Murata Group
Murata Corporate
Ethics Policy
and Code of Conduct

The Origin of Murata
At Murata, we believe that it is of the utmost importance foreach and every officer and employee to embrace the “Murata
Philosophy” and to sincerely put it into practice as the basis fortheir thoughts and actions.
The goal of founder Akira Murata was not tocompete over profits with competitors, but rather
to “contribute to the advancement of society bycreating innovative products and solutions.” When
he inherited his family’s business at the young ageof 20, Akira was able to continue the businessdue to the help he received from many people,
thanks to the trust that Akira’s father had built up
during his lifetime. From these experiences, Akira
remembered to always remain grateful and placed
great importance on building trust. He establishedthe Murata Philosophy with these ideas in mind.
From its establishment in 1954 until today,
Murata officers and employees have used the
Murata Philosophy as the basis for their professional actions not only in situations where they facehesitations and difficulties, but also as guidelines
for their everyday business activities. The Murata
Philosophy, which has been carefully handed downover time, remains the basis of Murata’s business.

1

Positioning of the Murata Corporate Ethics Policy and Code of Conduct
The Murata Philosophy forms the basis for our thoughts and actions.
The Murata Philosophy integrates our best practices, management
ideology and attitudes toward work, and the development of Murata

Murata Corporate Ethics Policy

has been supported by the spirit of the Murata Philosophy. Since theWe will respect laws, regulations and fair social rules, and thespirit thereof, in the countries where we conduct business,
and act in good faith while maintaining the highest ethicalstandards.

the world around us has dramatically changed and continues to evolve,

We will create excellent technologies and products toachieve customer trust and satisfaction, and through which,contribute to realizing a prosperous society.

creation of the Murata Philosophy by founder Akira Murata in 1954,
but the Murata Philosophy will always remain the same. Murata, its
officers, and its employees are required to perform their work in goodfaith in accordance with the Murata Philosophy.
In addition, the Murata Corporate Ethics Policy is a set of principles
of conduct under which officers and employees have promised totake appropriate actions with respect to society in order to concretely
implement the Murata Philosophy. The Murata Corporate Ethics Policy

We will respect each employee’s personality and humanrights and provide a safe and comfortable working
environment oriented toward open communication.

is shared with all Murata officers and employees, and they will comply

We will positively provide information about our business toenhance corporate transparency.

Ethics Policy, the content on which Murata’s officers and employees

We will conduct activities for improving the global
environment in a positive and voluntary manner.

foundation of their daily business activities and duties.

We will, as a good corporate citizen, strive to achieve
co-prosperity with our stakeholders, including customers,
shareholders, investors, business partners, as well as
governments, communities and society.

with the Policy.
Further, in order to effectively comply with the Murata Corporate
should base their actions has been prescribed in the Code of Conduct.
Murata’s officers and employees use the Code of Conduct as the
At Murata, each any every officer and employee put the Murata
Philosophy, the Murata Corporate Ethics Policy, and the Code of
Conduct into practice every day.

Murata Group: Murata Corporate Ethics Policy and Code of Conduct

2

President’s Message“Contribute to the advancement of society by creat-

backgrounds, both domestically and internationally.

ing innovative products and solutions”

It is exactly because we are in this era of greatand bychange and diversity that we need a “basis for“being trustworthy and, together with all our stake-decisions and actions” to clarify the standards ofholders, thankful for the increase in prosperity.”

conduct for each and every employee at Murata.
In our “Corporate Ethics Policy and Code of

These are phrases from the “Murata Philosophy”

Conduct,” we have compiled our basic principles andand these words have been cherished ever sinceideology that should serve as the basis for when each

Murata’s founding. Based on the Murata Philosophy, I

of us conducts our daily business or makes decisions

engage in fair business activities, and I hope forin our own fields.

Murata to continue to be a company which is trusted

I ask for each of you to comply with these policies.

by society. In order to create new forms of value andBy personally adhering to these policies, you can help

achieve robust, sustainable growth amidst changing

form the base of Murata’s value creation and willbusiness opportunities, it is essential for us to meetenable Murata to grow together with our stakehold-the expectations of our stakeholders, including ourers.

customers, shareholders/investors, suppliers, andLet us work together to create a Murata that earns

everyone in the local community, based on legal

even more of society’s trust by having each and every

compliance and a high degree of business ethics, anddomestic and international employee carry out their

to respect our Corporate Ethics Policy.

daily activities by using this “Corporate Ethics Policy

Recently, expectations and demands for company

and Code of Conduct” as the basis for their decisions

contributions have been increasing, not only from theand actions.

viewpoint of compliance with laws and regulations,

April 1, 2024

but also to contribute to the sustainability of society.
At Murata, we have positioned “solving social issues
through our business” as one of our key issues, andare carrying out initiatives to contribute to theadvancement of a sustainable society. In addition,

3

Norio Nakajima

while we leverage diversity to drive innovation, we

President

have a growing number of employees with diverse

Murata Manufacturing Co., Ltd.

Table of Contents
Section 1 Corporate and Social Rules

Section 2 Co-prosperity with our Stakeholders

Quality and Safety of
Products and Services

23

Respect for Human Rights

24

11

Donations and Sponsorship

25

Severance of relationships
with Anti-Social Forces

12

Dissemination of Information
and Communication

26

Respect for Diversity

27

Prevention of Conflicts of Interest

13

Health and Safety

28

Import/Export Controls

14

Relationship with our Suppliers

29

Prevention of Money Laundering

15

Contribution to
the Global Environment30

The Origin of Murata

1

Fair Competition and Trade

9

Positioning of the Murata
Corporate Ethics Policy and
Code of Conduct

2

Prevention of Corruption and
Corrupt Practices

10

President’s message

3

Political, Religious,and Lobbying Activities

Applicable scope

5

Relevant laws and regulations
in each country and region

5

Reporting on issues

5

No retaliation

5

Employee judgment standards

6

Revision process6

Compliance promotion systems

6

Responsibilities of each employee

7(Including Terrorism Groups,Gang Groups, Mafia, etc.)

Accurate Recording and16
Reporting of Financial Information
and Appropriate Tax Payment
Prevention of Insider Trading17

Use of Company Assets

18

Information Security

19

Protection of Personal Information

20

Respect ofIntellectual Property Rights

21

In this Corporate Ethics Policy and Code of Conduct,“Murata” refers to the Murata Manufacturing Group
as a whole, and “Murata Manufacturing Co., Ltd.” toMurata Manufacturing Co., Ltd. as a standalonecompany.

Murata Group: Murata Corporate Ethics Policy and Code of Conduct

4

Applicable scope

Reporting on issues

The Murata Corporate Ethics Policy and Code of Conduct (this “Code ofIf you discover any violation of or deviation from this Code of Conduct, or if you

Conduct”) has been enacted and may be revised by Murata Manufacturing Co.,

have any suspicion thereof, please report this to your superior or the relevantLtd., and is jointly applicable to the officers of Murata Manufacturing Co., Ltd.

department, or to the reporting and consultation hotline for complianceand each domestic and international company within the Murata Group and theviolations (the whistleblowing system). Whistleblowers who use this hotline may

employees thereof.

make their reports either under their own name or anonymously.
Murata will appropriately investigate and respond to each report received,
while also taking the wishes of the whistleblower into consideration.
Whistleblowers who report violations under their real names will be provided
with findings and details in an appropriate manner. To the extent possible,
whistleblowers who report anonymously will also be given feedback.

Relevant laws and regulations in eachcountry and region

Murata does not tolerate any retaliation towards whistleblowers. In addition to

All of our officers and employees will comply with the laws and regulations ofprotecting the anonymity and privacy of whistleblowers, we also take steps tothe countries and regions where we conduct business. Further, we will comply

prevent whistleblowers from being unfairly disadvantaged by their reporting by

not only with established laws and regulations, but also with their underlying

prohibiting retaliatory actions against whistleblowers and making this known toethical and moral spirit, and in anticipation of future laws and regulations we will

officers and employees.

act based on this Code of Conduct. Please act in accordance with this Code of
Conduct even in the case where a provision herein imposes a higher standard
than the relevant provision under applicable local laws or regulations or international standards.

5

No retaliation

Employee judgment standards

Compliance promotion systems

The Code of Conduct serves as the foundation for our daily business activities

Within the Compliance Promotion Committee, company-wide policies concerning compli-

and duties, but we know no code of conduct can cover all possible situations, andance are prepared and revisions are made to Compliance Programs (such as the Promotion

even in the situations provided in the Code of Conduct, we may have questions,and Operation Systems, the Murata Corporate Ethics Policy and Code of Conduct, andhesitations, and conflicts in dealing with real situations. At such times, we will

the Procedures for Responding to Employee Reports and Consultations). In addition, theask ourselves the following questions to make the right decision:

Compliance Promotion Committee reviews cases in which major violations have occurredand offers solutions thereto and reoccurrence prevention measures therefor.

“Are we going to act counter to law or the spirit of the law for short-term
interest?”“Do we maintain sincerity towards our customers and stakeholders?”“Might this be inappropriate in terms of common sense in society, though
it’s a common practice at Murata?”

The Compliance Promotion Committee Secretariat carries out daily duties regarding
the promotion of compliance, such as managing this Code of Conduct, creating thecompliance training plan, and receiving and handling employee reports and consultations.
Board of Directors
Representative Director
CSR Management Committee

Revision process
The Code of Conduct will be revised by a resolution of the Board of Directors of
Murata Manufacturing Co., Ltd.**This shall not apply to revisions, etc. which do not substantially change the content hereof.

Chairperson: Member of Board of
Directors and Executive Vice President

Compliance Promotion
Committee

Committee Members: five individuals or more(Composed of permanent and non-permanent members of
department general manager level and above)
Committee Secretariat

Secretary General: General Manager of Legal Department
Secretariat Department: Human Resources Department and Legal Department

Compliance Promotion LeadersAffiliated companies
Person in charge ofpromotion
Promotion personnel

Employees

Murata Group: Murata Corporate Ethics Policy and Code of Conduct

6

Memo

Responsibilities of each employee
Murata asks all of its officers and employees to understand this Code of
Conduct and to comply with the following. Officers and employees who violate
or deviate from this Code of Conduct may be subject to disciplinary measures inaccordance with internal rules and relevant laws and regulations.
I will practice this Code of Conduct and act with fairness and in goodfaith.
I will be aware of where issues exist by practicing this Code of
Conduct.
I will report to my superior or the relevant department, or to thereporting and consultation hotline for compliance violations, if I
discover any violation of or deviation from this Code of Conduct, or if
I have any suspicion thereof.

In addition, Murata further asks managers (officers and management staff) toalso comply with the following.
I will set a good example in the workplace.
I will create a working environment oriented toward open communication
by ingraining this Code of Conduct into our organization.

7

Section 1 Corporate and Social Rules
Murata is deeply aware of society’s standards,
and by acting with fairness and in good faith,
we will continue to be a company which is trusted by society.

Murata Group: Murata Corporate Ethics Policy and Code of Conduct

8

Fair Competition and Trade
We will comply with all applicable laws and regulations regarding fair competition and trade. We respect fair and free trade andwill conduct fair business.
We will comply with all applicable laws and regulations regarding fair competition and trade (“Antitrust Laws”).
Antitrust Laws prohibit any acts which impede free competition in a market
or which disadvantage consumers. Depending on the country, there may becases where a country applies its own Antitrust Laws extraterritorially (where

Appropriate and Required Individual Actions in the Workplacea country applies its own laws regarding unfair competition that occurred in a

I will comply with the “Basic Policy for Prevention of Cartels and Bribery” andlocation outside of that country’s borders), but officers and employees mustother related internal rules.

comply with all Antitrust Laws and these Policies, regardless of their nationality
or place of employment.
We understand the purpose of Antitrust Laws, and we will not enter into any
agreement or share any information with any competitor (a “Competitor”) regarding
price, cost, profit, market share, production capacity, sales terms, or any othermatter that may have an impact on competition (collectively, “Sensitive Matters”).
In addition, we will not use our position in a transaction to commit any act which
would unfairly disadvantage a supplier, such as imposing an unfair trade practice on
a supplier. We will prepare and disseminate internal rules relating to the foregoing.

I will avoid contact with Competitors whenever possible. When I must unavoidably have contact with Competitors, prior to such contact, I will properly obtainprior approval in accordance with the procedures applicable to the company
and department.
I will closely scrutinize whether or not the purpose of a meeting with Competitors or an organization which is including trade associations constitutes amonopolization of the market or an impediment to free competition. Even if ameeting with them is lawful, I will obtain the approval of the department head
before I participate.

Examples of consequences for violating or deviating from these Policies

I will not enter into any agreement or share any information with Competitors

If an officer or employee violates any Antitrust Law, Murata may be subject toadministrative or criminal sanctions or penalties such as large fines or monetary
sanctions, the suspension of our transactions, or the suspension of our business,and such individual officer or employee may be subject to fines or imprisonment.
Further, if a supplier incurs damage due to any Antitrust Law violation by a Murata
officer or employee, such officer or employee may be liable for compensation forsuch damage. Depending on the country, a class action lawsuit may also be filed
against such officer or employee by disadvantaged consumers or the like.

regarding Sensitive Matters under any circumstances.

*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

9

I will not commit any act which would impede free trade or unfairly disadvantage a supplier by restricting resale prices, abusing Murata’s dominant bargaining position, or through any other unfair trade practice.
If I observe any suspicious activity or receives any suspicious requests, I willpromptly report or consult thereon with my superior or the relevant Legal
Department.

Prevention of Corruption
and Corrupt Practices
In addition to extortion and embezzlement, we will not engage
in corruption or corrupt practices, including offering or accepting
bribes or other improper interests, in any of our business activities.
Ensuring fairness and transparency in our business activities is fundamental
to sound business activities. We will comply with all international laws andregulations regarding the prevention of corruption and corrupt practices(“Anti-corruption Laws”).
Anti-corruption Laws prohibit providing money or the like to public officials,
suppliers, etc., and prohibit offering or promising to do so. Anti-corruption Laws
prohibit any bribery concerning a business transaction, regardless of whether
the counterparty thereto is a public official or a private citizen; in other words, Anti-corruption Laws prohibit the provision of money or the like to any counterparty
in order to improperly influence that counterparty. In addition, Anti-corruption
Laws prohibit the receipt from and request or offer to a counterparty to receive
benefits such as money or the like in exchange for the provision of any businessadvantage.
Anti-corruption Laws have a wide applicable scope. Officers and employees of
Murata, as well as third parties such as Murata’s representatives, must comply
with all Anti-corruption Laws and these Policies, regardless of their nationality
or place of employment.

Examples of consequences for violating or deviating from these Policies
If an officer or employee violates any Anti-corruption Law, serious criminal oradministrative punishment or disposition may be taken against Murata and theindividual officer or employee. Further, such violation may also have a material
adverse effect on the trustworthiness of the company and could result in Murata
being suspended from doing business with administrative agencies or refusedbusiness by private companies.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

Appropriate and Required Individual Actions in the Workplace
I will comply with the “Basic Policy for Prevention of Cartels and Bribery” andother related internal rules.
Except when clearly and definitely permitted under laws, regulations, and business practices, I will not provide, offer, or promise to provide entertainment,
gifts, or preferential treatment in terms of money or other benefits and opportunities (collectively, “Benefits”) to any organization with which we do businessfor the purpose of obtaining or maintaining any business advantage, regardlessof whether the organization is public or private. In addition, I will not receive,
request, or promise to receive Benefits from any organization with which we
do business in exchange for the provision or maintenance of any businessadvantage.
I will not make facilitation payments (small payments of money to public
officials and others not required by law to facilitate or expedite routine administrative services, such as customs clearance and visas).
If I observe any suspicious activity or receive any suspicious requests, I willpromptly report or consult thereon with my superior, the relevant Legal
Department, or the relevant General Administration Department.
Murata Group: Murata Corporate Ethics Policy and Code of Conduct

10

Political, Religious,and Lobbying Activities
We will maintain healthy and normal relationships with all political, administrative, and religious bodies. We will not wrongfullyuse or provide any company money or facilities for the purpose ofpolitical or religious activities. We will also not be involved in any
unlawful lobbying.
We will not commit an act which may be misunderstood as colluding with(including providing benefits to) any political entity (such as national or local
assemblies, legislators and parties related thereto, and national or local
administrative bodies and any representatives, officers, or employees thereof).
On the other hand, we will build highly transparent relationships with politicalentities that enable the open and proactive exchange of opinions regarding thestate of the economy and economic policies.
When providing donations, contributions, or sponsorships to political or
religious groups, and when using company facilities or providing access thereto
for such groups, we will conduct such activities in accordance with applicablelaws and regulations and internal rules after adequately taking into
consideration the necessity and appropriateness of those activities to preventthe provision of any improper Benefits.

In addition, we will not engage in any activities that promote a particularreligion or ideology or benefit a particular religious or ideological group without
any adequate reasons.
We will comply with all applicable laws and regulations when we conduct any
lobbying* related to politics. In addition, even in situations where we have actualinteractions with legislators, we will do so through communication methods
which ensure transparency in order to avoid any suspicion of bribery or otherinappropriate acts.
*Lobbying involves contacting national and local assembly and legislative representatives,
as well as government agencies and their representatives, officers, and employees,
regarding legislative or regulatory issues that affect the company.

Appropriate and Required Individual Actions in the Workplace
If I have any dealings with those described above (being political, administrativeand religious bodies) will handle such dealings with sufficient care to avoid any
misunderstanding.
*Please see “Prevention of corruption and corrupt practices” on page 10.

I will not provide any company assets for political activities, even in relation
to Murata’s business, without the consent of my superior or the relevant
department.
I will not use any company time or assets for personal political or religious
activities without obtaining prior consent to do so.

Examples of consequences for violating or deviating from these Policies
There may be laws or regulations which restrict political contributions andlobbying, depending on the country or region. If an officer or employee violates anyof these laws or regulations, Murata and the individual officer or employee may besubject to criminal or administrative punishment (including fines, the suspensionof the right to tender bids, exclusion from transactions, etc.). Further, even if suchlaws or regulations are not violated, the trustworthiness of the company could besignificantly damaged if Murata or a Murata officer or employee is suspected ofhaving any inappropriate involvement in politics.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

11

When conducting lobbying activities as a representative of Murata, I will do soafter implementing the appropriate procedures in each country as necessary.
I will act in a straightforward manner and in good faith in accordance with alllaws and regulations of each country and region when interacting with thegovernment, a government agency, or a government representative thereof.
If I discover any improper political or lobbying activity, I will promptly reportor consult thereon with my superior or the relevant General Administration
Department.

Severance of Relationships
with Anti-Social Forces(Including Terrorism Groups, Gang Groups, Mafia, etc.)
We will not transact with, provide assistance to, or sympathizewith anti-social forces that adversely affect public order andsound corporate activities. Further, we will not engage in any
other acts that benefit such groups.

“Anti-social forces” refers to groups or individuals, including terrorism groups,
gangs and mafia groups, that seek economic benefits through the use of violence,

Appropriate and Required Individual Actions in the Workplace
I will take a resolute stance against anti-social forces and will not have any
relationship with them.
I will resolutely oppose unreasonable demands or intimidation and will not use
money or special treatment as a solution.

force, or fraudulent means.

If I am contacted by anti-social forces, I will ensure that any response to such

Taking a resolute stance against these groups and individuals and conducting

contact will be handled by multiple employees and not by only one individual.

corporate activities in a manner that does not allow them to take advantage of

If I am threatened or extorted, I will promptly report or consult thereon withus will contribute to the formation of a sound civil society and prevent damage

my superior or the relevant General Administration Department. If I have any

to our corporate value.

opportunities to report to the matter to the police and judicial authorities, I will

Murata will not have any relationship with any group or individual that posescooperate with the response by those authorities.

a threat to public order or safety. We will also take a resolute stance against
unreasonable demands and will not comply with such demands.

Examples of consequences for violating or deviating from these Policies
If a company has a relationship with anti-social forces, it will not only cause
serious damage to the company’s trustworthiness, but such relationship will alsomaterially interfere with business operations, such as causing the termination ofcontracts or exclusion from tendering bids.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

Murata Group: Murata Corporate Ethics Policy and Code of Conduct

12

Prevention of Conflicts ofInterest
We will avoid any actual or potential action in which an officer or
employee’s personal interests conflict with the interests of thecompany.
A “conflict of interest” refers to an actual or potential situation in which an
officer’s and employee’s personal interests conflict with the interests of thecompany.
Conflicts of interest may arise in various situations. If an officer and employee
or a relative or friend thereof has a close relationship with a competitor or
supplier, or a close financial interest therein, there may be a conflict of interest
between the employee and Murata.
When such a situation arises, officers and employees must not confuse theirpersonal position with Murata’s position, and must prioritize Murata’s interestsand objectives. Officers and employees must not use their position, duties, orcompany assets, nor relinquish their duties, in an attempt to gain personal
benefit or to benefit a third party.
Murata also avoids conflicts of interest by providing training to officers andemployees both domestically and overseas, and by introducing internal rules andestablishing reporting systems for companies that have conflicts of interest,
based on risks in each region.

Appropriate and Required Individual Actions in the Workplace
I must understand that a “conflict of interest” refers to an actual or potential
situation in which my personal interests conflict with the interests of thecompany, and will comply with internal rules to avoid such conflict.
I will use sufficient care in the situations listed below which raise concerns
about “conflicts of interest.”
When I, a relative or friend thereof, or any company operated by such
persons commences transactions with Murata
When I use non-public information which they handled or came to know inthe course of my duties in an attempt to gain personal benefit or to benefit
a supplier, competitor, or third party
When I am asked to serve as an officer of another organization without
Murata’s approval or instruction

Examples of consequences for violating or deviating from these Policies
Individual officers or employees who conduct acts in which there is a conflict ofinterest may be held liable for losses incurred by Murata as a result of such acts. In
addition to an action by Murata to enforce such liability, the officers or employees
may also be subject to criminal penalties if their acts involve criminal acts suchas fraud, embezzlement, or breach of trust. Such acts will also lead to significant
damage to the trustworthiness of the company.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

13

When I am intending to be employed by a company other than Murata or
attempting to start my own business
When any actual or potential situation arises in which my personal interests
conflict with the interests of Murata, I will appropriately notify and consult
thereon with my superior or the relevant Legal Department in accordancewith internal rules.

Import/Export Controls
We will comply with all laws and regulations on import andexport.
We will also request that lawful export controls are made inindirect transactions through our business partners.
We conduct our business activities globally, and each country and region inwhich we operate has its own laws and regulations governing imports andexports.
With respect to exports, for the purpose of maintaining peace and security in theinternational community, export control laws and regulations and economic
sanctions have been established to restrict exports of actual weapons as well ascivilian products and technologies usable for military purposes so that they do not
fall into the hands of countries developing weapons of mass destruction or terrorists.
With respect to imports, various laws and regulations have also been
established to ensure public health, protect domestic industry, and stop the
inflow of prohibited goods into each country.
In addition, laws and regulations relating to import/export controls andcustoms duties are frequently revised in light of the present global situation.
We will conduct our global business activities with the full understanding ofand in compliance with such laws and regulations. We will also request that
lawful import/export controls are made through our business partners and wewill inspect and examine those import/export controls as required.

Examples of consequences for violating or deviating from these Policies
If an officer or employee violates any of the laws and regulations related toimport and export, Murata may be subject to fines, prohibitions or restrictions onimports and exports, or other such penalties, and the individual officer or employee
may be subject to criminal punishment. Further, such violation may also lead todamage to Murata’s reputation and could result in Murata being suspended fromdoing business with public agencies or refused business by private companies.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

Appropriate and Required Individual Actions in the Workplace
When exporting products or providing services, technology, or the like to overseas parties (including Murata group companies), I will conduct the prescribedtransaction screenings based on export control laws and regulations, including
Japan’s “Foreign Exchange and Foreign Trade Act” and other laws or regulations
which are applied in the country or region concerned, as adopted in accordancewith international agreements.
When importing or exporting products or services, I will comply with the applicable laws and regulations of each country, including customs laws and export
control laws and regulations, confirm whether notification to or permission from
regulatory authorities is required, and implement the necessary procedures.
When importing or exporting certain products or services that have been specificallyregulated as having a high possibility of diversion for military use, or when conducting
transactions with countries, regions, or organizations that are subject to economic
sanctions, officers and employees will comply with relevant laws, regulations, andinternal policies and ensure that they confirm with the relevant Legal Department
and Import/Export Control Department. If I have any opportunities to consult withadministrative agencies, as necessary, I will follow their instructions.
I will actively participate in education and training to ensure compliance with
export control laws and regulations.
If I need advice on any of the matters stated above, I will consult thereon withthe relevant Legal Department.
Murata Group: Murata Corporate Ethics Policy and Code of Conduct

14

Prevention of
Money Laundering
We will comply with laws and regulations on the prevention ofmoney laundering. We will also make sure that we are not complicit in money laundering in the course of our transactions.
“Money laundering” generally refers to the act of a company or individual
making proceeds obtained through criminal activity or improper transactions(drug trafficking, tax evasion, window dressing accounting, etc.) appear as if they
were obtained through legitimate transactions or the act of a company orindividual concealing the source of its proceeds. Money laundering encourages
organized crime and has a serious adverse effect on sound economic activities,
given that proceeds from crime are used to maintain and strengthen future
criminal activity and criminal organizations.
Laws and regulations are being tightened around the world in response to
moves by the IMF (International Monetary Fund) and other internationalorganizations to prevent money laundering. We must be careful not to overlook
or otherwise assist in money laundering. Even if we are not intentionallycomplicit in money laundering, the company will be subject to significant risk if
we are involved in any way in such a serious crime.

Appropriate and Required Individual Actions in the Workplace
I will look out for warning signs of money laundering, such as those described
below.
-When a transaction is made with various types of checks or cash
-When a bank transfer is made in installments to more than one bankaccount-When a supplier designates that a bank transfer be made to an account held
under the name of a third party that differs from the name of the supplier-When a supplier designates that a payment be made to a bank accountoutside of the country or region in which the supplier conducts businessactivities-When a payment is made by someone other than the parties to the contract-When a payment is made in a different currency than the currency of an
invoice or contract-When reimbursement for overpayment is requested in cash

Examples of consequences for violating or deviating from these Policies
Money laundering is a serious financial crime. It is regulated under the financial
laws of each country, and involvement in money laundering, whether intentionalor unintentional, may result in serious criminal or administrative punishment.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

15-When unknown or unnecessary intermediaries are involved in the transaction-When a high-risk country or company is involved in the transaction
If I observe any suspicious activity or receive any suspicious requests frominside or outside the company, I will promptly report or consult thereon with mysuperior, the relevant Finance Department, or the relevant Legal Department.

Accurate Recording andReporting of Financial Information
and Appropriate Tax Payment
We will accurately record and report financial information incompliance with appropriate accounting standards and relevantlaws and regulations and internal rules.
Further, we will comply with the tax-related laws and regulations of each country and pay taxes appropriately.
For a company to conduct sound business activities globally, it is importantthat the company makes appropriate decisions based on accurate and complete
records of financial information and provides accurate financial reports toshareholders/investors and other stakeholders. To this end, we must establish
and maintain an internal control structure and system, keep records and carryout procedures in accordance with the rules, comply with the laws andregulations of the countries and regions in which we operate, and disclose

Appropriate and Required Individual Actions in the Workplace
I will accurately and promptly record and perform appropriate accounting for
all necessary transactions (e.g., recording sales and expenses) in accordancewith internal rules and procedures.

information in a timely and appropriate manner. Appropriate accounting and tax

I will not engage in inappropriate acts such as the falsification of businessprocessing also leads to appropriate tax payment.

results, accounting fraud, the falsification of or tampering with reporting mate-

Through these actions, we will ensure the reliability of financial information

rials for external or internal use, window dressing accounting, misconduct, or

provided to our stakeholders and maintain fair and transparent management.

the concealment of inconvenient facts.
Even if I have a target sales or profit figure to achieve, I will not attempt toachieve them through improper means.

Examples of consequences for violating or deviating from these Policies
If an officer or employee conducts any fraudulent accounting processing or
submits false financial information or other such misinformation to governmental
or tax authorities, civil, criminal, or administrative punishment may be taken
against Murata and the individual officer or employee, and the trustworthiness ofthe company may be affected.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

When undergoing audits or tax investigations, I will cooperate with internal andexternal auditors and investigators to ensure that the audits and investigations
proceed smoothly.
If I am instructed to do something that I believe to be improper, I will promptly
report or consult thereon with my superior, the relevant Accounting Department, or the relevant Legal Department.
Murata Group: Murata Corporate Ethics Policy and Code of Conduct

16

Prevention of
Insider Trading
We will not make share transactions using undisclosed inside
information of our company or other companies, nor will we allow
third parties to do the same.
“Insider trading” refers to the act of trading shares issued by a company by acompany insider who is aware of undisclosed information regarding that

Appropriate and Required Individual Actions in the Workplacecompany’s business, operations, or business results that will have a significant

I will not share material facts about Murata (including its group companies), cus-

impact on the investment decisions of investors (material facts) before thetomers, or suppliers with third parties, including my friends and family members,

information is made public. Insider trading is prohibited by law as an act thator even with other officers and employees within the company, except when

undermines the fairness of financial markets.

it is necessary in the course of business. Even when it is necessary to share

In order to prevent insider trading, Murata has established “Insider Trading

such material facts in the course of business, I will give the utmost care to thePrevention Regulations” to prevent the communication of material facts,

environment where they are shared.

prohibit recommending share trading, and prohibit anyone aware of material
facts from buying or selling shares.

Regardless of whether or not material facts will be shared, I must not recommend the purchase or sale of Murata’s or its business partner’s shares to any
person within or outside the company for the purpose of having a person
acquire benefits or avoid losses by the purchase or sale of such shares.
If I have come to know of material facts will not buy or sell the shares of
Murata, its customers, or suppliers before those facts are made public. Further,
I will comply with the Insider Trading Prevention Regulations when buying or
selling Murata’s shares. Officers and employees who routinely handle material
facts in their work and individuals with certain job positions (subject to trading

Examples of consequences for violating or deviating from these Policies
As insider trading is an act that undermines the fairness of financial markets,
officers and employees who engage in insider trading will be subject to severe
punishment such as criminal or administrative punishment. Murata may also lose
the trust of investors and other stakeholders.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

17

restrictions) are prohibited from buying and selling Murata’s shares in principle.**The persons who are subject to trading restrictions may purchase or sell Murata’s shares
only within the period of time following the disclosure of material facts and only in thecase they have received prior approval from the Information Management Manager.

If I am unable to determine whether I am allowed to buy or sell shares, I willconsult thereon with the relevant General Administration Department in chargeof preventing insider trading.

Use of Company Assets
We will appropriately control the company’s tangible and intangible assets to use them effectively.

Murata creates maximum value and conducts its business activities based on
its management resources. Management resources include any kind of assets,
whether tangible and intangible, such as funds, real estate, facilities, equipment,
information, intellectual property, and brands. One of our most important
responsibilities is to protect, effectively use, and appropriately control thesecompany assets. If company assets are damaged due to a disaster, or they arelost or stolen, we will be responsible for taking appropriate action immediately.

Appropriate and Required Individual Actions in the Workplace
I will use tangible and intangible assets held by Murata only for the purpose of
appropriately conducting business.
I will take the utmost care to ensure that I do not take any action that would
damage the value of any company assets and to not lose any company assets.
If I have any questions or inquiries regarding the handling of company assets, or
if I discover any potential damage to company assets, I will promptly report orconsult thereon with my superior or the department in charge of those assets.

Examples of consequences for violating or deviating from these Policies
If an officer or employee damages the value of any company assets on purpose,
Murata may take action to hold the officer or employee civilly and criminally liable
for such acts as required. Further, such acts may have a serious effect not only on
the company but also on its customers and suppliers.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

Murata Group: Murata Corporate Ethics Policy and Code of Conduct

18

Information Security
We will appropriately store, use, and dispose of confidential
information prepared by the company or obtained from others(e.g., customers and suppliers). Further, we will not illicitly obtainthe confidential information of others.

Information is one of Murata’s assets and sources of profit. We handle a wide
range of confidential information of the company (including its group companies)
and others on a daily basis. Such confidential information must be appropriately
obtained, prepared, stored, used, and disposed of in accordance with the internal
rules so that it is not published, disclosed, or leaked outside of the company.
Further, sufficient care must be taken against external cyber attacks,

Appropriate and Required Individual Actions in the Workplace
I will use the information held by the company only for the purpose of conducting business. I will also use the confidential information of others only for theapproved purposes.

unauthorized access, and theft. If an information security incident (e.g., any

I will not disclose, leak, or use any confidential information of Murata or others thatleakage, loss, theft, alteration, or destruction of information) occurs, thethey have come to know in the course of business, even after I leave Murata.

company will be responsible for taking appropriate action immediately.

In order to prevent information security incidents, I will strictly manage and appropriately handle information held by the company in accordance with the internal
rules. Further, when deleting or disposing of information, I will properly destroy the
information in such manner that such information cannot be restored.
When I am considering obtaining the confidential information of others, I will
examine the necessity for obtaining that information and obtain it throughlegitimate means. Further, when handling the confidential information ofothers, I will take measures equivalent to those taken to protect the compa-

Examples of consequences for violating or deviating from these Policies
If an officer or employee illicitly obtains, leaks, loses, steals, alters, or destroys
any confidential information, in addition to Murata, the individual officer or
employee may also be held civilly liable for such acts, or they may be subject tocriminal or administrative punishment. Further, such acts may have a serious
effect on not only the company but also on its customers and suppliers.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

19ny’s confidential information in order to maintain confidentiality and prevent
information security incidents.
I will actively participate in education and training related to information
security.
If I discover any actual or possible information security incident, I will promptly
report or consult thereon with the relevant General Administration Department
in charge of information security through my superior.

Protection of
Personal Information
Recognizing it as our important responsibility to protect thepersonal information of others (e.g., customers and suppliers) andour employees, we will ensure the appropriate handling of such
personal information in accordance with the applicable laws,
regulations, and internal rules.

“Personal information” refers to information which enables personal
identification by name, date of birth, address, photograph, or the like. Since many
countries and regions have laws, regulations, and guidelines regarding personal

Appropriate and Required Individual Actions in the Workplaceinformation with differing definitions and required measures for personal

I will handle all personal information with the utmost care. I will comply withinformation protection, it is important to confirm and comply with these laws,

all laws, regulations, and internal rules regarding the handling of personal

regulations, and guidelines and handle personal information appropriately.

information.
I will acquire personal information in accordance with laws and regulations andby fair means, and will announce, clearly define, or notify such acquisition to theperson concerned or obtain that person’s consent when doing so.
I will clarify the purpose of obtaining personal information and will use such
personal information within the scope of the purpose of use for which it was
obtained.

Examples of consequences for violating or deviating from these Policies
If an officer or employee fails to protect personal information or handles it inappropriately, or if an officer or employee leaks, loses, or alters personal information,
the laws and regulations of the relevant country or region will apply. In addition to
Murata, the individual officer or employee may also be held civilly liable for suchacts, or they may be subject to criminal or administrative punishment. Further,
the company’s credibility could be affected, resulting in a significant impact on its
business.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

If I receive an inquiry, complaint, or consultation request from a person
regarding their personal information retained by the company, I will respond
appropriately.
Any leakage, loss, or alteration of personal information constitutes aninformation security incident. If I discover any actual or possible information
security incident, I will promptly report or consult thereon with the relevant
General Administration Department in charge of information security throughmy superior.
Murata Group: Murata Corporate Ethics Policy and Code of Conduct

20

Respect of Intellectual
Property Rights
We will endeavor to create, protect, and strategically utilize intellectual property (including trade secrets and technical know-how).
We will also respect the intellectual property rights of othersand endeavor not to infringe them.
Intellectual property is an important company asset for us, a company that
performs integrated production from raw materials to products. We are actively
promoting worldwide intellectual property activities, such as aiming to build aglobal intellectual property portfolio that enables us to promptly protect andstrategically utilize the intellectual property we create. In addition to patents,
utility models, designs, trademarks, and copyrighted works, which are protected

When new intellectual property (such as an invention, idea, or design) is createdas intellectual property rights under the laws and regulations of each country

in the course of business, I will promptly report such intellectual property to theand region, we also emphasize the protection of expertise to allow us to protect

relevant Intellectual Property Department in accordance with the internal rules.

our manufacturing capabilities, which is Murata’s strength.
At the same time, we will make sure to protect all intellectual property rights
when transferring technology or know-how, and we will also respect the
intellectual property rights of others by endeavoring not to use them without
permission nor infringe them.
*Intellectual property rights: patent rights, utility model rights, design rights, trademark
rights, copyrights, etc.

Examples of consequences for violating or deviating from these Policies
If an officer or employee uses the intellectual property of others without permission or infringes those intellectual property rights, the officer or employee may
be subject to a claim for damages or an injunction from the original intellectual
property rights owner. Particularly, if Murata has expanded its business by utilizing
the intellectual property of others, it may be difficult to continue the business
depending on the details of the injunction. Further, Murata and the individual
officer or employee may be held civilly liable for the infringement of intellectual
property rights, or they may be subject to criminal or administrative punishment.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

21

Appropriate and Required Individual Actions in the Workplace

When launching a new product or service to the market or publishing a
copyrighted work, I will confirm whether they are infringing the intellectual
property rights of others.
If I discover any issue involving intellectual property, such as infringement by others ofintellectual property rights held by the company or infringement by the company ofintellectual property rights held by others, or if I have any suspicion thereof, I will promptly
consult thereon with my superior or the relevant Intellectual Property Department.
If I intend to disclose, lend, transfer, or sell any work-related intellectual
property to others, I will obtain prior approval from the relevant Intellectual
Property Department in accordance with internal rules.
If I have any doubts as to whether a matter that I handle (regardless of whether
it is matter relating to Murata or a third party) constitutes intellectual property,
I will, after confirming the internal rules, consult thereon with my superior or the
relevant Intellectual Property Department.

Section 2 Co-prosperity with our Stakeholders
We will seek sustainable value creation through dialog
and the co-creation of value with our stakeholders.

Murata Group: Murata Corporate Ethics Policy and Code of Conduct22

Quality and Safety of
Products and Services
We will comply with all laws, regulations, and standards on
product safety and provide high-quality and highly safe products
which exceed our customers’ expectations.

Appropriate and Required Individual Actions in the Workplace
In addition to complying with relevant laws and regulations on product quality
and safety and satisfying the agreements and agreed upon terms with our customers, I will practice science-based management oversight, which optimizes“Good devices come from good components, and good components come fromall of our business processes, people, materials, methods, and technologies,

good materials.”starting from the origins of our processes and throughout the operation.

“If we practice scientific management, we can deliver quality, on time, with no
mistakes.”
These are the words of our founder Akira Murata.
We have created integrated manufacturing systems from our materials tofinished products. Since the company’s founding, in addition to complying withlaws, regulations, and standards on product safety, we have uncompromisingly
pursued quality that will gain the trust of every customer by utilizing
science-based management oversight*, starting from the origins of our processes
and throughout the operation. In order to realize the foregoing, we adopted ourI will practice “Upstream Management,” which clarifies what to do in eachprocess and to ensure no problem are left behind. I will seek out the true causeof problems that arise by drilling down beyond the superficial factors of suchproblems to understand the root cause factors for the problems and takeappropriate measures.
I will endeavor to practice “Prevention” by estimating risks of all potential
problems, and implementing appropriate measures.

“Quality Policy” and established the M-QMS (MURATA Quality Management

I will practice “Continual Improvement,” in which we will maintain an awareness

System). Each and every one of us will enhance the quality of our work with aof targets, implement repeated PDCA (Plan → Do → Check → Act), and enhancefeeling of motivation based on the M-QMS and seek satisfaction for our customers

the quality of work to enable the continuous provision of products and services

and society by delivering high-quality and safe products to our customers.

that meet the expectations and needs of customers.

Examples of consequences for violating or deviating from these Policies
In addition to the product safety and specifications (performance) of products
stipulated in our agreements and agreed upon terms with our customers,
compliance matters under the relevant laws and regulations of each country
and region have also been established. If a defect in a product arises as a resultof any violation of such laws or regulations on purpose and such defect damages
the life, body, or property of a customer or the like, Murata may be subject tocivil liability or to criminal or administrative punishment or disposition. Further,
the individual officer or employee who committed such violation on purpose
may also be subject to civil liability or criminal punishment.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

23*Science-based management oversight: These words are taken from the Murata
Philosophy. This means thinking as quantitively, logically, and reasonably as possible not
only by utilizing inspiration, experience, or intuition, but also by using scientific analysis.

I will take product quality complaints as a serious “voice of the customer” (VOC)
matter for our business, and will promptly notify the relevant departments andrespond quickly to such complaints. In addition, what I learn through complaints
will be horizontally communicated throughout the company to prevent themfrom occurring again.
I will not conduct any act to misrepresent product quality or safety (including
the use of false or inaccurate performance data or test results). If a deficiency
in the quality or safety of a product could harm any life, body, or property, I willpromptly report or consult thereon with my superior or the relevant Quality
Assurance Department.

Respect for Human Rights
As a global company which develops its business throughout
the world, we respect the human rights of all people along ourvalue chain and will not be complicit in any human rights violations.
As a global company which develops its business throughout the world, we
declare that we will properly understand the international standards regarding
human rights and the laws and regulations of each country and region where we
conduct business. We also declare that we will always act with respect for humanrights, not be complicit in any human rights violations, and will strive to prevent
any negative impact on human rights. In addition to the human rights of ouremployees within the Murata Group, we will endeavor to ensure that the humanrights of all people directly involved in our business activities, products, services,and the human rights of those involved through transactions therewith, arerespected.*
In our “Human Rights and Labor Policies”, we prohibit forced labor and child laboras well as any form of discrimination and harassment in the workplace of all
people involved along our value chain. We also understand the importance ofequal employment opportunities and treatment, the freedom of association,

Appropriate and Required Individual Actions in the Workplace
I will understand and comply with all internal rules related to human rights,
including our “Human Rights and Labor Policies”.
I will respect the basic human rights of all people that I meet in the course of
their work and will treat those people with respect. I will also accept the beliefs
and values of people with different experiences.
I will not engage in any discriminatory conduct. In addition, I will not engage
in any acts of harassment, including sexual harassment (such as engaging insexual behavior or using sexual language) or workplace bullying (such as using
one’s authority as a pretext to engage in bullying language or behavior). I willcollective bargaining rights, and labor-management dialogue.

respond firmly to any form of sexual harassment and workplace bullying.

*This includes the human rights of not only the people inside Murata, but of all people such as
suppliers, customers, end-users, everyone in the local community (around the locations andareas where we procure materials), and individuals who desire to be employed at Murata.

I will consider whether a judgement, decision, or act in their work has a negative

Examples of consequences for violating or deviating from these Policies

I will ask about the impact of our business, products, and services on the human

If Murata infringes the human rights of any rights holders along our supply chain
or value chain as the result of a violation of internationally recognized standards
or the laws, regulations, or standards of the country or region where we conduct
our business activities, or if Murata takes any act which disregards human rights,
in addition to civil or criminal liability, Murata may also be subject to administrative
punishment. Further, Murata may be exposed to harsh social criticism, and its
reputation and trustworthiness may be significantly damaged.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

impact on the human rights of a third party.

rights of third parties.
If I become aware of any child labor, forced labor, discrimination, harassment,or any other act considered to infringe on the human rights of others, or I feelthat the provision of reasonable accommodation to minority individuals within
Murata and its supply chain is insufficient, I will promptly report and consult
thereon with my superior, the relevant Human Resources Department, therelevant Legal Department, or any other relevant department.
Murata Group: Murata Corporate Ethics Policy and Code of Conduct

24

Donations and Sponsorship
We will contribute to local communities through responsible
donations, sponsorships, and the like.

We hope to continue to be “a company whose presence in local communities is asource of pride and joy to those communities as well as a company that ouremployees are proud and happy to work for.” Based on this philosophy, we valuecommunication with local residents and conduct activities including donations
and sponsorships, which contribute to and meet local needs. We have determined

If I am considering a company-sponsored donation or sponsorship, I will consult
thereon with the relevant General Administration Department.

5 categories to be our “priority areas,” “support for the development of the next

I will take sufficient care to ensure that a donation or sponsorship does not

generation,” “local community support,” “environmental protection,” “cultural

result in any fraud. If I find the potential for any improper conduct or the poten-

support,” and “academic support”.

tial for complicity in any improper conduct, I will promptly report and consult

On the other hand, depending on their content, donations and sponsorships may

thereon with my superior or the relevant General Administration Department.

lead to the risk that Murata will have an improper connection with politics, religion,or the like. Therefore, when providing a donation or sponsorship, we will follow ourinternal approval process, ensure transparency, and adequately take into
consideration the necessity and appropriateness thereof. As specified in these
Policies, we will also prevent any improper conduct, including bribery, politicalcontributions meant to unjustly pressure the recipient or for other improper
purposes, and any complicitly in such improper conduct.

Examples of consequences for violating or deviating from these Policies
If Murata conducts any bribery under the guise of a donation or sponsorship,
Murata and the individual officer or employee who committed such act may besubject to criminal or administrative punishment. This may also lead to significant
damage to the trustworthiness of the company. Further, since this may adversely
affect our trustworthiness, Murata may be refused business by private companies
or held liable for the breach of our representations and warranties.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

25

Appropriate and Required Individual Actions in the Workplace

Dissemination of Information
and Communication
We will endeavor to disseminate appropriate corporate information, including financial information and non-financial information, and will maintain good communication with the public.

* “Accurate Recording and Reporting of Financial Information and Appropriate Tax
Payment” on page 16 with respect to information disclosure based on relevant laws andregulations.

Companies cannot operate without social trust.

Appropriate and Required Individual Actions in the Workplace

In order to be a highly transparent company, we will accurately disclose financial
information and timely disclosure information* based on relevant laws andregulations and the various rules regarding information disclosure. In addition, we
will proactively disseminate non-financial information such as our Murata
philosophy, process of value creation, and information on work safety and hygiene,
environmental

activities,

humanrights,CSR

procurement,social/local

contribution activities, compliance systems, and information security. We will
fulfill our accountability to society by fairly and impartially disclosing information
which is deemed to be important for society, even if such information isdetrimental for us. Further, we believe that it is necessary to sincerely listen to the

I will be aware that any and all communication made inside and outside thescope of my duties may affect Murata’s trustworthiness, corporate value,
brands, or the like, and may also contribute to the creation of new value for
Murata. Therefore, communication is an important activity for putting the
Murata Philosophy into practice and for realizing sustainable growth.
I will not leak any undisclosed information that I have come to know in theperformance of duty or conduct any improper information dissemination which
may damage the brands of other companies.

voices of our stakeholders, such as customers, shareholders/investors, suppliers,

When disseminating information on behalf of Murata, I will communicate

local communities, and employees, and to respond to their requests.

information that is useful and proper for our stakeholders within the scope of

By conducting proactive disclosure of our corporate information andthe authority and instructions Murata provides.

continuously communicating with our stakeholders, we seek to create new value,
and we will put the Murata Philosophy into practice and realize sustainablegrowth.

Examples of consequences for violating or deviating from these Policies
If we do not accurately disclose our information based on relevant laws andregulations and the various disclosure rules, Murata may be subject to civil liability
and criminal or administrative punishment. In addition, Murata may be unable tomaintain its listings on relevant stock exchanges or receive a proper evaluationfrom our stakeholders, which would cause Murata to lose its trustworthiness.
Further, liability may be imposed directly on individual officers or employees.

When communicating with our stakeholders, I will be aware that my statements will be deemed to represent Murata, and will take care to communicate
appropriately and in good faith.
When communicating with our stakeholders, I will respect the opinions,
identities, and privacy of those stakeholders.
I will sincerely listen to the voices of our stakeholders obtained from communications and will reflect those voices in our business activities as appropriate.

*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

Murata Group: Murata Corporate Ethics Policy and Code of Conduct

26

Respect for Diversity
We will continue to be an “Innovator in Electronics” through thepromotion of DEI (Diversity, Equity, and Inclusion).

We specify “contribute to the advancement of society” in the Murata Philosophy.
The promotion of diversity is essential in order to maximize the innate talents andabilities of each diverse employee and put the Murata Philosophy into practice. In
addition to diversity that can be seen, such as ethnicity, nationality, gender, andage, we recognize that diversity that cannot be seen, such as thought, knowledge,
experience, and perspective, must also be respected.
We recognize that each employee has a different starting point. We arecommitted toward establishing working environments, support systems, andstimulating an awareness of these that allow all of our diverse employees to standside by side at the starting line (equity).
Through engaging in diversity and equity, we will improve Murata’s innovationand competitiveness, and each and every employee will work to co-prosper withour collaborators, bringing out their own unique strengths.

Appropriate and Required Individual Actions in the Workplace
In addition to diversity that can be seen, such as ethnicity, nationality, gender,
and age, I will not discriminate against and will mutually respect, accept,
and recognize as individual diversity that cannot be seen, such as thought,
knowledge, experience, and perspective.
I will endeavor to stimulate an innovative, positive, comfortable, and healthy
working environment where individuals can be confronted with diverse
viewpoints, different thoughts, and opposing opinions with peace in mind.

Examples of consequences for violating or deviating from these Policies
Not respecting diversity may lead to the disrespect of human rights. Further,losing the chance to leverage diversity in human resources may result in a decline
in Murata’s competitiveness and the loss of business opportunities.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

27

If I see or notice any act which does not accept diversity, I will express my
opinion directly and in good faith to the person who conducted such act, andwill provide support to person affected by such act. If such an act is equivalent
to discrimination or harassment, I will promptly report and consult thereon
with my superior, the relevant Human Resources Department, or the relevant
Legal Department.

Health and Safety
We will comply with all laws and regulations on occupational
health and safety and endeavor to ensure a secure and safe working environment and the health of our employees.
Ensuring workplace health and safety and maintaining appropriate workplace
conditions are our significant responsibilities.
The foundation of CS and ES*, which are the most important values of Murata, isthe health of employees and a secure and safe workplace. Based on thisunderstanding, we aim to establish a working environment where all employees
can work while feeling that they are healthy.
In order to realize our goals, we will identify potential risk sources regarding
health and safety from various perspectives, including ergonomics. We willconduct risk identifications and risk assessments and systematically implement
measures and improvements based on the results thereof. We will also provide
the necessary education and training in order to make such initiatives sustainable.
Should an industrial incident/disease or an emergency occur, in addition to
identifying the situation and implementing emergency countermeasures, we willpromptly spread those countermeasures horizontally throughout the company
and endeavor to prevent a recurrence of the incident.

*At Murata, CS means “continuing to create and provide value that isrecognized by the customer” and ES means “every employee achieves
satisfaction and continuing growth through the performance of theirwork duties.”

Appropriate and Required Individual Actions in the Workplace
I will comply with all laws and regulations and internal rules regarding occupational health and safety.
Murata strongly encourages to maintain and improve the employees’ healthconditions so that they can concentrate on their work.
I proactively participate in professional activities and education related tomaintaining and improving safety and physical and mental health, and I will

Examples of consequences for violating or deviating from these Policies

endeavor to take the proper actions.

In addition to the matters related to occupational health and safety stipulated
in the internal rules, compliance matters concerning occupational health andsafety are also stipulated in the relevant laws and regulations of each country.
If an officer or employee violates any law or regulation concerning occupational
health and safety, such violation may result in a serious industrial incident or harmto the physical and mental health of employees. As a result of any such incident
or employee harm, Murata may be subject to the pursuit of civil responsibility or
criminal and administrative punishment resulting from it. In addition, any relevant
individual involved may be subject to criminal and administrative liability.

I welcome and encourage good communication with the employees and society*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

to aim for a condition of social well-being in which our “mind,” “body,” and“relationship between the employees and society” are in harmony.
If I find any act which will, or is likely to, damage workplace safety or health orcause any other problem in the working environment, I will endeavor to ensure
safety, while giving first priority to saving human life, and promptly report andconsult thereon with my superior, the relevant Safety and Health Department,
and any other relevant departments, and request response measures.
Murata Group: Murata Corporate Ethics Policy and Code of Conduct

28

Relationship with our Suppliers
Based on the Basic Procurement Policies underpinned by theprinciples of “legal compliance,” “fairness,” “impartial andhonest,” and “social responsibility”, Murata has been building
partnerships with its suppliers, working to realize mutually satisfying and prosperous relationships across our supply chain.
Suppliers are one of the essential partners for our business activities. In order torealize mutually satisfying and prosperous relationships with suppliers, the Basic
Procurement Policies stipulates the meaning of “legal compliance,” “fairness,”“impartial and honest,” and “social responsibility” as follows.

I will provide suppliers with broad and impartial opportunities and conduct fair
supplier evaluations.
I will conduct fair transactions with suppliers without unjustly treating suppliersor abusing our dominant bargaining position.
I will fairly and equitably evaluate and select suppliers based on rational
criteria such as consideration for quality, delivery date, continuation of supply,

1. Legal compliance2. Fairness

business conditions, product technical capabilities, human rights and labor,

We observe laws and ordinances,
regulations, and company rules,
and we conduct business inaccordance with social ethics.

We broadly open the door on a
global level and strive for equality
in business opportunities.

Plan, and information security.

3. Impartial and honest

4. Social responsibility

We build relationships of trustand cooperation with suppliers
and aim to develop strong
partnerships with suppliers.

We fulfill our social responsibility
with respect to human rights andthe environment, etc. through our
procurement activities.

Examples of consequences for violating or deviating from these Policies
If Murata neglects to build partnerships with its suppliers which work to realize
mutually satisfying and prosperous relationships across our supply chain, this maylead to a decline in Murata’s product quality and competitiveness in our businessactivities, and it may also lead to the loss of trust of our stakeholders. Any act toimpose transaction conditions which unilaterally disadvantage a supplier or any
act to treat a supplier in a discriminatory manner in connection with the selectionof a contract partner may violate applicable Antitrust Laws.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

29

Appropriate and Required Individual Actions in the Workplaceenvironmental conservation, safety and health, ethics, Business Continuity

Contribution to
the Global Environment
In addition to recognizing the impact of our business activities andproducts on the global environment and complying with all environmental laws and regulations, we will conduct business activities
and provide products in harmony with the environment globally.
We aim to contribute to the development of culture through co-creation withpartners, realize manufacturing that harmonizes with society, and contribute to
the environment globally through our business activities and by providing products
which are environmentally conscious.
Murata will obtain any and all required permits and licenses from administrative bodies
related to environmental conservation, and even after obtaining such permits andlicenses, we will comply with the standards necessary for environmental conservation.
We will control chemical substances in accordance with laws and regulations. In
addition, we will minimize the environmental impact of wastewater, sludge,
exhaust and other pollutants through adherence to our voluntary standards inAppropriate and Required Individual Actions in the Workplace

addition to compliance with relevant laws and regulations. We will reduce

I improve my environmental awareness through proactive participation ingreenhouse gas emissions and waste by appropriately monitoring and managing

professional training related to the environment and by confirming my businessthem and setting up voluntary reduction targets.

activities and conduct my daily professional life from an environmental conser-

We will establish and implement the management system to promotevation perspective.

environmental activities based on the Plan-Do-Check-Act (PDCA) cycle andreduce the environmental impact in a product’s life cycle, including in research anddevelopment, manufacturing, distribution, use, and disposal.

Examples of consequences for violating or deviating from these Policies
If Murata cannot meet the expectations and requirements regarding ourcontribution to the global environment, this may lead to a decline in Murata’s
competitiveness in our business activities, and it may also lead to the loss oftrust of our stakeholders. Any violation of environmental protection laws may
result in criminal or administrative punishment against Murata.
*In addition to the content stated above, officers or employees who violate or deviate from these Policies may besubject to disciplinary measures in accordance with internal rules and relevant laws and regulations.

I promote co-creation with business partners and take on the challenges oftechnical development or innovation in order to conduct business activities
and provide products for the sustainable global environment.
I actively participate in professional preservation activities for the global
environment.
If I find the possibility that laws and regulations and internal rules are being
violated, or if any doubt regarding our position on the environment arises,
I will promptly report and consult thereon with my superior, the relevant
Environmental Department, or the relevant Legal Department.
Murata Group: Murata Corporate Ethics Policy and Code of Conduct30

Publisher : Murata Manufacturing Co., Ltd.
Ver. April 1, 2024