THE MUTOH GROUP
CODE OF CONDUCTMUTOH HOLDINGS CO., LTD.

MUTOH GROUP CODE OF CONDUCTPreface
The MUTOH Group Code of Conduct stipulates the behavioral
criteria that all officers and other employees in our company,
subsidiary companies, and other affiliated companies (hereafterreferred to as the “MUTOH Group”) shall practice with an ethicalsense of values while complying with current laws andregulations.
The MUTOH Group clearly classifies its roles in management
control and business execution. Then, through mutualcooperation based on the following management philosophiesand basic policies, the MUTOH Group shall make its maximum
efforts to improve its business value and to secure efficientmanagement and growth opportunities for the whole Group.

Management Philosophies
In accordance with the Group basic policies upheld below, weshall comply with social ethics and the laws and regulations inJapan and overseas. We shall also commit ourselves to ourcorporate activities based on common sense, to theimprovements of the Group’s business values, to the permanent
maintenance and expansion of the MUTOH brands, and to thehealthy development of the companies.

1Basic Policies[Innovation]
The MUTOH Group shall rapidly respond to the fast-changing
market environments and to always innovate for theimprovement and expansion of the MUTOH brand value.

[Challenge]
In the MUTOH Group, each group company shall focus on
business in its respective fields of proficiency. The Group shallalso aim at improving the business values and at maximizing thesynergistic effects among all Group companies. Each one shallcontinue to challenges new things.

[Contributions]
The MUTOH Group shall contribute to society throughappropriate corporate activities, actively participate in social
contribution activities as a strong corporate citizen, and dedicate
itself to social development.

2Specific Rules(Respect for human rights/prohibition of discrimination)(1) We shall avoid irrational discrimination and harassment against
people based on their birth, race, ethnicity, beliefs, religion, gender, age,physical/mental disabilities, academic background, or other matters.
(2) We shall avoid resorting to violence, yelling, defamation, libel, or
threat to force people to work. We shall also avoid bullying and other suchactions that may violate human rights.
(3) We shall make our decisions regarding employment, transfer, andadvancement based on fair and equitable criteria free from discrimination.

(Sexual harassment)
We shall avoid carrying out any sexual actions and saying any sexual
words that may make people uncomfortable. We shall also avoid carrying out
any action and avoid saying any word or words that might be misinterpreted
as a sexual action or reference. Furthermore, we shall take thoroughmeasures to prevent and ban such actions and words.

(Privacy protection)
Except for valid purposes, we shall avoid using personal informationand other confidential information that we have come to know while
conducting our business regarding our employees and also persons
outside the companies. We shall also strictly manage such information incompliance with laws and regulations to prevent any information of this kindfrom being disclosed and leaked without permission.

(Neutrality regarding political and religious activities)
We shall maintain our workplace neutrality regarding political andreligious activities.

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(Safety and health)
We shall comply with the Labor Standards Law, secure our workplacesafety and health, and make efforts to maintain our workplace and work
environments in ways that will make them efficient, healthful, and pleasant
in which to carry out our responsibilities.

(Disclosure of information for the public interest)
We shall establish a window for information disclosure for the public
interest and thoroughly ensure compliance in the companies.

(Compliance with our work rules)(1) We shall avoid carrying out any prohibited matters stipulated in thework rules and avoid any unfair or insincere actions contrary to work rules.
(2) We shall review the work rules, company regulations, and otherinternal rules while considering our actual business situations and othermatters to make sure they have appropriate contents.
(3) We shall dedicate ourselves to our work and shall make efforts toimprove our corporate value.

(Compliance with the laws/appropriate business operations)(1) We shall comply with the laws and regulations, shall have a basicsocial common sense and a sense of justice, and shall always make efforts
to carry out actions with good common sense so that we do not participate
in illegal or antisocial acts.
(2) We shall obtain social confidence by carrying out appropriate
business activities and make efforts to improve our corporate and brandimages. Moreover, we shall always make efforts to develop and provide
socially useful products and services capable of responding to consumers’needs.

(Appropriate transactions)(1) When we select our business partners among plural vendors, weshall decide the most appropriate ones by fairly comparing and evaluating4

their qualities, prices, due dates, technology development capacities,
stable supplies, and other conditions.
(2) We shall comply with contracts between our business partners andothers, and we shall also carry out appropriate explanations and reports
according to needs.
(3) We shall maintain sincere, modest, and healthy relations withbusiness partners and others. When we receive or offer gifts or businessentertainment, we shall avoid deviating from the boundaries of healthy
commercial customs and social common sense.
(4) We shall avoid bribing public officials and others and refrain fromactions that may be regarded as payoffs to receive business-related unfair
profits. Moreover, we shall establish healthy and transparent relations withpoliticians and public administration authorities.

(Compliance with the Antimonopoly Act, Subcontract Act, and other laws)(1) Under all circumstances we shall avoid carrying out actions that may
result in violating the Antimonopoly Act, and we shall fairly and freely
compete with other corporations in the markets. In particular, we shall pay
full attention to avoid carrying out unfair business activities such as cartels,
bid riggings, resale price maintenance, transactions with unfair restraining
conditions, abuse of superior positions, dumping goods, misleading
representations, and cross-selling.
(2) When business partners are subcontractors, we shall conclude thecontracts and transactions with a full understanding of the Subcontracting
Act while paying attention to avoid unfairly persuading them to lower prices,
declining to receive their products/services, returning their products, latepayments, or similar.
(3) We shall comply with other laws and regulations related to products
and services.

(Fair advertisements)
When we carry out promotional and advertising activities, we shall
avoid using any expression that defames and libels others, and we shall
avoid using any words that may result in social discrimination. Moreover,
we shall avoid exaggerated advertisements that may be contrary to facts.

5(Disconnecting relationships with antisocial groups)(1) We shall firmly respond to antisocial groups and shall avoid having
any relationship with them.
(2) Moreover, when we receive an unfair demand from an antisocialforce, we shall firmly deal with it and shall avoid trying to solve the problem
by giving out money or something similar.
(3) We shall avoid using antisocial forces to obtain profits for ourcompanies. We shall avoid carrying out any transaction with an antisocial
force or with a business partner that has a relationship with an antisocialforce.

(Environmental conservation/protection)
When we research, develop, manufacture, sell, dispose, and conduct
other activities regarding our products, we shall fully recognize theimportanceofenvironmentalprotection.
Weshallcreateenvironmental-friendly products and actively participate in environmentalprotection activities.

(Social contribution activities)
We shall actively carry out social contribution activities, such as culturaland art assistance and cooperate with activities of this kind in local
communities.

(Contributions to the international society)We shall maintain global viewpoints and comply with international rules
and local laws. And by centering on our overseas offices, we shall manage
our companies while respecting local customs and cultures, and we shallcontribute to regional development.

(Assets protection)(1) We shall recognize that company assets need to be efficiently
utilized and kept in conditions in which they can be used at all times. We6shall appropriately care for these assets, tangible or intangible, to prevent
them from being damaged, stolen, or otherwise suffering loss.
(2) The companies’ intellectual property rights shall be our importantcompany assets. We shall appropriately use them and shall make efforts toconserve the rights. Regarding inventions resulting from manufacturing
and development activities, we shall promptly apply for their patents andshall make other efforts to preserve the companies’ intellectual property
rights.
(3) We shall use business partners and others’ intellectual property
rights after concluding appropriate contracts and shall avoid unfairly using
them. In particular, when using others’ software and technologies, we shallcomply with their terms of use stipulated in the contracts, and we shall
avoid carrying out such actions as unauthorized copying that may violate
others' intellectual property rights.

(Appropriate management of corporate secrets)(1) We shall strictly manage our corporate secrets and those of othercompanies, avoid leaking them to outsiders, and avoid using them forpurposes other than our own business purposes.
(2) When disclosing a company’s confidential information to outsiders,
we shall conclude confidentiality agreements and shall make otherpreparations to prevent any unexpected leakage of this information.
(3) We shall not steal other companies’ corporate secrets and shall
avoid using such secrets for purposes other than those designated by theother companies.

(Appropriate information management)(1) Regarding documents that we create during our business
operations, we shall correctly make them based on facts, and we shallappropriately manage them.
(2) We shall maintain our system to save and manage information so as
to appropriately and efficiently use and operate company assets.

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(Management information disclosure)(1) To our shareholders, investors, and others, we shall precisely
disclose our management information such as financial contents andbusiness activity conditions at appropriate times and in appropriate ways.
We shall also clearly communicate our company management
philosophies and policies and sincerely accept opinions and criticisms
regarding these matters.
(2) In writing entries into our accounting books, we shall correctly record
them according to all related laws and regulations and internal regulations.
We shall avoid describing false or fictional matters and building
off-balance-sheet assets.
(3) When we learn undisclosed internal information about ourcompanies, associated companies, or business partners based on ourbusiness positions and business executions, we shall avoid buying or
selling those companies’ shares and corporate bonds until the information
is officially released. Moreover, we shall avoid unfairly using suchinformation and leaking it to outsiders.

(Unfair or illegal competition prevention)(1) We shall avoid obtaining and using other companies’ trade secrets
through unfair or illegal means, such as theft, for whatever reasons.
(2) We shall avoid obtaining and using other companies’ trade secrets
while knowing that they were obtained, or could have been obtained,
through unfair or illegal means.

(Prohibition of competitive work/adverse profits)
We shall avoid participating in business operations and transactions
that may result in producing conflicts of interest with our companies. We
shall also avoid participating in such activities that may damage ourcompanies' credibility and honor and that may cause losses to ourcompanies.

(Product safety)(1) In all the processes of developing our products, such as
manufacturing, storing, exporting, and repairing, and, where applicable,

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products we purchase and import from our suppliers and othermanufacturers, we shall always pay attention to the issues of safety. We
shall also fully understand the laws and safety criteria regarding productsafety, and we shall comply with these matters and constantly aim at higher
safety.
(2) We shall prevent accidents and trouble from occurring orreoccurring by maintaining product quality, by inspections to secure safety,
and by maintaining and correcting the quality inspection system as needed
through cooperation among the respective operational departments. When
we obtain information regarding product safety, we shall immediately confirm
it. Moreover, when a problem affecting safety is discovered, we shallpromptly contact its related department(s) and appropriately and quickly
respond to prevent the difficulties and damages or their possibility fromspreading.

(Security export control)(1) We shall avoid exporting arms, weapons, and related technologies
that may result in hindering the continuity of international peace and security.
(2) When importing and exporting our products or those of others’,
technologies, services, and similar, we shall carry out appropriate export andimport customs procedures according to the Foreign Exchange and Foreign
Trade Law and as prescribed by other related laws and regulations.

Established on 21, 20079