NESIC Group Code of Conduct
Version 4
December 2019
NEC Networks & System Integration Corporation

Contents.
What is the NESIC Group Code of Conduct?

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General Provisions

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Scope of application
Establishment and revision
Compliance with the Code of Conduct
Consequences of Violation
Operational system

１． Basic Position

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Acts in good faith based on high ethical standards
Awareness and responsibility as an employee of an ICT company
Coexistence with local communities
Fair relationship with stakeholders
Prohibition on any act contrary to the Company's interests

２． Respect for Human Rights

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Respect for human rights
Respect for privacy
Respect for each other’s way of life

３． Environmental Preservation

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Global environmental preservation using advanced technology and creation ofa sustainable society
Measures taken by each individual

４． Business Activities with Integrity
Safe and reliable quality for all customers
Information disclosure to, communication and joint creation with stakeholders
Fair competition
Relationship with distributors
Prevention of bribery and corruption
Responsible procurement
Entertainment, gifts, donations, and political activities
Prohibition against involvement in antisocial acts
Management of import and export
Responsibility as a construction businessp.6

Sincere publicity and advertising
Accurate financial reporting
Response to emergency

５． Management of the Company's Assets and Information

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Management and proper use of the Company's assets
Management of confidential information
Management of personal information
Prohibition on insider trading
Protection and utilization of intellectual property rights

Consultation and Report on Doubts and Concerns about Compliance
Strict Maintenance of Confidentiality
Prohibition against Retaliation

NESIC Group Code of Conduct

What is the NESIC Group Code of Conduct?
In order to realize a sustainable society, the NESIC Group contributes to solving our customers' issues andadvancing the resolution of social issues through the power of ICT, and thereby continues promoting our valuesof safety, security, fairness and efficiency.
To provide our customers and society with excellent value, we need to have “Integrity”, or in other words, highethical standards and sincerity, as a foundation for all of our actions. This Code of Conduct provides detailed
guidelines for this “Integrity”.
As a member of the NESIC Group, we promise to comply in good faith with this Code of Conduct so as to beconnected with people all over the world, beyond boundaries, and to enable the solving of social issues andsustainable economic growth for the future.

General Provisions
Scope of application
This Code of Conduct shall apply to all officers and employees of each company in the NESIC Group (including
fixed-term contract employees, temporary employees, and part-time employees). The “NESIC Group” refers
to NEC Networks & System Integration Corporation and its consolidated subsidiaries.
Establishment and revisionThis Code of Conduct shall be established or revised upon approval of the Board of Directors of NEC Networks& System Integration Corporation, following deliberations by the Management Quality Improvement
Committee of NEC Networks & System Integration Corporation. Each company in the NEC Networks & System
Integration Group may partially amend the content of this Code of Conduct to the extent that such amendment
is consistent with this Code of Conduct, and apply such amended Code of Conduct to its officers andemployees upon approval thereof by the Board of Directors of such company.
Compliance with the Code of Conduct
Officers and employees are required to comply with this Code of Conduct. The officers, General Manager ofeach division, and managerial personnel shall take leadership in implementing this Code of Conduct anddeveloping an open culture in their organization, and also provide advice and guidance to employees to ensurethat they comply with the provisions set forth in this Code of Conduct. Relevant divisions shall establish inhouse policies, guidelines and behavior manuals, promote awareness of specific rules to be observed, provide
advice and guidance, and perform other necessary activities.
Consequences of Violation
In cases where an officer or employee violates this Code of Conduct, such officer or employee may be subject
to disciplinary action in accordance with applicable laws and regulations, and in-house policies. If the Companysuffers any loss or damage caused by such violation, the Company may make a claim for damages and takeother legal actions.
Operational system
This Code of Conduct shall be supervised by the Legal & Compliance Division of NEC Networks & System
Integration Corporation, which shall promote compliance with this Code of Conduct in cooperation with relevant
NESIC Group companies and divisions. The Corporate Auditing Division of NEC Networks & System
Integration Corporation shall audit the status of compliance with this Code of Conduct.

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NESIC Group Code of Conduct

1. Basic Position
Acts in good faith based on high ethical standards
I will comply with international rules, applicable laws and regulations, this Code of Conduct, and in-housepolicies and guidelines in every aspect of the Company’s activities at all times, and also understand the culturesand customs of countries and regions, and act in good faith in accordance with a good social conscience basedon high ethical standards.
Awareness and responsibility as an employee of an ICT company
I will recognize my responsibility as an employee of the Company that creates new value through ICT, and will
actively and appropriately utilize ICT. In addition, I will fully understand the value and importance of informationand ensure to respect human rights in data utilization and to implement information security including
measures against cyber-attacks, and thereby will aim to earn trust from customers and society.
Coexistence with local communities
I will always accept social demands in a modest and sincere attitude, and act so as to contribute to thedevelopment of local economies, cultures and education through our business and community-based
corporate citizen activities.
Fair relationship with stakeholders
I will maintain a fair, equitable, and transparent relationship with stakeholders and will not perform any act ofcorruption, collusion, coercion or fraud, or any other misconduct.
Prohibition on any act contrary to the Company's interests
I will not perform any act pursuing my own or a third party's interests contrary to the Company's legitimate
interests or any act that may damage the trust or honor of the NESIC Group or cause any loss or damage tothe Company.

2. Respect for Human Rights
Respect for human rights
I will understand the Universal Declaration of Human Rights and other international human rights standards
and respect human rights. I will not allow any act that may be prejudicial on the grounds of race, beliefs, age,social position, family origin, nationality, ethnicity, religion, gender, sexual orientation and gender identity, ordisability, or any act that may offend the dignity of any individual such as bullying, harassment, child labor, orforced labor.
Respect for privacy
I will respect the private information of individuals that is acquired at the workplace or in the course of myduties. In addition, I will pay the utmost attention to ensure that our business activities that solve social issues
by utilizing ICT do not cause any privacy or other human rights issue.
Respect for each other’s way of life
I will respect the diverse characteristics and values of my colleagues and other stakeholders, thereby I will
create and encourage others to create new social value and innovation. In addition, I will aim to keep a balance
between my work and private life by utilizing ICT to diversify work styles and improve productivity and thereby
realize my way of life filled with cheer and hope.

3. Environmental Preservation
Global environmental preservation using advanced technology and creation of a sustainable society
I will aim to reduce the impact of climate changes and environmental loads, to promote recycled resources
and to preserve biological diversity together with our customers and through our business activities by
providing ICT solutions and services using our strengths in advanced technology, thereby contributing to thecreation of a sustainable society.
Measures taken by each individual
For the sustainable use of limited resources, I will implement what each of us can do, such as saving energy,reducing the amount of waste, and properly separating waste for reuse or recycling.

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4. Business Activities with Integrity
Safe and reliable quality for all customers
I will always endeavor to satisfy our customers and pay full attention to the safety and quality of our solutions
and services. In addition, I will aim to realize a sustainable society in which the benefits of ICT can spread toall people by provision of our solutions and services that adopt diversifying individual and social perspectives
and also have universal design.
Information disclosure to, communication and joint creation with stakeholders
I will appropriately and actively disclose corporate information to stakeholders and also communicate withthem in a way that goes beyond boundaries to create new value and solve social issues.
Fair competition
I will recognize the importance of fair and free competition in the market, and will not engage in any unjust
restrictions on transactions, such as collusion and cartels, any unfair transactions, or any act that may beconstrued as doing any of the above.
Relationship with distributors
I will always carry out transactions in good faith with our distributors and in a fair and equal manner. I will not
engage in any unfair or discriminatory treatment, acts of exclusion, restriction on business activities, or any
other act of bad faith. In addition, I will encourage our distributors to act in accordance with this Code ofConduct.
Responsible procurement
I will always carry out transactions in good faith with our suppliers in a fair and equal manner. I will not seek
personal gain or carry out any transaction that causes another party to suffer an inappropriate disadvantage
due to the abuse of a superior position. In addition, I will encourage our suppliers to act in accordance with thisCode of Conduct.
Prevention of bribery and corruption
I will not be involved in any act of corruption with other parties, including public officials and government officials,
in any country or region where we do business.
Entertainment, gifts, donations, and political activities
I will maintain a sound relationship with other parties, including public officials and government officials, in allcountries and regions where we do business, and will not provide or receive any entertainment or gift beyond
the extent reasonable under social convention. With respect to donations, political funds, and political activities,
I will fully consider the necessity and validity thereof and comply with applicable laws and regulations.
Prohibition against involvement in antisocial acts
I will not have any relationship with antisocial organizations or entities and will not perform any act that may
promote the activities of such entities.
Management of import and export
In order to maintain international peace and safety, I will properly carry out the import and export of products,
technology, and services in compliance with applicable domestic and international laws, rules, regulations, andeconomic sanction measures.
Responsibility as a construction businessAs a member of a group of companies engaged in the construction business, I will carry out the construction
business in compliance with the Construction Industry Law, Occupational Health and Safety Law and otherrelevant laws and regulations.
Sincere publicity and advertising
I will accurately indicate the quality, performance, and specifications of solutions and services in our publicity,advertising, and all other sales activities to avoid misleading expressions, and will not use any expression that
may be slanderous, libelous, or socially discriminatory.
Accurate financial reporting
I will keep all financial records, accounting records, and all other records accurately and fairly. I will not perform
accounting processing in an improper manner or any other act that may cause any loss or damage to theCompany.
Response to emergency
In the event of a disaster, such as a natural disaster, a cyber-terrorist attack, or infectious disease, as a memberof a group of ICT companies that supports society with its advanced technology, I will endeavor to bring about
the early recovery of social infrastructure and minimize the impact on stakeholders. In addition, I will realize awork style that allows for business continuity by utilizing ICT.
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5. Management of the Company's Assets and Information
Management and proper use of the Company's assets
I will properly manage the Company's assets (tangible and intangible) and will not use them for private
purposes or any other purpose unrelated to the Company's business operations.
Management of confidential information
I will strictly manage the confidential information of internal and external parties that is acquired in connection
with my duties or business transactions and will not disclose or divulge such information in a manner that
violates the procedures stipulated in in-house regulations or improperly or unjustly use such information not
only during my employment at the Company but also thereafter.
Management of personal information
I will recognize the importance of protecting personal information and appropriately obtain, use, provide anddestroy personal information. In addition, I will take necessary and appropriate security measures for thepersonal information handled so that I will prevent or recover the leakage, loss or destruction of such personalinformation.
Prohibition on insider trading
I will not use non-public information of the NESIC Group or other companies acquired through the executionof my duties or business transactions for the sale or purchase of marketable securities, including the tradingof stocks. In addition, I will not abuse such non-public information to provide any form of benefit or convenience
to a third party.
Protection and utilization of intellectual property rights
I will protect and maintain the intellectual property rights such as patent rights, copyrights, and trademarks thatare obtained from our research and development or other intellectual activities and will try to actively utilize
them. I will respect and not infringe or illegally use third party’s legitimate intellectual property rights.

Consultation and Report on Doubts and Concerns about Compliance
In cases where I am uncertain about this Code of Conduct, in-house policies and guidelines, or applicable laws
and regulations, or become aware of any act in violation thereof, I will not ignore it and will consult with mysuperiors or the relevant divisions to solve the issue. If I am unable to consult with my superiors or the relevant
divisions, I will contact the NESIC Corporate Ethics Hotline or a similar contact point of each company.
If I am requested by the Company to cooperate in investigating the matter consulted or reported, I will meetsuch request in good faith.
The Company will respond in good faith to such consultation or report.

Strict Maintenance of Confidentiality
The Company guarantees that the confidentiality of the facts and content of consultations and reports will bestrictly maintained in order to protect the person who has consulted or reported regarding such matter or has
cooperated in an investigation.

Prohibition against Retaliation
The Company prohibits any detrimental treatment of, or retaliation against any person who has consulted orreported on a matter or has cooperated in an investigation.

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