COMPLIANCE
GUIDELINE

Table of Contents
Introduction

Nippon Filcon Group Compliance Code .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 2What Is Compliance? .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 4Responsibility to Stakeholders  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 5What Is CSR? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
What Are SDGs?  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 7

1

2

3

Stakeholders

1-1
1-2
1-3
1-4

Sound Work Environment

2-1

Respect for Basic Human Rights  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 16
Reference: What Is Diversity? .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 18
Reference: What Are Gender, SOGI and LGBT? .  .  .  .  .  .  .  .  . 19
2-2
Proper Working Environment  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 20
2-3
Prohibition of Harassment .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 22
Reference: Types of Harassment That Are Prone to Occur in the Workplace .  . 24
2-4
Protection of Privacy .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 26
2-5
Prohibition of Forced Labor and Child Labor .  .  .  .  .  .  .  .  .  .  . 28

Honest Corporate Activities

3-1
3-2
3-3
3-4
3-5
3-6

3-7
3-8
3-9
3-10

4

Providing Products & Services that Maintain Quality and Safety .  . 8Honest Activities in Relation to Our Customers .  .  .  .  .  .  .  .  . 10
Engaging in Fair Competition and Transactions  .  .  .  .  .  .  .  .  . 12
Prohibition of Dishonest Acts .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 14

Outsourcing Contract Compliance (Prohibition of Disguised(Fraudulent) Contracting)  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 30
Meeting the Demands of Society  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 32
Prevention of Misconduct .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 34
Compliance with Tax Laws and Accounting Standards  .  .  .  .  . 36
Compliance with Trade-Related Laws .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 38
Compliance with Local Laws Overseas and Respect forOverseas Cultures and Customs .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 40
Cautions on Using Social Media .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 42
Protection and Use of Intellectual Property Rights  .  .  .  .  .  .  . 44
Management and Use of Buildings, Facilities, Equipment, Etc.  .  .  . 46
Use of Vehicles in Compliance with the Road Traffic Act andDriving Etiquette .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 48

Anti-Social Forces

4-1

Sever Connections with Anti-Social Forces .  .  .  .  .  .  .  .  .  .  .  . 50

5

6

7

8

９

Management of Company Information

5-1

Timely and Appropriate Recording and Disclosure ofInformation .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 52
5-2
Management of Company Information .  .  .  .  .  .  .  .  .  .  .  .  .  . 54
5-3
Prohibition of Insider Trading  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 56
Reference: What Is Insider Trading? .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 58
5-4
Inquiries from Various Media Organizations and Investors  .  .  . 60

Management of Personal Information

6-1
6-2
6-3

Management of Personal Information  .  .  .  .  .  .  .  .  .  .  .  .  .  . 62
Cautions on Using Email .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 64
Appropriate Use of IT .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 66

Prohibition of Bribery

7-1
7-2
7-3

Prohibition of Bribery and Inappropriate Entertainment  .  .  .  . 68
Prohibition of Bribing Foreign Public Officials, etc.  .  .  .  .  .  .  . 70
Limitations on Donations and Political Contributions  .  .  .  .  .  . 72

Safety and Environmental Conservation

8-1
8-2

Workplace Safety and Sanitation .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 74
Environmental Conservation Initiatives .  .  .  .  .  .  .  .  .  .  .  .  .  . 76

Contribution to Local Communities

9-1

Harmonious Relationship with Local Communities .  .  .  .  .  .  .  . 78

AppendixCompliance Hotline  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 80
The Main Penalties Related to Compliance Violations .  .  .  .  .  .  .  .  .  . 82

Revision of Compliance Guideline

As employees of the Nippon Filcon Group, we sometimes encounter various
compliance issues in our day-to-day work and are not sure how to resolve
them. We must face these issues head-on without running away from them.
Solving them may not be easy. However, by thinking about what is importantto the Nippon Filcon Group, we will likely realize the right course of action.
If you find it difficult to make legal or ethical decisions, please use thisCompliance Guideline to help you.
September 2022
Compliance Promotion Committee, Nippon Filcon Group1

Nippon Filcon Group
Compliance Code(Definition)
Article 2	"Compliance" as used in this code of Nippon Filcon Group means not
only to comply with laws and regulations, but also to follow an approachin line with corporate philosophy and social ethics, as well as to remainaware of the group's social responsibility to fulfill our stakeholders' trust.
(Scope of this code)
Article 3	This code shall apply to all directors, corporate officers and employeesof Nippon Filcon Group (hereinafter referred to as “we”).
(Corporate philosophy)
Article 4	We shall deeply understand and agree with each item of following ourcorporate philosophy and realize them in our daily activities.
・Pursue dreams and enjoy the pursuit in earnest
・Endeavor to stay one step ahead as leaders in productdevelopment and manufacturing
・Give back to society with gratitude and sincerity(Social mission)
Article 5	Our corporate purpose is to maximize the customer satisfaction, that is,
to provide the best value that meets the various needs of the industry.
And it is our mission to contribute society by always pursuing the top
level of the technology in the world and by providing innovative and highquality product and services continuously.
(Code of conduct)
Article 6	We shall perform daily activities in conformity with every item infollowing code of conduct.
1.	Strive for the sustainable development of fair, honest, and transparent
relationships with all stakeholders, including shareholders, customers,
business partners, and host community residents.
Related pages 1. Stakeholders
2.	R espect the basic human rights of all people, strictly refrainfrom behavior that demeans the dignity of individuals, and neverdiscriminate according to race, nationality, ideology, belief, age,gender, social status, or disability.
Related pages 2. Sound Work Environment
3.	In business activities, observe laws and internal regulations and do
not engage in behavior contrary to social justice or public order andmorals.
Related pages

2

3. Honest Corporate Activities

4.	Provide no benefits to and sever any relations with anti-social groups
that threaten the order and safety of civil society.
Related pages

Introduction

Introduction(Purpose)
Article 1	This code establishes the basic policies and management systems
related to compliance for Nippon Filcon Group in order to ensure
thorough compliance within the group.

4. Anti-Social Forces

5.	S trive for appropriate storage, management and disclosure ofbusiness information and do not engage in insider trading or othermisconduct.
Related pages

5. Management of Company Information

6.	Carefully store and manage information that constitutes trade secrets
and personal information and do not divulge such information to any
outside party without due cause during employment or after retirement.
Related pages

6. Management of Personal Information

7.	R efrain from exploiting an advantageous position in a business
relationship to make unreasonable demands or arbitrarily cause
a disadvantage to trading partners and from encouraging
entertainment or gift-giving that deviates from the commonly
recognized limits.
Related pages 7. Prohibition of Bribery
8.	Recognize that worker safety, industrial disaster prevention, and thepreservation of the environment must be maintained as the highest
priorities in business activities and pursue active contribution toconservation efforts and protection of the global environment.
Related pages 8. Safety and Environmental Conservation
9.	Pursue close cooperation and harmony with local communities andstrive to make community contributions.
Related pages

9. Contribution to Local Communities

10.	Make appropriate decisions and take appropriate action in keepingwith the Company’s corporate philosophy and social mission
imperatives with respect to matters not specifically mentioned in thisCode of Conduct.
(Operational system)
Article 7	In case of violation of the code or non-compliance, either intentionallyor by gross negligence, penalties will be imposed on the individual
according to law. Additionally, punishment will be given according to thecompany regulation.
(Revision or abolition)
Article 8	Revision and abolition of this regulation shall be made by resolution of
the board of directors.
Application and enforcement: December 1, 2007
Date of revision: December 1, 2015
Date of revision: June 1, 2019
Date of revision: September 1, 2020
Date of revision: January 1, 2024

3

Responsibility to Stakeholders

Compliance is often thought of as compliance with laws andregulations. However, the reality is that compliance is not only aboutcomplying with the stipulations of the law but it is also about meetingthe expectations of society. To meet the expectations of society,
you should understand that we must not only comply with laws andregulations but that we must also engage in honest business activities
that respect the rules, social decency, manners and morals. For
example, society requires us to follow work procedures, ensure aharassment-free workplace, maintain good relationships with those we
do business, and avoid causing inconvenience to anyone outside thecompany.
When a corporate scandal is discovered due to a compliance violation,
the problem does not rest with just the perpetrator, as the company
is also held accountable. Consequently, the company involved loses
credibility and suffers a great deal of damage.
Therefore, as company employees, it is important that we have astrong awareness of compliance and create a corporate culture that isable to prevent scandals from happening.
You may in fact face various compliance issues yourself in the future.
Even if faced with compliance issues, practicing compliance correctly
and continuing to be a trusted organization will lead to the growth ofthe company and the well-being of the people that work here.

Stakeholders are people or groups that are affected by corporate
activities and have an interest or concern in a business. Stakeholders
include customers, employees, suppliers, local communities,
government agencies and officials, and shareholders.
In addition to pursuing profits, companies must also meet the
expectations of these stakeholders. To achieve this, it is important
to be aware of the stakeholders that are affected by our corporate
activities.
Stakeholders’ expectations of companies vary depending on theirrespective position, such as expecting the company to provide
products that are useful for users in their everyday lives, to provide
financial benefits, to create stable employment opportunities, orto protect the local environment. Given that the interests of all
stakeholders are not necessarily the same, in the unlikely event thatthe interests of stakeholders come into conflict with one another, we
will judge our activities based on our mission and corporate philosophy.
In order for us as a company to continue to provide value to eachstakeholder and continue our business endeavors, we must practicecompliance as a member of society and carry out sound activities while
always being aware of the stakeholders.

Introduction

Introduction

What Is Compliance?

Oﬃcers &Employees

Ethics & Honesty
Suppliers

Customers

Social Decency,
Manners, Morals

Company

Company Rules

Local
Communities

Shareholders

Compliancewith Laws &Regulations

4

Government
Agencies5

What Are SDGs?

CSR (Corporate Social Responsibility) indicates the ‘social responsibilityof a company’, but what exactly is the responsibility of a company tosociety? The first responsibility of a company is to establish a businessso that the company can continue to exist. Consequently, it can besaid that creating jobs and paying taxes are important missions for acompany.
However, these are not the only activities and responsibilities thatcompanies are required to fulfill by society. CSR efforts include
activities in a wide range of fields such as the environment, social
contribution, and human rights. For example, devising measures toprevent human rights violations and environmental problems, andactively working on support for cultural causes and problems relating
to poverty. CSR can be said to be the attitude of a company to strive
to improve together with society.
It is not possible to promote CSR only by the people at the
management level. A company is made up of individual employees,
including part-time staff. To become a company that actively engages
in CSR, the way of thinking and actions of each of us at the company
are extremely important. And, what supports them is compliance.
Compliance is no longer just a term that means complying with laws
and regulations.
It is now the responsibility of companies to think and act in a waythat is useful for people, the environment, and society across a broad
spectrum.

SDGs refer to Sustainable Development Goals, which are international
goals that all countries and regions aim to achieve by 2030.
“Sustainable development” means achieving the following both now
and in the future:

Introduction

Introduction

What Is CSR?

● Securing employment through economic growth and promoting economic
growth by improving education and health● Preventing damage to the environment by improving the economy,
education, and health● Making an improved living environment and economic growth possible
through a rich natural environment

To achieve the above, the SDGs outline 17 goals (shown below) andeach goal has specific targets.
SDG initiatives have become an important concern not only for national
and local governments but also for stakeholders of companies andorganizations. A reason for this is that “sustainable development”
is required for the survival and growth of a company. Furthermore,companies that engage in SDGs earnestly are regarded highly bystakeholders.
Some of the 17 SDGs are related to compliance. Let’s work with theSDGs in mind to realize a sustainable and better world.

Corporate Social
Responsibility (CSR)
Social Decency,
Manners, Morals
Company Rules

Source: United Nations Information Center (UNIC)

Compliancewith Laws &Regulations

6

7

1 -1

Providing Products & Services that
Maintain Quality and Safety

Code of Conduct■ We Will Provide Products and Services Consideredfrom the Perspective of the Customer
We will provide products and services that please our customers. We will
always listen to what our customers have to say, thoroughly consider our
products and services from their perspective, and make any necessary
improvements and revisions.

■ Products or services that are highly functional and multifunctional, but do not consider ease of use.

■ Products or services that have not had their expected safety
fully checked.

Stakeholders

Stakeholders▌Our Promises

The following are examples of products and services that lack quality orsafety:11

Strive for the sustainable development of fair, honest, andtransparent relationships with all stakeholders, including
shareholders, customers, business partners, and hostcommunity residents.

Things We Must Not Do■ Products or services that have not been inspected as requiredby law.

■ Products or services for which their impact on the environment
when used or disposed of has not been considered.
■ Products or services for which the inspection process is omitted
in order to give priority to delivery dates.

■ We Will Provide Products and Services That Are Safe,
Reliable, and Environmentally Friendly
Products and services must be something that customers can use withpeace of mind.
We strive to provide products and services that are safe, reliable, andenvironmentally friendly, and comply with laws and ordinances, public
guidelines, and company rules.
Related laws

8

PL Act (Product Liability Act), Electrical Appliance and Material
Safety Act, etc.

9

1 -2

Honest Activities in Relation to Our
Customers

Code of Conduct

The following acts are examples of publishing incorrect information or
not acting in good faith:■ Concealing defects in products or services spotted after they
have been sold.

1

1

Strive for the sustainable development of fair, honest, andtransparent relationships with all stakeholders, including
shareholders, customers, business partners, and hostcommunity residents.

Things We Must Not Do▌Our Promises■ We Will Publish Correct Information Regarding Our
Products and Services
Our customers purchase our products and services because they trustus.
We will do our best to act in good faith without betraying this trust.
The disclosure of correct information is one of the essential actions wemust take. Concealing or misrepresenting information is an unacceptable
act that damages or puts our customers at risk.

Stakeholders

Stakeholders■ Forging the results of quality inspections.

■ Concealing important contract matters or indicating information
in a way that is intentionally difficult to understand.

■ Ignoring or lying in response to inquiries about products andservices.
False Indication of Food Production Area by a Manufacturing andWholesale Company of Agricultural Products

Bamboo shoots from China were labeled and sold as being from Japan.
Malicious tricks were used, such as using fake producer photos on productpackaging. The company was forced into bankruptcy and the president wasarrested.

Putting the safety of our customers first, we will thoroughly disclose
correct information with appropriate expressions and indications.

■ We Will Respond to Inquiries in Good Faith
We are accountable for the products and services we provide. When acustomer makes a complaint, we will respond sincerely without being
deceptive or making an excuse.
If there is something wrong, we will openly acknowledge it and respondin good faith, which will lead to developing a trusting relationship withour customers.
Related laws

10

Not
okay!

Unfair Competition Prevention Act, Act against Unjustifiable
Premiums and Misleading Representations, Consumer Contract
Act, Food Labeling Act (false labeling)

11

1 -3

Engaging in Fair Competition andTransactions

Code of Conduct■ We Will Compete and Trade in Compliance With the
Law
Companies operate to earn profits while complying with laws andregulations and industry rules. It is absolutely not acceptable to use
fraudulent means to make a profit.
We always compete and trade in a fair and just manner. In all corporate
activities, we will never carry out any act that violates the law.

■ We Will Value Our Business Partners
We value business partners who cooperate with us in our corporate
activities. Business partners are part of the driving force behind our
corporate activities.
We always do our business on equal footing with our business partners.
We will not abuse our superior bargaining position and force unfair
transaction conditions on other parties.
Related laws

12

Anti-Monopoly Law (Act on Prohibition of Private
Monopolization and Maintenance of Fair Trade), Subcontracting
Act (Act against Delay in Payment of Subcontract Proceeds to
Subcontractors)■ Deciding on price and sales volume and so on throughconsultation with companies that make up an industry body.

■ Making a request to manufacturers so they do not supply raw
materials to companies that are newcomers to the market.

Stakeholders

Stakeholders▌Our Promises

The following acts are examples of actions prohibited under the AntiMonopoly Law:
1

1

Strive for the sustainable development of fair, honest, andtransparent relationships with all stakeholders, including
shareholders, customers, business partners, and hostcommunity residents.

Things We Must Not Do■ Instructing retailers to obey sales prices.

■ Selling at significantly lower prices only to competitors’
customers in order to deprive the competitors of theircustomers.
■ Selling popular products with unpopular products as a set(package sales).
■ Forcing sales on suppliers and burdening them with expenses
that they are not obliged to pay.

Those Involved in Price Cartel Imprisoned
Three steel sheet manufacturers jointly decided to raise the price of aluminumzinc alloy plated steel sheets and strips from a shipment at a certain time, andimplemented this scheme.
The three companies and those involved in the price cartel were charged withviolating the Anti-Monopoly Law (price cartel). While the three companies werefined, eight officials, including the officers in charge of sales, were sentenced to
imprisonment with hard labor.

Not
okay!

Bid-Rigging

13

1 -4

Prohibition of Dishonest Acts

Code of Conduct■ We Will Not Carry Out Acts That Place the Company
at a Disadvantage
We must not damage the company’s reputation or credibility or doanything that will cause disadvantage to the company. Among these, actsthat cause damage (disadvantage) to the company such as by reducing
the profits that the company would have made so to gain personal
benefits or to benefit a third party are called acts of conflict of interest.
Specifically, colluding with a particular supplier and neglecting a statein which high costs are incurred or leaking confidential information tocompetitors are deemed acts of conflict of interest.
Acts of conflict of interest are acts that cause trouble for not only
companies but also many people, such as work colleagues and theirfamilies.
We will never carry out a conflict of interest.

■ We Will Not Claim Improper Expenses
There are various expenses such as transportation expenses, businesstrip expenses, and the cost of equipment as a result of undertaking work.
We will properly charge the company for these expenses.

Things We Must Not Do
The following acts are examples of conflict of interest:

Stakeholders

Stakeholders▌Our PromisesCompanies Act, Penal Code, Labor Contract Act

1

1

Strive for the sustainable development of fair, honest, andtransparent relationships with all stakeholders, including
shareholders, customers, business partners, and hostcommunity residents.

Related laws

■ Performing acts that unduly use up or damage the company’s
tangible and intangible assets, or using the company’s property
and expenses for personal purposes.
■ Undertaking, without the permission of the company, a side job suchas simultaneous employment with another company, taking a role as
an executive of another company, or running one’s own business.

■ Receiving benefits such as money, gifts, entertainment, etc.
from a supplier and so on that go beyond the bounds of social
courtesy, and extends to actions that may cause collusion withbusiness partners.
■ Acquiring expenses from the company through foul means(padded invoicing of traffic expenses and purchased
equipment, the falsifying of private food and drink expenses asentertainment expenses, and fake business trips).

■ Embezzling cash vouchers (taxi tickets, beer tickets), postage
stamps, and revenue stamps, etc.

■ Secretly selling our products and waste products (old PCs, etc.)
for personal gain.

■ Using refueling cards and ETC cards provided for company
vehicles with one’s own car.

Not
okay!

■ We Will Not Carry Out Personal Activities Unrelated
to Work During Work Hours
If you engage in activities unrelated to work, such as those relating topolitics, religion, community associations, and volunteer work, during
work hours, not only will the profits that the company should earndecrease, but it will also ruin the atmosphere of the workplace and makeit difficult to work there.
We will work by drawing a line between public and private matters.

14

15

2 -1

Respect for Basic Human Rights

Code of Conduct■ We Will Accept Each Other
We have, in our daily activities, the opportunity to interact with people
with different ways of thinking and values to ourselves such ascolleagues at work as well as customers, suppliers, and people of local
communities.

■ Speaking badly of someone without reason just because you do
not see eye to eye.
■ Ignoring or disassociating yourself with someone just because
they state opposing opinions in meetings.

■ Mocking the appearance, age, educational background, etc. ofother people.

Sound Work Environment

Sound Work Environment▌Our Promises

The following acts are examples of discrimination or harassment:

2

2

Respect the basic human rights of all people, strictly
refrain from behavior that demeans the dignity of
individuals, and never discriminate according to race,
nationality, ideology, belief, age, gender, social status, ordisability.

Things We Must Not Do■ Spreading rumors about sexual minorities (for example, LGBT) or
making fun of someone being LGBT.

■ Doing or saying something that makes others feel uncomfortable,
such as teasing them because of their physical disability.
■ Not giving educational training or promotion opportunities to andsetting different conditions for female only.

We will, as the basis of our lives in society, be conscious of diversity,
accept each other and treat each other with respect and dignity without
dismissing other people.
What’s more is that by exchanging ideas and inspiring one another,stagnant activities can be revitalized, ideas that cannot be conceived
alone can be created, and we can make a positive impact.

■ We Will Eliminate All Discrimination
How would you feel if you were subjected to unfair discrimination orharassment by people around you for reasons not directly related toyour work? It would surely wipe away your smile and any positive feelingtowards your work.
We will eliminate discrimination and harassment to create thefoundations of a work environment where our employees can work withenergy and vigor.

16

Related pages“2-3 Prohibition of Harassment”

Related laws

Constitution, Labor Standards Act, Equal Employment
Opportunity Law, etc.

17Diversity is the practice or quality of including or involving people from a
range of different social and ethnic backgrounds and of different genders,sexual orientations, etc. A better understanding of diversity in the workplace
will increase your willingness to accept the differences between yourself andothers. By doing so, it will improve relationships and make the workplacea better working environment. In a workplace where staff members areunable to appreciate the concept of diversity, people who are different fromothers may feel sad or upset because they suffer prejudice or are excluded.
If everyone is conscious of diversity, no one will suffer harassment or bediscriminated against, and this will create a comfortable working environment.

Gender includes not only the physical genders of male and female, butalso the gender one identifies oneself to be (gender identity) and sexual
orientation. We must have equal human rights and be fully respected nomatter what gender we may be. Discriminatory behavior on the groundsof gender or making fun of others as a part of casual conversations must
not take place in the workplace either. Also, do not impose roles by gender.
It is important to think about things from other people’s points of view,
understanding that imposing roles by gender can hurt people’s pride andcause distress.

An advantage of respecting diversity is that we will be able to employ a wide
range of individuals, utilize their individuality, and respond to a wide rangeof challenges as an organization. Diversity also enables lots of different
perspectives and increases the chances of getting new ideas.

■ Differences Between People
When trying to understand the differences between people in the workplace,such differences may be simpler to understand by thinking of things interms of “attributes”. Attributes are properties common to people orthings belonging to a certain group. The table below gives some examples.
Combinations of various attributes mean that the human population is madeup of countless personalities and individuality.
Attributes

PhysicalWay of Thinking

Affiliation

Work

GenderRace
Age
Disabled or not
Sexualorientation

Hobbies
Preferences
Ideology
Religious beliefs
ValuesNationality
Birthplace
SchoolStatusFamily members

Employment
statusWorking hours
Place ofemployment
IncomeThere are many types of attributes other than those outlined above, as
human diversity has no limits.

■ To Respect People Who Are Different from You
Accepting people who are different from you may not be as easy as it
sounds. If you find it difficult to respect others at work, you should try andput yourself in the other person’s shoes. Anyone would feel sad as a result of
being rejected by others just because they are different. It is also importantto think that people with different strengths and weaknesses are working
while helping each other. It may be easier to accept others if you consider it
only natural that people are different and that no two people are the same.

18■ GenderSound Work Environment

Sound Work Environment

Reference: What Are Gender, SOGI and LGBT?

2

2

Reference: What Is Diversity?

Gender is a socially constructed concept to highlight the differences between
men and women, such as “masculinity” and “femininity”. Gender harassment
is the process of imposing gender stereotypes and values on people andforcing them to accept predetermined roles based on their gender. The
notion of masculinity or femininity differs depending on various factors suchas the era, regions, and personal ways of thinking and experiences, so it is not
something that others can impose. Restricting work styles based on gender
may violate the Equal Employment Opportunity Law.

■ SOGI and LGBTSOGI is an acronym for “Sexual Orientation” and “Gender Identity”, which are
attributes that everyone possesses. Sexual orientation is which gender you
are sexually attracted to. Sexual orientation is not limited to men or women,with some people sexually attracted to both men and women, while others are
attracted to neither sex. Gender identity is the gender one identifies oneself
to be. Likewise, gender identity is not only male or female, with some people
identifying themselves as being neither male nor female. Discriminating
against SOGI is called “SOGI harassment”.
LGBT is an acronym for “Lesbian”, “Gay”, “Bisexual”, and “Transgender”, andis one of the terms describing sexual minorities. It is generally said that about
8% of the population in Japan is LGBT. The difference between SOGI andLGBT is that SOGI refers to the attributes that everyone possesses, while
LGBT refers to people with a specific sexual orientation or gender identity.

19

2 -2

Proper Working Environment

Code of Conduct■ We Will Get Proper Wages
We receive wages from the company by conducting our predefined
duties in good faith. Labor that is not paid a fixed wage or overtime laborthat is not paid on in addition to one’s wage is not allowed.
We do not permit illegal activities such as unpaid overtime work, andstrive to maintain a proper working environment.

■ We Will Not Overwork and We Will Not Let Others Do
So
You may be required to work overtime or work on holidays, such as inorder to meet deadlines or for accounting at the end of the work month.
However, overwork due to late-night overtime work over long periods orworking on holidays is never permitted.
Overwork can fatigue our minds and bodies, resulting in the onset of
depression or even death in the worst-case scenario.

■ Forcing or tolerating unpaid overtime.

■ Forcing or tolerating late-night overtime or work on holidays
beyond the legal limit.

■ Giving the cold shoulder to a subordinate who refuses to do
unpaid overtime, engaging in excessive late-night overtime, or
working on holidays.

Sound Work Environment

Sound Work Environment▌Our Promises

The following acts are examples of actions by a superior to his/her
subordinates that cause an inappropriate working environment:

2

2

Respect the basic human rights of all people, strictly
refrain from behavior that demeans the dignity of
individuals, and never discriminate according to race,
nationality, ideology, belief, age, gender, social status, ordisability.

Things We Must Not Do■ Not allowing paid leave to subordinates for no good reason.

General employees should also be aware that the following acts are also
examples of actions that cause an inappropriate working environment:■ Increasing overtime for yourself and your colleagues throughundertaking one’s duties in an inefficient manner.

■ Not cooperating in reviewing the division of labor in theworkplace for the purpose of shortening working hours.
The Labor Standards Inspection Office Demands Corrective Actions
Due to “Hidden Overtime” and “Unpaid Overtime”
Company H, a manufacturing company with factories and plants, instructed sitemanagers to keep monthly overtime to less than 100 hours. In the end, the sitemanagers underreported so that the monthly overtime hours would be around
100 hours. Not only did Company H receive a formal demand to take corrective
actions, but this fact was published online, resulting in a drop in Company H’s
corporate value.

We not only prevent ourselves from overworking, but we also do notforce or tolerate others overworking.

20

Related pages“2-3 Prohibition of Harassment”, “2-5 Prohibition of Forced
Labor and Child Labor”

Related laws

Constitution, Labor Standards Act, Industrial Safety and Health
Act, Part-Time Employment Act, Labor Contract Act, Worker
Dispatching Act, etc.

21

2 -3

Prohibition of Harassment

Code of Conduct

Abuse of Authority■ Taunting or being violent.

■ Ignoring, not giving any work, questioning mistakes more thannecessary.

2

2

Respect the basic human rights of all people, strictly
refrain from behavior that demeans the dignity of
individuals, and never discriminate according to race,
nationality, ideology, belief, age, gender, social status, ordisability.

Things We Must Not Do▌

Our Promises■ We Will Not Harass Anyone
Harassment generally refers to ‘acts that cause disrespect orannoyance’. The victim of harassment suffers various disadvantages
and mental distress. Typical examples of harassment include abuse of
authority, sexual harassment, and pregnancy discrimination.
We take care not to harass or act in a way that could be perceived asharassment by others and strive to maintain a working environment freeof harassment.

Sound Work Environment

Sound Work Environment

Sexual Harassment■ Touching someone’s body, staring at someone’s body, making
sexual jokes, and forcing a sexual relationship.
■ Forcing someone to drink alcoholic beverages and perform duetsat karaoke.
Pregnancy Discrimination■ When a member of staff reports the fact that they are pregnant,saying unpleasant things such as “How could you go and get
pregnant when we’re up to our eyeballs in work”.
■ Demoting an employee or reducing their salary due to taking
childcare leave.

■ We Will Put Ourselves in the Other Person’s Shoes
Even if you do not intend to hurt the feelings of other people, if they
feel distress as a result of your actions, the act is harassment. In otherwords, there is a possibility that you may become the perpetrator ofharassment without realizing it.
For example, even if it is a work-related supervision or instruction,
anything that goes beyond the appropriate scope shall be deemed asabuse of authority.
Everyone thinks differently and feels differently.
We will try to put ourselves in the other person’s shoes without making
simple conclusions such as, “I expect this level of behavior shouldn’t be a
problem”.

22

Related pages“2-1 Respect for Basic Human Rights”, “2-2 Proper Working
Environment”

Related laws

Constitution, Labor Standards Act, Equal Employment
Opportunity Law, Act on Comprehensive Promotion of Labor
Policies, Child Care and Family Care Leave Law, etc.

Not
okay!
Not
okay!

23

Reference: Types of Harassment That Are Prone
to Occur in the Workplace

Abuse of authority means that the working environment of an employedworker is harmed by behavior in the workplace taken by someone in aposition of power above them that goes beyond what is necessary or
acceptable in one’s line of work. Abuse of authority occurs not only by asuperior to his/her subordinates, but in such situations where subordinates
are more skillful or constitute majority, it may also be done by subordinates
to their superior and seniors, as well as to colleagues and employees of otherdepartments. If your superior is aware of the fact that a subordinate is beingharassed or engaging in harassment, he/she should not tolerate this and takeprompt action in order to tackle the situation.

Believing that only one’s own values and morals are correct, workplacebullying means trying to control or exclude others. Workplace bullying is
ignoring someone you don’t like, talking badly of someone, or intentionallynot telling them information necessary for their work and causing emotional
distress and disadvantage.

■ Sexual Harassment■ Pregnancy Discrimination

Sexual harassment refers to causing disadvantages to the working conditionsof employees due to sexual behavior (quid pro quo sexual harassment*1)
or harming the working environment of employees due to sexual behavior(environmental sexual harassment*2).
*1 F orcibly attempting to instigate sexual relations as conditions forpromotion, recruitment, or contracts, etc. Suffering unfair treatment, suchas dismissal, demotion, relocation, or termination of one’s contract, in
retaliation for refusing sexual advances or a sexual relationship.
*2 Hugging, touching the shoulders, waist, chest, buttocks, etc. of anothermember of staff. Engaging in sexually explicit conversations. Asking
another member of staff to talk about their sexual experience. Spreading
rumors about another member of staff being sexually promiscuous. Putting
up nude posters in the workplace or leaving pornographic magazines lying
around.

■ Gender Discrimination
Gender discrimination refers to imposing values and stereotypes such as“masculinity” and “femininity”, and determining roles by gender to discriminate
one’s work tasks and job title. One’s ideas about social gender differences
depend on various factors such as the person in question, their age, and theirenvironment. We must understand that social gender differences are not justarbitrarily decided by other people. Sexual harassment refers to harassmentthat is ‘sexual’ in nature, while gender discrimination refers to discriminationthat relates to one’s ‘gender’.
There is also a difference between the self-identifying sex of people suchas LGBT and their sex as seen by other people. We must know that if we
discriminate by saying things like “because you’re a man” or “but you’re awoman” we will hurt other people with such words.

24

While the backdrop to the abuse of authority is superiority such as one’s job title or skill level, workplace bullying occurs regardless of the level ofsuperiority. Workplace bullying is an example of psychological abuse, where agroup of people ignores and isolates an individual. You should never fuel thesituation and harass anyone because others around you are doing so.

Sound Work Environment

Sound Work Environment■ Workplace Bullying

22■ Abuse of Authority

Pregnancy discrimination refers to discrimination at work or unfavorable
treatment from an employer in relation to pregnancy, childbirth, or childcare.
Typical pregnancy discrimination is to verbally abuse a member of staff for
not coming to work due to morning sickness. Unfavorable treatment on the
grounds of pregnancy or childbirth is prohibited by law.
Companies are required to provide a job reassignment at the request of
the individual and to take measures to reduce their work hours under theguidance of a physician.

■ Causing Somebody Discomfort through Strong Odors
Causing somebody discomfort through strong odors refers to making thesurroundings unpleasant by applying too much perfume or cologne orsmelling of sweat caused by not bathing or changing one’s clothes. Given
that it is hard to notice the smell that one emits, there are many cases where
the person in question is unintentionally causing discomfort to those aroundthem all the while unaware that they are doing so. In order to prevent thisodor-related discomfort, it is important for each and every employee to be
conscious of their appearance, such as checking one’s clothes and how one
presents oneself throughout the workplace on a daily basis.

■ Forced Alcohol Consumption
This is a harassment problem related to alcohol, typically in connection toforcing others to drink alcohol or committing unwelcome behavior associatedwith drinking. Becoming uninhibited and engaging in unwelcome behavior ismore likely when drinking, but if you feel uncomfortable in a setting wherecolleagues are drinking, it may affect your personal relationships in theworkplace. It should also be noted that coercing someone to drink alcoholshould not be done because doing so is very dangerous and could even result
in death in the worst-case scenario.

25

2 -4

Protection of Privacy

Code of Conduct■ Opening a locker and so on that has been loaned to an employee.

■ Investigating the social status, permanent domicile, birthplace,ideologies, religious beliefs, and faith of employees, as well as
matters not required for work.

■ Examining emails and so on without permission (Unless themethod and content are appropriate under socially accepted
conventions, it will also be deemed a breach of privacy even if
the said person is informed.)

Sound Work Environment

Sound Work Environment▌Our Promises

The following acts are violations of privacy:

2

2

Respect the basic human rights of all people, strictly
refrain from behavior that demeans the dignity of
individuals, and never discriminate according to race,
nationality, ideology, belief, age, gender, social status, ordisability.

Things We Must Not Do■ We Will Not Investigate or Interfere with Employees’
Personal Lives
Privacy is not just the right not to have other people know about orinterfere with one’s private life. It also includes the right to look into what
information others have about you and the right to seek corrections tothis content or for it to be deleted.
When collecting employees’ personal information for work reasons, wewill give prior notice and due consideration so as not to violate theirprivacy.

■ We Will Not Leak an Employees’Personal Information
We do not leak personal information obtained through work to third
parties without the permission of the person themselves or without
justification in terms of work. The same also applies for after the person
retires or leaves the company.

26

Related pages“6-1 Management of Personal Information”

Related laws

Constitution, Personal Information Protection Act (lawconcerning the protection of personal information)

Not
okay!

27

2 -5

Prohibition of Forced Labor and Child
Labor

Code of Conduct■ We Will Not Force Employees to Work
In order for employees to work properly, it is important to create aworkplace and environment that makes employees self-motivated toengage in their work.
We will be careful not to unduly force somebody to work against theirwill, work unreasonable overtime, or work unpaid overtime.

■ We Will Not Allow Child Labor
Young children working in a dangerous and harmful environment impairs
their health, safety and morals, and hinders their healthy development.
This is a form of child abuse.

■ Forcing employees to work against their will.
■ Forcing unpaid overtime.

■ Having employees work more than the time specified in the 36
Agreement.

Sound Work Environment

Sound Work Environment▌

Our Promises

The following acts are examples of forced labor, child labor, or related
acts:

2

2

Respect the basic human rights of all people, strictly
refrain from behavior that demeans the dignity of
individuals, and never discriminate according to race,
nationality, ideology, belief, age, gender, social status, ordisability.

Things We Must Not Do■ Having children aged between 13 to under 15 work (only jobs
such as delivering newspapers that are not harmful to children
can be undertaken with the approval of the Labor Standards
Inspection Office).

■ Having children under the age of 13 work (excluding child roles
in movies and theater).
■ Procuring from companies engaged in forced labor or child labor.
36 Agreement

Companies that have employees work in excess of the legal working hours(40 hours a week, 8 hours a day) need to submit a written agreement (36Agreement) to the Labor Standards Inspection Office. Companies that have
employees work beyond the legal working hours without submitting the 36
Agreement will be punished with imprisonment for up to 6 months or a fine of
up to 300,000 yen for violating the Labor Standards Act.

We will never permit child labor under any circumstances.
Penalties• Those found guilty of forced labor are subject to imprisonment between 1 to
10 years with hard labor or a fine of between 200,000 to 3 million yen.
• Those found guilty of child labor are subject to imprisonment for up to 1 yearwith hard labor or a fine of up to 500,000 yen.

28

Related pages“2-2 Proper Working Environment”

Related laws

Constitution, Labor Standards Act, Child Welfare Act, etc.

Not
okay!

29

3 -1

Outsourcing Contract Compliance(Prohibition of Disguised (Fraudulent)Contracting)Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

In a contract for the consignment of business operations (outsourcing
contract), the contractor takes on the responsibility to “complete thework”, and the procedure and hours, etc. of the work are decided by thecontractor. The party who places the order cannot specifically instruct(command) the procedure and hours, etc. of the work to the staff of thecontractor.
The act of directly instructing the staff of a contractor in the same way
as instructing the dispatched employees regarding the work despite it
being outsourced is called “disguised contracting” and is an illegal act
that violates the Worker Dispatching Act, Employment Security Act,
Labor Standards Act, etc.
Understand the content of the outsourcing contract and do not give
instructions directly to the staff of the contractor. Demands andrequests regarding the work are communicated to the person in charge
at the company who will undertake the outsourced work. In particular,
be aware of how you communicate with any staff members of thecontractor who are resident in the workplace.

Things We Must Not Do
The following are examples of types of disguised contracting:■ For work related to system development, etc., giving detailed
work instructions to the staff of a contractor who is resident in
the workplace or managing when they come to and leave work
(representative type disguised contract).

Honest Corporate Activities

Honest Corporate Activities■ We Will Not Give Instructions Directly to the Staff ofContractors

Worker Dispatching Act, Employment Security Act, Labor
Standards Act

3

3▌Our Promises

Related laws

■ Giving detailed work instructions to the person in charge at thecontractor and having the person in charge communicate thesame information to each staff member (person-in-charge typedisguised contract).
■ Having the staff of Company C, which was subcontracted by
the Contractor Company B, stationed at Company A, whichplaced the order, and letting Company A and Company B instruct
the staff of Company C on the work (employer-unknown typedisguised contract).

■ Not entering into a labor contract with the appointed staff,
entering into an outsourcing contract with this staff as a sole
proprietor, and making the staff do the work according to yourinstructions (individual-contract type).

* If you want to give direct instructions for executing the work, you needto enter into a dispatched labor contract.

■ We Will Not Let the Staff of the Contractor Help withWork That Is Not Included in the Contract
We understand the content of the outsourcing contract and do not ask
the staff of the contractor to help with any work that is not specified in
the contract.
For example, even if they give a reason such as they have time on theirhands, be careful not to let the staff of a contractor who is resident in
the workplace help you with work that is not included in the contract.

30

31

3 -2

Meeting the Demands of Society

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

We have a responsibility to respond to demands from various
stakeholders (customers, employees, suppliers, local communities,
government agencies and officials, shareholders, etc.). With this in mind,
we will understand and comply with social norms.

■ Following instructions from a supervisor without objecting
because it is a work-related order regardless of being doubtfulof the legitimacy of the instructions.

■ Not reporting to one’s supervisor or the relevant departmentseven if you witness an act that violates our internal rules (turninga blind eye).

Honest Corporate Activities

Honest Corporate Activities■ We Will Be Aware of Our Responsibility to the
Demands of Society and Meet These Demands

The following acts are examples of actions that violate social norms:

3

3▌Our Promises

Things We Must Not Do■ Causing nuisance and harm to others in public places.

■ Intimidating those around you by performing dangerous driving
or acts of road rage.

■ Crossing a pedestrian crossing while ignoring the traffic lights.

■ Behaving in a way that causes nuisance to others, such as
walking while looking down at one’s smartphone.

If an act that violates social norms comes to light, the company may
lose its social credibility and it may put the company’s business under
threat. To prevent such a situation from happening, each and every oneof us shall be aware of the fact that we are a member of society and act
responsibly.

■ We Will Understand and Comply with Laws,
Regulations, and Social Norms Such as Manners andMorals
We will properly understand and comply with laws and regulations that
relate to our business activities and internal rules. If you have any doubt
about the interpretation of laws and regulations, etc., check with yoursupervisor or the relevant departments.
Also, if any behavior or suspicious behavior that violates any law or
regulation occurs in the workplace, we will make sure to report or consult
with our supervisor or the relevant departments to make corrections andimprovements.
Furthermore, as we are required to act with manners and morals as amember of society, we will do so.

32

Related pages“3-3 Prevention of Misconduct”

Related laws

Constitution, Penal Code, Civic Code, Commercial Code, Companies
Act, various government ordinances, various rules, etc.

33

3 -3

Prevention of Misconduct

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

Misconduct such as fraudulent accounting and falsification of quality
data will damage a company’s social credibility and, in the worst-casescenario, cause the company to go bankrupt.
To prevent this from happening, we will always maintain a sound work
environment and conduct honest business activities.

■ We Will Prevent Misconduct
Misconduct tends to take place when the three elements of “motivation(the necessity to commit misconduct such as being pressurized to doso,)” “opportunity (a situation where misconduct has the potential tooccur,)” and “rationalization (the mindset that engaging in misconduct isinevitable” are aligned. This is called the “Fraud Triangle”.
We suppress the three elements of “motivation”, “opportunity” and“rationalization” to prevent fraud.

Related laws

Penal Code, Commercial Code, Companies Act, Unfair Competition
Prevention Act, Financial Instruments and Exchange Act, etc.

Things We Must Not Do
The following acts are examples of misconduct that does not comply
with the rules and then damages the company or others:

Honest Corporate Activities

Honest Corporate Activities■ We Will Engage in Honest Business Activities“1-1 Providing Products & Services that Maintain Quality and
Safety”, “3-2 Meeting the Demands of Society”

3

3▌Our Promises

Related pages■ Falsifying application data to obtain certification.

■ Falsifying performance inspection figures at the time of
shipment.

■ Making financial statements with contents that differ from theactual company balance.

■ Shipping products that do not conform to standards due toreasons such as needing to meet deadlines.

■ Falsely labeling the product size, weight, performance, etc.

■ Conducting inspections without complying with the prescribed
procedures.
<Fraud Triangle>

We will not create ⁄ Do not set excessive targets, quotas, or incentives. Do nota “motivation”
establish a penalty for not achieving them.
to engage in⁄ If there are people in your department who have troubles
misconduct
at work or in their private life, listen to what they have tosay.
Reduce⁄ Establish a check process carried out by a third party.
“opportunities” to ⁄ Do not fix persons in charge of business operations in the
be able to engage
same position.
in misconduct⁄ Do not make a black box in business operations.
We will not⁄ Have it known throughout the company that misconduct“rationalize”
should not be engaged in for any reason.
misconduct⁄ Understand that excuses such as “I did it for the company’s sake”, “I did it to improve revenue”, or “I did it to makework more efficient” are not acceptable. Understand thatyou will be punished.

As it is difficult to eliminate all “motivations” and “opportunities”, a strong will to“not rationalize misconduct” will act as a barrier against misconduct occurring.

34

35

3 -4

Compliance with Tax Laws andAccounting Standards

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

Financial affairs and accounting must all be done accurately and withoutomission in full compliance with all relevant laws and regulations.
We will manage the company’s funds and assets properly and not
use them in a way that deviates from the purpose of our work. For
settlements such as expenses, we will prepare settlement documents,
attach invoices and receipts, and clarify the amount of the expense as
well as the purpose of the transaction.

■ At the request of a business partner, rewriting a bill so that thecontent is different from fact.

■ Recording fictitious sales to hide debt.

■ Falsifying records of the company’s business and financial
performance.

Honest Corporate Activities

Honest Corporate Activities■ We Will Carry Out Correct Financial Affairs andAccounting

The following acts are examples of accounting fraud and window
dressing:

3

3▌Our Promises

Things We Must Not Do■ Making false or misleading entries in ledgers.

■ Holding funds and assets not included in ledgers.
Incident of Fraudulent Accounting by a Major Cosmetics
Manufacturer
Large-scale window dressing was carried out to cover the company’s excess
liabilities (insolvency), and the former president involved in doing so was foundguilty. The audit firm was suspended from engaging in business, and the CPA
that was a member of the firm was accused of violating the Securities andExchange Act (misrepresentation in the securities report). It eventually caused
the accounting audit system to be reviewed.

■ We Will Eliminate All Foul Accounting
We must not make inaccurate or false records, misleading records, oralter records. Companies and personnel can be fined, penalized, andimprisoned for the inaccuracy of their business and financial reports.
As the foundation for the company to fulfill its legal and social
responsibilities, we do not tolerate fraudulent accounting and actions
that cause damage to the company.

Related laws

Penal Code, Commercial Code, Companies Act, Financial
Instruments and Exchange Act, etc.

lcia s
an ent
Fin tem
Sta

Inv

36

Not
okay!

Fict
Saleitiouss“5-1 Timely and Appropriate Recording and Disclosure ofInformation”

oices

Related pages

Job
Done!

37

3 -5

Compliance with Trade-Related Laws

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

We will comply with the import and export laws and regulations ofJapan and the countries in which we operate. Import and export laws
and regulations are complicated, but we will comply with the laws andregulations of the business field in which we work.
Violation of these laws and regulations may result in individuals or
the company being subject to criminal penalties such as fines or
imprisonment. Offending individuals or the company may also be subject
to administrative sanctions such as being prohibited from importing
and/or exporting.

■ Not correctly declaring the product name, price, place of origin,quantity, etc. when importing/exporting.

■ Exporting without checking the intended use of the product ortechnology or the end customer while at the same time knowingthat it could be converted into arms or weapons.

Honest Corporate Activities

Honest Corporate Activities■ We Will Comply with Import and Export Laws andRegulations

The following actions are examples of violations of trade-related laws
and regulations:3

3▌Our Promises

Things We Must Not Do■ Importing/exporting cargo without carrying out the necessary
procedures (this may be subject to punishment even if it is notintentionally so).
Suspected Illegal Export of Drones That Could Be Converted for
Military Use

A manufacturer of transportation equipment was accused of illegally exportinga drone that could be used for military applications, and was subject tosummary indictment for violating foreign exchange and foreign trade laws. If
exported, it is believed that it would have been delivered to armed forces via acompany affiliated with the military in the respective country.

We will pay attention to the communication back and forth not only
between Japan and overseas bases, but also between overseas bases.
In addition to complying with Japanese laws and regulations, we mustnot be involved in improper transactions in accordance with the export/
import control laws of each country/region including the United States,
UN Security Council resolutions, international agreements, etc.
* S ome countries and regions, such as Hong Kong, also require theacquisition of licenses for the import of regulated cargo. (The importer,
etc. applies for such licenses.)■ We Will Also Pay Attention to the Importing andExporting of Non-Product Cargo
We will comply with laws and regulations not only in importing andexporting of the final products, but also prototypes, technologies, knowhow, chemical substances, software, designs, etc.
Related laws

38

Foreign exchange and foreign trade laws, customs laws, EAR,
and various laws and regulations concerning import and exportof each country.

39

3 -6

Compliance with Local Laws Overseas
and Respect for Overseas Cultures andCustoms

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

Depending on the country or region, the contents of laws and regulations
may differ from those in Japan, and local subsidiaries may have theirown internal rules and policies.

■ Reading and listening about and experiencing local history andculture first-hand.

■ Actively interacting with the local people so as to become
familiar with their values and customs.

■ Always upholding your pride as a Nippon Filcon Group employee
when you act.

Honest Corporate Activities

Honest Corporate Activities■ We Will Comply with Overseas Laws and Regulations

It is hoped that you will understand the local culture and customs bytaking the following actions:3

3▌Our Promises

Things to Keep in Mind

■ Understanding that ‘culture and customs’ are different between
Japan and the local area, and act appropriately (be careful
as even actions (gestures, etc.) that are fine in Japan may beconsidered locally as lacking common sense).

We shall, while complying with the laws and regulations of each country
and region, adhere to the internal rules and policies established by eachcompany.

■ We Will Understand and Respect Cultures and Customs
When doing business overseas, we will, of course, adhere to the laws
and regulations of the country or region, but this alone is not enough. In
some cases, it may not be possible to make appropriate decisions andact based on Japanese business customs and common sense.
We will understand and respect the culture, customs, and values uniqueto each country and region. We will treat people with respect and act ingood faith. Doing so will facilitate developing our business, and in turnwill also contribute to each other’s economic, social, and environmental
progress.
Related laws

40

The laws and regulations of each country and region.

41

3 -7

Cautions on Using Social Media

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

There have been many reports of problems related to information
published on Internet blogging services, various social media platforms(Twitter, Instagram, Facebook, etc.), and anonymous forums. The
inappropriate disclosure of information may expose your own personal
information on the Internet.
We shall, when using these services, take responsibility for the
information we publish, and be careful not to do anything that could leadto a loss of company trust or impact the business negatively. Also, toprotect yourself, do not disclose inappropriate information under any
circumstances.

■ We Will Be Aware That What We Post Will Be Shown
to the World
Unlike email and phone calls, information disclosed and posted on social
media can be seen by anyone in the world. You are not as safe as you
may think even if your posts are made public to friends only or you
use an anonymous account. Inappropriate information disclosure andposting spreads across the world instantly, and once made public, it may
continue to remain online even if the original post is deleted.
Related laws

42

■ Disclosing and posting the company’s confidential informationand information obtained through work.

■ Disclosing and posting information that could disrupt anothercompanies’ business.
■ Disclosing and posting personal information of yourself andcustomers, such as addresses and phone numbers.

Honest Corporate Activities

Honest Corporate Activities■ We Will Not Post Anything Inappropriate Online

The following acts are examples of actions that are problematic in termsof disclosing or posting information online:3

3▌Our Promises

Things We Must Not Do■ Disclosing and posting slanderous or discriminatory information.

■ Disclosing and posting information that violates the law, violatesmanners, and is viewed as a problem morally.

■ Publishing images of or writing about messing around in theworkplace.

■ Disclosing information, images, videos, etc. that infringe on the
copyrighted material of others.

■ Disclosing photos of people from whom permission has not been
granted.

■ Disclosing and posting false information that could spread
damaging rumors.

Not
okay!

Personal Information Protection Act (law concerning theprotection of personal information), Financial Instruments
and Exchange Act, Copyright Act, etc.

43

3 -8

Protection and Use of Intellectual
Property Rights

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

Intellectual property is something that has no physical form but isadvantageous, such as copyrighted works, trademarks, and know-how.
We own a lot of intellectual property, and by making use of it, we offer
many products and services to our customers.

■ Providing and disclosing intellectual property owned by thecompany to a third party without permission.

■ Copying or installing software used within the company without
permission.
■ Creating an imitated version of another company’s product,
service, or brochure, or requesting a supplier to create an
imitated version.

Honest Corporate Activities

Honest Corporate Activities■ We Will Understand the Value of Intellectual Property
and Protect It Properly

The following acts are examples of intellectual property right
infringement:

3

3▌Our Promises

Things We Must Not Do■ Copying and using texts from books, internet, etc. without citing
the source.
■ Buying and using an item while knowing that it is a fake or
pirated version.

We will properly protect our intellectual property as an importantcompany asset.

■ We Will Respect Other Companies’ Intellectual
Property
As intellectual property has no physical form, it is easy to use without
permission. However, using the intellectual property of another company
without permission is the same as stealing the possessions of anotherperson. For example, the scope of usage of software used in daily
operations is determined by the license agreement, and installing it on acomputer beyond the scope of usage violates the intellectual property
rights of other companies.
We will respect and carefully handle other companies’ intellectual
property as well as protect our own intellectual property.

44

Related pages“5-2 Management of Company Information”, “6-1 Managementof Personal Information”

Related laws

Copyright Act, Patent Act, Trademark Act, Design Act, Utility
Model Act, Intellectual Property Basic Act, etc.

45

3 -9

Management and Use of Buildings,
Facilities, Equipment, Etc.

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

■ Using a computer borrowed from the company for things thathave nothing to do with work (online auctions, stock trading,etc.).
■ Using equipment such as batteries, pens, envelopes, etc. forprivate purposes.

Honest Corporate Activities

Honest Corporate Activities■ We Will Use Buildings, Facilities, and Equipment
According to the Rules

The following acts are examples of using buildings, facilities, and/or
equipment for private means:33▌Our Promises

Things We Must Not Do■ Borrowing unused company equipment without permission.

Buildings, facilities, and equipment owned by the company are importantcompany assets. No longer being able to use them normally due to loss,
damage, or ignoring the rules, etc., will hinder corporate activities andcause great inconvenience to customers and suppliers.
We will take good care of our buildings, facilities, and equipment and use
them properly in accordance with internal rules.

■ We Will Use Items Borrowed from the Company for
Company Activities Only
We will use items lent to us by the company only for work and activities
permitted by the company. Using these items for private purposes orselling them without permission is not only a violation of company rules,
but it is also a criminal offense.
Related laws

46

Penal Code (business embezzlement, theft, etc.), Labor
Contract Act

Not
okay!

47

of Vehicles in Compliance with the
3 -10 Use
Road Traffic Act and Driving Etiquette

Code of Conduct
In business activities, observe laws and internal
regulations and do not engage in behavior contrary tosocial justice or public order and morals.

Driving a vehicle without observing the Road Traffic Act and driving
etiquette can lead to tragic accidents resulting in death or serious injury
and/or property damage. It is against the law to commit acts of roadrage towards other vehicles (such as driving dangerously close to othervehicles) or littering garbage from inside the vehicle.

■ Leaving items that could provoke someone to break into thevehicle and steal them such as work bags, valuables, laptops, andconfidential information (not only will the vehicle be damaged but
it will also result in the leaking of information).
■ Not reporting to the company any traffic accidents or traffic
violations that occur during working hours or commuting.

Honest Corporate Activities

Honest Corporate Activities■ We Will Observe the Road Traffic Act and Driving
Etiquette

The following acts are examples of improper management of a vehicle,
violation of driving etiquette, or unwelcome behavior:

3

3▌Our Promises

Things We Must Not Do■ Committing acts that violate the Road Traffic Act (driving withouta license, parking illegally, using a cell phone while driving, notfastening seat belts, etc.).

■ Driving while slightly intoxicated or driving while drunk.

■ Intimidating those around you by performing dangerous driving
or acts of road rage.

We will observe the Road Traffic Act and strive to drive safely.

■ We Will Be Aware That How We Drive Is Witnessed by
Members of Society
Whether it is with a company-owned vehicle or your own vehicle, causing
an accident or violating driving etiquette will damage the reputationof the company. In recent years, in particular, there have been manycases in which footage of dangerous driving and people violating
driving etiquette have been recorded and uploaded to social media andattracted widespread attention while identifying the offenders.
We will drive with caution, conscious of the fact that the eyes of the
public are on us.
Related laws

48

Not
okay!

Road Traffic Act, Act on Punishment of Acts Inflicting Deathor Injury on Others by Driving a Motor Vehicle, etc. (crimes ofdangerous driving resulting in deaths or injuries), Penal Code(crimes of violence)

49

4 -1

Sever Connections with Anti-Social
ForcesCode of Conduct
Provide no benefits to and sever any relations with antisocial groups that threaten the order and safety of civilsociety.

Anti-social activities and forces/groups such as gangsters and corporate
racketeers pose a threat to the order and security of peaceful civil life.
We stand firm against these anti-social forces and have no connection tothem whatsoever. Furthermore, we will not do anything that supports theactivities of anti-social forces.
Some anti-social activities and forces/groups disguise as ordinary
companies or organizations.
If there is a company or organization that you are in contact with for the
first time, we make sure to research information on them and check as
to whether there are any concerns.

■ We Will Not Give in to the Unreasonable Demands ofAnti-Social Forces■ Looking to financially resolve unreasonable demands made byanti-social forces.
■ Providing money and services to anti-social forces.
■ Buying goods from anti-social forces.

■ Subscribing to magazines and books published by anti-social
forces or placing advertisements in the said magazines andbooks (there is a risk that this could be considered to be an
illegal payoff).

Anti-Social Forces

Anti-Social Forces■ We Will Have No Connection Whatsoever with AntiSocial Activities or Forces

The following acts are examples of having connections with anti-social
activities and forces (corporate racketeers, gangsters, etc.):

4

4▌Our Promises

Things We Must Not Do■ Doing business with a company who is connected to anti-social
forces.

■ Requesting anti-social forces to act on one’s behalf (debt
recovery, etc.).
■ Providing profits to anti-social forces when they exercise theirrights as shareholders.

If you receive a request to engage in an anti-social activity or from ananti-social force, consult and report the matter to your supervisor or theCompliance Hotline and try to resolve this matter promptly. We must
work closely with the police and government agencies to eliminate antisocial forces.

When we receive any request from anti-social forces, we will resolutely
decline and not seek a simple resolution. Providing money, goods, or
profits, etc. to anti-social forces can cause the situation to escalate even
if done once. Thoroughly adhere to the “3 Nots” principle of “Not having
relations with”, “Not giving money”, and “Not being afraid”, and do notunder any circumstances engage in these anti-social transactions.
Related laws

50

Act for the Prevention of Wrongful Acts by Members ofOrganized Crime Groups, Commercial Code, Companies
Act, Act for Punishment of Organized Crimes, organizedcrime group elimination ordinances stipulated by each local
government

51

5 -1

Timely and Appropriate Recording andDisclosure of Information

Code of Conduct
Strive for appropriate storage, management anddisclosure of business information and do not engage ininsider trading or other misconduct.

▌Our Promises

We strictly ensure accurate recording so that stakeholders (customers,
employees, suppliers, local communities, government agencies andofficials, shareholders, etc.) can obtain complete, fair, accurate,
sufficient, and easy-to-understand information in a timely manner.

■ Accurately drawing up business-related records based on thefacts and making sure there are no omissions.

■ Making sure that the information to be disclosed is accurate andeasy to understand so that there is no risk of misunderstandings
or misconceptions.

■ Disclosing also negative information that is disadvantageous
to the company, such as the occurrence of defective products,
without hiding it.

Management of Company Information

Management of Company Information

The accurate recording of business-related information such as quality
inspection results and manufacturing records is important in fulfilling ourlegal responsibilities as a company. Listed companies in particular are
obligated to disclose some information about their corporate activities.

The following actions are examples of timely and appropriate recording
and disclosing of information:

55■ We Will Record Accurate Information

Things to Keep in Mind

■ Undertaking thorough management to prevent loss, leakage,theft, unauthorized use, etc. of information, and ensuring that
unnecessary information is discarded.

■ Engaging in two-way communication with stakeholders, and in
addition to disclosing information, reflecting assessments andrequests concerning the company into our business.

■ We Will Disclose Information at the Appropriate Timeand in the Appropriate Manner
As a member of society, it is important for a company to actively
disclose its activities, such as business and social contribution activities,
in order to build good relationships with stakeholders and gain theirtrust.
Given that the purpose of disclosing information (disclosure) is tohave people learn about the activities of the company and support thecompany, it is not enough just to provide information unilaterally.
We will endeavor to actively communicate with stakeholders by devising
effective and efficient methods.

52

Related pages“3-4 Compliance with Tax Laws and Accounting Standards”

Related laws

Financial Instruments and Exchange Act, stock exchange rules,
Commercial Code, etc.

53

5 -2

Management of Company Information

Code of Conduct
Strive for appropriate storage, management anddisclosure of business information and do not engage ininsider trading or other misconduct.

▌Our Promises
We thoroughly ensure that information is “only used when necessary
by personnel who requires it for work purposes”, and do not use it for
private matters.

■ We Will Act in Such a Way So as to Prevent
Information from Being Released or Leaked
Information within the company includes a lot of confidential informationsuch as pre-announced product information, manufacturing know-how,and information on clients, etc. If confidential information is released orleaked regardless of whether it is done so intentionally or carelessly, it
will cause serious damage such as a loss of competitiveness or a loss oftrust. The “unmalicious releasing of information”, such as by “information
being released from a computer infected with a virus”, “emailed tosomeone unintentionally by mistake”, or “losing one’s laptop”, is also
unforgivable.

■ Obtaining confidential information within the company withoutauthorization, and taking it outside the company without
permission.

■ Handling confidential information at home or on a computer
brought in from outside the company.

■ Installing unauthorized software on the computer you use atwork.

■ Leaving devices containing confidential information, etc.
unattended on a plane or train (placed on a storage shelf andthen left unattended while asleep, etc.).

Management of Company Information

Management of Company Information

Information, just like money and people, is an asset that a company
needs to operate. By “properly managing and ensuring accuracy andcompleteness”, information can be used as a corporate strength.

The following acts are examples of actions that lead to the release orleakage of information:

55■ We Will Manage Information Properly

Things We Must Not Do■ Sending emails or faxes without sufficiently confirming therecipient.

■ Talking about confidential information in a location where there
is a third party such as on a train, in an elevator, in a dining area,etc.

■ Discussing confidential information at a gathering with family
and acquaintances.
■ Losing a smartphone (or other information-carrying device) thathas confidential or personal information.

■ Not reporting the loss of an information-carrying device.

We will take extra care not to fall prone to the aforementioned incidents
and act in such a way so as to prevent information from being releasedor leaked.

54

Related pages“3-8 Protection and Use of Intellectual Property Rights”, “5-3Prohibition of Insider Trading”, “6-1 Management of Personal
Information”, “6-2 Cautions on Using Email”, “6-3 Appropriate
Use of IT”

Related laws

Personal Information Protection Act (law concerning theprotection of personal information), Unfair Competition
Prevention Act, etc.

55

5 -3

Prohibition of Insider Trading

Code of Conduct
Strive for appropriate storage, management anddisclosure of business information and do not engage ininsider trading or other misconduct.

▌Our Promises

Things We Must Not Do
The following acts are examples of actions that could be deemed as
insider trading:■ Buying company stock under your family’s name based on inside
information.

■ Buying the stock of an acquaintance’s company based on inside
information obtained from the acquaintance.

■ We Will Not Leak Non-Public Information

Management of Company Information

We may come to learn of information about our company and business
partners prior to it being made public. If this information is leaked, it
gives only the people who know the information the opportunity to buy
and sell stocks for profit, and thus harms the fairness of the market.

■ Leaking development information of your company’s new
product to a close friend, who then buys your company’s stock.

We should be careful not to accidentally leak confidential information toeven our close friends or family.

Insider Trading by Staff at a Broadcasting Station‘Insider trading’ refers to buying and selling stocks by using nondisclosed important information such as information about mergers andnew products that will affect the stock price if it is made public. Thosefound guilty of insider trading will be severely punished according to thelaw.

■ Selling shares of the company based on inside information thatthe company’s performance is expected to worsen.

The staff of a broadcasting station learned on their computer at work that amajor company that runs a restaurant chain would purchase another restaurant
chain to form a group company, and used it to purchase stocks by foul means.
The staff involved were dismissed from their job as disciplinary action.

Not
okay!

We will never buy or sell stocks in such a way.
Penalties• Imprisonment of up to 5 years with hard labor or a fine of up to 5 million yen,or both.
• A company found guilty of inside trading will be fined up to 500 million yen.
• All property gained from insider trading will be confiscated and collected.
• A surcharge payment order may be issued even if a criminal punishment is
not.

56

Related pages“5-2 Management of Company Information”

Related laws

Financial Instruments and Exchange Act

Management of Company Information■ We Will Not Buy or Sell Stocks Based on Non-PublicInformation

5

5■ Purchasing your company’s stock after learning that yourcompany has succeeded in developing a groundbreaking new
product.

k
StoiccePr

57

Reference: What Is Insider Trading?

Insider trading is the trading of stocks, etc. using undisclosed material facts(facts that significantly affect the investment decisions of investors) obtainedin one’s work or position. Insider trading is an act prohibited by the Financial
Instruments and Exchange Act.
For example, suppose a listed company’s performance is much better than
expected, but this hasn’t been announced publicly yet and is known only tosome employees of the company. One of such employees thought, “If thisinformation is made public, it’s likely that the stock price will rise significantly.
If I buy the stock now and sell it after the stock price rises, I could make aquick fortune”. And that employee bought the own company’s stock. This
type of cases may be considered as insider trading.

Material facts are considered to have been made public if any of the following
three are carried out. After the material facts are made public, you can tradestocks as doing so will be no longer be considered insider trading.
1. Twelve hours have passed since the material facts were made public
to two or more media outlets such as newspapers, news agencies, andbroadcasters.
2. T he material facts were communicated to the Financial Instruments
Exchange, and the information was published on a service that enables
browsing of timely disclosure releases of all listed companies (TDnet).
3. S ecurities registration statements, securities reports, extraordinary
reports, etc. containing material facts have been made public.

The Financial Instruments and Exchange Act specifically lists material facts
by dividing them into decision facts, occurrence facts, and financial results
information. However, even if the facts do not fall under these categories,“important facts related to the operation, business, or property of the listedcompany, etc. that significantly affect the investment decisions of investors”
are defined as material facts. This is what is referred to as a basket clause.

■ Material Facts■ Penalties

Material facts are important facts about the operation, business, or property
of a listed company, etc., and have a significant influence on the investment
decisions of investors. Material facts can be broadly divided into three
categories: decision facts, occurrence facts, and financial results information.
The main ones are as follows.
Decision facts
Issuance of shares
Stock split
Merger ofcompanies, etc.

Occurrence facts

Financial results information

Occurrence of scandals andSignificant revision ofincidents
earnings forecast andLicense revocation and business dividend forecast
suspension
Punishment by other government
agencies
Suspension of transactions withmajor business clientsManagement of Company Information

Management of Company Information

Those subject to insider trading regulations are company stakeholders andthose who have received material facts from them. “Company stakeholders”
are stipulated in the Financial Instruments and Exchange Act and refer toofficers and employees of listed companies and officers and employees ofbusiness partners, etc. Those who have been informed of material facts bythese persons are called “primary recipient of information”, and those up to
this point are subject to insider trading regulations. Company stakeholders
are subject to this regulation up to one year after leaving the company.

55■ Insider Trading Regulations■ Disclosure of Material Facts■ Basket Clauses

The statutory penalty for violating insider trading regulations is imprisonmentof up to 5 years, a fine of up to 5 million yen, or both. In past cases, both
imprisonment and fines have often been imposed.
In principle, all property gained from insider trading will be confiscated.
Profits are not the only thing that are confiscated. For example, if you buy
stocks for 500,000 yen and sell them after the stock price has risen to 1
million yen, not only the 500,000 yen in profit but the 1 million yen of the saleprice will be confiscated.
Separate from the punishment, the Financial Services Agency may also issue
a surcharge payment order as an administrative penalty. The surcharge iscalculated based on the equivalent of the financial profits earned from insider
trading.

It should be noted that, in addition to these facts specifically stipulated bylaw, there are “basket clauses” that deem anything that has a significant
influence on the investment decisions of investors to be material facts.

58

59

5 -4

Inquiries from Various Media
Organizations and Investors

Code of Conduct
Strive for appropriate storage, management anddisclosure of business information and do not engage ininsider trading or other misconduct.

▌Our Promises■ There is a phone call from a mass media organization or
investors requesting an interview, and the employee who
happens to answer the phone gives an ambiguous answer.
■ Expressing your personal opinion for interviews or inquiries frommass media organizations, investors, etc., without connecting to
the person in charge, because it was information that you knew.

■ Transferring the person on the other end of the phone around or
responding with a poor attitude.

■ Sparking rumors or slandering on the basis that it is fine to do so
if it is about another company.

Management of Company Information

Management of Company Information

We, as a listed company, may receive inquiries from mass media
organizations such as newspapers, magazines, radio and television
channels as well as securities analysts, institutional investors, individual
investors, lawyers, and government agencies.

The following are examples of inappropriate responses to inquiries:

55■ We Will Firstly Consult with Our Supervisor

Things We Must Not Do

Providing information to these mass media organizations and individuals,
even if it is a personal opinion, will be regarded as the official opinion of
the company and may be communicated to the world.
When we receive an inquiry, we do not answer it at our own discretion,
but instead, firstly consult with our supervisor. Depending on the content
of the inquiry, we will ask the department in charge such as Management
Planning, General Affairs, Accounting, etc. to respond.

Not
okay!

60

61

6 -1

Management of Personal Information

Code of Conduct
Carefully store and manage information that constitutes
trade secrets and personal information and do not divulge
such information to any outside party without due cause
during employment or after retirement.

▌Our Promises■ Taking a customer or employee list outside the company without
permission, or talking to people outside the company about the
information on the list.
■ Printing the personal information of customers and employees
without permission and copying it to recording media.

■ Posting a customer’s or employee’s personal information on a
website or forum without their consent.

■ Discarding materials that contain printed or displayed personal
information without shredding it.

Management of Personal Information

Management of Personal Information

Personal information is information that can specify or identify anindividual. Name, address, phone number, and email address correspondas personal information.

The following acts are examples of leaking or misusing personal
information:

66■ We Will Handle Personal Information Properly

Things We Must Not Do■ Using or disclosing personal information for a purpose different
from the original purpose.

Recognizing the importance of and properly handling personal
information is an essential part of maintaining a trusting relationship with
employees, customers, and suppliers.
We adhere to the policies and rules regarding the handling of personal
information as defined in the company rules.

■ We Will Not Misuse or Leak Personal Information
Companies that have leaked personal information will lose credibility
over it, and it takes a great deal of time and effort to recover from suchan incident. The personnel whose personal information is leaked will not
only receive unwanted sales activities and solicitation but also risk fraud
and other damages.
We only use personal information for the purposes for which it was
acquired and within the scope of the agreement with the provider.
Also, the disclosure of personal information is limited to the scope of
personnel defined in the company rules.

62

Related pages“2-4 Protection of Privacy”, “3-8 Protection and Use ofIntellectual Property Rights”, “5-2 Management of Company
Information”, “6-2 Cautions on Using Email”, “6-3 Appropriate
Use of IT”

Related laws

Personal Information Protection Act (law concerning theprotection of personal information), etc.

U
Us nau
e tho

riz

ed

Personal
Information
Documents

63

6 -2

Cautions on Using Email

Code of Conduct
Carefully store and manage information that constitutes
trade secrets and personal information and do not divulge
such information to any outside party without due cause
during employment or after retirement.

Things We Must Not Do
The following acts are examples of actions that lead to the inappropriate
use of email and the release or leaking of information:■ Sending large attachments that will cause trouble for therecipient.

■ Sending an email that is libelous of others.

▌Our Promises
We will use email correctly with this risk in mind.

■ We Will Prevent Information Being Leaked by EmailWe will take extra care not to leak information by email, and before
sending an email, we will make sure to check that the recipient is correct.

■ Sending confidential information to a personal email address,
such as the one used at home, or the transferring of files.

Management of Personal Information

Management of Personal Information

While email is very useful as a tool for communicating information,
confidential information may be easily released when sending emails.

■ Sending emails that contain excessive symbols, decorations, andcoloring that is inappropriate for work.

6

6■ We Will Use Email Properly■ Replying to or transferring unknown or suspicious email
addresses.

■ Sending emails or faxes without sufficiently confirming therecipient.

■ Opening the file attached to an unfamiliar email without checking
its email address because the sender name appears to be that ofa business partner.

If you use the ‘Reply to all’ function, check before sending the email
whether its content can be disclosed to all recipients.
When sending confidential information, encrypt it with a password
before sending.
Emails from unknown senders and emails from suspicious addresses
may carry viruses, so delete them without opening them.

■ We Will Be Cautious of Targeted Email Attacks
Targeted email attacks are emails that are cleverly disguised as
containing business-related content but in actual fact are designed to
infect the recipient’s computer with a virus. The tricks of targeted email
attacks are evolving and becoming more sophisticated day by day.

EstimateWhat
company
is this?

We will not inadvertently open emails or attachments from strangers, butwill delete them immediately according to internal rules.
In addition, we will verify the email address, even if it looks it is fromsomeone we know or the subject line is familiar.

64

65

6 -3

Appropriate Use of IT

Code of Conduct
Carefully store and manage information that constitutes
trade secrets and personal information and do not divulge
such information to any outside party without due cause
during employment or after retirement.

▌Our Promises
However, although it is convenient, if you make a single mistake whenusing IT, doing so may cause a great deal of damage to the company. In
using IT, company rules stipulate action against incidents that requireparticular attention such as the leakage, destruction, falsification, anddeletion of information assets, as well as the infection of computerviruses, and unauthorized access, etc.
If any uncertainties arise when using IT, we will read the company rules
or consult with information system staff.

■ Imposing information handling restrictions (Secret, Confidential,etc.) on information assets in accordance with the classificationof information defined in the company rules.

■ When storing electronic data such as confidential documents,
taking measures such as adding passwords to files and storingthem in a folder for which an access restriction has been set.

■ Before taking company information outside the company,
obtaining permission from an approver beforehand (dependingon the classification of the information assets).

■ Never performing company work on a privately owned personal
computer. If you absolutely must do work outside the company,
borrow a company-owned computer.

Management of Personal Information

Management of Personal Information

IT is an essential tool for carrying out all kinds of work.

The following acts are examples of the appropriate use of IT:

66■ We Will Use IT Appropriately

Things to Keep in Mind

■ Tidying your desk when leaving the office. Locking yourcomputer when leaving your seat (Windows key + L key).

■ Making sure that the ID and password you are using are notknown to others. Also, setting a password of a suitable lengthand complexity.

■ Not handling confidential information on computers not ownedby the company such as those at home or those installed in a
hotel or internet cafe.
■ Not installing unauthorized software on computers used for
work.

66

67

7 -1

Prohibition of Bribery andInappropriate Entertainment

Code of Conduct
Refrain from exploiting an advantageous position in abusiness relationship to make unreasonable demands
or arbitrarily cause a disadvantage to trading partners
and from encouraging entertainment or gift-giving thatdeviates from the commonly recognized limits.

▌Our Promises

We do not give gifts or entertain public officials in order to facilitate
favorable treatment in the course of our work. We will also not do things
that are likely to be misunderstood as having the intention of receiving
favorable treatment in return, such as giving gifts or treating public
officials to dinner, etc.

■ Entertaining a procurement manager of a government agency torequest that your bid be successful at the time of bidding.

■ Giving a gift to a police officer that you are acquainted with andasking them to suppress (cover-up) any traffic violations.

■ Handing over payment of any kind to a parking inspector who
is in the process of confirming a neglected vehicle to ask themto overlook the parking violation (as a parking inspector is a“deemed public official”).
The following acts are examples of inappropriate entertainment andgiving of gifts:■ Giving an individual from a business client a gift that exceeds thescope of common sense.

Prohibition of Bribery

Prohibition of Bribery

Entertainment and gifts to public officials are, in principle, prohibited bylaw. Also, even in the case of a non-public official, those who engage inwork that is of a highly public nature defined by laws and regulations
are called “deemed public officials”, and so entertainment and gifts areprohibited/restricted for such people as well.

The following acts are examples of bribing a public official:

77■ We Will Not Give Bribes to Public Officials

Things We Must Not Do■ Entertaining an individual from a business client at a locationthat could be offensive to public standards of decency.
Requesting a Mayor to Inform About the Estimated Order Price

The executive of a construction company urged the mayor to tell them theestimated order price of a local health spa, handing the mayor a reward of 14
million yen. The executive was found guilty in court.

■ We Will Not Receive or Give Improper Entertainment
or Gifts
We will offer entertainment and/or gifts to business partners within thescope of sound business practices or general common sense.
When we receive entertainment and/or gifts from business partners,
etc., we will stay within the scope of sound business practices or generalcommon sense. We also do not receive gifts and/or entertainment fromsuppliers of materials and services.

68

Related pages“7-2 Prohibition of Bribing Foreign Public Officials, etc.”

Related laws

Penal Code (bribery), Companies Act, National Public Service
Ethics Act, National Public Service Officials Ethics Code, theordinances of local governments, etc.

Not
okay!

69

7 -2

Prohibition of Bribing Foreign Public
Officials, etc.

Code of Conduct
Refrain from exploiting an advantageous position in abusiness relationship to make unreasonable demands
or arbitrarily cause a disadvantage to trading partners
and from encouraging entertainment or gift-giving thatdeviates from the commonly recognized limits.

Related laws

Unfair Competition Prevention Act (bribery of foreign public officials),
U.S. Foreign Corrupt Practices Act (FCPA), U.K. Anti-Bribery
Act (UKBA), etc.

Things We Must Not Do
The following acts are examples of bribing a foreign public official, etc.:▌Our Promises* Those who work for foreign national or local governments, government
agencies, public enterprises, public international organizations, etc., andthose who have been delegated authority by foreign governments.

■ We Will Not Respond to Unreasonable Demands from
Foreign Public Officials, Etc.
When we receive any request for money, etc. from a foreign public
official, etc., we will resolutely decline and not seek a simple resolution.
If demands continue despite refusing, consult with the legal affairs
officer of the local subsidiary and/or the local Japanese embassy,
consulate, chamber of commerce, etc.

Prohibition of Bribery

Prohibition of Bribery

We do not give gifts or entertain foreign public officials, etc.* in orderto facilitate favorable treatment in the course of one’s work. We do notpromise or offer to provide gifts or entertainment as a reward for giving
favorable treatment.

■ Providing money or expensive items to the staff of foreign
inspection agencies and requesting the falsification of inspection
results.

7

7■ We Will Not Give Bribes to Foreign Public Officials, Etc.

■ In order to win a bid for a public project overseas, providing
money or expensive items to the staff of the ministry in charge
to sound out the minimum bid.

■ Appointing a company run by a relative of a politician as a consultant
in order to receive an order for a foreign state-owned enterprise.

■ In foreign customs clearance and so on, as a result of the
improper handling of products such as delayed importprocedures despite submitting the necessary applications,providing money to a person in charge and asking them toundertake the procedures immediately.

Providing Money on Demand for Bribes to Prevent Delays inConstruction Projects
Due to insufficient application to use the facilities of a port in a foreign country,
the landing of construction materials was stopped. The construction project
managers paid about 39 million yen in response to a bribe demand from thechief of the port bureau to prevent delays to the project. At a later date, they
were disciplined, charged, and convicted for their wrongdoings.

■ We Will Not Allow Overseas Subsidiaries or Agents to
Make Bribes
When doing business overseas, if a local subsidiary or agent provides
money or goods to a foreign public official, etc., we may be punishedand lose our social credibility as a company.
We will properly instruct and supervise local subsidiaries and agents, etc.
so that they do not bribe.
Related pages

70

Not
okay!

“7-1 Prohibition of Bribery and Inappropriate Entertainment”

71

7 -3

Limitations on Donations and PoliticalContributions

Code of Conduct
Refrain from exploiting an advantageous position in abusiness relationship to make unreasonable demands
or arbitrarily cause a disadvantage to trading partners
and from encouraging entertainment or gift-giving thatdeviates from the commonly recognized limits.

▌Our Promises

Furthermore, contributions under the name of others and the purchasingof party tickets are also prohibited. Political contributions fromcompanies are limited to political parties, local branches of a politicalparty, and political funding organizations.

■ Companies making political contributions to specific politicians,
and not political parties or other political organizations.
■ Companies making political contributions to organizations otherthan political parties.
■ Companies subsidized by the government and companies in the
red for three consecutive years making political contributions.

■ Making political contributions or purchasing a party ticket for apolitical funding party in the name of another person.
■ Making political contributions in the name of a company without
going through the in-house payment approval procedures.

Prohibition of Bribery

Prohibition of Bribery

In present-day Japan, companies and industry organizations areprohibited from making contributions to specific politicians by the
Political Funds Control Act. This is because politicians who receive
contributions from companies can distort government policies.

The following are examples of illegal or improper donations andcontributions to political parties or political organizations:

7

7■ We Will Make Appropriate Contributions to Political
Parties and Political Funding Organizations in
Accordance with the Law

Things We Must Not Do

Illegal Contributions by a General Contractor under the Cover of a
Political Organization
A semi-major general contractor established a political organization represented
by a former employee. Employees were made to pay a “membership fee” to bea member of the political organization. The funds were then contributed by thepolitical organization to members of the Diet. Meanwhile, for employees who
were forced to pay the membership fee, the membership fee was added to theirbonus as compensation.

When making a political contribution, we will comply with the relevantlaws and regulations and follow all appropriate in-house approval
procedures.
*S o-called political contributions (providing funds to politicians andpolitical parties) are called “donations” in the Political Funds Control
Law.
Penalties• If a company makes a contribution to someone other than a political party,
etc., the person responsible will be imprisoned for up to 1 year without hardlabor or fined up to 500,000 yen.
• If you make a political contribution or purchase a party ticket in the name ofanother person, you will be imprisoned for up to 3 years without hard labor or
fined up to 500,000 yen.

Related laws

72

Political Funds Control Law

73

8 -1

Workplace Safety and Sanitation

Code of Conduct
Recognize that worker safety, industrial disasterprevention, and the preservation of the environment
must be maintained as the highest priorities in businessactivities and pursue active contribution to conservation
efforts and protection of the global environment.

▌Our Promises
Each and every one of us will strive to improve workplace safety andmaintain a sanitary environment on a daily basis.
If you find or see something in your workplace that concerns you,mention or report the matter to your supervisor.

■ We Will Not Personally or Let Others Overwork and
Do Anything That Jeopardizes Safety

Things We Must Not Do
The following situations are examples of an unsound working
environment:■ Bringing dangerous goods into the workplace without any
necessity in terms of one’s work.

■ Making long working hours the norm.

■ The temperature, lighting, sound, or air pollution being
uncomfortable or inappropriate.
■ Providing no measures, places, or facilities to recover fromphysical and/or mental fatigue.

Safety and Environmental Conservation

Safety and Environmental Conservation

We must not get injured or sick during work.

Labor Standards Act, Industrial Safety and Health Act,
guidelines concerning measures for creating a comfortableworkplace environment that businesses ought to take, etc.

88■ We Will Strive to Create a Safe and Sanitary Work
Environment

Related laws

The onset of depression caused by constant long working hours
A young individual who joined a major advertising agency began to suffer fromdepression after working long overtime hours on a regular basis and committed
suicide about two years after joining the company. The company was accusedof violating its duty of care and was ordered to compensate for damages ofabout 100 million yen.

We do not undertake ourselves or force unreasonable long working
hours, even if it is necessary from a work standpoint. Long working
hours impose not only a significant physical burden but also a mental
one as well. If you ever feel unwell, consult a physician immediately.
Never carry out work without proper safety measures in place. In theevent of an accident, one could lose physical capabilities or it could
result in death.

■ We Will Be Prepared for Natural Disasters
We must protect the lives and property of our customers and employees
from disasters and minimize any damage. We will actively participate indisaster drills so that we can deal with the situation calmly in the eventof an emergency. We will regularly check emergency response rules andevacuation routes to prepare ourselves for natural disasters where it is
impossible to know when or where they will strike.

74

75

8 -2

Environmental Conservation Initiatives

Code of Conduct
Recognize that worker safety, industrial disasterprevention, and the preservation of the environment
must be maintained as the highest priorities in businessactivities and pursue active contribution to conservation
efforts and protection of the global environment.

▌Our Promises■ We Will Abide by Environmental Laws and Regulations■ We Will Endeavor to Reduce Our Impact on theEnvironment■ Striving to plan, design, and develop products with low
environmental impact, and promoting energy-saving and the 3Rs(reduce, reuse, recycle).
■ Continuing the switch to environmentally-friendly raw materials
and giving consideration to the safety and health of consumers
as well as the environment.

■ Keeping waste, noise, wastewater, and other emissions within thescope of legal standards and working to further reduce them.

■ Adopting technologies and energy-saving devices that are
excellent in helping prevent global warming and striving forenvironmentally-conscious driving such as by accelerating gently
and turning off an idling engine.

Safety and Environmental Conservation

Safety and Environmental Conservation

We will be fully aware of and comply with the laws and regulations that
apply to our business activities.

The following actions are examples of initiatives to conserve theenvironment:88

In order to create a society in which the next generation of children canlive with peace of mind, there is an urgent need to cut down on using
global resources and consider the environment.

Things to Keep in Mind

■ Trying to separate waste and to recycle.

■ Reducing the amount of electricity consumed by offices byraising the temperature of air-conditioning, lowering thetemperature of heating, or turning off unnecessary lighting.

To reduce our impact on the environment, we will control the amount ofgreenhouse gases, harmful chemical substances, and waste we produce.
We will also continue to save energy and use resources effectively andactively work on recycling by separating garbage appropriately forcollection.

■ We Will Continue Familiar Initiatives Such as
Environmentally-Conscious Driving and the Use of
Eco-Friendly Products
We will not assume that someone will conserve the environment for us,
but rather, we will take the initiative to do what we can. We will endeavor
to install energy-saving equipment, implement environmentally-conscious
driving, and turn off any equipment that is not being used.
Related laws

76

Wastes Disposal and Public Cleansing Act, The Basic Law
for Establishing the Recycling-based Society, Law for the
Promotion of Effective Utilization of Resources, The Basic
Environment Law, Act on the Rational Use of Energy, etc.

77

9 -1

Harmonious Relationship with Local
Communities

Code of Conduct
Pursue close cooperation and harmony with local
communities and strive to make community contributions.

▌Our Promises■ We Will Build Good Relationships with Local
Communities
Companies and local communities are two sides of the same coin. A
good relationship with the community in which we live and work is built
on integrity and trust.

The following acts are examples of initiatives aimed at a harmonious
relationship with local communities:■ Complying with laws and regulations, behaving ethically and ingood faith, and earning the trust of the local community.

■ Being aware that you are always the subject of interest from thecommunity and to be disciplined in how one behaves in one’s
private life.

■ Continuing to establish disaster-resilient and safe workplaces forour employees, business partners, and local communities.

■ Trying to understand and respect local culture, customs, andvalues.

Contribution to Local Communities

Contribution to Local Communities■ Through dialogue with the local people, learning about the views,
ways of thinking, and values of the local community toward thecompany and employees, and incorporating the shared values
into our business activities.

99

We will build a good relationship in which we are trusted by thecommunity by always acting with high ethical standards and creating ties
with people in the community.

Things to Keep in Mind

■ We Will Aim for a Harmonious Relationship and Mutual
Prosperity with Local Communities
Companies are part of the community. Each of us as employees acting
responsibly as good citizens and good members of society and striving
to contribute to the local community in turn leads to the acceptance ofthe company by the local community and a harmonious relationship andmutual prosperity with the local community.
We will willingly participate in activities that help to develop the local
area.

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79

Compliance Hotline● If you feel that there is a compliance violation taking place in the workplace,
you need not suffer alone but instead talk to the people around you.
● There may be hidden compliance violations in incidents that take place
at work. We must work toward a solution without thinking it’s a personal
problem and turning a blind eye to what is happening in the workplace.
The Compliance Hotline can be used to help resolve any compliance issues.
It is recommended to resolve compliance issues in the workplace, however,if the issue cannot be resolved in the workplace, for example, if the party
violating compliance is your superior, please contact the Compliance Hotline.
In accordance with the objectives of the Whistleblower Protection Act,
whistleblowers will not be treated unfavorably by speaking out.
The Compliance Hotline strictly observes its confidentiality (nondisclosure)obligation regarding information about people who contact the hotline andany details of matters that are reported.
You can also contact the hotline anonymously.

Details of the Compliance Hotline and contact information are as follows.

■ Compliance Hotline of Nippon Filcon Co., Ltd.
[Internal Points of Contact](1)	Internal audit Department of Nippon Filcon Co., Ltd.
Address:2220 Ohmaru, Inagi-shi, Tokyo 206-8577
TEL & FAX: 042-377-7090
E-mailnf-naibukansa@filcon.co.jp(2) Auditor of Nippon Filcon Co., Ltd.
Address:2220 Ohmaru, Inagi-shi, Tokyo 206-8577
TEL & FAX: 042-377-7091
E-mail:nf-kansa@filcon.co.jp[External Point of Contact]
Appendix

Appendix(3)	Toshihide Tsuchimori, Attorney at law(Oku, Katayama & Sato Law Office)Address:	8th floor, Tokyo Club Bldg. 3-2-6, Kasumigaseki,
Chiyoda-ku, Tokyo 100-0013, Japan
E-mail:nfg-hotline@okslaw.jp*Please fill in the form found on the internal online bulletin board andsend it to the external point of contact by e-mail or post.

■ Reports on Progress and Results of Investigations
Reports are investigated by the Internal audit Department to assess thefacts and authenticity of the report. If the reported behavior is judged to be
a compliance violation, the President and Representative Director shall ordercorrective measures to prevent a recurrence.
The outcome of the investigation into the facts of the report and an outlineof corrective and preventive measures shall be reported to the person who
made the report.
*For compliance hotlines of companies other than Nippon Filcon, please checkthe company rules of the respective company.

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81

The Main Penalties Related to Compliance
Violations
Act

Sexual harassment

Abuse of authority

Leaking of trade secrets

Penalties

Inflicting injury: imprisonment of up to 15 years withhard labor or a fine of up to 500,000 yen.

Infringement of trade secrets (Unfair Competition
Prevention Act): Imprisonment of up to 10 years withhard labor or a fine of up to 20 million yen, or both.
Theft: Imprisonment of up to 10 years with hard labor
or a fine of up to 500,000 yen.

Copyright infringement

Embezzlement of deposits Corporate embezzlement: imprisonment of up to 10
years with hard labor.
Theft: Imprisonment of up to 10 years with hard labor
Misuse of company
or a fine of up to 500,000 yen.
property for personal
needs
Corporate embezzlement: imprisonment of up to 10
years with hard labor.
Defamation of character: imprisonment up to 3 years
Speaking badly of
someone in front of many with or without hard labor or a fine of up to 500,000
yen.
colleagues
Slander: detention or a penal fine.
Aggravated breach of trust: imprisonment of up to 5
Receiving a kickback(rebate) personally from a years with hard labor or a fine of up to 500,000 yen.
supplier82

Fraud: imprisonment of up to 10 years with hard labor.

Forgery of private seal: imprisonment of up to 3 years
with hard labor.
Forgery of private documents: imprisonment for
between 3 months to 5 years with hard labor.

Making someone sick by continuing to harass them.

Leaking trade secrets for the purpose of harming
profits, illegally acquiring trade secrets, etc.
A fine of up to 500 million yen for corporations, or if the
trade secret is used overseas, a fine of up to 30 million
yen for individuals and1 billion yen for corporations.
Even if the information does not fall under trade secrets
in the Unfair Competition Prevention Act, taking home
media that has information recorded on it.
This includes software piracy.

The act of taking home company items and equipment
may also be punished.

If it has the potential to spread to an unspecified
number or a large number of people, it is considered
defamation of character even if it is a rumor among asmall number of people.
Aggravated breach of trust: A crime in which a person
carrying out business affairs for another person
breaches his/her duties and inflicts damages for the
purpose of profiting oneself or a third party or todamage the victim.
Example of aggravated breach of trust: The act ofusing one’s position in the procurement departmentof a company to purchase items at high prices from a
supplier and receiving the difference as a bribe.

Act

Penalties

Supplementary Information

Violation of obligation to issue written purchase order
Placing an order verbally Subcontracting Act
under the Subcontracting Act.
Actual offender: a fine of up to 500,000 yen.
(For transactions
Corporate punishment: a fine of up to 500,000 yen.
that come under the
Subcontracting Act)
Bribery: imprisonment of up to 3 years with hard labor
Providing, offering, or
promising bribes to public or a fine of up to 2.5 million yen.
officials
You may be punished by the law in countries other thanBribery of foreign public officials, etc.
Providing, offering, orJapan.
Actual offender: imprisonment of up to 5 years withpromising bribes tohard labor or a fine of up to 5 million yen, or both.
foreign public officials,
Corporate punishment: fine of up to 300 million yen.
etc.
In principle, all assets obtained from insider trading are
Insider trading
Financial Instruments and Exchange Act
confiscated and collected.
Actual offender: imprisonment of up to 5 years withhard labor or a fine of up to 5 million yen, or both.
Corporate punishment: fine of up to 500 million yen.
For trading based on spreading rumors: imprisonment
Financial Instruments and Exchange Act
Distributing unfoundedof up to 10 years with hard labor or a fine of up to 30
Actual offender: imprisonment of up to 10 years withinformation for the
million yen.
hard labor or a fine of up to 10 million yen, or both.
purpose of fluctuating
In principle, all assets obtained from such trading are
Corporate punishment: fine of up to 700 million yen.
stock prices (spreading
confiscated and collected.
rumors)Spreading false rumors or using fraudulent means toSlander of other
Damage to credit or obstruction of business:companies
imprisonment of up to 3 years with hard labor or a fine damage the credit or obstruct the business of othercompanies.
of up to 500,000 yen.
Workshop on safe bicycle riding (when subject to safety It covers 15 offenses such as ignoring traffic lights
Committing dangerous
and obstruction of driving. If it is malicious, it may be
enforcement twice or more within 3 years): If you do
acts such as ignoring
traffic lights while riding a not attend, you will be subject to a fine of up to 50,000 punished in the same manner as an automobile. For
example, in the case of ignoring a traffic light, theyen.
bicyclepenalty is imprisonment of up to 3 years with hard labor
or a fine of up to 50,000 yen.
Violation of Road Traffic Act: imprisonment of up to 1
Even if you do not cause an accident, you will be
When a traffic hazard
year with hard labor or a fine of up to 300,000 yen.
imprisoned for up to 6 months with hard labor oris caused by using a
receive a fine of up to 100,000 yen just for using acellphone while driving acellphone while driving.
car, etc.
Drunk driving
Drunk driving: imprisonment of up to 5 years with hard Drunk driving: Driving (steering) while heavily under the
influence of alcohol in a state where one lacks the ability
labor or a fine of up to 1 million yen.
to drive regardless of one’s alcohol concentration level
Driving under influence of alcohol: imprisonment of up (35 points (immediate license revocation) disqualified
from driving for a period of 3 years).
to 3 years with hard labor or a fine of up to 500,000
Driving under influence of alcohol: Driving (steering)yen.*while one’s breath or blood alcohol concentration is*If injury or death occurs as a result, you may be
above a certain level due to drinking, etc. (25 points forcharged with vehicular homicide.
0.25 mg or above, 13 points for less than 0.25 mg).
Requesting or demanding Drunk driving: imprisonment of up to 3 years with hard This also applies when riding in a vehicle while knowing
labor or a fine of up to 500,000 yen.
to ride in a person’s carthat the driver is driving under the influence of alcohol
who is under the influence
but not being able to refuse.
of alcohol
Driving under influence of alcohol: imprisonment of up
to 2 years with hard labor or a fine of up to 300,000 yen.
Providing alcohol to those Drunk driving: imprisonment of up to 3 years with hard Drinking together with someone while knowing that they
drivinglabor or a fine of up to 500,000 yen.
will be driving (this can even equate to pouring alcohol
into the cup of the designated driver).
Driving under influence of alcohol: imprisonment of up
to 2 years with hard labor or a fine of up to 300,000 yen.
Malicious obstructive driving (road rage) is also subject
Dangerous driving,
Vehicular homicide
malicious driving, etc.
Imprisoned for a fixed term of at least 1 year with hard to punishment as driving to intend obstructions.
labor (drunk driving, speeding, obstructive driving, etc.). If driving without a license, an even more significant
Imprisonment of up to 15 years with hard labor (driving penalty may be added to the statutory penalty.
in a state in which significant obstacles to normal driving Fleeing to avoid the detection of the influence anddegree of alcohol and drugs is charged with evasion ofmight occur).
detection (up to 12 years in prison with hard labor).
Dangerous driving resulting in injuries
Imprisonment of up to 15 years with hard labor (drunk If vehicular homicide cannot be applied, such as
the influence of alcohol is unknown, it will fall underdriving, speeding, obstructive driving, etc.).
Imprisonment of up to 12 years with hard labor (driving negligent driving resulting in injury or death (up to 7
in a state in which significant obstacles to normal driving years imprisonment with or without hard labor or a fineof up to 1 million yen).
might occur).

Appendix

Appendix

Copyright law
Actual offender: imprisonment of up to 10 years withhard labor or a fine of up to 10 million yen, or both.
Corporate punishment: fine of up to 300 million yen.
Trademark infringement Trademark Act
Actual offender: imprisonment of up to 10 years withhard labor or a fine of up to 10 million yen, or both.
Corporate punishment: fine of up to 300 million yen.
Unfair Competition Prevention Act
Actual offender: imprisonment of up to 5 years withhard labor or a fine of up to 5 million yen, or both.
Corporate punishment: fine of up to 300 million yen.
Forgery of private documents or uttering: imprisonment
Padded invoicing ofof between 3 months to 5 years with hard labor.
expensesInvoicing of fake expenses Fraud: imprisonment of up to 10 years with hard labor.

Unauthorized creation ofcompany seal
Creating a contract
without permission

Supplementary Information

Indecent assault: imprisonment from 6 months up to 10 Minor crimes, such as performing an act of molestation
years with hard labor.
by touching the body of another person over theirclothes, are punished under the local prefectural
government’s ordinance against disturbing the peace.
Distribution of obscene objects: imprisonment of up to Posting up an obscene poster.
2 years with hard labor or a fine of up to 2.5 million yen
or a penal fine.
Defamation of character by giving facts in front of
Defamation of character: imprisonment up to 3 years
many colleagues.
with or without hard labor or a fine of up to 500,000
yen.
Slander: detention or a penal fine.
Insulting someone without giving facts.

Evading the detection of the influence of alcohol (fleeing
to avoid the detection of the influence and degree ofalcohol and drugs).
Up to 12 years in prison with hard labor.

83

Act

Hit and run

Road rage

Driving without a license
Molestation

Camera voyeurism

There are 10 types of road rage, such as being
dangerously close to other vehicles, changing direction
suddenly, and braking suddenly, and administrative
sanctions for revoking the license of offenders are also
Obstructive driving (risk of causing a significant traffic imposed. In the case of bicycles, 7 types of road rage
are also subject to punishment. If an injury or death
accident)
Imprisonment of up to 5 years with hard labor or a fine occurs, you may be guilty of dangerous driving resulting
in deaths or injuries.
of up to 1,000,000 yen.
Violation of Road Traffic Act: imprisonment of up to 3
Includes driving with an expired license due to reasons
years with hard labor or a fine of up to 500,000 yen.
such as forgetting to renew, etc.
Ordinance against disturbing the peace (in the case of Doing or saying something obscene in a public place oron public transport that causes people to feel extremely
the Tokyo metropolitan area): imprisonment of up touneasy or anxious.
6 months with hard labor or a fine of up to 500,000
yen (if the offender is observed to be a serial offender,
imprisonment of up to 1 year with hard labor or a fineof up to 1 million yen).
Indecent assault: imprisonment from 6 months up to 10
years with hard labor.
Ordinance against disturbing the peace (in the case of
the Tokyo metropolitan area): imprisonment of up to
1 year with hard labor or a fine of up to 1 million yen(if the offender is observed to be a serial offender, up
to 2 years in prison with hard labor or a fine of up to 1
million yen).
Minor Offenses Act: detention or penal fine.

Snatching

Intimidation84

For boys and girls under the age of 13, it is deemedsexual assault or rape even if there is consent.
This offense is judged to have occurred when an
intoxicated person commits grossly crude or violent
behavior that disturbs members of the general public ina public place or on public transport.
There are penalties in place that punish repeatedly
following the same person as an act of stalking.

Ordinance against disturbing the peace (in the case of
the Tokyo metropolitan area): imprisonment of up to 1
year with hard labor or a fine of up to 1 million yen (serial
offender: up to 2 years in prison with hard labor or afine of up to 1 million yen).
Theft: Imprisonment of up to 10 years with hard labor The charge may escalate to robbery if you knock a
or a fine of up to 500,000 yen.
clerk, etc. out of the way to escape.
Theft: Imprisonment of up to 10 years with hard labor
or a fine of up to 500,000 yen.
Robbery: imprisonment for a definite term of at least 5
years with hard labor.
Intimidation: imprisonment of up to 2 years with hardlabor or a fine of up to 300,000 yen.

Penalties

Supplementary Information

Fare evasion

Fraud: imprisonment of up to 10 years with hard labor.

Fighting or quarreling

Assault charges: imprisonment of up to 2 years withhard labor or a fine of up to 300,000 yen or detention
or a penal fine.
Inflicting injury: imprisonment of up to 15 years withhard labor or a fine of up to 500,000 yen.

Fare-evading through an automatic ticket gate will becharged with computer fraud.

BlackmailAct

It is considered a robbery charge when the crimeis accomplished by violence or the threat of it toovercome resistance from the victim.
It may also be considered extortion if the employer
Forcing others to write an Extortion: imprisonment of up to 3 years with hardlabor.
forces the worker to choose whether to be fired orapology letter
leave the company for personal reasons, and have them
Forcing others to undress
write a letter of resignation (“for personal reasons”(without sexual intent)
rather than “for company reasons”).
Embezzlement of lost property: imprisonment of up to Cases such as realizing later that you had been given
Concealing lost items
1 year with hard labor or a fine of up to 100,000 yen or too much change but decided not to return it.
or not returning extra
a penal fine.
changeFraud: imprisonment of up to 10 years with hard labor. Cases such as realizing that you had been given too
much change but left the scene without saying anything.

Nuisance telephone calls

Mahjong-related betting,golf-related betting

Act on Regulation and Punishment of Acts Relating to Children are deemed to be persons under the age ofChild Prostitution and Child Pornography: imprisonment 18.
of up to 5 years with hard labor or a fine of up to 3
million yen.

Simple possession of child pornography: imprisonmentof up to 1 year with hard labor or a fine of up to 1
million yen.
Sexual assault or quasi-sexual assault: imprisonment of
between 6 months to 10 years with hard labor.
Law concerning Prevention of Acts of Nuisance byUnwelcome behavior in
public places or on public Intoxicated Persons: detention or penal fine.
transport while under the (If you resist checks made by police officers, you will
receive a fine of up to 10,000 yen.)influence of alcohol
Stalking
Stalker Regulation Law: imprisonment of up to 1 yearwith hard labor or a fine of up to 1 million yen.

Shoplifting

Supplementary Information

It is still deemed failing to assist persons in danger even
if you go to the police later on.

Charging your cellphone
without permission at arestaurant
Purchasing something
while knowing it is stolen
goodsBlackmail: imprisonment of up to 10 years with hardlabor.

Slander: detention or a penal fine.

Fraudulent obstruction of business: imprisonment of
up to 3 years with hard labor or a fine of up to 500,000
yen.
Inflicting injury: imprisonment of up to 15 years withhard labor or a fine of up to 500,000 yen.
Gambling charges: a fine of up to 500,000 yen or apenal fine (up to 3 years in prison with hard labor if theoffender is observed to be a serial offender).

Theft: Imprisonment of up to 10 years with hard labor
or a fine of up to 500,000 yen.

It is considered inflicting an injury when the act damages
the health of the victim, such as them suffering a
nervous breakdown (It is also considered an injury if
you cause dizziness or nausea, or have somebody faintfor a long time).
Except when betting on something that is consideredmomentary entertainment (it is not consideredgambling if one of the parties involved prepares prizes
and another party loses but does not suffer financial
damages, such as a bingo game that often takes placeat parties, etc.).

Appendix

AppendixChild prostitution

Penalties

Failing to assist persons in danger: imprisonment of up
to 10 years with hard labor or a fine of up to 1 million
yen.
Negligent driving resulting in injury or death:imprisonment with or without hard labor for up to 7
years or a fine of up to 1 million yen.
Obstructive driving (risk of causing a traffic accident)
Imprisonment of up to 3 years with hard labor or a fineof up to 500,000 yen.

Receiving compensation for stolen goods: imprisonmentof up to 10 years with hard labor and a fine of up to
500,000 yen.

1) Imprisonment with hard labor・ ・・・ Detaining a person in a criminal facility and having them carry out the prescribed work(from 1 month to 20 years with hard labor or an indefinite term).
2) Imprisonment without hard labor・・・ Detaining a person in a criminal facility (from 1 month to 20 years or an indefinite term).
3) Detention・ ・・・・・・・・・・・・・ Detaining a person in a criminal facility (from 1 day to 29 days).
4) Combined penalty・ ・・・・・・・・・ Two or more penalties, such as both imprisonment with hard labor and a fine.
5) Antragsdelikt・ ・・・・・・・・・・・ A crime that cannot be prosecuted without the victim pressing charges.
6) Fines and penal fines・・・・・・・・・ The amount of the fine is 10,000 yen or more (it can be reduced to less than 10,000yen). Penal fines are between 1,000 yen and 9,999 yen.
Disclaimer
This information is current as of the publication date of this document. It may not reflect the latest law and regulation revisions.
Although we make every effort to provide as accurate information as possible,
we do not guarantee the accuracy, reliability, or usefulness of the content provided.
Please consult a legal expert regarding any cases that you actually encounter.

If the victim suffers an injury, it is considered to be
robbery resulting in bodily injury (imprisoned for anindefinite term or imprisonment for at least 6 years withhard labor).
It is blackmail when obtaining something throughintimidation.

85

Nippon Filcon Group Compliance Guideline
Publication date: September 2022 (First edition)
Publisher: Nippon Filcon Co., Ltd.
TEL: 042-377-5711
FAX: 042-377-5714