
Ｃ Proper Import/Export Control
Companies must maintain a clear management system and conduct appropriate procedures forthe import and export of technologies and goods regulated by law.
Ｄ Establishing a Grievance Mechanism
Companies must establish a grievance mechanism that can be used by stakeholders including
workers and suppliers in order to prevent illicit behavior in their inside as well as throughout
the supply chain.
Ｅ Disclosing the Activities
Companies must disclose information regarding their actions according to these guidelines andrelevant laws and regulations.

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Annex
Section 1: Description of Code of Conduct
1 Respecting the Laws and Internationally Recognized Standards[Code Interpretation]
In recent years, various laws, regulations, and policies regarding the environment, humanrights, and bribery and corruption have been introduced and adopted around the world.
Companies must understand and comply with them. Some laws and regulations also apply
beyond the country where companies are doing their operations. With the globalization of
supply chains and markets, companies are required to ensure compliance with laws andregulations not only in their own company but throughout the supply chain, while also
respecting international standards.
[Description of Terms]
Internationally Recognized standards refer to expectations in the behavior of a socially
responsible organization, guided by customary international law, generally-accepted principles
of international law, and intergovernmental agreements that are universally or
near-universally accepted (including conventions and treaties).
For example, this corresponds to documents such as the Guiding Principles on Business andHuman Rights and Sustainable Development Goals (SDGs) of the United Nations, theGuidelines for Multinational Enterprises of the Organisation for Economic Co-operation andDevelopment (OECD), and the MNE Declaration (Tripartite Declaration of Principles
Concerning Multinational Enterprises and Social Policy) of the International Labour
Organization (ILO).
２ Human Rights and Labor[Code Interpretation]
Worker(s) refers to anyone that works, regardless of the form of employment, including regular
employees, temporary employees, migrant workers, students, contract employees, and directly
hired employees.
International human rights standards to refer include the Universal Declaration of Human
Rights and International Bill of Human Rights of the United Nations and the Core Labor
Standards of the ILO.
（2-1） Prohibiting Forced Labor[Background]In 2021, 50 million people were estimated to be victims of modern-day slavery, including 27.6
million people that were victims of forced labor in the private sector. *Freedom from forcedlabor is a basic human right associated with the right to freely choose one's work. Work shouldmeet with individual expectations and ability, and should be decent.
(*Source: Global Estimates of Modern Slavery: Forced Labour and Forced Marriage, ILO, 2021)[Code Interpretation]
Companies are prohibited from transporting, concealing, employing, transferring, and receiving
people by means of threat, coercion, abduction, or deceit. Having workers pay fees for
employment may also lead to forced labor. Forced work to pay off such a fee is also prohibited.
In particular, there are many reports of migrant workers including foreign workers being forced
to work. When employing foreign workers, those workers must be provided with an employment
contract containing the employment conditions in a language that they can understand, before

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they leave their home country.
Other acts that lead to forced labor include hindering workers from using theirgovernment-issued identification, passport/visa, work permit, or immigration application(except when the law stipulates that someone other than the worker retain such documents) bymeans of concealment or confiscation, or imposing limitations on worker entry/exit to facilities
or movement within facilities.
[Description of Terms]
Forced labor refers to involuntary labor conducted under the threat of penalty, etc. Types offorced labor include the following.
⑴Abusing vulnerabilities (such as employment contracts not in the native language of migrant
workers)⑵Deception (such as employment/labor conditions not explained correctly, or replaced during
employment process)⑶Isolation (such as having workers work in locations that are difficult to access orcommunicate with from the outside)⑷Threats and intimidation (such as penalizing workers for workplace complaints or
demanding that workers pay a fine when they want to terminate employment)⑸Withholding wages (such as delaying wage payments or forcibly storing or putting aside partof wages)⑹Debt coercion (such as workers having debt in order to pay off recruitment fee)⑺Excessive overtime (such as making workers work overtime in excess of what is allowed by
the law or the labor-management agreement)⑻Prohibiting movement (such as restrictions on movement not based on a reason such as
information security or health and safety, or constant monitoring of a dormitory via
surveillance camera)⑼Physical or mental abuse (such as violence, yelling, or sexual harassment)⑽Withholding the original copies of identification (such as when the employer holds the
passport of a worker)
Bonded labor refers to labor that workers cannot voluntarily terminate. This includes cases
where workers are forced to incur debt in order to pay recruitment fee, and not allowing theworkers to leave until that debt is paid.
Exploitation refers to unfair treatment based on the abuse of a superior bargaining position,and exploitative prison labor refers to the act of making prisoners work without paying
adequate wages.
(Modern) Slavery is defined by the United States Department of State as umbrella terms withtrafficking in persons and human trafficking to refer to both sex trafficking and compelled labor.
It is also defined by Modern Slavery Act of 2015 in the United Kingdom as unfair exploitation ofpeople in a forced labor circumstances.
（2-2） Prohibiting Child Labor and Respecting the Rights of Young Workers[Background]
160 million children are working over the world, with about half that number, 79 million, areengaged in hazardous work. One in five children in Africa and one in thirteen children in the
Asia Pacific region are engaged in child labour. This form of exploitation not only violates therights of children, but also leads to vulnerable economic growth and hinders equal development.
(Source : ILO/UNICEF Child Labor: 2020 Global Estimates, Trends and Outlook, 2021)

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TMR-CSR-G1007-06-E[Code Interpretation]
Child labor is prohibited in all circumstances by the ILO and national laws. In particular, there
is a pressing need to immediately address the worst forms of child labor. The Worst Forms ofChild Labour Convention, 1999 (No. 182) of the ILO defines these as the following four forms ofchild labor.
⒜all forms of slavery or practices similar to slavery, such as the sale and trafficking of children,
debt bondage and serfdom and forced or compulsory labour, including forced or compulsory
recruitment of children for use in armed conflict;⒝the use, procuring or offering of a child for prostitution, for the production of pornography orfor pornographic performances;⒞the use, procuring or offering of a child for illicit activities, in particular for the production
and trafficking of drugs as defined in the relevant international treaties;⒟work which, by its nature or the circumstances in which it is carried out, is likely to harm thehealth, safety or morals of children.
Workers (including students etc.) under the age of 18 should be guaranteed satisfactory
working conditions, and The Minimum Age Recommendation, 1973 (No. 146) of the ILO
stipulates the following benefits in particular.
⒜the provision of fair remuneration and its protection, bearing in mind the principle of equalpay for equal work;⒝the strict limitation of the hours spent at work in a day and in a week, and the prohibition of
overtime, so as to allow enough time for education and training (including the time needed forhomework related thereto), for rest during the day and for leisure activities;⒞the granting, without possibility of exception save in genuine emergency, of a minimum
consecutive period of 12 hours' night rest, and of customary weekly rest days;⒟the granting of an annual holiday with pay of at least four weeks and, in any case, not shorter
than that granted to adults;⒠coverage by social security schemes, including employment injury, medical care and sickness
benefit schemes, whatever the conditions of employment or work may be;⒡the maintenance of satisfactory standards of safety and health and appropriate instruction
and supervision.
(Source (Translation from Japanese original): International Labour Standards and Sustainable
Sourcing Handbook Towards the Realisation of Decent Work through the Tokyo 2020 Olympic
and Paralympic Games, ILO 2019)
Due diligence is also required to protect the rights of children.
[Description of Terms]
Child labor refers to any kind of activity or work which, by its nature or the circumstances inwhich it is carried out, is harmful to the intellectual, physical, social and moral development ofyoung people and undermines their education, preventing them from going to school,
constraining them to abandon schooling too soon or requesting them to work and study at thesame time.
(Source (Translation from Japanese original): International Labour Standards and Sustainable
Sourcing Handbook Towards the Realisation of Decent Work through the Tokyo 2020 Olympic
and Paralympic Games, ILO 2019)
Minimum age for employment shall not be less than the age of completion of compulsory
schooling and, in any case, shall not be less than 15 years according to the Minimum Age

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Convention, 1973 (No. 138) of the ILO (during the transitional period, a country whose economy
and educational facilities are insufficiently developed may initially specify a minimum age of 14
years). The age at which employment is allowed also differs according to the nature of labor. In
regard to hazardous work, all countries must set a minimum working age of 18 years. However,such work may be allowed from the age of 16 years in cases where:・National organizations of employers and workers concerned have been consulted beforehand;
・The health, safety and morals of the young persons concerned are fully protected; and・The young persons have received adequate specific instruction or vocational training in therelevant field of activity.
Minimum age for employment
Developed countries
Developing countries
Regular work
15 years
14 yearsHazardous work
18 years
18 years
Light work
13 years
12 years(Source (Translation from Japanese original): International Labour Standards andSustainable Sourcing Handbook Towards the Realisation of Decent Work through the Tokyo
2020 Olympic and Paralympic Games, ILO 2019)
Hazardous work refers to the following.
⒜work which exposes children to physical, psychological or sexual abuse;⒝work underground, under water, at dangerous heights or in confined spaces;⒞work with dangerous machinery, equipment and tools, or which involves the manual
handling or transport of heavy loads;⒟work in an unhealthy environment which may, for example, expose children to hazardous
substances, agents or processes, or to temperatures, noise levels, or vibrations damaging totheir health;⒠work under particularly difficult conditions such as work for long hours or during the night orwork where the child is unreasonably confined to the premises of the employer.
(Source: Worst Forms of Child Labour Recommendation, 1999 (No. 190))（2-3） Decent Working Hours[Background]Studies of business practices clearly link worker strain to reduced productivity, increased
turnover and increased injury and illness.
[Code Interpretation]
Companies are required to assign work hours and grant sleave and rest period based on
applicable laws and regulations. They should also consider internationally recognized
standards.
For example, as in the Hours of Work (Industry) Convention, 1919 (No. 1) and Hours of Work
(Commerce and Offices) Convention, 1930 (No. 30), international standards of the ILO (notratified by Japan) stipulate that weekly work hours must not exceed 48 hours including
overtime, except in emergency or unusual situations. The Weekly Rest (Industry) Convention,
1921 (No. 14) and Weekly Rest (Commerce and Offices) Convention, 1957 (No. 106) (not ratified
by Japan) stipulate that workers must be granted at least one full day (24 hours or longer) off or

14

TMR-CSR-G1007-06-E
longer weekly rest period each week (work must not exceed six consecutive days). Although theHours of Work (Industry) Convention, 1919 (No. 1) and Hours of Work (Commerce and Offices)
Convention, 1930 (No. 30) are important conventions, they are not the up-to-date instrument.
The ILO has also issued Reduction of Hours of Work Recommendation, 1962 (No.116), which
promotes the ratification of Forty-Hour Week Convention, 1935 (No. 47) as the social standards
to achieve (not ratified by Japan).
Several industry standards also set a weekly limit on work hours at 60 hours including
overtime.
[Description of Terms]
Appropriate manage refers to the following:・Annual working days shall not exceed the maximum set by law.
・Weekly work hours including overtime shall not exceed the maximum set by law (excluding
unavoidable times of disaster or emergency).
・Workers shall be allowed the right to paid annual leave, maternity leave, and childcare leave
as stipulated by the law.
・Workers shall be allowed the break time stipulated by the law.
・Physical and mental health checks shall be conducted to ensure the health of workers.
（2-4） Adequate Wages and Allowances[Code Interpretation]
Minimum wage refers to the minimum wage stipulated by laws regarding wages in the country
where the company is doing its operation, and employees must be paid wages at or above theminimum wage. In addition to the legally-binding minimum wage, it is also desirable thatcompanies voluntarily consider a living wage calculated as the wages required to maintain aminimum living standard.
Unfair wage deductions may be deemed to be a non-payment of wages. For example, in the
SA8000 international standard regarding labor and human rights, pay cuts must not be madefor the purpose of discipline, but as an exception, companies are allowed to do so when (1) it isallowed by domestic law and (2) doing so is agreed upon in a collective agreement that was
freely negotiated.
Furthermore, compensation for overtime work must be paid to workers at a rate higher than
the standard pay rate by hour, according to the laws and regulations of the corresponding
region. Upon payments, companies must provide a wage slip that includes information thatenables the breakdown of payments to be checked.
[Description of Terms]
Minimum wage refers to the minimum wage stipulated by laws regarding wages in the country
where the company is doing its operation. This must be paid to workers at the appropriate time
without delay, based on the law where the company is doing its operation.
Living wage refers to a level of wages that meets the needs of a worker and their family andsatisfies the dignity of that worker, according to international standards.
Unfair wage deductions refer to wage deductions that violate laws regarding labor, etc. For
example, companies cannot deduct the cost of uniforms, personal protective equipment required
for work, or the cost of cleaning uniforms from wages. However, this does not include
nonpayment of wages corresponding to time not worked due to worker's late to work or absence.

15

TMR-CSR-G1007-06-E（2-5） Prohibiting Inhumane Treatment[Background]
Inhumane treatment such as sexual harassment and verbal abuse may exacerbate in theworking environment without other people around realizing.
[Code Interpretation]
Companies are required to establish, notify workers and operate a disciplinary policy andhandling procedures, and an internal reporting system (grievance mechanism) for identifying
the facts of inhumane treatment.
Appropriate worker living conditions are required both in terms of human rights and healthand safety, and are explained separately in Item (3-7).
[Description of Terms]
Psychological abuse refers to the act of causing mental or emotional harm throughpsychological violence to others by means, for example, of inhumane expressions or harassment,
neglect, or words that damage one's self-esteem.
Physical abuse refers to violence and work under harsh circumstances.
Coercion refers to the act of forcing others to do something against their will throughintimidation, etc. For example, forcing workers to work overtime.
Harassment refers to the act of making others feel unpleasant due to pestering or bullying. This
includes sexual harassment, sexual abuse, physical punishment, physical or mental oppression,
verbal abuse, and the withdrawal of basic physical comfort (such as chairs or personal
protective equipment).
In addition, it also includes abuse of authority, or pregnancy discrimination and maternity
harassment.
The Violence and Harassment Convention, 2019 (No. 190) of the ILO defines violence andharassment as indicated below.
⒜the term violence and harassment in the world of work refers toa range of unacceptablebehaviours and practices, or threats thereof,whether a single occurrence or repeated, that aim
at, result in, or arelikely to result in physical, psychological, sexual or economic harm,and
includes gender-based violence and harassment;⒝the term gender-based violence and harassment means violenceand harassment directed at
persons because of their sex or gender, oraffecting persons of a particular sex or gender
disproportionately, andincludes sexual harassment.
（2-6） Prohibiting Discrimination[Code Interpretation]
Behavior that may lead to discrimination is not allowed in wages, promotions, rewards, accessto training, hiring, and employment practices, including discrimination based on race, color, age,gender, sexual orientation, gender identify and expression, ethnicity or national origin,disability, pregnancy, religion, political affiliation, union membership, veteran status, protected
genetic information, or marital status.
Furthermore, health checks and pregnancy tests are also regarded as discrimination if they
could harm equal opportunity or the fairness of treatment.
The grounds of discrimination are diverse.
・Race and color: Discrimination made on the basis of belonging to a specific ethnic group,
which may affect ethnic minorities, indigenous peoples, or tribal populations.
・Sex: Discrimination on the basis of biological characteristics and functions that distinguish

16TMR-CSR-G1007-06-E
men and women and of social differences between men and women. It also includes
discrimination on the basis of marital status, family structure, or motherhood.
・Religion: Discrimination on the basis of membership to a certain religion or expression ofreligious belief. It also includes discrimination against atheists.
・Political opinion: Discrimination on the basis of different opinions with respect to establishedpolitical principles, membership to a particular political party, political or sociopolitical
attitudes, civic commitment, or moral qualities.
・National extraction: Discrimination on the basis of a person's birthplace, ancestry or foreign
origin. It may target national or linguistic minorities, nationals who have acquired theircitizenship by naturalization, and the descendants of migrants from other countries, etc.
・Social origin: Discrimination on the basis of social class, occupational category, or caste.
Social origin may affect one's career.
(Source (Translation from Japanese original): International Labour Standards andSustainable Sourcing Handbook Towards the Realisation of Decent Work through the Tokyo
2020 Olympic and Paralympic Games, ILO 2019)
The principle of non-discrimination in respect of employment and occupation comprises theprinciple of equal remuneration for men and women who accomplish work of equal value.
According to the Equal Remuneration Convention, 1951 (No. 100) of the ILO, the principle
refers to all the elements of remunerations, such as salary or ordinary wage and other basic
fees, directly or indirectly paid, in cash or in kind, by the employer to the worker arising out of
the employment (Convention No. 100). Objectively determining the value of work requires theconsideration of the elements such as work components, responsibilities, skills, efforts, working
conditions, and major achievements.
(Source (Translation from Japanese original): International Labour Standards andSustainable Sourcing Handbook Towards the Realisation of Decent Work through the Tokyo
2020 Olympic and Paralympic Games, ILO 2019)
Discrimination can also be based on factors such as age or disability, health (in particular
HIV/AIDS), membership of a labor union, and sexual orientation. In the United States, thefollowing factors must also be considered.
・Veteran status: United States law defines the covered veteran status as a veteran of theVietnam war, and defines employment measures, consideration, and protection. This is because
veterans are thought to face discrimination based on inability to communicate with otherworkers due to being treated as a murderer, as well as disorders due to military service (such as
post-traumatic stress disorder (PTSD)).
*Information on covered veteran status: https://www.dol.gov/ofccp/regs/statutes/4212.htm
・ Protected genetic information: In the United States, GINA (Genetic Information
Nondiscrimination Act of 2008) defines genetic information as the results of genetic diagnosis.
Genetic information is given as a factor for discrimination due to the possibility of
discrimination based on genetic information such as the latent risk of disease.
*Information regarding the Genetic Information Nondiscrimination Act of 2008:https://www.eeoc.gov/laws/types/genetic.cfm（2-7） Freedom of Association and Right to Collective Bargaining[Code Interpretation]
Companies are also required to respect the right of workers to establish and join trade unions of
their own choosing, and at the same time respect the rights of workers not to join a trade union17

TMR-CSR-G1007-06-E

or refrain from such activities. Furthermore, workers and their representatives must be able toengage in collective bargaining to formally gain mutual understanding with management
regarding concerns about working conditions and management practices, without fear of
discrimination, retaliation, intimidation, or harassment.
[Description of Terms]
In regard to Collective Bargaining, the Right to Organise and Collective Bargaining Convention,
1949 (No. 98) of the ILO requires that companies recognize representative organizations of theworkers for the purpose of collective bargaining, promote bona fide negotiations between bothsides, and incorporate provisions for dispute resolution into collective agreements. The
following items are recommended as concrete examples of relevant corporate activities.
・Provide such facilities as may be necessary to establish effective collective agreements.
・Enable duly authorized representatives of workers to negotiate with representatives ofmanagement who are authorized to take decisions on the matters under negotiation.
・Not threaten or suggest retribution to influence unfairly negotiations or hinder the exerciseof the right to organize.
・Provide information required for meaningful negotiations.
・When requested by the government, respond constructively with relevant information on
their operations.
(Source: The ILO Tripartite Declaration of Principles concerning Multinational Enterprises
and Social Policy (Paragraph 47 to 63))
３ Health and Safety[Code Interpretation]
Minimizing work-related injury and illness and maintaining a safe and healthy working
environment leads to quality of products and services, consistency of production, and worker
retention, and morale. Moreover, it is essential for companies to have worker input and provide
workers with training in order to identify and resolve safety and health problems in theworkplace.
The Guidelines on occupational safety and health management systems (ILO-OSH 2001) of the
ILO and recognized management systems such as OHSAS18001 and ISO45001 were referred towhen establishing these guidelines and may contain additional useful information.
（3-1） Occupational Safety[Code Interpretation]
Companies must identify safety hazards in the workplace and their risk of occurrence, andimplement safety measures for workers. Examples of safety hazards in the workplace include
contact with chemical substances, electricity, or other energy sources, fire, vehicular accidents,and fall hazards. Example safety measures are indicated below. Companies mustsystematically promote such measures.
・Identifying and assessing safety hazards, including their risk of occurrence
・Designing an appropriate workplace that eliminates safety hazards and considers safety
・ Implementing safety communications (including the handling of personal protective
equipment) It is also necessary to take reasonable measures to protect pregnant women andnursing mothers from conditions with high hazards.

18

TMR-CSR-G1007-06-E[Description of Terms]
Risks regarding occupational safety refer to the potential risk of health problems and accidents
that occur during work, due to factors such as electricity or other energy, fire, vehicles ormoving objects, floors that are slippery or prone to tripping, and falling objects.
Proper design, engineering, and administrative controls refer to the elimination or reduction ofrisks according to the hierarchical control of (1) Elimination of risk factors or substitution tosafer options, (2) Engineering control (such as monitoring dangerous places using sensors andshutting down the power source of machinery or equipment (lock out)), (3) Administrative
control (such as signs indicating prohibition of energy shutdown equipment operation during
shutting down of the power source (tag out)), and (4) Providing personal protective equipment(safety gear such as protective goggles, helmets, and gloves).
Reasonable steps to protect pregnant women and nursing mothers from conditions with highhazards includes avoiding risks such as lifting/moving heavy objects, exposure to infectious
diseases, exposure to lead, exposure to poisonous chemical substances, physically demanding
work, exposure to radioactive substances, threats of violence, long work hours, extreme
temperatures, and extreme noise. For one year after childbirth, if it is necessary for a worker tonurse a child, it is desirable for a company to provide an appropriate break time for nursing or
milking, and to implement measures such as providing a safe and clean place to do so, thatcolleagues and the general public cannot enter and cannot see.
（3-2） Emergency Preparedness[Background]
Evacuation routes are sometimes not accessible in times of emergency by locks and obstacles.
Workers are dying by inhalation of flame and smoke or falling and jumping down in case of fire
accident occurs because they cannot escape from a building. That is why it is important toensure an evacuation route that enables workers to escape, to maintain systems that all
workers surely can evacuate in safe and to conduct adequate evacuation drill.
[Code Interpretation]
Emergency plans refer to, for example, emergency reporting, communication to employees,
clarifying evacuation procedures, installing evacuation equipment, ensuring easily identifiable
exits without obstruction, providing appropriate exit facilities, storing medical supplies for
emergency, installing fire detection systems, installing fire extinguishers, fire shutters, andsprinklers, securing external communication methods, and maintaining recovery plans.
Dissemination of emergency plans within the workplace is also required. This involves, forexample, providing emergency training (including evacuation drill) to workers, and placing/
posting emergency procedures in the workplace in an easily accessible location.
（3-3） Occupational Injury and Illness[Background]Companies must prioritize worker health and safety and also consider occupational injury.
[Code Interpretation]
Companies must record occupational injury and worker illness, provide necessary medical
treatment, investigate cases, identify and eliminate causes, implement corrective actions
including preventing, managing and reporting. It is also necessary to define rules for promoting
worker's return/restart to work and to report implementation thereof.

19

TMR-CSR-G1007-06-E[Description of Terms]
Appropriate countermeasures refer to systems and measures for promoting worker's reporting,classifying and recording injury and illnesses, providing medical treatment when necessary,investigating injury and illnesses, implementing corrective actions to eliminate causes, andfacilitating worker's return to work. This also includes implementing the required
administrative procedures stipulated by the law and taking out industrial accident insurance.
（3-4） Industrial Hygiene[Code Interpretation]
The possibilities of hazard must be eliminated or controlled according to the appropriate designand engineering and administrative control. When hazard cannot be adequately controlled
through such methods, it is necessary for workers to be provided appropriate personal
protective equipment that is well managed and maintained, and to use that equipment
appropriately.
[Description of Terms]
Hazardous agents include substances that are poisonous, radioactive, or cause chronic illness(such as lead and asbestos). These substances may exist in smoke, steam, mist, or dust form.
Noise and odors may be deemed hazardous to the human body if they are significantly strong.
Appropriate control refers to the establishing and implementing management standards, andproviding the appropriate training and personal protective equipment to workers.
（3-5） Physically Demanding Work
[Description of Terms]
Physically demanding work includes long hours of work in an unnatural position, long hours ofrepetitive or continuous work such as data entry or assembly work that causes physicalexertion, and heavy labor such as the manual handling of heavy raw materials or manualtransport of heavy objects.
Appropriate management includes providing working circumstances based on humanengineering, regular breaks, providing supportive tools, and the sharing and coopering works
among multiple workers. (It is also effective to maintain circumstances that enable people tomove around properly and efficiently, and consider the reduction of accidents and mistakes.)
Ergonomics, or Human Factors is a field of research utilized in the actual design of objects andenvironments to ensure that humans can use them in as natural state as possible and withmovements as naturally as possible. (This also includes the reduction of accidents and mistakes
by maintaining circumstances that enable people to move around correctly and efficiently.)（3-6） Machine Safeguarding[Description of Terms]
Appropriate safeguarding refers to management for preventing injuries and accidents that
occur during work, safety mechanisms such as failsafe, foolproof, interlock, and tagout, andprotective barriers in place, as well as regular inspection and maintenance of machinery.
（3-7） Health and Safety at Facilities[Code Interpretation]
Maintaining health and safety refers to maintaining the cleanliness and sanitation of facilities,
and requires the following points to be considered.
・Drinking water: Water quality tests compliant with laws and regulations, and safe drinking
water (provided by a water cooler, etc.)
・Sanitary food preparation: Clothing cleanliness and health checks for kitchen workers, pest

20

TMR-CSR-G1007-06-E
control, temperature control of food storage, effective cafeteria business licenses, etc.
・Toilets: Clean toilet facilities of a sufficient number, providing toilet paper, etc.
・Dormitories: Fire response plan, emergency exit routes (egress), secured accommodations forstoring personal items (providing lockable storage), adequate living space (3.3 m2 or more perperson), ventilation, temperature control, adequate lighting, etc.
（3-8） Health and Safety Communication[Code Interpretation]
Companies must provide appropriate workplace health and safety information and training
regarding all the workplace hazards that workers will be exposed to (including but not limited
to machinery, electricity, chemicals, fire, and physical hazards). Occupational health and safety
information should be clearly posted in facilities or placed in a location identifiable andaccessible by workers. It also must be provided in a language that the workers can understand.
Training must be provided to all workers before starting work and regularly after that. It is also
encouraged that safety concerns from workers are raised. Items for training include the correct
use of personal protective equipment, emergency response measures, safe operation ofmachinery, and preparations before entering hazardous environments. Paragraph 43 of the ILO
Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy also
contains information concerning the fostering of a preventative culture based onlabor-management dialog.
（3-9） Worker Health Management[Description of Terms]
Appropriate health management refers to conducting health checks at least at the levelstipulated by law, and working on the prevention and early detection of worker illness. It is also
necessary to adequately consider treatment such as mental healthcare and the prevention ofhealth problems due to overwork.
４ Environment[Code Interpretation]
The responsibility to consider the environment refers to the promotion of measures forminimizing negative impacts on regional society, the environment, and natural resources, andprioritize maintaining the health and safety of not only workers, but all people in the local
community.
Recognized management systems such as ISO14001 were referred to when establishing theseguidelines, and may contain additional useful information.
（4-1） Environmental Permits and Reports[Code Interpretation]
Examples in Japan include the obligation to assign a manager that has obtained thequalifications stipulated by the law, such as laws on waste disposal (a specially-controlledindustrial waste manager), energy saving (an energy manager in plants that use a certain levelof energy), and the control of air pollution (a pollution prevention manager at plants that emit
chemical substances, dust, or smoke).
Furthermore, companies may be obligated to assign a manager responsible for poisonous/
deleterious substance management, designated chemical substance management, andhazardous substance management, depending on the chemical substances used in business.
It may also be necessary to receive permission for facilities that handle hazardous substancesand environmental impact assessments, depending on the type of business conducted and thelocation of plants.

21

TMR-CSR-G1007-06-E（4-2） Reducing Energy Consumption and Greenhouse Gas Emissions[Code Interpretation]
Improving energy efficiency involves minimizing energy consumption and the related scope 1
and scope 2 greenhouse gases (GHG), and companies must track and document energy
efficiency at each facility or business site. In addition, controlling global warming cannot be
achieved through our own efforts alone, it is necessary to also make efforts to understand andcontrol upstream and downstream emissions related to our business activities from othercompanies.
[Description of Terms]
There are various types of greenhouse gases, but the term greenhouse gas generally refers to
the six groups of substances defined in the Kyoto Protocol, which are carbon dioxide, methane,
nitrous oxide, HFC, PFC, and SF6.
Continuous efforts for reducing greenhouse gas emissions refer to the process of setting
voluntary reduction targets for the above six types of greenhouse gases, and making andexecuting plans to achieve them.
Scope 1 greenhouse gas emissions are direct emissions caused by a company, and scope 2
greenhouse gas emissions are indirect emissions caused by the use of electricity, heat, andsteam provided by another company. Scope 3 greenhouse gas emissions are indirect emissions
not included in scope 1 and 2 (other emissions including upstream and downstream emissions
related to our business activities from other companies).
（4-3） Air Emissions[Code Interpretation]
Hazardous substances discharged to the atmosphere include volatile organic chemicals,
aerosols, corrosives, microparticles, ozone depleting substances, and combustion by-products.
Companies must strive to analyze and monitor these substances prior to discharge, and only
discharge them after conducting the required control and treatment based on the results of thatanalysis and monitoring. Program includes routine monitoring of treatment systems for the
performance and the handling of substances to discharge.
（4-4） Water Management[Code Interpretation]
Water management requires monitoring water sources, use, and discharge, seeking
opportunities to conserve water, and controlling channels of contamination. Controlling
channels of contamination includes confirming that site water channels are free fromcontamination and are protected from contamination (such as confirming that there are no
pools of standing water and grease/oil slicks near storm drains) and that the emergency
response equipment is in place (shutoff valves and stopcocks must be installed to prevent
outflow or leakage of clean water and sewage due to a plant accident or natural disaster, andstreet inlets/sewage inlets and storage reservoirs installed to contain leaks or overflows are
deemed to be insufficient), etc.
（4-5） Effective Utilization of Resources and Waste Management[Code Interpretation]
Companies must identify and manage wastes not identified to be hazardous even when
disposing, implement a systematic approach for responsible disposal or recycling, and work forreducing waste.

22

TMR-CSR-G1007-06-E

Companies must implement measures for disposing substances according to local laws andregulations, and minimizing the disposing substances, and ensure that natural resources are
not wasted.
Programs include changing the production equipment at the source, using alternative
materials, and reusing and recycling resources. Companies should also settle voluntary targets
for the help of complying with laws and regulations. Natural resources refer to water, fossil
fuels, minerals, virgin forest, and the products of virgin forest, etc. The prevention ofenvironmental pollution leads to the saving of natural resources and is closely related to thesustainability of the planet.
（4-6） Chemical Substance Management[Code Interpretation]
In Japan, companies must perform management based on the Chemical Substance Control Law,
Poisonous and Deleterious Substances Control Law, Industrial Safety and Health Act, Fire
Service Act, and PRTR (Law Concerning Reporting, etc. of Releases to the Environment ofSpecific Chemical Substances and Promoting Improvements in Their Management). It is also
necessary to consider chemical substance management in manufacturing processes.
（4-7） Managing the Chemical Substances Contained in Products[Code Interpretation]
Companies must also consider customer demands regarding the chemical substances containedin products.
・Companies must follow the laws and regulations of the countries where the products are sold.
・Companies must take responsibility for the components included in the end products, andupstream companies must provide the required information to downstream companies.
For example, when exporting to the EU, the relevant laws and regulations include the RoHS
Directive and the REACH Regulation.
It is also necessary to consider the substances that are added, contaminated, or adhere during
the manufacturing process.
５ Fair Trading and Ethics[Code Interpretation]
Companies must comply with the laws and regulations not only of Japan but also of all thecountries where they do business. Furthermore, all employees must conduct business withhighest stantards of integrity and obtain trust from all stakeholders, with senior management
setting an example.
（5-1） Preventing Corruption[Code Interpretation]
Companies must uphold a policy of prohibiting any and all forms of bribery, excessive
entertainment or gifts, corruption, blackmail, or embezzlement, and maintain continuous
compliance.
Continuous compliance requires not only establishing policy, but also appropriately training
employees and continuing to ensure that policy is implemented.
（5-2） Prohibiting Inappropriate Provision and Improper Benefit[Code Interpretation]
Companies are prohibited from directly or indirectly providing or receiving something valuable,or promising or proposing to do so, in order to gain business or obtain inappropriate benefit.

23

TMR-CSR-G1007-06-E

It is necessary to clarify policies and procedures and monitor in order to comply with laws
regarding the preventing of corruption.
（5-3） Fair Information Disclosure[Code Interpretation]
Companies are required to actively provide and disclose information to stakeholders. The
information to provide and disclose to stakeholders includes the details of business activities,
financial situation, ESG (environmental, social, and governance) information, risk information(such as damage due to large-scale disasters, adverse impacts on the environment and society,and the discovery of significant legal violations), and information regarding the supply chain.
Disclosing information on critical risks in a timely manner, and communicating to customers
are also one of the examples actively providing information.
Companies are not allowed to tamper records, misrepresent information, or disclose false
information.
（5-4） Respecting Intellectual Property[Code Interpretation]
The protection of intellectual property applies not only to a company, but also to third parties
such as customers and suppliers.
[Description of Terms]
Intellectual property includes trade secrets and technical know-how in addition to intellectual
property rights.
Intellectual property rights are rights defined by law, and include patent rights, utility modelrights, design rights, trademark rights, and copyrights.
（5-5） Conducting Fair Business[Code Interpretation]
Companies must comply with laws regarding fair business, including fair competition andsubcontract law, and must not conduct illegal acts such as cartel agreements to restrict
competition, unfair business practices, or misleading representation.
It is also necessary to avoid forces that pose a threat to the order and safety of civil society, andcomply with laws, regulations, and all social standards. In the catalog presentations andadvertising of products and services, companies must not express untruths or mislead
consumers and customers, and must also make sure not to include information that slanders or
infringes the rights of other companies or individuals.
[Description of Terms]
Fair competition refers to complying with local laws regarding fair competition and fair tradingand promoting free and fair competition while avoiding cartel agreements to restrict
competition, unfair business practices, and misleading representation.
Fair advertising refers to advertising that provides factual information that is not for unfair
purposes.
（5-6） Protecting Whistleblowers[Code Interpretation]
In a grievance mechanism available to related parties including employees of the company andits suppliers, the company must ensure the anonymity of the whistleblower such as the supplieror employee, and the confidentiality of what was reported, and whistleblowers must be
protected from disadvantageous treatment by the company or an individual due to the act ofwhistleblowing.

24

TMR-CSR-G1007-06-E[Description of Terms]
Whistleblowing refers to reporting or disclosing unfair practices in one's company or supply
chain.
Whistleblower refers to a person who reports or discloses inappropriate activity by an employee
or director of a company or a public official or public institution.
Disadvantageous treatment refers to acts that harm the working circumstances includingharassment, as well as changes to working conditions such as unfair performance evaluation,
rewards, dismissal, or reshuffling.
（5-7） Responsible Minerals Procurement[Code Interpretation]
Due diligence regarding responsible minerals procurement refers to companies establishingpolicies, communicating expectations to suppliers (and incorporating them in contracts where
possible), identifying and reviewing risks in the supply chain, and establishing andimplementing strategies to handle the identified risks.
The following five steps are included in the internationally-recognized OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas document regarding due diligence for responsible mineral procurement.
Step1：Establish strong company management systems
Step2：Identify and assess risks in the supply chain
Step3：Design and implement a strategy to respond to identified risks
Step4：Carry out independent third-party auditof smelter/refiner's due diligence practices
Step5：Report annually on supply chain due diligence
Related laws include Section 1502 of the Dodd-Frank Wall Street Reform & Consumer
Protection Act in the United States and the Conflict Minerals Regulation of the European
Union.
６ Quality and Safety[Code Interpretation]
The safety, quality, and accuracy of information on products and services may have a profound
impact on not only customers but a wide variety of stakeholders. Recognized management
systems such as ISO9001 were referred to when establishing these guidelines, and may containadditional useful information.
（6-1） Ensuring Product Safety[Code Interpretation]
When companies design products, they must ensure adequate product safety and consider their
responsibility as a manufacturer when providing products. They must also consider the safetythat the product should ordinarily provide, in addition to legal compliance. Example Japaneselaws regarding product safety include the Electrical Appliance and Material Safety Act,
Consumer Product Safety Act, and Household Goods Quality Labeling Act. Safety standards
are defined in bylaws and JIS standards, etc. Overseas safety standards include UL, BSI, andCSA standards, etc. Effective measures for ensuring product safety include management suchas traceability (history of materials, components, and processes, etc.) and swift handling tosolve problems.

25

TMR-CSR-G1007-06-E（6-2） Quality Management[Code Interpretation]
Companies must comply with all laws and regulations that apply to the quality of products andservices, and are also required to establish appropriate frameworks and management systems
for complying with their own quality standards and customer requirements.
（6-3） Providing Accurate Information on Products and Services[Code Interpretation]
Companies are required to provide information to customers and consumers that is correct,
accurate and does not lead to misunderstandings. They must not provide false information or
information that has been falsified.
[Description of Terms]
Accurate information refers to the following, for example.
・Accurate information regarding the specifications, quality, and handling method of products
and services.
・Accurate information on the substances contained in the materials and components used in
products, etc.
７ Information Security[Code Interpretation]
With the development of the advanced information technology society in recent years,
information management is becoming more and more important. Problems with information
management such as the leak of confidential information and personal information can have a
profound effect on various stakeholders including the supply chain, in addition to the company
itself and its customers. Recognized management systems such as ISO27001 were referred towhen establishing these guidelines, and may contain additional useful information.
（7-1） Defense from Cyber Attacks[Code Interpretation]
Companies are required to prevent trouble caused by cyber attacks, such as the leak or
modification of information and the stopping of information systems. Since attackers can
expand their target of attack based on customer and client information they obtain, the scope ofdamage from cyber attacks is not limited to the company in question. The devices subject tocyber attacks are expanding from conventional computers and servers to industrial systems
and devices part of the IoT (Internet of Things), and countermeasures must also be
implemented for such devices. It is also important to establish a plan for quickest recovery froma remedy of cyber attack. Plans include data back up and redundancy of data server or data
center.
[Description of Terms]
Example of cyber attacks include targeted e-mail that leads to malware infections or malicious
sites, which can cause the leak of personal information, customer information, client
information, and confidential information such as trade secrets, as well as other harm such asimportant files becoming encrypted and held for ransom.
（7-2） Protecting Personal Information[Code Interpretation]
Companies are required to comply with local laws and regulations to carefully handle thepersonal information of suppliers, customers, consumers, and employees. Personal information

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must only be collected, stored, processed, transmitted, and shared within the scope required toachieve the specified purpose it is used for.
[Description of Terms]
Personal information is information regarding a living individual, and contains informationthat enables that particular individual to be identified, such as name, date of birth, or otherattributes (including information that can be easily matched with other information to identify
a particular individual).
Appropriate management refers to establishing and implementing a general management
framework for personal information, and includes establishing rules and policies that workers
must comply with, establishing plans, and implementing of measures, as well as audits andreviews.
Appropriate protection includes preventing personal information from being wrongfully or
unfairly retrieved, used, disclosed, or leaked.
（7-3） Preventing the Leak of Confidential Information[Code Interpretation]
Companies are required to establish an appropriate framework and management system for
managing the confidential information collected by the company or received from third parties.
This includes defining information management levels and employee training.
[Description of Terms]
Confidential information generally refers to information disclosed according to a written
confidentiality agreement (including digital information recorded magnetically or optically) or
information disclosed orally upon confidential notice.
Appropriate management refers to establishing and implementing a general management
framework for personal information, and includes establishing rules and policies that workers
must comply with, establishing plans, the implementing of measures, as well as audits andreviews.
Appropriate protection involves preventing confidential information from being wrongfully or
unfairly retrieved, used, disclosed, or leaked.
８ Business Continuity Planning[Code Interpretation]
The occurrence of large-scale natural disasters such as earthquakes and typhoons as well as
terrorism, riots, infectious disease, and accidents may cause a major impact on business
continuity. Companies must make appropriate preparations for such events to ensure that
production operations can quickly resume, and thereby minimize impact on the supply chain.
Recognized management systems such as ISO22301 were referred to when establishing theseguidelines and may contain additional useful information.
（8-1） Developing and Preparing a Business Continuity Plan
[Code Interpretation]
Business continuity risks include large-scale natural disasters (such as earthquakes, tsunamis,
floods, heavy rainfall, heavy snowfall, and tornadoes) as subsequent power outages, water
outages, and traffic obstructions, accidents (such as fires or explosions), the spread of infectious
and contagious diseases, and terrorism or riots. Advance countermeasures required include
local recovery strategies indicating how to protect, mitigate, and recover the various elements
of production sites from estimated damage. It is also important to secure alternative methods of27

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recovery from damage when it takes longer than expected. Companies must provide continuous
training to employees so that they can act in the event of an actual disaster, and establish amanual for quickly recovering business according to a business continuity plan (BCP).
[Description of Terms]
A business continuity plan (BCP) is a plan created in advance that enables production activities
to be swiftly resumed so that a company can fulfill its responsibility of supply when thecompany or its suppliers are affected by a disaster such as a large-scale natural disaster.
Manual for quickly recovering business is documenting activities from establishing to recovery,
and the process and procedures until recovery is complete.
Section 2: Description of Establishing a Management System
Ａ Establishing a Management System[Code Interpretation]
The following points must be considered when establishing a management system for achieving
the various items in Section 1: Code of Conduct.
・ Whether it complies with the laws, regulations, and customer requirements regarding
business practices and products
・Whether it is according to the content of these guidelines
・Whether it identifies and reduces the risks regarding the content of these guidelines
・Whether continuous improvements can be expected based on the above[Description of Terms]
A management system is establishing a framework for continuous improvements through thePlan-Do-Check-Action (PDCA) cycle regarding policy compliance, implementation systems,
corrective actions, and stakeholder engagement. This is not necessarily for the purpose of
acquiring certification. Furthermore, a management system includes the following.
・Company commitment
・Management accountability and responsibilities
・Legal and customer requests
・Risk identification and risk management
・Improvement objectives
・Training・Communication
・Worker feedback, participation, and grievance・Audits and assessments of identified risks
・Corrective Action Process・Documentation and recording
Examples of well-known management systems are indicated below.
・Health and safety management systems such as ILO Guidelines on occupational safety andhealth management systems, OHSAS18001, and ISO 45001
・Environmental management systems such as ISO 14001 and Eco-Action 21
・Quality management systems such as the ISO 9000 family, IATF16949, and ISO13485
・Information security such as ISO/IEC 27001
・Business continuity such as ISO22301
Due diligence guidelines regarding all corporate conduct include the OECD Due Diligence
Guidance for Responsible Business Conduct. This guidance includes the following six processes.

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TMR-CSR-G1007-06-E⑴ Embed responsible business conduct into policies and management systems⑵ Identify and assess actual and potential adverse impacts associated with the enterprise's
operations, products or services⑶ Cease, prevent and mitigate adverse impacts⑷ Track implementation and results⑸ Communicate how impacts are addressed⑹ Provide for or cooperate in remediation when appropriate
Due diligence is the process enterprises should carry out to identify, prevent, mitigate andaccount for how they address these actual and potential adverse impacts in their own
operations, their supply chain and other business relationships, as recommended in the OECD
Guidelines for MNEs. Effective due diligence should be supported by efforts to embed RBC into
policies and management systems, and aims to enable enterprises to remediate adverse
impacts that they cause or to which they contribute.
(Source: OECD Due Diligence Guidance for Responsible Business Conduct)
The ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social
Policy defines due diligence in the field of labor as indicated below, and emphasizes stakeholder
engagement (the process for actively engaging with stakeholders via dialog, etc. in order toachieve mutually acceptable results as a company fulfills its social responsibility) andharmonization with host country development.
10. (e) In order to gauge human rights risks, enterprises - including multinational enterprises should identify and assess any actual or potential adverse human rights impacts with which
they may be involved either through their own activities or as a result of their business
relationships. This process should involve meaningful consultation with potentially affectedgroups and other relevant stakeholders including workers’ organizations, as appropriate to thesize of the enterprise and the nature and context of the operation. For the purpose of achieving
the aim of the MNE Declaration, this process should take account of the central role of freedomof association and collective bargaining as well as industrial relations and social dialogue as an
ongoing process.
11. Multinational enterprises should take fully into account established general policy
objectives of the countries in which they operate. Their activities should be consistent withnational law and in harmony with the development priorities and social aims and structure of
the country in which they operate. To this effect, consultations should be held between
multinational enterprises, the government and, wherever appropriate, the national employers’
and workers’ organizations concerned. (Source: The ILO Tripartite Declaration of Principles
concerning Multinational Enterprises and Social Policy)
Ｂ Supplier Management[Code Interpretation]
In the Guiding Principles for Business and Human Rights of the United Nations and OECD
guidelines, companies are required to take the same responsibility for CSR in their supply
chain as they do at their own company. Therefore, it is necessary to communicate therequirements in Section 1: Code of Conduct to suppliers, monitor the status of compliance, andpromote improvements.
Supply chain management is covered in Chapter 2 of International Labour Standards andSustainable Sourcing Handbook Towards the Realisation of Decent Work through the Tokyo

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2020 Olympic and Paralympic Games by the ILO. This handbook provides specific examples ofrecommended practices, points of attention for each process, and supply chain management
process, in order to promote the implementation of sustainable supply management according
to international labor standards, particularly regarding aspects of labor and human rights.
・Supply chain management process (role of in-house expertise, etc.)
・Human rights/labor due diligence process for new suppliers, etc.
Preliminary research → on-site due diligence → agreement on action plan → contracting andmonitoring
・Assessing human rights and labor risks
Risk indices/factors, examples of questions to suppliers
・Dialogue/communication with suppliers
Content and method of discussions in dialogue process, interviewees and interviewing
techniques
・On-site occupational safety and health check・Consultation with third parties regarding labor issues
Things to keep in mind for consultation with trade unions, employers' organizations, andNGOs, sources of information, etc.
(Source (Translation from Japanese original): International Labour Standards and Sustainable
Sourcing Handbook Towards the Realisation of Decent Work through the Tokyo 2020 Olympic
and Paralympic Games, ILO 2019)[Description of Terms]
A supply chain refers not only to the process starting from raw materials and to the end when
products and services arrive at the consumers, but all relationships including such as worker
dispatch agents and contractors, regardless of the individual roles of each company.
Ｃ Proper Import/Export Control[Code Interpretation]
Companies must understand and comply with the various national laws and regulations forimporting and exporting. Technologies and goods regulated by law refer to components,
products, technologies, equipment, and software subject to import/export control according tolaws and regulations based on international agreements, etc. (such as the Wassenaar
Arrangement). It may be necessary to obtain permission, etc. from the competent authorities
regarding importing and exporting.
Ｄ Establishing a Grievance Mechanism[Code Interpretation]
In order to comply with Part 1 of the Code of Conduct, in addition to due diligence, it isimportant to establish a grievance mechanism to receive whistleblowing reports fromstakeholders (including workers and suppliers) and to provide relief to the victims, to respondand make corrections, and to enable response to problems as a continuous process. If it isdifficult for your own company to establish a grievance mechanism, one method is to participate
in a collective grievance mechanism.
A fundamental aspect of dealing with complaints is to enter into engagement and dialogue withstakeholders, including whistleblowers. In order for the complaint handling mechanism to30

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function effectively, it is useful to promote understanding among stakeholders who may become
whistleblowers, conduct surveys of awareness to confirm the level of understanding, andinvolved parties and experts in continuous improvement by having them propose advice.
Disclosing information regarding whistleblowing reports is also important in order to increasetransparency and gain credibility for the mechanism.
Furthermore, Principle 31 of the United Nations Guiding Principles on Business and Human
Rights defines the following requirements for grievance mechanisms:
a. Legitimateb. Accessiblec. Predictable
d. Equitablee. Transparent
f. Rights-compatible
g. A source of continuous learning
h. Based on engagement and dialogue[Description of Terms]
A grievance mechanism is a framework that enables related parties to report acts suspected to
be in violation of Section 1: Code of Conduct to promote corrective action For example, asuggestion box, telephone hotline, email address, post on a website, reporting app, or externalorganization commissioned to act as a reporting center may be used.
A collective grievance mechanism is a mechanism that is operated by an industry associationand is open to participation by multiple companies.
It is important that complaints can be lodged via anonymous reporting. Whistleblowers mustnot be treated disadvantageously due to their complaints Example of grievance mechanism
include a suggestion box, telephone, e-mail, or hotline managed by an external organization.
Ｅ Disclosing the Activities[Code Interpretation]
Companies must not only disclose information as stipulated by the law, etc., but also disclose
information regarding efforts for these guidelines to stakeholders including customers.
Examples types of information disclosure include CSR reports and sustainability reports via
company websites and printed media. Guidelines to refer to include GRI Standards andEnvironmental Reporting Guidelines from the Ministry of the Environment.

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Supplier Agreement Form

We request that all trading partners whom received these guidelines sign and submit the Agreement Form.
By signing this Agreement Form, we confirm that all trading partners will supply all parts/materials orservices to the Tamura Group in agreement with all the items and terms within.
*Signatory: The officer in charge or responsible person supervising sustainability activities

Name of Company
Affiliate

Department

andTitle of Signatory
Signatory

Date Signed

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