Japan Airport Terminal Co., Ltd. Basic Compliance Guidelines
The purpose of these Guidelines is to establish a compliance regime at Japan Airport
Terminal by prescribing a code of conduct, etc. pertaining to compliance and having all
officers and employees thoroughly implement these Guidelines, thereby establishingcredibility of this Company in society and aiming towards its continuous growth
All officers and employees will comply with laws and regulations and social rules aswell as put in practice the customer first principle by engaging in behavior pursuant tothe code of conduct prescribed in these Guidelines and acting in line with this Company's
Articles of Incorporation, management philosophy and management policy.
I

Management Philosophy"Harmony between the Business and the Society"
The Company's public mission is achieved by private sector management techniques.
While providing high-quality passenger terminal services, this Company will
maximize profits, prepare for future investment and also engage in managementbalancing its corporate nature and public nature that aims to pass-on appropriate
benefits to airline companies, airport users, shareholders and employees.

II

Management Policy
12
3
4IIIEstablish absolute safety in passenger terminal buildings
Operate passenger terminals for the benefit of customers (for convenience,comfort and functionality)
Operate passenger terminal stably and efficiently
Reinforcement of the corporate structure and improvement of the combinedcompetence of group companies

Code of Conduct
The code of conduct should be a shared vision in order to realize the management
philosophy and management policy and it denotes the standard that will be the basisof the behavior when all officers and employees act.
1. To the society
Being conscious of obligations as corporate citizens and recognizing that
all officers and employees are the entities that realize the policy of theCompany, we will actively fulfill our responsibilities as an entity to thecountry and the community.
(1) Contribution to the society
We will actively perform social contribution activities as a good
corporate citizen and contribute to the vitalization of the community,
and the development of safe, comfortable and sustainable airport
infrastructure through the construction, management and operation,etc. of passenger terminals that are of highly public nature, and therealization of a barrier-free society, etc.
(2) Respect for human rights
We will respect human rights throughout its business activities,
including prohibition of discrimination based on gender, age,nationality, race, ethnicity, religion, social status, disability, sexual
orientation and gender identity, etc., prohibition of forced labor andchild labor, prohibition of harassment, and ensuring an appropriate
working environment.
(3) Consideration for global environment
We will comply with the environment-related laws and actively workon the conservation and protection of the global environment throughthe measures against climate change, effective use of limited resources,prevention of environmental pollution and consideration forbiodiversity, etc.
(4) Co-existence and co-prosperity with community
We will strive to be in harmony with the community for theirdevelopment and achieve mutual development of us and thecommunity.
(5) Disclosure of corporate information
We will ensure active communication with the society and disclose thecorporate information timely in an active and fair manner.
2. To our customers
We will work on the improvement of customer satisfaction at all times inorder to realize “Customer First” as our business policy.
(1) Pursuit of customer satisfaction
We will aim at the maximum level of satisfaction at all times so thatcustomers who use the airport terminal buildings will use them again.
(2) Compliance with consumer-related laws
When entering into contracts with customers, we will conducttransactions in a clear and fair manner. We will not induce customers

using a deceptive method or unreasonably expensive giveaways in thecourse of conducting representations, advertisements, or campaigns.
(3) Management of customer information
We will strictly manage the personal information of customers. We will
not use it for any purpose other than intended purposes or cause
leakage or unauthorized use of the information in accordance with thelaws related to personal information protection and the privacy policy.
(4) Handling of complaints
We will strive to deal with consultations and complaints by customers
in a prompt and sincere manner.
3. To our regular clients, business partners, and competitors
We will abolish empty formalities with regular clients, subcontractor
companies or competitors and devote ourselves to the development of fairtransactions and competitions.
(1) Relations with regular clients and subcontractor companies(i) We will comply with all relevant laws and codes and sound businesspractice and act based on a high standard of ethics.
(ii) We will provide entertainment or gifts appropriately in accordancewith the prescribed standards for approval and expense processing
procedures and to the extent deemed reasonable in light of social
norms only in cases where necessary for corporate activities.
(iii) We will strive to establish a sustainable value chain together withregular clients and subcontractor companies.
(2) Relations with competitors
We will ensure fair transactions and will not engage in unfair acts, suchas defamation of competitors and inappropriate comparative
advertising. If such act of any other company occurs, we will takeresolute measures and responses.
(3) Management of customer or industry information
We will exercise due care in handling any confidential information ofregular clients and industry members that is obtained in the course ofour duties (including personal information) and maintain suchinformation in confidence. We will not obtain such information by
fraudulent means or use such information for any purpose other thanintended purposes.
4. To our shareholders and investors

We will strive to earn an appropriate evaluation in capital markets andmaximize the interests of shareholders through timely and highly
transparent information disclosure and active IR activities.
(1) Fair and transparent accounting reporting
We will make fair and transparent report on business results by wayof accounting processing in compliance with accounting principles andcompanies act, etc. as well as ensure the reliability of accounting audit.
(2) Information disclosure
We will comply with the relevant laws and standards, etc. and disclosethe corporate information appropriately.
(3) Active IR activities
We will provide, in an active and fair manner, not only the information
required to be disclosed under the laws and regulations but also theinformation necessary and sufficient for gaining appropriate
evaluation in capital markets and for enabling shareholders andinvestors to make adequate judgment.
5. To politics and administration
We will maintain sound and normal relations with political groups andpublic officials and will not engage in any illegal acts or even misleadingacts.
(1) Maintenance of sound and normal relations with politics(i) We will make a judgment, on a case by case basis, about the
propriety of the request for donation to or purchase of party ticketsof political parties or political fund organizations in accordancewith the relevant laws and internal rules, and take appropriateactions.
(ii) In the course of election campaigns, we will neither commit illegal
acts, such as provision of money, articles, or wining or dining, norcooperate with political candidates in illegal acts.
(iii) In order to ensure the freedom of thought and belief, we will not
engage in any act of forcing, as an organization, individuals to
express their support for a specific candidate in election.
(2) Prohibition of giving of bribe to public officials(i) We will not engage in any act of giving a bribe to public officials or
deemed public officials, etc. or any act that may be misleading assuch.
(ii) We will not engage in any act of giving a bribe to public officials of

foreign countries or any act that may be misleading as such.
(3) Accurate and transparent tax reporting(i) We will comply with the tax-related laws and contribute to the sounddevelopment of society through adequate tax reporting andpayment.
(ii) In compliance with the tax-related laws, we will utilize thepreferential taxation system, etc. appropriately and strive to maketaxation costs more proper. In addition, we will not engage in any
act that is deemed, in light of social norms, to constitute a tax
avoidance that is contrary to the purport of tax-related laws.
6. To antisocial forces
We will ban any relations with antisocial forces that threaten the civilsociety.
(1) Refusal of grant of benefits
We will not grant any benefits to antisocial forces.
(2) Sharing of information
We will share information about antisocial forces within the group anddevelop the system for reporting and taking actions.
(3) Cooperation with relevant bodies
We will strive to eliminate antisocial forces in cooperation with theindustry members and the society and in close collaboration with policeand other relevant administrative bodies.
7. Relations between the Company and its officers and employees
The Company and its officers and employees will establish a relationshipof mutual trust through sincerely fulfilling their mutual obligations andresponsibilities.
(1) Obligations of the Company toward its officers and employees(i) Elimination of discrimination and harassment
・We will eliminate discrimination based on gender, age, nationality,race, ethnicity, religion, social status, disability, sexual orientation,
gender identity, etc. We will never allow workplace bullying, sexual
harassment, pregnancy discrimination or any other harassment.
(ii) Improvement of wellbeing
・We will strive to maintain and improve an employee-friendly work
environment, taking the safety, health, and mental health intoaccount.

・ We will strive to establish the environment that provides job
satisfaction to various human capital.
・We will provide the opportunity for skill development so that various
human capital can make full use of their abilities and cultivate theirpotentials.
・We will strive to enhance various welfare benefit systems.
・We will take and support measures necessary for the maintenanceand promotion of health of officers and employees.
(iii) Confidentiality of personal information of officers and employees
・Taking privacy of officers and employees into consideration, we will
disclose the personal information of officers and employees only tothe departments and management staff on a need to know basis andwill not engage in any act of providing such information
unnecessarily outside the Company as well as within the Company.
・We ensure that we will protect whistleblowers who report to thecompliance information desk and that whistleblowers will not treateddisadvantageously on grounds of whistleblowing.
(2) Obligations of officers and employees toward the Company(i) Duty of loyalty
・In order to realize the management philosophy, we will fulfill ourobligations faithfully in compliance with not only laws but also theRules of Employment, this Code of Conduct and other internal rules.
We will not abuse the authority given to us.
・Except in cases where required for business activities and approvedby the Company, we will not engage in political and religious
activities in the capacity of a position at the Company or of an
employee of the Company.
(ii) Prohibition of acts of conflict of interest and mixing of business andpersonal affairs
・We will not engage in any act of conflict of interest with the Company
or act of mixing business and personal affairs, such as personal useof company assets(iii) Appropriate procedures for application and approval of expenses
・ We will appropriately disburse investments or expenses inaccordance with the prescribed standards for internal approval andexpense processing procedures and appropriately perform accounting
and tax processing in accordance with the relevant laws, accounting

standards, and internal rules.
(iv) Information management (confidential information and insider
information)
・Whether during the period of employment or after retirement, we will
exercise due care in managing any confidential information of theCompany or any third party that we have learned in the course of ourduties and will not use such information without due authorizationor leak such information to any third party.
・We will comply with the regulation on insider trading and will not
engage in unjust transactions of shares, etc. utilizing insider
information that we have learned in the course of our duties or leaksuch information to any third party.
(v) Compliance with laws and regulations and prohibition of acts thatdamage the honor or credibility of the Company
・In our private life, we will maintain the dignity as sound working
members of society and behave in a moderate manner. Not to mention
compliance with laws, we will not engage in any speech or behavior
that results in damaging the honor or credibility of the Company.
IVCompliance Promotion System

1.

Establishment of a Compliance Promotion Committee
We have established a "Compliance Promotion Committee", chaired by the President
and Representative Director, as the organization that oversees and supports reliablepractices of compliance-oriented management and grant it the authority to investigate
and supervise matters relating to compliance.
(Duties)(i) Determine Policies relating to Compliance Promotion(ii) Consider Concrete Measures relating to Compliance Promotion(iii) Monitor the Status of Compliance Promotion

2.

Establishment of a Compliance Information Desk
A compliance information desk have been established to prevent the occurrence ofillegal, fraudulent and unethical acts as well as to minimize the impact on theCompany by promptly grasping the relevant facts in the event that these acts shouldoccur.

3.

Implementation of Compliance Education and Training
The department in charge of Legal affairs will conduct education and training
necessary for compliance with respect to officers and employees to promote anunderstanding of the importance of compliance. Officers and employees must attend

education and training sessions and must seek to diligently educate themselves.
4.

Disciplinary Action against Offenders
In the event of breach of these Guidelines, officers and employees will be subject todisciplinary action pursuant to the provisions of the employment rules etc. even if theCompany does not suffer damage.
The endConcerning the Use of the "Compliance Information Desk" (Notification System)【Compliance Promotion Committee】

President and other Directors

DirectReport[Internal desk]
Vice president incharge of legal affairs(Compliance Promotion CommitteeSecretariat)

Keep even
namedinformers
anonymous if
they wish

Coordinate

Information(Name)
Feed backInvestigation/remedy
results

Attorneys[External desks]
Attorneys

Information(Name /Anonymous)
SelectFeed backInvestigation/remedy
results

Informer[Informer]
Information will be transmitted to either the internal or external desk when judging
whether one's own actions are in compliance with these Basic Compliance Guidelines,
when judging that there are points to be improved in the Company regarding compliance,or when judging that other officers and employees have engaged in actions in breach ofthese Basic Compliance Guidelines.
[Desk]For information provision, primarily action will be taken at the desk that received theinformation. With respect to the provision of information to the external desk, the external
desk will, if necessary, work in cooperation with the internal desk. The internal desk will
confer as required with the Compliance Promotion Committee.
[Protection of Informer]
The information desks will not disclose the name of the informer or the contents of theinformation provided to persons other than required relevant persons. Furthermore, theinformer will not suffer disadvantages for appropriately using this system.