1

Suncall Group
Code of conduct
To All of the Suncall group employees
We have conducted corporate activities with the purpose of building good relationships with various
stakeholders (interested parties: customers, local residents, governments, shareholders, etc.).
Maintaining and expanding relationships is essential for the company's survival and development.

Corporate activities are the accumulation of the actions of each and every employee working in thecompany. Therefore, in order to be a company that is favorably accepted by various stakeholders,
all employees must comply with laws and regulations, respect "social norms", and act in accordancewith corporate ethics. The thoroughness of the "compliance" is essential.

It was more than 20 years ago that companies began to actively work on "compliance" in Japan.
During that time, "compliance" has expanded its scope to corporate's "social responsibility" (CSR),
and has become more sophisticated and complex. At the same time, social norms are alsochanging. What was "right" in the past may not be "right" in the present age. In that sense,"compliance" can be said to be "activities that should be continuously addressed on a daily basis,
while responding promptly to the demands of a changing society, and incorporating them into ourwork and life.

"Compliance Promotion Activities" at Suncall have been promoted by the Compliance Committee,
based on the thorough dissemination of the "Code of Conduct" established in 2003.
We appreciate and recognize the daily activities and steady efforts of initiatives such as the"Compliance Reinforcement Week" at each workplace, and no major issues have occurred to date as
the outcome of the high awareness from each one of you.

This "Code of Conduct" is organized into two categories, "CSR Policy" and "Code of Conduct", inaccordance with the "increasing sophistication and complexity of CSR" and "changing in social
norms" mentioned above. In other words, we have a "CSR policy" that shows our company's overall
approach to CSR both inside and outside the company, and a "code of conduct" that shows that
Suncall employees can act with an awareness of the practice of compliance.

This document titled "Suncall Group Code of Conduct" covers all the content that should becommunicated to employees, including an explanation of the "hotline (reporting system)".
This applies to all employees, including executives, employees, and temporary employees.
Each employee is encouraged to follow this code of conduct as a guideline for daily work, and takesensible and responsible action in daily life as a member of the Suncall Group and a member ofsociety.

Compliance Committee
Suncall Group Code of Conduct

2● CONTENTS
Ⅰ. Suncall Philosophy
Ⅰ-1. Management Philosophy
Ⅰ-2. Basic Philosophy（CORPORATE MIND IN MIND）
Ⅱ. CSR Policy
Ⅱ-1. Corporate Social Responsability（CSR）
Actions with an awareness of Corporate Social responsibility (CSR)
Ⅱ-2. Fair Trade/Ethics
Compliance with laws and social norms
Earning trust from customers and business partners
Handling Anti-social Forces
Ⅱ-3. Information Management
Information management and confidential leakage prevention
Protection of personal information
Prohibition against insider trading
Protection of intellectual property
Ⅱ-4. Environmental Conservation
Ⅱ-5. Safety and HealthⅡ-6. Quality
Ⅱ-7. Technology
Ⅱ-8. Stakeholders
Respect of Human Right
Environment creation toward self-fulfillment of the employees
Coexistence with the community
Promotion of communication with society
Ⅲ. Code of Conduct
Ⅲ-1. Corporate Social Responsibility（CSR）
Action with Corporate Social Responsibility (CSR) in mind
Ⅲ-2. Fair Trade and Ethics
Compliance with Laws, Regulations, and Social Norms
Compliance of the contracts
Compliance with competition laws (Antimonopoly Act, Unfair Competition Prevention Act,
Subcontract Act, etc.)
Earning trust from customers
Establishing Relationships of Trust with Business Partners
Fairness in opening doors
Management of export transactions
Responsible procurement of resources and raw materials
Business entertainment and gift-giving
Healthy relationship with Politics and Governments
Handling anti-social force
Ⅲ-3. Information Management
Information Management
Confidential Leakage Prevention Measurement
Support for e-commerce and protection against threats on computer networks
Privacy Prevention
Prohibition of insider trading
Protection of Intellectual Property

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Ⅲ-4. Environmental Conservation
Ⅲ-5. Safety and HealthⅢ-6. Quality
Ⅲ-7. Technology
Ⅲ-8. Stakeholders
Respect for Personalities and Human Rights
Environment creation toward self-actualization of the employees
Safe, clean and comfortable working environment"Report, Communicate, Discuss" System
Maintaining a Healthy Work Environment
Prohibition of sexual harassment
Prohibition of power harassment
Distinction between business policy and private interest● Prohibition against using company equipment etc. for personal purposes● Protection of Company Assets● Prohibition of Conflict of Interest Transactions
Coexistence with Local Communities
Promotion of communication with society
Timely and accurate information disclosure to investors and funders
Ⅳ Suncall Compliance Organizational Chart
Ⅴ Compliance keywords
Ⅵ Hotline（Reporting System）

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Ⅰ Suncall Philosophy
Ⅰ-1.

Management Philosophy
TECHNO PROGRESS & CREATIVE CHANGE

技(Gi) 翔(Syo) 創(Sho) 変(Hen)
Ⅰ-2.

Basic Philosophy of the Corporation（CORPORATE MIND IN MIND）
We define our business theme as"To create technology-intensive precision products"
For society, it is our raison d’etre to"To provide wisdom and quality inside of the products we create,"
and we are targeting to"Become a company with a strong corporate culture, internationality, andtechnological capability that makes a lasting impression to people's hearts."
Our corporate principle is to strive toward"Prioritize public morality, Respect for people, Balanced management, Cosmopolitan
Outlook, and Be one step ahead of the market. Esteem challenging mind
(CHALLENGE), Pay careful attention (CARE), and Be Sensitive (SENSIBILlTY); Be fair
(FAIRNESS), Possessing a wider vision (FLEXIBILlTY), and Be creative (CREATIVITY);
Follow the rules (RULE), and foster the good teamwork (COOPERATION)."

For the people who get to be involved with us,"We promise a higher performance leading to mutual profits."
And all of the above, we promise"To supply suitable price, suitable quality, suitable machine (3S) to the customers.
"To conduct fair and open-door policy, and consistent transactions" to the suppliers.
"To provide fair performance evaluation and be a company that everyone take a pride"to the employees.
"To perform steady management and stable dividends" to the stockholders.
"To be a good neighbor" to the community.

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Ⅱ CSR Policy
Ⅱ-1. Corporate Social Responsibility（CSR）▶Action with Corporate Social Responsibility (CSR) in mind
SUNCALL group’s executive officers and employees shall always conduct responsible actions
with CSR (Corporate Social Responsibility) in mind as a member of society.
Ⅱ-2. Fair Trade and Ethics▶Compliance with laws and social norms
We shall respect and follow the laws and regulations, and obligate the social norms.
▶Earning trust from customers and business partners
We shall earn the trust by responding sincerely to our customers and business partners.
▶Handling Anti-social Forces
We shall have no relationship with antisocial forces that threaten social order and safety, andhave no compromise on unreasonable demands. We shall correspond with a resolute attitude.

Ⅱ-3. Information Management▶Information management and confidential leakage prevention
We shall not illegally acquire or use trade secrets or other confidential information owned by
the third parties such as customers and business partners. If duly obtained through businessactivities such as product manufacturing and distribution, we shall properly manage toprevent leakage.
▶Protection of personal information
We shall obtain all personal information related to employees, customers, business partners,
etc. in a legitimate manner, and strictly manage and protect the information.
▶Prohibition against insider trading
We shall not conduct insider trading. We shall not leak insider information to customers,
business partners, family, relatives, acquaintances, friends, etc.
▶Protection of intellectual property
In addition to protecting our intellectual property, we shall value the intellectual property ofothers, and manage it appropriately to prevent unauthorized use and infringement.

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Ⅱ-4. Environmental Conservation
Through our business activities, we shall promote environmental management in order tocontribute to both a prosperous society and environmental conservation.
Ⅱ-5. Safety and HealthIn order to prevent accidents and health problems from occurring during work, we shallpromote the creation of a workplace environment which provides a sense of security andsatisfaction to the employees.
Ⅱ-6. Quality
We shall commit to quality to meet the expectations of our customers.
Ⅱ-7. Technology
We shall plan, research and develop, and manufacture and distribute safe products;
understand social demands and customer needs accurately with conservation of the global
environment.
Ⅱ-8. Stakeholders▶Respect for Human Rights
We shall respect the human rights of each individual and respond with dignity.
▶Environment creation toward self-actualization of the employees
We shall strive to provide professional development opportunities for our employees toimprove the skills and knowledge necessary to our business.
We shall focus on to create a pleasant, safe, and comfortable work environment.
▶Coexistence with Local Communities
We shall place importance on awareness of being a member of the community, and initiate
and preserve an attitude of progressing together.
▶Promotion of Communication with Society
We shall make efforts to deeply listen to social voices through open and fair communication,and reflect these voices in our business activities.

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Ⅲ. Code of Conduct
Ⅲ-1. Corporate Social Responsibility（CSR）
Action with Corporate Social Responsibility (CSR) in mind
We shall conduct responsible actions as a member of society with pride and awareness of
being SUNCALL group’s executive officers and employees.
We shall not only observe laws and regulations, social norms, and company rules, but also
be aware of social common sense and manners, and make efforts to respond to social trust
through making actions to be proud of as a part of business based on corporate ethics.
【Supplementary information】 We should speak and act with common sense even outside thecompany. We should strictly refrain from incurring debts through gambling activities or illegal
acts. As relates to alcohol consumption, we should maintain self-control so as not to allow
alcohol to take control of our lives, and not force others to drink. Enjoy alcohol consumption
within the bounds of common sense. As for cigarettes, we should be careful not to cause
discomfort to others.

Ⅲ-2. Fair Trade and Ethics
Compliance with Laws, Regulations, and Social Norms
We shall observe laws and regulations, and social norms.
We shall seek to be a company that is trusted in each country and region, conducting
corporate activities in accordance with not only domestic, but also international laws andregulations, practices, and social rules and norms.
We shall understand and comply company regulations including office regulations and othercompany rules based on their purposes. Also, we shall improve and revise various rules
according to changes in values of the times.

【Supplementary information】 It is not correct to think that we can do anything as long as we
do not break the law. The standards of social norms, ethical values, social common sense,and manners for social life alter with the times. We should always verify that our values
correspond to these changes.
【Supplementary information】 What are social norms?
Compliance with applicable laws and regulations of each country such as child labor, forcedlabor, wages, and working hours; respect for human rights, non-use of conflict minerals;
freedom of association, the right to organize and bargaining collectively, and other laws,
standards, and regulations around the world; furthermore, ban on any relationships with
antisocial forces. (Underline details, refer to below)

Suncall Group Code of Conduct8[Child Labor]
・We do not use child labor.
・The working age shall be 15 years old, the minimum working age or the age
atcompletion of compulsory education according to the applicable laws and regulations of eachcountry, whichever is the highest.
・We do not use employees under the age of 18 for hazardous work.
・Vocational training and apprenticeship shall be allowed for employment only to the extent
permitted by the applicable laws and regulations of each country.
[Forced Labor]
・We do not use forced labor, or slave labor.
・We can ensure that all labor is voluntary, and our employees can leave their jobs freely.
・We do not require our employees to hand over passports, official identification cards orwork permits as a condition of employment.
・All employees must be legally employed.

[Wages]・We shall pay salaries to employees in compliance with applicable laws and regulations ineach country regarding minimum wage, overtime, wage deductions, piece wages, and otherbenefits.
・We shall provide legal required payment.
・Salary and other payment, company benefits and deductions shall be communicated to
employees in a timely and clear manner in compliance with applicable laws and regulations ineach country.
[Working Hours]
・We shall comply with the applicable laws and regulations of each country and region that
stipulate the determination of employees' working hours (including overtime), the granting ofholidays and annual paid leave, and other matters.

[Freedom of Association]
・We recognize the right of employees to freely associate or not to associate in accordancewith the applicable laws and regulations of the countries we conduct business activities.
・We shall ensure that employees have the right to communicate openly and directly withmanagement without fear of retaliation, intimidation or harassment.

Compliance of the contracts
We shall respect contracts with customers and business partners, accurately fulfill our
obligations in accordance with the agreements, and strive to build and maintain relationships
of mutual trust through sufficient communication.

Suncall Group Code of Conduct9Compliance with competition laws (Antimonopoly Act, Unfair Competition Prevention
Act, Subcontract Act, etc.)
We shall comply with the competition laws (Antimonopoly Act, Unfair Competition
Prevention Act, Subcontract Act, etc.) of each country and conduct our business inaccordance with sound and fair business practices. We shall not engage in violations, such asprivate monopolies, unfair trade restrictions (cartels, bid rigging, etc.), unfair trade practices,or abuse of a dominant position.
【Supplementary information】
Prohibition of abuse of dominant bargaining position
Abuse of a dominant bargaining position refers to the use of a company in a superior
position, such as a subcontractor or a long-standing business partner, to make unreasonable
demands or conduct forced transactions contrary to normal business practices.
Unless otherwise officially decided by the company, we shall not dispatch employees,
request cooperation money, or demand personal matters (such as recruitment) to ourbusiness partners.
We should not force our business partners to acquire other companies’ information andother companies’ confidential information by using our superior position.

Earning trust from customers
For customers, we shall be aware of being representatives of SUNCALL, and always make asincere, precise, timely, and trusted response.
We shall listen to every customer’s voice, think from the perspectives of our customers,
make customer-oriented responses, and intend to make creative suggestions to generate
new values.
We shall respond sincerely to customer complaints, which will lead to quality improvement
and recurrence prevention.
Establishing Relationships of Trust with Business Partners
We shall build fair and healthy relationships of trust with our business partners based on awide range of mutual understanding, such as compliance with laws and social norms andglobal environmental conservation, and strive to strengthen partnerships while pursuing
mutual development.
(Reference) Obligation of competition laws, and p rehibition of abuse of dominant position

Fairness in opening doors
We shall provide equal opportunities, and fairly open our doors to business partners andcandidates. We shall select suppliers by prescribed procedures, and conduct fair-trading.
Management of export transactions
In accordance with laws and regulations related to export transaction management, we shallconduct transactions with the products and technologies to be exported after confirming
whether they are regulated items.

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Responsible procurement of resources and raw materials
We shall conduct procurement activities in consideration of the impact on local communitiesof the use of raw materials (e.g., conflict minerals from Congo, conflict minerals (3TG), etc.)that may cause social problems such as human rights violations and environmental
destruction, and shall avoid using them when there are concerns.
【Supplementary information】 Congo’s conflict minerals
Minerals (3TG: tin, tantalum, tungsten, and four mineral resources of gold + cobalt)
produced in the Democratic Republic of the Congo and surrounding countries, and theminerals that fund the activities of armed groups in the region.

Business entertainment and gift-giving
We shall not offer or receive excessive business entertainment, gifts, money to or from
customers, suppliers, and other business partners for the purpose of gaining or maintaining
unfair profits or unfair preferential treatment. (Corruption prevention)【Supplementary information】 It is necessary to respond carefully even in the customary
Japanese middle and year-end holidays. When eating and drinking together, please avoid
placing a financial burden on the other party.
When providing entertainment, receiving entertainment, or responding to ceremonial
occasions, please do not make decisions alone, but consult with your supervisor thoroughly.

Healthy relationship with Politics and Governments
We shall make political contributions and donations in accordance with the laws of eachcountry, and strive to build transparent and fair relationships with politicians and government
officials. We shall not engage in unfair collusion such as excessive entertainment and gifts,
both public and private, and avoid suspicious relationships.
【Supplementary information】 Gifts of money or goods to employees of government offices
are prohibited by law. Even overseas, it is prohibited by law to provide benefits such as bribes
to foreign public officials, so the same care must be taken as in Japan.

Handling anti-social force
We shall have no relationship with antisocial forces that threaten social order and safety, andwe shall not compromise on unreasonable demands and reject resolutely.
【Supplementary information】 When making a new contract or transaction, it is necessary to
pay attention to whether the other party is involved in antisocial forces such as so-calledorganized crime groups. Not knowing is not an option.

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Ⅲ-3. Information Management
Information Management
We will not disclose confidential information such as trade secrets, customer information,technical information, etc. obtained through business activities such as the manufacture andsale of products, and the identity of our company. Treat all information as an important asset
and strictly manage it, and we shall endeavor to never leak information to the outside(competitors, customers, business partners, mass media, acquaintances, family members,parents, relatives, etc.). We will not publish it to an unspecified number of people on blogs on
the Internet, SNS, etc.
【Supplementary information】 If confidential information such as trade secrets, customer
information, and technical information is leaked, the company's profits and social credibility
will be lost. In addition, there is a risk of counterfeiting and plagiarizing by outsiders if thecompany's product information is leaked or exposed.

Confidential Leakage Prevention Measurement
We shall pay attention on a daily basis to prevent the leakage of work-related informationand data so that it can be accessed only by authorized people. For taking information outside
the company or responding to provision or request for information from third parties, we shallprovide great consideration, handle it with caution by consulting superiors, etc., and conduct
prescribed procedures.

Support for e-commerce and protection against threats on computer networks
In order to communicate efficiently and effectively between customers, business partners,
and within the company, it is important to exchange information quickly and with highaccuracy. We strive to be e-commerce responsive and to prevent damage by taking defensive
measures against threats on computer networks.
【Supplementary information】 Example measures are shown below.
1. Protect the screen with a password when leaving your desk, and turn off the power source
when leaving the room to prevent your PC from being used or glanced at by others.
2. Appropriately lock offices, manufacturing facilities, and lockers and cabinets at each
workplace.
3. Store electronic data including confidential information on a server, etc., and make sure
not to allow your PC to be stolen.
4. For taking in-house information outside the company, prescribed procedures are required.
In particular, avoid exposure of important documents and important prototypes with extra
caution, and provide consideration for protection against theft by storing documents andprototypes in a lockable place, etc. Organize and control customer-entrusted drawings andother materials on a customer-by-customer basis to prevent accidental leakage of
information.
5. When sending e-mails outside the company, take measures to prevent the leakage by
password-protecting attached files, etc., in consideration of the degree of secrecy.
6. Dispose of paper materials and information media by destroying them in an appropriatemanner.
7. Conduct interviews with visitors in the lobby, a reception room, or conference room. In
principle, visitors are prohibited from entry into offices and production floor.
8. If entry into office(s) or production floor(s) is unavoidably required, obtain specificpermission, and then provide consideration related to security means and information leaks tothe extent as much as possible.

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Privacy Prevention
We shall obtain all personal information about our employees, customers, and business
partners, etc. in a legitimate manner, strictly manage, use, and protect it to an appropriate
extent.
【Supplementary information】 In the event of a leakage of personal information, it will cause
great pain and damage to the victim due to misuse. In addition, for those who cause an
accident, there may be irreversible situations such as the burden of apologies and alimony,damage to corporate brand value, and loss of social credibility.

Prohibition of insider trading
We shall not conduct insider trading. Also, we shall not leak insider information tocustomers, business partners, family members, relatives, acquaintances, friends, etc. Before
trading treasury stock, we shall always submit an “application for trading stocks, etc.” to thecompany and obtain approval. [Supplement 1] Insider trading refers to trading of securities,
such as stocks, of our company (including subsidiaries and affiliates: hereinafter referred toas “our company".
【Supplementary information1】
Insider trading refers to trading of securities, such as stocks, of our company (including
subsidiaries and affiliates: hereinafter referred to as “our company, etc.,”) or business
partners by executive officers or employees, etc. who have knowledge of the importantmanagerial facts as a matter of duty before disclosure of the important facts. It also refers to
trading of securities, such as stocks, of our company, etc., or business partners by those whohave been informed of the important facts by executive officers or employees, etc., who haveknowledge of their important managerial facts as a matter of duty before disclosure of theimportant facts. These include all transactions whatever their name is: family members,
acquaintances, and others.
【Supplementary information2】 Through work, sometimes you might come across important
facts such as Suncall's financial results that have not yet been made public. Buying and sellingsecurities such as shares of the Company, etc. for one's own economic gain corresponds toinsider-trading.
In this case, not only will the person who engages in insider trading be subject to civil andcriminal sanctions, but Suncall's social reputation will drop significantly.
【Supplementary information3】 In April, 2014, the revised Financial Instruments andExchange Act regulated not only the act of transmitting information, but also the act ofrecommending trading. It is prohibited for company officials who have knowledge of
undisclosed important facts from transmitting information or recommending transactions toothers for the purpose of making them gain profits (elude losses) by making them trade
before disclosure.

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Protection of Intellectual Property
We shall protect our intellectual property, and also value others’ intellectual property.
More specifically, we shall consider how products under development can be privileged as
our intellectual property and differentiated from others, while considering the likelihood of
their infringement on others’ rights.
We shall handle (transfer, grant, loan, disclosure, etc.) our and others’ intellectual property
with precaution, and conduct necessary procedures, such as approval of the right holder.

【Supplementary information1】“Intellectual property” means inventions, ideas, new plantvarieties, designs, work and other things created by human creative activities (discovered or
elucidated laws or phenomena of nature), trademarks, trade names and other items
indicating goods or services used in business activities, trade secrets and other technical or
business information useful for business activities.
(Intellectual Property Basic Law Article 2)"Intellectual property" is protected by law as an "intellectual property right". It helps to avoid
counterfeiting of other companies and to secure the superiority of the company.
【Supplementary information2】 For example, “intellectual property rights” include:
Patent right:
Gives patentees the right to practice their inventions and protects their inventions.
Utility model rights:
Protect ideas related to the shape of an object, etc.
Design right:
Protect industrial design.
Trademarks/Trademarks/Service Marks:
Protect business credibility (brands) embodied in trademarks.
Copyright:
Protect the creative expression of thoughts and feelings (Copyright Law, Berne Convention,
TRIPS Agreement). Distribution rights include reproduction rights, performance rights,
performance rights, screening rights, public transmission rights, dictation rights, exhibitionrights, distribution rights, transfer rights, rental rights, translation rights, and adaptationrights.
We should perform control and not to infringe on others’ intellectual property rights such as
by making illegal copies in-house of computer software and the like.

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Ⅲ-4. Environmental Conservation
We shall comply with relevant laws and company rules regarding the environment.
（Reference） Environmental Law, Recycling Law, etc.
We promote people and environment-friendly "manufacturing" through the construction andoperation of an environmental management system that complies with ISO 14001.
In our daily work, each and every one of us strives to eliminate "unreasonableness,wastefulness, and unevenness", thoroughly conserves resources and energy, and aims tocreate an environment-friendly workplace.
In addition to complying with the environmental laws and regulations of each country, we
strive to develop and manufacture products with excellent performance that areenvironmentally friendly, such as global warming prevention, resource conservation, andrecyclability.
For the realization of the above statements, we shall ask for the understanding andcooperation of suppliers of materials and parts.
【Supplementary information】 The above statements also include management of chemical
substances included and disclosure of their information, and certification of non-inclusion ofcustomer-specified prohibited substances.
Ⅲ-5. Safety and HealthWe shall comply with relevant laws and company rules regarding health and safety.
We shall make effort to prevent disasters and accidents, and report any deficiencies tosuperiors.
For buildings, on-site facilities, production equipment, etc., we shall establish the necessary
safety standards and implement safety measures through periodic audits.
We shall prepare a manual for responding to accidents, fires, etc., and conduct drills
regularly.
Assuming possible disasters and accidents, we shall prepare measures for emergency
response, and make them thoroughly known in workplaces.
In addition, we shall support employee to maintain healthy lifestyles through healthenhancing activities and guidance to prevent diseases at workplaces.

Ⅲ-6. Quality
We shall control quality by recognizing that "quality is a major premise of our business".
We shall work toward developing technologies and innovating production engineering,satisfy both cost reduction and quality maintenance, and pursue cost-competitiveness.
Ⅲ-7. Technology
Based on the increasing importance of technology in the three fields of environment, safety,
and comfort, we shall accurately grasp the demands of society and the global environment
and the needs of our customers, and embody them ahead of others, and have as many ascustomers to benefit from it.

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Ⅲ-8. Stakeholders
Respect for Personalities and Human Rights
We shall protect human rights and respect for personalities.
【Supplementary information】 The concept of Suncall's symbol is "reliability as a company",
and represents the consolidation of "technology", "information", "wisdom", and "people". "Acompany is its people."
We should not only develop the abilities of the executive officers and employees employed at
SUNCALL but also respect their human rights, and aim to be an active group of people withfair evaluation, treatment, and place the right person in the right position.

We shall never accept unjustifiable discrimination and harassment.
【Supplementary information】 We should respect the human rights of officers and employees;
discrimination, harassment, unfavorable treatment, and employment/treatment based on
status/status, age, nationality/registered domicile, gender, unmarried/married, religion,
physical disability, etc. must not be reflected.
In addition, we do not ask employees to undergo medical examinations or physicalexaminations that may lead to unfair discrimination.

Environment creation toward self-actualization of the employees
We shall always strive for self-improvement, maximize our abilities, and strive to make theworkplace a place for self-fulfillment.
【Supplementary information】 Versatility and diversity of executive officers and employees are
SUNCALL’s greatest asset. Workplaces are a field of experience and a field of education
through our duties. We should support the growth of each other, enhance our morale, andmaintain workplaces where each other’s self-actualization is achieved.

Safe, clean and comfortable working environment
We shall work to create a bright and comfortable workplace. Maintain a safe, clean, andcommunicative workplace where employees can work safely and efficiently. In order to keeporders in the workplace, we shall raise the morale to prohibit harassment related to humanrights and personal activities related to politics and religion.

【Supplementary information】
1. We should be organized voluntarily.
2. It is prohibited to carry out political, religious, and personal activities other than tasks at
workplaces
3. We should understand the Labor Standards Act and relevant laws and regulations, andshould not do anything that violates laws.

Report, Communicate, Discuss System
As for information obtained internally and externally, we shall ensure reporting,communication, and discussion to appropriate departments in a timely manner, regardless ofgood or bad information.

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Prohibition of sexual harassment
We take responsibility for our own actions and refrain from actions that may damage ourcredibility as members of society. Even in public places, we shall act and speak in a sensible
manner that is appropriate for a Suncall officer or employee.
【Supplementary information】 Sexual harassment is an act of making the other person feel
uncomfortable or requesting a form of affection from him or her by sexually-oriented
conduct.
Examples are given by explicit or implicit sexual requests, such that a superior forces
someone to go with him or her by using his or her position at a workplace.
A particular example is to force a subordinate to have a relationship or make a sexual
request on condition of his or her employment security, favorable treatment for personnel
evaluation, etc.

Prohibition of power harassment
In the workplace, we shall not engage in words or deeds that go beyond what is necessary
and reasonable for the job, and that are against the background of a superior relationshipthat harms the working environment of workers.
Pay close attention to your own behavior (physical/mental aggression, disconnection from
relationships, excessive/small demands, personal infringement).
【Supplementary information】 “Workplace power harassment” refers to an act of giving
mental or physical pain to workers at the same workplace or worsening the work
environment beyond the appropriate bounds of tasks against the background of the position,
human relationship, or other superiority at the workplace. “Superiority” is wide-ranging in the
background, not only from superiors to subordinates but also between seniors and juniors,
between colleagues, etc. “Workplace power harassment” is an unforgivable act that impairs
the dignity and personalities of workers. Also, not only those who receive it but also people
and companies around them suffer significantly. For example, “workplace power harassment”
includes such acts as:
1. Violence, injury (physical attack)2. Threat, defamation, insult, verbal abuse (psychological attack)3. Segregation, ostracization, neglect (isolation from human relationships)
4. Forcing of obviously unnecessary or impossible matters, disturbance ofwork (imposition)
5. Ordering of irrational, low-level work far from abilities and experiences,not giving work (underrating)
6. Excessive intrusion into private matters (invasion of privacy)

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Distinction between business policy and private interest● Prohibition against using company equipment etc. for personal purposes
We shall be aware that company property, including company facilities, equipment, fixtures,and systems, should be used for business activities, and shall not be used for personal
benefits.
【Supplementary information】 For example, it is prohibited to use expendable office supplies,
equipment and fixtures, and information technology devices (computers, software, printers,etc.) of the company for personal benefits.

● Protection of Company Assets
We shall protect corporate assets. We shall use corporate assets, such as facilities,
equipment, fixtures, corporate information (including electronic data), intellectual property,
and trade secrets, in-house irrespective of whether they are material or immaterial, and shallnot take them outside the company without approval (or illicitly) or divert them on a private
basis, and shall keep them secret. (Prohibition against illicitly taking out corporate assets, andprohibition against diverting intellectual property)【Supplementary information】 If there is a need to take them out, necessary in-houseprocedures (submission of a signed sworn statement, etc.) should be conducted, andpermission should be obtained in advance by following company regulations and rules.
In addition to taking-out of documents related to company business, the same applies tomail delivery of Word, Excel, and other electronic data.
【Supplementary information】 For example, it is not permitted to access any softwarepurchased for company business via a home PC.

We shall draw a line between public and private in managing information (including
electronic data).
【Supplementary information】 For example, we should not use both privately owned data anddata related to company business on a mobile device (tablet or smartphone).

● Prohibition of Conflict of Interest Transactions
We shall avoid conditions in which the interests of each individual (family) and those of thecompany presumably conflict with each other.
We shall refrain from having a personal stake with business partners or competitors. We
shall refuse inappropriate personal profit sharing, and we shall not make an inappropriate
response or request.
【Supplementary information】 For example, it is prohibited to offer or receive money andgoods in association with business transactions, provide expediency to particular companies,(for relatives of) find employment at competitors, conduct insider-trading, and so on.
This is because giving priority to individual profits may cause conflicting interests with
SUNCALL.

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Coexistence with Local Communities
In the case where a natural disaster, accident, or incident occurs in the neighborhood, weshall first make a swift response placing top priority on human life, and act so as to minimize
damage.
【Supplementary information】 One example of this is promoting voluntary participation insocial contribution activities, such as making preparations to actively respond to emergency
requests demanded by local communities, such as emergency disaster countermeasures.

We shall develop business that respects the history, culture, and customs of the region, andstrive to coexist with the community.
【Supplementary information】 We should be aware of being a member of the community, pay
attention to words and deeds outside the company, and refrain from such words and deeds
that may cause a feeling of discomfort or distrust to local residents.
We shall focus our eyes on each area’s social challenges toward local community
development, and aim at social contribution activities that will lead to resolutions incooperation with the community.

Promotion of communication with society
We shall disclose useful information, such as information related to management, finance,
environment, society, and social contribution to stakeholders in an accurate and timely
manner. Also listen carefully to the voices of society through open and fair communication
and reflect it in our business activities.

Timely and accurate information disclosure to investors and funders
We value the trust of our investors and funders, and shall strive for conscientious corporate
communication by disclosing appropriate and sufficient information to all relevant
stakeholders in a timely and appropriate manner.
【Supplementary information】 The above statements intends to improve managementtransparency and secure credibility by timely and appropriate disclosure, good or bad to
SUNCALL, irrespective of the impact on the company’s stock price.

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Ⅳ Suncall Compliance Organizational Chart

Board of auditors

Boad of directors
Check
AdviceExternal
stakeholders
Check
AdvicePresident,
management conference
Consultative
body

Hot-Line ropoting
E-mailCompliance Committee
Secretariat
Report of resultsof monitoring

External expert(lawyer)

Promotion
Persons responsible for complianceInternal audit
department

Directors general,division managers,
department managers

Presidents ofdomestic
subsidiaries

Presidents ofoverseassubsidiaries

SUNCALL
CORPORATION

Domestic
subsidiaries

Overseassubsidiaries

Code of Conduct
Compliance communications
Case study materials

Hot-Line ropoting
verbally,in a suggestion box,
by telephone or e-mailing

Promotion
Employees,etc.

Ⅴ Compliance Keywords• CSR（Corporate Social Responsibility)
Corporate social responsibility• Compliance
To observe not only laws and regulations but also social norms and corporate ethics, andfairly proceed with corporate activities in order to keep corporate social responsibility andmeet the expectations of various stakeholders.
• Compliance Regulations
Stipulations regarding SUNCALL’s general compliance structure• Code of Conduct
Established for each and every employee in the SUNCALL Group to be aware of complianceand act in a sensible and responsible manner (this book).
• Signed sworn statement of compliance
All employees’ swearing observance once a year via e-learning• Hot-Line Regulations (reporting system)
System for each and every employee to consult with or report to the nerve center of thecompany when detecting compliance violation (violation of laws and regulations, violation of
corporate ethics, violation of company rules, etc.) in-house; which is linked to early detection
and correction of misconduct, etc.
• Compliance communications
To transmit information and compliance related information from the Compliance
Committee to all employees.
• Stakeholders
Interested parties (customers, local residents, administrative authorities, stockholders,etc.)

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Ⅵ Hotline（Reporting System）
If you detect any acts in violation of the SUNCALL's Code of Conduct or have any doubts,
which may be difficult to solve by yourself or at the workplace, you should communicate by
any of the following methods.
Early detection and correction of misconduct, etc., prove useful for minimizing problems andprotecting society.
Reporting method（1） Put a document in the compliance suggestion box equipped in each domestic plant(which will be opened by the Secretariat of the Compliance Committee).
（2） Report verbally or by telephone or e-mailing to the Secretariat of the Compliance
Committee (person in charge of reception: the manager of the personnel and general affairs
department or the manager of the general affairs section)（3） Report by e-mailing to our legal adviser（4） Report by e-mailing to the audit committee member (This is given to the fact that there
might be difficulties to report or consult with the organizational reporting line or (1) to (3)hotlines.)Upon receipt of a report
For researching the facts, sufficient consideration is given to the protection of privacy ofreporters to prevent them from being identified in-house.
The Hotline Regulations define the protection of reporters, etc., as follows:（1） The company should not handle reporters, etc., against their interests on the groundsof their consultation or reporting.
（2） The company should take appropriate measures to prevent the work environments ofreporters, etc., from worsening.
（3） If reporters, etc. are handled against their interests or harassed (a so-called act ofretaliation), the company shall place sanctions on the person(s) who is involved in the act inquestion in accordance with the “Employment Regulations.”
Eligible users can use the hotline anonymously.
However, please note that feedback cannot be given.

SUNCALL Group’s Code of Conduct
First edition issued in July 2003
Second edition issued in May 2014
Third edition issued in May 2023

Compliance Committee
All rights reserved.

Suncall Group Code of Conduct