Maxell Group
Supply-Chain CSR Procurement Guidelines

July 2023
Maxell, Ltd.
Procurement & SCM Business Unit

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Contents
１．Introduction ···························································································· 2
２．CSR Procurement Guidelines ···································································· 4
2.1 Labor ································································································· 4
2.2 Health and Safety ················································································ 5
2.3 Environment ······················································································· 7
2.4 Ethics ································································································ 8
2.5 Quality and Information Security, etc. ······················································10
2.6 Management System ··········································································· 11
2.7 Self-assessment ·················································································12３．Maxell Group Corporate Credo ·································································13
４．Maxell Group Codes of Conduct································································15
５．Maxell Group Policy on CSR Activities and Initiatives ····································16
６．Material Procurement Guidelines·······························································1711. Introduction
In July 2020, the Maxell Group established a corporate philosophy called "MVVSS (MISSION VISION VALUESPIRIT SLOGAN)" (https://www2.maxell.co.jp/corporate/vision.html). In order to realize this corporate philosophy,
there are "Maxell Group Code of Credo" and "Code of Conduct", and under the "CSR Activity Policy" inaccordance with these, the "Supply Chain CSR Procurement Guidelines" are positioned.
Maxell Group Procurement System
Maxell Group
Corporate Credo

Maxell Group Codes ofConduct
Maxell Group Policy on CSR
Activities and Initiatives
Material Procurement
Guidelines

Supply-Chain CSR
Procurement Guidelines

This guideline was established based on the Maxell Group various policies, and the global standards(*) widely
recognized.
(*) The main references are as follows:
・ RBA (Responsible Business Alliance) Code of Conduct 7.0 (2021)
・ JEITA (Japan Electronics and Information Technology Industries Association) Responsible Business Conduct
Guidelines (2020)
・ The Ten Principles of the UN Global Compact
Requests for cooperation from our business partners
What we would like to ask our business partners is to regularly evaluate their implementation status regarding
labor, safety and health, environment, ethics, quality and information security, management systems, etc.
shown in the procurement guidelines and if necessary, we could provide support them. To achieve this, wewould like you to respond to regular questionnaires, issued by our Procurement SCM Headquarters. Until now,
we have only targeted direct material business partners, but from 2023 we will also include equipment-related
business partners. The results of the evaluation will be published annually on the Maxell website.
In addition, for business partners, regularly resulted low ranks of self-assessment evaluation we will ask forsubmission of improvement plans. If you cannot respond to any improvement requests or if issues are notresolved even after a certain period, there is a possibility that we might review our business-partnership, so
please strengthen your efforts within your company.
We have already concluded basic contracts and memorandums on quality with our business partners andhave confirmed chemical substances, but our procurement guidelines are intended to promote improvementwith our business partners beyond the scope, agreed upon in these contracts in the fields, related to SDGs.
SDGs initiatives are demanded from the international society, and the procurement guidelines are revised
based on contributions to SDGs and declare that we will cooperate with our business partners to enhance
corporate value throughout the supply chain.
(Note): Contributions to the SDGs
The Sustainable Development Goals (SDGs) are the set of 17 goals and 169 targets to be resolved on a global
level by 2030. They were unanimously adopted at the United Nations Sustainable Development Summit in
September 2015 by the 193 Member States of the United Nations. Governments from around the world,
including Japan, agreed to these goals. They position companies in every industry as important partners
in achieving the SDGs and call for proactive efforts toward achieving these sustainable development goals.

2The following chart explains the relationship between these guidelines and the 17 SDGs.
Full list of SDGs

Relevant SDGs (and section numbers in these guidelines)
2.2 (8) Management of Employee
Health2.3 (1) Management of Chemical
Substances in Products
2.3 (2) Management of Chemical
Substances Used in
Manufacturing Processes

2.3 (6) Effective Utilizationof Resources and Energy

2.2 (7) Safety and Hygiene ofFacilities

2.3 (7) Reduction ofGreenhouse Gas Emissions

2.1 (1) Prohibition of ForcedLabor

2.4 (1) Prohibition of
Corruption and Bribery, etc.

2.3 (8) Reduction of Waste

2.1 (4) Prohibition ofDiscrimination

32. CSR Procurement Guidelines
Self-assessment-based trade policy• We ask for the cooperation of business partners to confirm the status of CSR initiatives performed bythem. This will be done via a CSR self-assessment questionnaire or via onsite assessments performed byMaxell. New business partners will be required to submit their responses to the questionnaire at the startof trading.
• We request that business partners who receive self-assessment ranks of C Grade or lower in thequestionnaires submit a plan for improvement. If a business partner receives an assessment of D Grade,the Maxell Group will implement measures to correct the situation through communication with thebusiness partner. Future trade may be reconsidered if requests for improvement are not responded to, or
if issues are left unresolved for a certain length of time.
Self-assessment ranks
A GradeB GradeC GradeD Grade2.1 Labor(1) Prohibition of Forced Labor
Employ all employees on a voluntary basis and do not subject any employee to forced labor.
Forced labor refers to all work that is performed against one’s free will. The following are examples of‘being forced’ or ‘being forced to work.’ Forced labor where a worker labors against their free will; bonded
labor where a worker’s ability to leave a job is restricted due to repayment of a debt, etc.; slave labor as aresult of human trafficking; inhumane convict labor where a prisoner works in harsh environments; forcedlabor where a worker does not have the right to leave a job freely; any practice that obliges a worker todeposit their personal identification, passport, or work permit with an employer.
(2) Prohibition of Inhumane Treatment
Respect the human rights of employees and forbid all cruel and inhumane treatment, including abuse andharassment of any kind.
Inhumane treatment refers to such things as abuse, physical punishment, sexual harassment, and power
harassment (verbal abuse and coercion).
(3) Prohibition of Child Labor
Do not employ children under the minimum working age or engage children in work that compromises theirdevelopment.
In general, child labor refers to the employment of children under the minimum working age, as defined inconventions or recommendations of the International Labor Organization (ILO), or neglect of young worker
protections. For example, prohibited child labor in Japan includes employment of anyone under the age of
15 and violation of laws and regulations designed to protect young workers. Examples of laws andregulations designed to protect young workers from employment that may compromise their health, safety,
or morals are restrictions on night-time work and dangerous work. Overseas as well, child labor includes
employment of children under the minimum working age, as defined by each country’s laws andregulations, and violations of child protection obligations. In countries without relevant laws andregulations, child labor is regarded as employment in violation of minimum age conventions andrecommendations of ILO.
(According to ILO Convention No. 138, the minimum age for employment is 15 years old.)(4) Prohibition of Discrimination
Do not discriminate during recruitment or employment and endeavor to achieve equal opportunity and fairtreatment for employees.
Discrimination refers to the creation of differences in opportunities or treatment for employment, promotion,
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compensation, and training participation, etc. using factors other than reasonable factors such as thecapabilities, competence, or achievements of an individual. Examples of this are discrimination on thebasis of race, ethnicity, nationality, birthplace, skin color, age, gender, sexual orientation, disability, religion,
political affiliation, union membership, and marital status. Other examples of discriminatory acts are when
the results of health examinations or pregnancy tests compromise the equal opportunity or fair treatment of
the individual.
(5) Payment of Proper Wages
Pay employees at least the legal minimum wage and do not make improper wage deductions.
Minimum wage refers to the lowest allowable wage as defined in the wage-related laws and regulations ofeach country. This item includes overtime allowances, statutory benefits and other payments. Improperwage deductions refer to wage deductions in violation of labor-related laws and regulations.
(6) Working Hours
Manage employee working hours, rest days, and vacations appropriately to ensure statutory limits on working
hours are not exceeded.
Appropriate management includes the following.
• Not exceeding statutory limits for normal annual working days
• Not exceeding statutory limits for weekly working hours including overtime (excluding emergency
situations)• Providing at least one rest day per week
• Providing the right to annual paid vacation as defined by laws and regulations(7) Right of Employees to Organize
Respect the right of employees to organize as a means of discussing with employers such things as working
environments and wage levels.
Respecting the right of employees to organize refers to giving consideration to such things as freedom of
association, freedom to join labor unions in accordance with laws and regulations, freedom to protest, andfreedom to participate in workers’ councils, without retribution, intimidation, or harassment.

2.2 Health and Safety(1) Safety Measures for Machines and Equipment
Take appropriate safety measures for machines and equipment used at your company.
Appropriate safety measures refer to management to prevent accidents and ill health occurring duringwork. These measures include adoption of failsafe, foolproof, interlocking and other forms of safetymechanisms, installation of safety devices and protective barriers, and regular inspections andmaintenance of mechanical equipment.
(2) Workplace Safety
Conduct assessments of risks to workplace safety and ensure safety through appropriate design, and technicaland administrative controls.
Risks to workplace safety refer to potential risks of accidents or ill health occurring during work due toelectricity and other forms of energy, fire, vehicles, slippery or trip-prone floors, or falling objects, etc.
Examples of appropriate design, and technical and administrative controls, are monitoring of dangerous
locations with sensors, using locks to block (lock-out) power source supplies to machines and equipment,
attaching tags (tag-out) prohibiting operation of energy blocking devices while the power source is blocked,
and providing protective equipment such as protective goggles, hard hats, and gloves. This also includes
providing additional safety considerations for women who are pregnant or raising children, such as moving
them away from highly dangerous working environments and eliminating or reducing occupational healthand safety risks.
(3) Workplace Health
Understand all contact in the workplace with organisms, chemical substances, noises and odors that areharmful to physical health and take appropriate measures.

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Examples of chemical substances that are harmful to physical health include smoke, vapor, mist, dust,
toxic substances, radiation, and substances that cause chronic diseases (lead, asbestos, etc.).
Noises and odors are also included in this item because they can also be harmful to physical health if
particularly loud or strong. Examples of appropriate measures include identifying and assessing
opportunities for direct contact with any of these, establishing and implementing management standards,
and providing appropriate education and protective equipment to employees.
(4) Occupational Accidents and Illnesses
Understand the status of occupational accidents and illnesses and take appropriate measures.
Appropriate measures include systems and measures for facilitating reporting by employees, classifying
and recording accidents and illnesses, providing medical treatment when necessary, investigating any
accidents or illnesses, taking corrective action to eliminate causes, and facilitating the return of employees
back to work (including joining worker’s compensation insurance). These measures also include anynecessary government procedures in line with laws and regulations.
(5) Emergency Responses
Anticipate possible disasters and accidents, prepare emergency responses, and communicate throughout theworkplace to maintain the safety of life and limb.
Emergency responses include reporting during emergencies, notifying employees, clarifying evacuation
procedures, establishing evacuation facilities, storing emergency medical supplies, installing fire detection
systems, installing fire suppression equipment, securing means of external communication, anddeveloping recovery plans. Methods of communicating throughout the workplace include providing
emergency response training (including evacuation drills) to employees and storing or displaying
emergency response procedures and other documents within easy reach in workplaces.
(6) Consideration of Physically Demanding Work
Identify physically demanding work and manage appropriately to avoid accidents or illness.
Physically demanding work includes not only heavy work such as manually carrying heavy objects, butalso assembly, data entry and other repetitive tasks and continuous labor performed for long periods oftime. Appropriate management includes ensuring regular small breaks are taken, providing assistive
devices, and burden sharing and cooperating between several workers.
(7) Safety and Hygiene of Facilities
Ensure appropriate safety and hygiene of facilities provided for the use of employees (dormitories, canteens,
restrooms, etc.).
Facilities provided for the use of employees refer to facilities provided for employees in the workplace(restrooms, water fountains, locker rooms, canteens, etc.), and facilities provided for employees outside of
the workplace (dormitories, etc.). Examples of ensuring safety and hygiene, in addition to maintaining
cleanliness and hygiene, include measures for safe drinking water, fire, air ventilation, temperature control,
emergency escape routes (exits), and secure storage of personal belongings.
(8) Management of Employee HealthAppropriately manage the health of all employees.
Appropriate health management refers to efforts to prevent, and achieve early detection of, employee
illnesses by providing health examinations to at least the levels specified by laws and regulations.
This also requires that sufficient consideration be given to preventing ill health due to overwork andproviding mental health care. As part of occupational health and safety, it is necessary to define policies ofsenior management and work to manage health and productivity. This also includes HR training andinitiatives to obtain certification as a Health and Productivity Management Outstanding Organization from
the Ministry of Economy, Trade and Industry.
(9) Communication of Health and Safety
Provide appropriate health and safety information and training in respect to workplace dangers.
Provide appropriate workplace health and safety information and training, in the mother tongue of
employees or in languages that they can understand, in respect to all workplace dangers (including but notlimited to machine, electrical, chemical, fire, and physical dangers) that employees may encounter. Display
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information related to health and safety within facilities or where accessible by employees. Provide training
to all employees at the time of taking up their post and at other regular intervals thereafter.

2.3. Environment(1) Management of Chemical Substances in ProductsManage chemical substances, as specified in laws and regulations, contained in all products.
Management of chemical substances in products includes, in addition to the products not containing any
chemical substances that are prohibited by laws and regulations, complying with mandatory labelingobligations, and carrying out required testing and evaluations. Refer to the following URL for details.
https://www2.maxell.co.jp/csr/chemical_control/eng_version.html(2) Management of Chemical Substances Used in Manufacturing Processes
Manage chemical substances, as specified in laws and regulations of each country, used in manufacturing
processes.
Management of chemical substances used in manufacturing processes refers to, in addition to managing
chemical substances that must not be included in products, efforts to understand amounts of emissions ofchemical substances into the external environment, report to governments, and reduce emissions of thesubstances.
(3) Environmental Management System
Develop and operate an environmental management system.
An environmental management system refers to a general management system for promoting
environmental activities, with the system including an organizational structure, scheduled activities, adivision of responsibilities, practices, procedures, processes, and management resources. Environmental
activities refer to establishment of environmental policies, implementation of measures in line with thosepolicies, and achievement, review, and maintenance of those measures. They also include continuous
improvement of environmental conservation activities through implementation of PDCA (plan–do–check–act) cycles. A typical example of an environmental management system is the international standard ISO
14001.
(4) Minimization of Environmental Impacts (Wastewater, Sludge, Emissions, etc.)
Comply with laws and regulations of each country in relation to wastewater, sludge and emissions, etc., andapply voluntary standards to achieve further improvements where necessary.
Voluntary standards refer to targets, for reducing environmental burden, that exceed levels specified bylaws and regulations. In addition to preventing pollution, activities to achieve further improvements include
improving monitoring methods, control methods, and treatment methods for such pollutants as wastewater,sludge and emissions, and reducing discharge amounts of each.
(5) Environmental Permits and Government Approvals
Where required by laws and regulations of each country, obtain licenses and approvals from governments andalways submit the required management reports to the governments.
In Japan, laws and regulations specify an obligation to install managers with certain qualifications. These
include special controlled industrial waste managers in the Waste Management and Public Cleansing Act,
qualified energy managers in plants using more than a certain level of energy in the Act on the Rational
Use of Energy, and pollution prevention mangers in plants emitting chemical substances, dust, or soot in
the Air Pollution Control Act, etc. Depending on the chemical substances used in a business, there is also
an obligation to install managers for toxic and hazardous material management, specified chemical
substance management, and dangerous goods management, etc. Depending on the business description
and plant location, government licenses and approvals may be required for environmental impact
assessments and dangerous goods handling facilities, etc.
(6) Effective Utilization of Resources and Energy (3R: Reduce, Reuse, Recycle)
Establish voluntary targets for saving resources and energy and endeavor to effectively utilize resources andenergy on an ongoing basis with consideration given to biodiversity.

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Resource saving refers to efforts to make effective utilization of resources. Ways to achieve this goal
include reducing material usage and waste materials when making products and facilitating the use ofrecycled resources and parts (including water resources). Energy saving refers to efforts to rationalize useof thermal and electrical energy. By conserving the use of energy, it is possible to make more effective useof fuel resources such as oil, natural gas, coal, and coke.
(7) Reduction of Greenhouse Gas Emissions
Establish voluntary targets for reducing greenhouse gas emissions and endeavor to make continuous
reductions.
Greenhouse gases refers to carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons
and sulfur hexafluoride, etc. Continuous reduction activities include establishing voluntary reduction
targets, formulating plans, and actively implementing them in relation to these greenhouse gases.
(8) Reduction of Waste
Establish voluntary targets for reducing final waste materials and endeavor to make continuous reductions.
Final waste materials refer to waste materials that must be buried in landfills or incinerated. Continuous
reduction activities include establishing voluntary reduction targets, formulating plans, and actively
implementing them in relation to these final waste materials.
(9) Disclosure of the Status of Environmental Conservation Initiatives
Disclose the outcomes of environmental activities where required.
Outcomes of environmental activities include measures implemented for environmental conservation,discharges to the atmosphere, wastewater systems, and earth, resource usage, and waste material
volumes, and include harmful impacts on the environment caused by a business site. To ensure regularcollection of outcomes, establish a body and manager for conducting environmental conservation
activities, and continuously record management indicators for the environmental conservation activities,
achievement of objectives, and other important matters related to the environment. Methods of disclosure
include publishing environmental reports and reporting where required to stakeholders.

2.4 Ethics(1) Prohibition of Corruption and Bribery, etc.
Maintain healthy and normal relationships with political and government organizations and make no bribes orillegal political donations, etc.
Bribery refers to offering money, entertainment, or gifts, or providing some other form of benefit oradvantage to public servants or their equivalents with the expectation of receiving some business favor in
return, such as licenses or approvals, obtaining or maintaining business, or access to non-public
information. Bribery also includes offering entertainment or exchanging gifts to public servants or theirequivalents that exceed social norms even without the expectation of receiving some business favor in
return. Illegal political donations include contributions to political organizations with the expectation ofreceiving some business favor in return, such as licenses or approvals, obtaining or maintaining business,or access to non-public information, and contributions to political organizations that do not follow theregular procedures.
(2) Prohibition of Abuse of Dominant Bargaining Position
Do not act in such a way as to cause disadvantage to suppliers by abusing a dominant bargaining position.
Abuse of a dominant bargaining position refers to using a position as a purchaser or outsourcer tounilaterally determine or change trading conditions with suppliers, etc., or to impose unreasonable
demands or obligations. Conduct procurement activities in a sincere, fair and just manner and inaccordance with contracts, etc., and do not act in such a way as to abuse a dominant bargaining position.
In countries with legal restrictions on abuse of a dominant bargaining position, comply with relevant laws
and regulations. (Such laws and regulations in Japan include the Act against Delay in Payment of
Subcontract Proceeds, Etc. to Subcontractors.)(3) Prohibition of Inappropriate Provision or Receipt of Benefits
Do not provide or receive inappropriate benefits in dealings with stakeholders.

8Inappropriate provision or receipt of benefits include the following. Acts in the nature of a bribe, including
providing customers with, or receiving from customers, any free gift, award, or prize money, etc. thatexceeds legally defined limits, and providing or receiving any money, goods, or entertainment that exceedsocial norms; acts to provide inappropriate benefits to anti-social forces (criminal organizations, terrorist
organizations, etc.) that negatively impact public order and healthy activities; insider trading in shares, etc.
of a company based on important non-public information related to the operations of customers, etc.
(4) Prohibition of Acts that Restrict Competition
Do not act in a manner that obstructs fair, transparent, and free competition.
Acting in a manner that obstructs competition includes cartel behavior where companies in the samebusiness mutually agree on prices, volumes, and sales territories, etc. for products and services, andcollusive bidding where bidders determine successful bidders and bidding prices between themselves.
This also includes acts of unfair competition such as obtaining and using another company’s trade secrets
in an illegal manner and making fraudulent claims or claims to mislead customers about anothercompany’s products.
(5) Provision of Accurate Product and Service Information
Provide consumers and customers with accurate information about products and services.
Provision of accurate information includes the following.
• Providing accurate information on product and service specifications, quality, and handling procedures• Providing accurate information on substances used in materials and components of products• Excluding non-factual expressions and expressions that mislead consumers or customers, and anythingthat might slander, defame, or infringe on the rights of another company or individual, from catalogues andother media, or in advertising and publicity, for products and services.
(6) Respect of Intellectual Property
Do not infringe upon another person’s intellectual property rights.
Intellectual property includes patent rights, utility model rights, design rights, trademark rights, copyrights,
and trade secrets. Before engaging in the development, production, sale, or supply, etc. of products orservices, conduct sufficient research of third-party intellectual property. Excluding where good reasons
exist, any unauthorized use of a third party’s intellectual property constitutes an infringement on theirintellectual property rights. Illegal duplication, etc. of computer software and other copyrighted material
also constitutes an infringement of intellectual property rights. Equally, obtaining and using trade secrets ofa third party by an illegal means also constitutes an infringement of intellectual property rights.
(7) Information Disclosure
Actively provide and disclose information to stakeholders, regardless of whether or not disclosure is required bylaws and regulations.
Information to be provided or disclosed to stakeholders includes information on business activities,
financial status, business performance, and risk-related information (such as disclosure of damage frommajor disasters, adverse impacts on environments and communities, and serious violation of laws, etc.).
An example of active provision of information is disclosing information about major risks as they occur
while also communicating that information to customers.
(8) Prevention and Early Detection of Misconduct
Carry out activities for preventing misconduct and develop systems for early detection and response.
Activities for preventing misconduct refer to educating and raising the awareness of employees andcreating workplaces with an open atmosphere. Systems for early detection and response to misconduct
include the following. Establishing internal and external contact points for reporting misconduct andmanagement working to detect misconduct at an early stage; maintaining the confidentiality ofwhistleblowers and providing appropriate protection; and handling misconduct promptly and providing
feedback on outcomes to whistleblowers as required.
(9) Responsible Procurement of Minerals
Do not purchase minerals that may cause human rights abuses and other social issues.
When purchasing tantalum, tin, tungsten, gold, and cobalt for use in your own company’s products, make9

reasonable and ongoing checks to ensure that they do not directly or indirectly serve as a source of funds
for armed groups committing serious human rights abuses in the Democratic Republic of the Congo andbordering countries. Conduct due diligence on place of origin of minerals and disclose the outcomes tocustomers upon request.
(10) Privacy
When handling personal information, comply with regulatory requirements for privacy and information security.
Work to meet the reasonable expectations for privacy of personal information of all parties to transactions,
including suppliers, customers, consumers, and employees. When collecting, storing, handling,transferring, or sharing personal information, comply with regulatory requirements for privacy andinformation security.

2.5 Quality and Information Security, etc.
(1) Ensuring Product Safety
When designing products as the responsible company, ensure the products meet all safety standards as
defined by the laws and regulations of each country.
When designing products, develop designs that ensure sufficient product safety, and consider
manufacturer’s liability before selling them. In addition to complying with laws and regulations on productsafety, always consider normally required levels of safety. Examples of laws and regulations on productsafety in Japan include the Electrical Appliance and Material Safety Act, the Consumer Product Safety Act,and the Household Goods Quality Labeling Act. Safety standards are defined in the bylaws of laws andregulations, and in JIS and other standards. Examples of international safety standards include UL (U.S.),
BSI (U.K.), and CSA (Canada). Ensuring product safety includes traceability (history of materials,
components, and processes, etc.) and other management and prompt responses for problem solving.
(2) Quality Management System
Develop and operate a quality management system.
A quality management system refers to a general management system for promoting quality assurance
activities, with the system including an organizational structure, scheduled activities, a division of
responsibilities, practices, procedures, processes, and management resources. Quality assurance
activities refer to establishment of quality policies, implementation of measures in line with those policies,
and achievement, review, and maintenance of those measures. They also include continuous improvementof quality assurance activities through implementation of PDCA (plan–do–check–act) cycles. Typicalexamples of quality management systems are the international standards ISO 9000 family, ISO/TS 16949,
and ISO 13485.
(3) Defense Against Threats to Computer Networks
Take measures to defend against threats to computer networks and manage the networks to prevent damage
to your company and others.
Threats to computer networks include computer viruses, computer worms, and spyware. If an internetconnected personal computer becomes infected with a computer virus or other threat, there is a risk that
customer information and confidential information stored on that computer could be leaked, or that thecomputer could be used to stage an attack on computers in other companies, which could lead to severe
losses through suspension of business or loss of credibility. Therefore, it is important to take measuresagainst threats to computer networks to prevent negative impacts internally and externally.
(4) Prevention of Leaks of Personal Information
Appropriately manage and protect the personal information of customers, third parties, and your own
employees.
Personal information refers to information about living people, including names, birth dates, and otherpersonal descriptions, that can be used to identify specific individuals (including information that can beeasily compared with other information to identify specific individuals). Appropriate management refers tobuilding and operating a general management system for personal information and it includes creating
codes and policies to be observed by employees, etc., and formulating plans, implementing measures,
auditing and reviewing in accordance with them. Appropriate protection refers to preventing improper orinappropriate acquisition, use, disclosure, or leaking of personal information.
10(5) Prevention of Leaks of Customer or Third-Party Confidential Information
Appropriately manage and protect confidential information received from customers and third parties.
Confidential information generally refers to information disclosed from documents, etc. (including
electromagnetically and optically recorded data) that are agreed to be confidential in nature, andinformation disclosed verbally after notification that it is confidential in nature. Appropriate management
refers to building and operating a general management system for confidential information and it includes
creating codes and policies to be observed by employees, etc., and formulating plans, implementing
measures, auditing and reviewing in accordance with them. Appropriate protection refers to preventing
improper or inappropriate acquisition, use, disclosure, or leaking of confidential information.
(6) Contributions to Society and Communities
Carry out voluntary activities that contribute to the development of global society or local communities.
Activities that contribute to global society or local communities refer to using management resources of acompany in support activities for the community, and generally include the following.
• Social contribution using normal business operations and technologies, etc.
• Non-financial social contribution using facilities and human resources, etc.
• Social contribution through financial donations
Specifically, this may include cooperating with communities during times of disaster, employees performing
volunteer activities, supporting the activities of NPOs and NGOs, donation activities, and disseminating
and providing information. Companies should determine the scope of activities they are capable of andthen actively work to make contributions to society.
(7) Appropriate Import/Export Control
Develop clear management systems for security export control, and import clearance procedures according to
the Customs Act, etc., and carry out appropriate import/export procedures.
Security export control refers to management of exports, etc. according to the Foreign Exchange andForeign Trade Act, within an international framework, for the purpose of preventing the spread of weaponsof mass destruction and the excess accumulation of conventional weapons within the context ofmaintaining peace and safety globally. Import clearance procedures according to the Customs Act refer tofollow-up investigations conducted by customs offices after the fact to determine whether or not importcargo-related tax returns have been implemented appropriately. In the case of adverse findings fromfollow-up investigations, which require payment of additional taxes or heavy penalties for serious offenses
of inappropriately paid taxes, company names may also published, so it is preferable that checks are
regularly made to confirm that import clearances have been conducted appropriately.
(8) Management of Borrowed Assets
When using borrowed assets from the Maxell Group for production, always comply the terms of contracts andrelevant laws and regulations. Manage the borrowed assets appropriately to ensure they are always able tooperate normally. Promptly respond to any requests from the Maxell Group to submit deposit receipts, conduct
physical inventories, or accept onsite inspections to confirm usage, etc.
Note. The Maxell Group may provide loans of equipment required for producing deliverables. However,master agreements or individual lease agreements must be entered into at these times, and inclusion ofclauses clarifying the management obligations of suppliers is mandatory.
(9) Business Continuity Management (BCM)
Formulate a Business Continuity Plan (BCP) with a range of measures to address how your business could
continue, or how it could be restarted within a target period of time, in the event of disaster, accident, spread of
new infectious diseases or other abnormal situation across the supply chain. Also, build a Business Continuity
Management (BCM) system for minimizing damage or loss to your business. Prevent or minimize any
interruption to supply to fulfill your responsibility to ensure supply.

2.6 Management System(1) Company Commitments
Inform workers about the company’s management-approved CSR policy, including compliance with theseguidelines and efforts toward continuous improvements, through methods such as posting notices within
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facilities in the local language.
(2) Statutory and Customer Requirements
Identify, understand, and monitor applicable laws, regulations, and customer requirements.
(3) Risk Assessment and Management
Identify risks to labor, health and safety, ethics, quality, and information security, assess the level of impact andfrequency of each risk, and take applicable measures.
(4) Improvement Targets
Establish and implement improvement targets and action plans (including regular assessments to ensure target
achievement).
(5) Training
Educate managers and workers to ensure implementation of policies and improvement targets.
(6) Worker Feedback, Participation, and Complaints
Develop processes for assessing the level of understanding of workers in relation to initiatives in each area
detailed in these guidelines, obtaining feedback, and carrying out continuous improvement.
(7) Corrective Measures and Processes
Take corrective measures against nonconformities identified through internal and external assessments,
investigations, and audits.
(8) Documentation and Records
As much as possible, record implementation of initiatives detailed in these guidelines. Appropriately manage,
according to applicable laws and your company’s requirements, internal and external documents and records
containing personal information or business information of a confidential nature.
(9) Supplier Responsibilities
Where your company has its own policies and guidelines, clearly and accurately convey that information to
suppliers in relation to practical application, expectations, and achievement.

2.7 Self-assessment
To confirm the status of CSR initiatives carried out, conduct self-assessments, and work to continuously
improve, CSR activities via a CSR self-assessment questionnaire.
Refer to the separate CSR self-assessment questionnaire.

123. Maxell Group Corporate Credo
The Maxell Group hereby adopts this Corporate Credo in full awareness of its mission and duties and with aview to continued growth and development as a truly international group. The Credo applies to all members of
the board, officers and employees of the Maxell Group (hereafter referred to as "We"). The “Maxell Group”
means: (1) Maxell, Ltd.; (2) any company with more than 50% of its issued stock or interests with voting rights
owned directly or indirectly by Maxell, Ltd.; and (3) such other companies as will from time to time be includedby the Board of Directors of Maxell, Ltd.
3.1 Fundamental Philosophy
The fundamental philosophy of the Maxell Group is, inheriting the founding spirit of "harmony and cooperation","working with heart and soul", and "being of service to society", to maintain the pride as members of Maxell
Group and to contribute to society through the development of outstanding and unique technologies andproducts, under the new corporate creed of "harmony and cooperation, working with heart and soul, andcontributing to society".
At the same time, we acknowledge our responsibility as a member of society and will ensure that our conduct isfair and transparent. As a good corporate citizen, we also intend to contribute to the creation of a truly richsociety by working in harmony with the environment and by engaging in corporate citizenship activities.
3.2 Guidelines and Commitments
1. We will build strong relationships of trust with various stakeholders by fostering cooperation to strengthencohesion throughout Maxell and the rest of the Maxell groups. These efforts shall be based on respect forindividual human rights and dignity, and a healthy rivalry among one another that is balanced with a spirit ofharmony at all times.
2. We are strongly committed to serving customers with the utmost sincerity by developing ever more reliable
technologies and products, and promoting thorough product safety as we seek to accurately identify thevarious needs of the international community and promptly satisfy them.
3. We aim to grow in harmony with society at the leading edge of technology and business on the global stage.
This will be accomplished by conducting proprietary surveys and R&D activities that harness our pioneer
spirit.
4. We will act in accordance with correct corporate ethics and comply with various laws and regulations athome and abroad in the course of business and in our private lives. These laws and regulations cover suchfields as fair trade and competition, import and export transactions, intellectual property, the environment,
the protection of personal information and accounting and tax rules.
5. We will strive to coexist with the Earth’s natural environment as we take the initiative to serve communities,
based on a strong recognition of our social responsibilities and roles as a corporate citizen.
6. We will act as a global corporation closely tied to local communities as we work to foster mutual
understanding and build cordial relationships with each community. These efforts will be guided by a respect
for the cultures, customs and history of various regions throughout the world.
7. We will further raise the value of the 「Maxell」 brand, so as to prove worthy of the public’s trust in our brand.
8. Maxell Group managers will take the initiative to implement this Corporate Credo as befits their position.
They will also properly manage and guide the employees in their charge to ensure the smooth execution ofbusiness operations. At the same time, they will strive to ensure the proper observance of workplace rules
as they strive to build positive, safe and fulfilling workplaces that motivate and inspire their employees.

133.3 Implementation
1. The Maxell Group will require all officers and employees to observe and implement this Corporate Credo
wherever in the world they work.
2. The Maxell Group will establish the “Maxell Group Codes of Conduct” which shall be a guide for the
implementation of this Corporate Credo by Maxell officers and employees. We will educate and encourage
implementation of this Corporate Credo from an international perspective, with due respect for differences insocial and political conditions, culture, language, customs, legal systems or any other relevant concerns
3. We will periodically review this Corporate Credo, with the objective of continuous improvement. In
practicing this Corporate Credo, we will identify sections within the organization with the required
accountability, and/or introduce management systems that meet international norms, as deemed
appropriate.
4. Should there be any conflict between content of this document and local laws, rules or regulations of thecountry or region where Maxell Group members work, the Group members involved shall consult with thelegal counsel of their company or the department in charge of compliance with this Corporate Credo at theheadquarters of Maxell, Ltd.

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4. Maxell Group Codes of Conduct
The Maxell Group Codes of Conduct have been established as specific codes of conduct that apply to allcompanies of the Maxell Group. Under the leadership of top management, we will thoroughly implement theCodes of Conduct to ensure that all our business activities are conducted on the basis of corporate ethics andcompliance, in accordance with "Basics and Ethics."
Chapter 1 Sincere and Fair Business Activities
1.1 Provision of Safe High-Quality Products and Services
1.2 Sales Activities
1.3 Procurement Activities
1.4 Respect of the ｢Maxell｣Brand
1.5 Observance of Engineering Ethics
Chapter 2 Environmental Protection
2.1 Promoting Environmental Management
2.2 Environmentally Conscious Business Activities and Environmental Management
2.3 Communication with Stakeholders
Chapter 3 Relations with Society
3.1 Disclosure of Company Information
3.2 Contribution to Local Communities
3.3 Relations with Politics and Government Administration
3.4 Prevention of Anti-social Transactions
3.5 Regarding Gifts, Business Entertainment, Etc.
3.6 Observance of Laws and Regulations and Respect of the Culture and Customs of Each Nation and Region
Chapter 4 Respect of Human Rights
4.1 Promoting Respect of Human Rights
4.2 Eliminating Discrimination
4.3 Respect of Human Rights in Information Management
4.4 Respect of Basic Rights at Work
Chapter 5 Management Foundations
5.1 Management and Use of Information
5.2 Use of Inside Information and Related Considerations
5.3 Management and Preservation of Company Assets
5.4 Arranging a Work Environment That Draws Out Employee Strengths
5.5 Observance of Laws and Regulations Governing Imports and Exports
Chapter 6 Complete Observance of Codes of Conduct
6.1 Complete Observance of Rules
6.2 Implementation of Self-Audits
6.3 Internal Reporting System
Chapter 7 Responsibilities of Top Management

The above table of contents has been included here for your reference. For more details, refer to the Maxell
Group Codes of Conduct on the following page.
https://www2.maxell.co.jp/corporate/rule/15

5. Maxell Group Policy on CSR Activities and Initiatives
5.1 Commitment to corporate social responsibility
The Maxell Group, including all its executives and employees, recognizes CSR as a vital part of corporate
activity and is therefore committed to a course of social responsibility in accordance with this CSR policy forthe sustainable development of society and business.
5.2 Contribution to society through our business activities
The Maxell Group will contribute to the building of a prosperous and vibrant society by providing customers
with safe, high-quality products and services through business activities based on its excellent research andtechnology development.
5.3 Information disclosure and communication
The Maxell Group will disclose information fairly and transparently in order to maintain and develop a
relationship of trust with its various stakeholders and will act responsibly towards them through various meansof communication.
5.4 Corporate ethics and respect for human rights
The Maxell Group will undertake its business based on the principles of fairness and sincerity, act with theutmost respect for human rights and pursue a high sense of corporate ethics in the global business market
which encompasses diverse culture, morals, ethics and legal systems.
5.5 Environmental conservation activities
The Maxell Group will strive to minimize environmental impacts and utilize limited resources towards thedevelopment of a sustainable society that is in harmony with the environment.
5.6 Corporate citizenship activities
The Maxell Group will actively promote social contribution activities as a good corporate citizen in order torealize a better society.
5.7 Good working environment
The Maxell Group will make every effort to create a pleasant and motivating working environment for all its
employees and to actively support those employees who desire self-fulfillment and self-development throughtheir work.
5.8 Sharing awareness on social responsibilities with business partners
The Maxell Group will make every effort to promote fair and sound business practices among its business
partners by fostering a common awareness of social responsibility.

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6. Material Procurement Guidelines
6.1 These guidelines contain standards of behavior that procurement departments and other relevant
departments should follow when procuring external materials, products, services, and information requiredfor business operations.
6.2 To develop good partnerships with business partners, we strive to maintain and improve mutual
understanding and relationships of trust from the long-term perspective.
(1) We treat all business partners impartially and ensure advantageous treatment is not given to specificbusiness partners while disadvantaging others.
(2) We respect fair business relationships with business partners and do not impose a disadvantage on ourbusiness partners due to unfair acts in the light of normal business practices.
(3) We strive to strictly manage and maintain confidentiality of trade secrets of business partners learned
through procurement transactions.
6.3 We strive to develop optimal business partners and maintain competitive procurement from a global
perspective, keeping the following points in mind.
(1) When approached by new companies, etc. offering to trade, we respond and proceed sincerely to provide
information related to trade items, etc.
(2) In respect to ongoing procurement transactions, we regularly review the eligibility of business partners andconsider the possibility of more advantageous transactions with other business partners.
6.4 When selecting business partners, in addition to assessing the quality, reliability, delivery, and price ofmaterials, and the business stability and technical capabilities, etc. of business partners, we assess
suitability in line with the Policy on CSR Activities and Initiatives, comply with matters specified below, andproperly carry out the prescribed procedures.
(1) We do not request quotations without a clear intention of purchasing.
(2) In accordance with internal procedures, rights and responsibilities for determining procurement
specifications, contract conditions, and acceptance (inspections) lie with the respective requesting
departments, procurement departments, and inspection departments.
(3) Procurement departments represent the Maxell Group in contracts with business partners.
6.5 We receive no personal benefits from business partners in procurement transactions.
6.6 Persons in charge of procurement lead by their own example to ensure implementation of these guidelines
and strive to fully inform workers in their own department and managers and workers in related
departments. All relevant workers also look to their seniors for advice and guidance if they have any
questions regarding these guidelines.
6.7 Co-creation with Business Partners
We collaborate with business partners to carry out activities on a win-win basis through joint value engineeringand “Less Engineering” initiatives.

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