Nintendo of America's Code of Business Conduct (Summary)
Overview
Nintendo of America Inc. has adopted a Code of Business Conduct that applies to all of its employees, officers, anddirectors. As set forth in its Code of Business Conduct, Nintendo expects those working for and representing thecompany to maintain a high standard of conduct, to treat others with respect, and to conduct themselves in anethical and professional manner. Nintendo emphasizes courtesy, dignity, respect, and safety as corporate values, andseeks to create an atmosphere of mutual respect for all Nintendo employees, temporary workers, contractors,vendors, customers, and visitors.
Conflicts of Interest
It is Nintendo's policy to conduct its business affairs ethically, fairly, and impartially. It is the responsibility of all
employees, officers, and directors to avoid situations that are, or could be construed as, conflicts of interest orinappropriate attempts to influence business decisions. To that end, Nintendo prohibits its employees from accepting
any gift of more than nominal value or entertainment that is more than a routine social amenity in that it could be, orcould appear to be, an attempt to influence the recipient into favoring a particular customer, vendor, consultant, orother outside entity.
Insider Trading
It is against Nintendo's policy for one of its employees, officers, or directors to be involved in any way in thepurchase or sale of securities of another company about which they may become aware, during the course of theiremployment, of confidential information that could affect the value of the securities of Nintendo or other companies
with whom Nintendo does business.
AntitrustNintendo employees are required to comply with all antitrust laws and to always act in accordance with Nintendo's
Antitrust Policy.
Foreign Corrupt Practices Act
Nintendo employees are required to comply with foreign legal requirements and United States laws that apply toforeign operations, including the Foreign Corrupt Practices Act, which generally makes it unlawful to give anything ofvalue to foreign government officials, foreign political parties, party officials, or candidates for public office on behalfof Nintendo.
Bribery, Kickback, and Fraud
No funds or assets of Nintendo shall be paid, loaned, or otherwise disbursed as bribes, "kick-backs," or otherpayments designed to influence or compromise the conduct of the recipient, and no employee, officer, or director ofNintendo shall accept any funds or other assets (including those provided as preferential treatment to the employee
for fulfilling their responsibilities) for assisting in obtaining business or for securing special concessions fromNintendo.
Compliance
All Nintendo employees, officers, and directors are expected to comply with Nintendo's Code of Business Conduct andto perform their work with honesty and integrity in any areas or ways not specifically addressed by the Code ofBusiness Conduct.
If you know of or suspect a violation of any of the above policies, please notify us by email (you must include theword "Complaint" in the subject line) at codeofconduct@noa.nintendo.com. All reported information will be acted
upon promptly, including reasonable steps being taken to keep confidential the identity of anyone reporting
information for investigation, consistent with appropriate evaluation and investigation.