FURUNO Group Code of Conduct

Basic Principles
To meet and exceed the trusts and expectations from the society, and by
conforming to our Management Principles:
We will conduct our business activities in a fair, sound, sincere, and ethicalmanner.
We will develop and provide products and services with safety and reliability.
We will comply with laws and regulations as well as social ethics of eachcountry and region, international rules, business contracts, and internal rules.
[Mindset of FURUNO Group Employees](1) Conduct as a FURUNO Group Employee
 We will be conscious that we are a member of society and act with dignity,
class and decency as well as observe social morals, etiquette.
(2) Respect for Culture, Custom, and Human Rights, and Work Environment
 We will do our utmost to understand and respect the local cultures andcustoms of each country and region, and strive for a harmonious
co-existence.
 We will respect fundamental human rights without discrimination based on
their race, nationality, religion, belief, birth, sex, age, social status,
mental/physical disability or other factors.
 In order to sustain and improve our safe and healthy work environment, wewill comply with applicable laws and regulations, internal rules and createa workplace environment where anyone can demonstrate their abilities.

[Points to Note Regarding Business Activities](3) Products / Services
 We will provide safe, user friendly products and services to earncustomer’s trust by valuing the opinions of our clients and working
assiduously to develop and improve high quality products and services.
 We will comply with applicable laws and regulations as well as social
ethics of each country and region, international rules, business contracts
and internal rules in R&D, manufacturing, sales, and services.

(4) Environmental Conservation
 We will promote improvement in energy efficiency, conservation of raw
materials, recycling of materials and green procurement, and will develop
1and provide environmentally friendly products and services.
 We will actively promote activities towards the conservation of ourenvironment and improve such activities continuously, and at the sametime, comply with international standards, laws, and internal standards
relating to the environmental conservation in order to contribute towardrealizing a sustainable society.
(5) Free Competition and Fair Trading We will comply with applicable laws and regulations of each country andregion relating to free competition and fair trading.
(6) Export Control
 We will comply with applicable laws and regulations of each country andregion relating to the export control aimed for sustaining international
peace and security.
(7) Affiliations with Politics and Bureaucracies
 We will refrain ourselves strictly from affiliating in a manner that can beperceived as an inappropriate relationship from our society with regard toaffiliating with politics and bureaucracies.
 We will act appropriately in compliance with applicable laws andregulations in order to build sound and fair relationships with politicalparties and government agencies.

(8) Relationships with Clients, Suppliers, and Business Partners
 We will never offer or accept inappropriate profit or personal benefit
through our business activities in any form, in order to maintain soundrelationships with our clients, suppliers, and business partners. We will actin a lawful and ethical manner, and therefore will not attract any
misunderstandings or criticisms from our society.
 We will never act in a way which contradicts our company’s interests orengage in any personal activities that may disadvantage our businessactivities.
(9) Participation in anti-Social Forces We will refuse any relationships or affiliations with “anti-social forces” thatthreatens the order and safety of our society, and adversely affect to oursound business activities.
(10) Accounting Practices, Tax2

 We will practice fair accounting, and file our tax appropriately incompliance with applicable laws and regulations, accounting standards,and internal rules.

(11) Public Disclosure We will disclose and provide the information on our company in a timely,accurate and intelligible manner in compliance with applicable laws andregulations as well as internal rules and thereby improving the fairness andtransparency of our management along with our company image.
 We will sincerely engage in corporate public relations activities based on
perspective facts, appropriate promotion methods in order to promotecorrect understandings of our company among clients, investors, and local
societies of country and region.

[Company Assets](12) Company Assets
 We will recognize that the company assets are necessary and provided to
us in order to perform business activities for our company, and we will
utilize them appropriately under our responsibility.
 We will handle the assets which are lent to us by our clients or business
partners appropriately in compliance with their contractual conditions.

(13) Intellectual Properties
 We will actively create intellectual properties as important assets to ourcompany. We will appropriately protect them as intellectual property rightsand expertise in compliance with applicable laws and regulations as wellas internal rules, and utilize them effectively in our business activities.
 We will respect intellectual properties of a third party, and will not infringethem.

[Information Control](14) Confidential Information
 We will properly control and protect information our company holds incompliance with the applicable laws and regulations, internal rules, andtheir contractual conditions.
 We will be constantly aware that information our company holds are highly
important assets for our business activities, and will utilize themappropriately and effectively.
 We will do our utmost to be careful with the confidential information of our3

company and third parties from a loss, a theft, an alteration, and an unfair
use. We will also adopt information security measures in order to prevent
such events.

(15) Personal Information
 We will recognize the importance of the personal information provided byour clients, suppliers, business partners, and our employees andappropriately acquire, manage, utilize and provide personal information incompliance with applicable laws and regulations, internal rules and theircontractual conditions.

(16) Insider Trading We will appropriately handle the insider information on our company orother companies gained through regular business activities or from othercompanies in compliance with applicable laws and regulations as well asinternal rules, and refrain from engaging in the sales of stocks and bondsof the company relating to such information until it has been publicallydisclosed.

Established
Revisedonon

September

1

2011

March 1 20164