DISCLAIMER
THIS ENGLISH VERSION OF “CODE OF CONDUCT” WAS CREATED AS A
REFERENCE MATERIAL FOR SELECTED PART OF THE ORIGINAL JAPANESEVERSION.
THE ORIGINAL JAPANESE VERSION IS THE ONLY OFFICIAL AND COMPLETE
DOCUMENTATION.
NET ONE SYSTEMS CO., LTD. MAKES NO GUARANTEES WHATSOEVER WITHREGARD TO THE ACCURACY OF TRANSLATION OR CONTENTS OF THISENGLISH DOCUMENTATION.

0Code of Conduct

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Integrity & Trust“Integrity & Trust” is the most basic value to be shared by us for conducting
our business. Both “Integrity” and “Trust” have a meaning of fairness,honesty and respect. Based on this value we maintain a good relationshipwith every stakeholders and take social responsibility as a good citizen.

3 Principles of Conduct“Conduct of Integrity and Trust” is formed by day-to-day activities of each ofus. In day-to-day activities, we bear in mind the following three (3) principles:(1) Make judgement with evidently fairness and behave(2) Speak and act honestly following your conscience(3) Have a relationship with others based on mutual respect

Important things to achieve compliance
When we face legal or ethical questions during doing business, we makejudgements and behave taking into consideration the following four (4)points:(1) We do not make judgement unfaithfully like “Oh, well”, “No muchproblem”. Instead, we make judgements based on the spirit of “Integrity& Trust” that is the basic value. In the event that we cannot makejudgement after reference of this Code of Conduct, we consult with our
superior or Compliance Division.
(2) Quick decision making is required in the business. However, we do notmake an irresponsible judgement like “Maybe OK” even in the imminentsituation. We behave based on responsible judgements which are madethrough consideration from all aspects.
(3) Due to rapid technological innovation in the ICT market, sometimes laws
go behind the reality. We do not think “it is OK, because it is not illegal”.
We behave appropriately taking into consideration whether it is ethical ornot.
(4) Due to the current remarkable change, “Empirical Rules” rapidly
becomes obsolete not meeting the current situation in some cases. We
do not depend solely on “Empirical Rules” and always behave inaccordance with the most recent internal rules.
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20 Standards of Conduct
Re：Employees
1 Healthy, Safe and Supportive Work Environment
2 Respect for Personality and Individuality and Appropriate Communication
3 Respect for Fundamental Human Rights
4 Maintenance of Discipline
5 Protection and Management of Assets and Information
6 Distinction between Public Matters and Private Matters
7 Moderate Relationships with Customers and No Relationships with Anti-Social
Forces8 No Insider Trading
9 Protection of Privacy
Re： Customers
10 Customer Needs are first
11 Fair and Transparent Business Relationships with Customers
12 Developing Business in accordance with Laws and Ethics
13 Handling Customers’ Complaints Promptly and Appropriately and Preventing
Troubles beforehand
14 Managing Customers’ Confidential Information and Personal Information
Strictly
Re: Partners (Suppliers, Subcontractors, Consultants etc.)
15 Fair and Transparent Business Relationships with Partners
16 Selecting and Managing Partners Adequately
17 Maintaining and Controlling Product Quality
Re: Shareholders
18 Proper Accounting Processing
19 Disclosure of Management Information in a Timely and Proper Manner
Re: Social and Environment
20 Contribution to Society, Preservation and Protection of Global Environment3

1 Healthy, Safe and Supportive Work Environment
Our Commitment
A. Provide and Maintain a Healthy and Safe Work Environment
Safety, hygiene and health are fundamental things for all working
conditions. We have a medical check annually for health care by ourselves.
In addition, if necessary we receive a professional counselling service
provided by the Company to resolve the problems that we have forourselves.
Managers and the Company take good care of safety and hygiene
including employee’s mental health. In addition, we improve and maintainthe working environment to make each employee fulfill one’s capability.

B. Prevent Disaster and Accident in close corporation
We observe the laws and company’s internal rules with respect tosecuring safety and hygiene in the working place and endeavor to preventthe occurrence of disaster and accident. The Company holds various safety& hygiene prevention activities to secure employees’ safety in collaboration
with employees.
In the event that state of emergency including disaster, accident,
epidemic disease arises, we act pursuant to directions issued byemergency headquarters or related divisions. We promptly report to HR
division an accident which arises while working or commuting.

42 Respect for Others’ Personality and Individuality and Appropriate
Communication
Our Commitment
A. Respect for Others’ Personality
Appropriate Communication

andIndividuality

andIn the Company which has vibrant atmosphere a polite greeting is thebasis of all manners. And RCT (Respect, Communication & Teamwork) is
indispensable to create and maintain a corporate culture which is liberaland open-minded, and values compliance.
We endeavor to communicate with each other smoothly and, respect andtrust the other’s personality and individuality.

B. Cultivate Professionality and Creativity to Fulfill Ability andPotential
We always endeavor to develop ourselves to improve our professionality
and creativity in order to create a new marketplace meeting social needs.
The Company also endeavor to create a vibrant corporate culture anddevelop professional and creative human resources. The Company pays
attention to the creation of a fair and transparent performance evaluation
system in order for each employee to feel a sense of accomplishment by
self-fulfillment.

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3 Respect for Fundamental Human Rights
Our Commitment
A. Respect Fundamental Human Rights and Not Discriminate
against Other Persons
The Company respect each employee’s fundamental human rights anddoes not distinguish employees with irrational reasons irrelevant to
conducting the business which includes but not limited to type of hiring,
race, religion, color, sex, nationality, language, physical characteristics, age,marriage/single.
We never abuse, slander or harass other employees or outsiders inside oroutside the office.

B. Never Tolerate Harassments
Harassments cause a serious adverse effect on (1) atmosphere and orderof the office where a cause person and a victim work together and (2)motivation of the employees in the office.
We make good human relationships and good office environment
preventing harassment and teasing pursuant to “Rules for Harassment
Prevention”.
Each Manager always watches an office environment in charge and is
careful about how he/ she speaks and behaves, and endeavors to prevent
harassment through coaching and warning statements.
The Company takes strict measures against harassments. If harassment
has occurred, the company takes strict measures including disciplinary
punishment against a cause person and give a relief for a victim, andendeavors to prevent recurrence of such harassment as well.

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4 Maintenance of Discipline
Our Commitment
A. Comply the Company’s Internal Rules
We comply our Company’s internal rules and regulations and behaveorderly. This is imperative for soundly managing the organizations of ourCompany and our Net One group. We do not make selfish judgement like“we can do anything which breaches internal rules so long as not found byothers”.
The Company take strict measures against breach of internal rules.

B. Conduct Business in accordance with Company’s Rules andMake Records based on the Fact
Net One Group companies have various internal rules in which decision
making process and authorized person for each task are described.
We conduct business pursuant to the process described in the internal
rules and obey the decision made by authorized person described in theinternal rules.
And we precisely record and preserve all of decision making processes. In
addition, we make all of the documents or reports accurately and evidently
showing the contents and substances based on the facts.

C. Do Not Behave Against the Ethics
We do not behave against socially accepted ethics even if not clearly
described as forbidden matters in the internal rules or laws or regulations.

75 Protection and Management of Assets and Information
Our Commitment
A. Protect and Manage the Company’s Tangible or Intangible
Assets Properly
Neglect of management of the Company’s assets gives material effect on
business operation and the company’s financial results. We properly
protect and manage not only tangible assets, but also intangible assets
including intellectual properties. We do not use the Company’s assets for a
private matter.

B. Do Not Cause the Company’s Confidential Information to Leak
Out
Once we leak the Company’s confidential information and personal
information, there is risk that social trust of the Company is lost and we bear
criminal and civil liabilities.
We strictly manage the Company’s confidential information and personal
information and do not cause them to be leaked to any third party. Even
after we left the Company or were fired, we do not disclose such information
to any third party or the other company we newly enter.

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6 Distinction between Public Matters and Private Matters
Our Commitment
A. Clarify Distinction between Public Matters and Private Matters
We do not bring a private life or interest into the Company.
Also, we do not bring a public role into a private life or outside the Company.
We respect freedom of ideology and religion of individual persons, but during
working hours we concentrate on our duty work and do not engage inmissionary work or persuasion and keep order of the office.

B. Do Not Use the Company’s Property for Personal Matter
We carefully treat building, equipment, facility, system and software and use
them only for conducting the business following the Company’s internal rules.
We never use them for personal matter.
We do not charge the Company the fee for personal matter as expenses.
We charge only the actual expenses for business activities including
business trip and reception of the guests. We never take unjust monetary
profit. We attach necessary proof document required by an adequate
decision-making process for payment of house expenses. The manager who
noticed that his subordinate is using the Company’s property for his personalmatter must instruct him to use the Company’s property only for conducting
the business.

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7 Moderate Relationships with Customers and No Relationships with
Anti-Social Forces
Our Commitment
A. Have Relationships with Customers with Modesty
We do not give or receive an entertainment or gift in excess of sociallyapproved pattern of behavior in order to fairly conduct our duties. Especially
we never give a government official or a deemed government official any
entertainment, gift or benefit.

B. Do Not Have Relationships with Individual Politician or AntiSocial Forces
We respect individual political belief, but the Company does not support
specific politician and political organization. Accordingly, we never give any
cash gift, entertainment or benefit to any individual politician or politicalorganization in the course of business.
We never have any relationships with anti-social forces which threaten orderand safety of civic society. We stand against any menace and threats, andare not involved in anti-social activities and activities against public order andmorality.

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8 No Insider Trading
Our Commitment
A. Strictly Manage Non-Public Important Facts Regarding Group
Companies
The Company strictly manages non-public facts regarding the groupcompanies (the Company and its affiliates) and prevent leakage. We
preclude insider trading in order for investors to invest without worry.
In case we come to know important facts, we never disclose them to any
person except for the persons concerned.

B. Obtain a Permission in advance to buy and sell the Company’s
stocksWe never do any insider trading. When we trade the Company’s stocks, wenotify to the division of that in charge in advance and follow its direction.

C. Pay Attention to Non-Public Important Facts regarding
Customers and Partners
We also pay close attention to treatment of non-public important facts
regarding customers and partners (subcontractors, suppliers).

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9 Protection of Privacy
Our Commitment
Pay Close Attention to Personal Information and Privacy
We fully understand our Company’s “Policy of Protection of Personal
Information”.
We do not disclose employee’s personal information and privacy recklessly
without his or her consent. Especially the one who handles personal information
pays close attention in handling personal information and manages it properly
and strictly.
And we also manage customers’ confidential information and personal
information not to be leaked to any third party.

1210 Customer Needs are first
Our Commitment
A. Grasp Individual Customers’ true Needs
We always think from viewpoint of customers and endeavor to grasp
customers’ diverse needs promptly and appropriately.

B. Provide Excellent Products and Services
We provide products and services which conform to customers’ true needs.
We find new markets within the ICT territory, endeavor to develop excellent
products and services, and create a market which meets social needs.

1311 Fair and Transparent Business Relationships with Customers
Our Commitment
A. Endeavor to Provide Precise Information and Respect
Judgement of Customers by themselves
We never neglect necessary explanation at any time. We fully provide
precise information in order for customers to use our products and services
without worry and safely.
It is our customers who decide to purchase the products and services
provided by our Net One group.
We do not give our customers any entertainment or gift in excess of sociallyapproved pattern of behavior for the purpose of influencing their judgements.

B. Execute Written Contracts with Customers
We execute written contracts which describe the items agreed regarding
contents and terms & conditions of deals with customers, including without
limitation sales agreements, consignment agreements and construction
agreements. It is very important to execute proper written contracts for
decreasing risks.

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12 Developing Business in accordance with Laws and Ethics
Our Commitment
A. Do Not Perform Illegal or Unfair Sales Operations WhichHarms Customers’ Interests
If we perform sales operation with illegal or unfair methods, we losecustomers’ trust for Net One group. In some case we may be expelled fromthe market.
We always perform legitimate and transparent sales operations based
upon fair and free competition.
If we perform joint sale operations with other companies, we pay attention
to them not performing illegal and unfair sales operations.

B. Surely Acquire Necessary Permission, License andRequirement
Prior to dealings, we confirm whether we have necessary permission,
license and requirement in advance. If we trade with certain customers
such as national or local governments, permission acquisition is provided
in some national or local laws and certain license or requirement may berequired.

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13 Handling Customers’ Complaints Promptly and Appropriately, andPreventing Troubles beforehand
Our Commitment
A. Act Faithfully, Promptly and Properly
In the event that some trouble has occurred or we have received acomplaint from a customer, how to act first is a crucial point. If we takeerroneous action against the customer’s complaint, we have risks suchas facing trouble with the customer or lowering our trust. Therefore,reasonable action is required in light of risk control.
Firstly, we communicate with the customer faithfully and politely.
Secondly, we investigate the fact promptly in cooperation with related
divisions. Lastly, we take appropriate measures as an organization after
consulting managers. In this way, we change occurrence of a complaint
or a trouble into an opportunity of acquisition of the customer’s trust.

B. Improve Our Products and Services through Complaints
Customer’s complaints and requests are free advice for the Company’s
products and services.
We analyze their contents and take action for prevention of recurrence,and utilize them for future development of products and services.
Therefore, we share information such as complaints and requests in Net
One Group.

C. Always Endeavor to Improve Our Skills and Prevent
Occurrence of Complaints
We endeavor to improve ourselves utilizing opportunities for improving
our skills inside and outside the Company, and cope with change ofbusiness environment in ICT market. We maintain quality of products andservices, and prevent occurrence of complaints and troubles.

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14 Managing Customers’ Confidential Information and Personal
Information Strictly
Our Commitment
A. Strictly Manage Customers’ Confidential Information and

Personal Information
Leakage of customers’ confidential information and personal information
gives material effect on business operation and the Company’s financial
results. The value of precious confidential information and personal
information is maintained only by keeping them secret.
We strictly manage and use customers’ confidential information andpersonal information in accordance with the terms of “Non-Disclosure
Agreement”. We never use them for unjust purpose or leak them to any
third party. After we leave the Company or are fired, we do not disclosesuch information to a third party or the other company we newly enter.

B. Do Not Get Confidential Information and Personal Information
Unjustly and Leak Them
We fully understand the Company’s Policies including “Policy of Protection
for Personal Information” and “Fundamental Policy of Information Security”,
and never leak customers’ confidential or personal information.

(1) We do not receive customers’ confidential and personal information until
we enter into “Non-Disclosure Agreement” with such customers.

(2) We do not get confidential or personal information of a customer who is
a competitor for us in order to avoid unjust acquisition of suchinformation.

(3) When we get customers’ information, we confirm the route of acquisition
and get it with proper way. Also, we record the acquisition precisely andin detail.
Example of High Security

Configuration Chart of Customer’s Network

Information

Configuration Information
IP Address
Pass Code
Personal Information

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15 Fair and Transparent Business Relationships with Partners
Our Commitment
A. Maintain Sound and Normal relationships
We maintain sound and normal relationship with partners (sub-contractors
and suppliers) following the principle of fair, transparent and freecompetition. If we are at a superior position, we maintain equal and fairbusiness relationships based on the foregoing stance.
If we received a request irrelevant to Net One Group from partners, weconsult and report with managers.

B. Do Not Receive an Entertainment or Gift in excess of Socially
Approved Pattern of Behavior
We do not receive personal benefit from partners. To receive anentertainment or gift is exceptionally permissible so long as withincourtesy and in accordance with certain procedures described in theinternal rule of ethics. We do not receive any entertainment or gift which
may influence Company’s business decisions even if it is given to each
employee on a personal basis.

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16 Selecting and Managing Partners Adequately
Our Commitment
A. Make Proper Relationships with Partners
When we select partners (sub-contractors, suppliers), we comply withselection guidelines or rules set out in the Company’s related internal rules.
In addition, we fairly evaluate partners and procure and order properly.
Also we observe the relevant laws and sound business customs as well,and build up and maintain a cooperative relationships with customers.

B. Manage and Instruct Sub-Contractors and Endeavor tomaintain quality of their businessWe manage and instruct sub-contractors and endeavor to maintain qualityof their business. We check eligibility of partners continuously.

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17 Maintaining and Controlling Product Quality
Our Commitment
A. Thoroughly Control Quality of Delivered Products and Services
We always think what quality is required to the Company from customers
and markets. We conduct responsible quality control by properly checking
delivered products and services from partners (sub-contractors andsuppliers). Occurrence of defective products and services may give an
adverse impact on the Company’s financial results.
In the event that we find defective products and services, we act promptly
and properly pursuant to the terms of contracts with partners by pointing
out where the defects exist and what the defects are in cooperation withrelated divisions.
In addition, we utilize information regarding defects to improve quality andcustomers’ satisfaction by feeding back them to partners.

B. Do Not Make a Complaint or Require to Send Back or replacewith Unjust Reason
We do not make a complaint regarding products and services or require tosend back or replace them for unjust reasons. If recognition or opinion issplit between us and partners, we resolve the matters with gentlemanly
discussion.

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18 Proper Accounting Processing
Our Commitment
A. Do Proper and Prompt Accounting Processing pursuant tovarious Laws and Accounting Standards
We conduct business in accordance with Company’s internal regulations orrules regarding internal control. In addition, we prepare financial documents(consolidated, non-consolidated) correctly and promptly based on the facts
pursuant to laws and accounting standards in order to secure soundness offinancial conditions. We never counterfeit accounting documents or sales
amount leading to window-dressing accounting.
The Company prepares financial documents pursuant to laws andregulations and have them audited by auditors and auditing officers.

B. Operate our business making much of shareholders
We can gain correct results of operations by piling up of each one’s properaccounting processing. We keep shareholders’ interests in mind andoperate our business making much of shareholders. Our executives whoare entrusted by shareholders operate our business with integrity and trust.

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19 Disclosure of Management Information in a Timely and Proper
MannerOur Commitment
A. Disclose Correct and Fair Information In a Timely an Proper
MannerWe disclose correct and fair information which stakeholders require in atimely and proper manner. By this way, we aim to acquire trust ofshareholders, customers and all of society.

B. Conduct IR Activity Positively
We disclose various management information through IR activity forshareholders and investors and endeavor to secure transparency of ourCompany’s management.

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20 Contribution to Society, Preservation and Protection of Global
Environment
Our Commitment
A. Carry Out Social Mission and Contribute to Society
We carry out our social mission and contribute to society with highly valueadded technologies and services in ICT market which requires us more
technological innovation.
We, as a member of civic society, promote activities which contribute tosociety and aim for prosperous coexistence with society. In addition,
through actions which contribute to society we strengthen corporation
between employees, promote business operations including vitalization of
Net One Group and training of human resources.

B. Promote Environmental Preservation with Technologies andQuality inside and outside Company
We contribute to decrease of customers’ environmental burden by
improving quality of technologies, products and services provided by Net
One Group. In addition, we endeavor to improve our business operations
and change our work style by utilizing ICT technologies efficiently. In thisway, we aim for reduction and recycle of wasted materials and promote
green procurement.
Also, the Company endeavors to train personnel who can act taking into
consideration environment in any business operations.

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