Meiden Group
Corporate Code of Conduct

July 1, 2022

Meiden Group Corporate Code of Conduct
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Toward the Realization of a Sustainable Society
We actively embrace the challenges of creating new value and contributing to the realization of asustainable society through honesty to our planet, society, and people, as well as“the power ofco-creation.”

2Sincere and Fair Business Activities
We fully understand the intent of legal regulations, customs, and any other societal norms of countries
and regions where we conduct business activities. As we respect and comply with those, we continually hold ourselves to high corporate standards and decent public conduct.

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Respect for Human Rights
We understand and support various international human rights norms and respect the human rights ofall people by complying with the legal regulations of each country and region.

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Realization of a Working Environment Enabling Employees to Reach Their Full Potential
We support the growth of employees and promote the cultivation of a workplace where diverse
personnel can play an active role.

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Environmental Conservation
To realize a sustainable society, we will deal with issues such as climate change mitigation and adaptation, resource circulation, and biodiversity conservation. We will work on sustainability management
and strive for corporate development.

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Cooperation with and Contribution to Society
As a member of the international community, moreover as a member of local communities, we maintain a global perspective of respecting local cultures and customs and develop business activities
while striving for cooperation and harmony in each region.

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Information Management
We protect all information assets handled in business activities from threats such as disasters,accidents, crimes, and negligence.

8Appropriate Disclosure of Information
We disclose our corporate information in a timely and appropriate manner according to the rules oflegal regulations and other similar guidelines.

9Risk Management
We identify and evaluate all risks associated with business activities and establish company-wide,cross-sectional systems for appropriately controlling these.

10Responsibility of Top Management
Top management recognizes the realization of this Code of Conduct’s intention to be its own responsibility. They make every eﬀort to establish a governance of eﬀectiveness within the Company andGroup, as well as to operate business in accordance with this Code of Conduct.

Established: December 1, 1997
Revised: June 1, 2022

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1 Toward the Realization of a Sustainable Society
We actively embrace the challenge of creating new value andcontributing to the realization of a sustainable society through honesty tothe planet, society, and people, as well as“the power of co-creation.”（1）Promotion of Innovation
・In addition to embracing the challenge of creating new value that contributes
to the solution of social issues, we cooperation with external partners tosupport the realization of a prosperous and livable society.
（2）Ensuring Quality and Safety
・We establish policies to guarantee product quality and safety, and offer highquality products and services that comply with each country and region’s
relevant laws and regulations.
・We display and disclose product information in an easily understood manner
via labeling, instruction manuals, etc. to customers.
・To properly attain our customers’satisfaction and trust, we endeavor tocollect and analyze their needs, such as requests and complaints, and make
improvements. In the event of a problem, we will respond sincerely and swiftly
while thoroughly preventing recurrence by applying the problem data to thesubsequent version’s development and design.

32 Sincere and Fair Business Activities
We fully understand the intent of laws and regulations, customs, and anyother societal norms of countries and regions where we conduct businessactivities. As we respect and comply with those, we constantly behavewith high corporate standards and public decency.

（1）Fair and Free Competition
・We conduct fair business dealings and comply with the competition laws ofeach country and region where we conduct business activities.
（2）Appropriate Transactions
・We do not engage in acts of bribery or exchanges of gifts that go beyond thelimits of socially accepted standards. We comply with the relevant laws andregulations of countries and regions where we conduct business activities,
particularly in relation to politics and government, and do not act in any way
that could be suspected of collusion or corruption, such as providing favors.
・We protect our intellectual property rights and respect the intellectual property
rights of third parties, utilizing them appropriately in our business activities.
・We comply with laws and regulations related to foreign trade security, anddo not conduct improper exports nor brokerage transactions of foreign trade,technology, etc.
（3）Responsible Procurement
・Our procurement policy reflects the principles of this code of conduct and isshared with business partners to promote sustainable procurement.
・Together with our business partners, we realize the philosophy of ourprocurement policy and build a sustainable supply chain.
・We promote environmentally conscious procurement activities and contributeto the conservation of the global environment together with our business
partners.
・We reject the use of conflict minerals which fund armed groups whorepeatedly commit inhumane acts such as human trafficking, forced labor, childlabor, and abuse.
（4）Creating a Reporting System
・We establish systems for reporting business partners and/or employees
for violations of laws, rules, etc. to quickly detect and correct illegal andinappropriate acts. We protect informants by strictly maintaining theconfidentiality of reports.
（5）Rejecting Relationships with Antisocial Groups
・We reject any relationships with antisocial forces and organizations thatthreaten the order and safety of civil society, and we endeavor to prevent
those groups from making any illegal profit.

43 Respect for Human Rights
We understand and support various international norms related tohuman rights and respect the human rights of all people by complying
with the laws and regulations of each country and region.

（1）Compliance with International Human Rights Standards
・We comply with an established basic human rights policy to conduct businessactivities with respect for human rights in accordance with the internationallaws and norms of each country.
（2）Implementation of Human Rights Due Diligence・We introduce processes for human rights due diligence and continuallyimplement them.
・If it is found that our business activities cause or contribute to a negative
impact on human rights, we will administer appropriate remedial measures tothose affected.
（3）Contribution to the Creation of an Inclusive Society
・To contribute to the creation of an inclusive society in the countries andregions where we conduct our business activities, we collaborate with diverse
stakeholders to support the independence of people in socially vulnerablepositions.

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of a Working Environment Enabling Employees to4 RealizationReach Their Full Potential
We support the growth of employees and promote the cultivation of aworkplace where diverse personnel can play an active role

（1）Human Resources Development
・We clearly state all necessary qualities and abilities for personnel, andwe conduct systematic training in order to implement and promote ourbusiness strategy. Furthermore, we support employees in their active careerdevelopment by providing various learning opportunities.
（2）Creation of an Environment Enabling Diverse Personnel to Demonstrate TheirAbilities
・We create systems to foster a corporate culture which enables diverse
personnel to fulfill their potential by employees developing a deep mutual
understanding of diversity in terms of age, gender, nationality, religion, sexual
orientation, disability, etc.
・We create an environment that does not block the careers of motivatedemployees who face any variety of circumstances such as childcare, familycare, or illness.
（3）Occupational Safety and Health, and Health Management
・We strive to ensure a safe environment that is conducive to work, as wellas achieve comfort and affluence for employees by actively performing
occupational safety and health activities based on the notions of“safety comesfirst”and“nothing is more valuable than good health.”・In order to support the work-life balance of employees, we participate inendeavors to enhance labor productivity, reduce working hours, and promotehealth.
（4）Honest Dialogue and Consultation Between Employees and Top Management
・In addition to complying with relevant labor laws and regulations, we respect
basic labor rights such as the right of employees to collectively bargain. We
endeavor to provide opportunities for regular exchange of opinions betweenlabor and management, as well as create an environment which enables
employees to work with peace of mind through sincere discussions.

65 Environmental Conservation
To realize a sustainable society, we will deal with issues such as climatechange mitigation and adaptation, resource circulation, and biodiversity
conservation. We will work on sustainability management and strive forcorporate development.

（1）Compliance with Environmental Laws and Regulations
・We comply with all environmental laws and other constraints related tobusiness activities. As well, we obtain permits and approvals required by thelaws and regulations of each country and region where we conduct businessactivities.
（2）C ontribution to the Realization of a Carbon-Free Society and a RecyclingOriented Society
・In addition to working to reduce greenhouse gas emissions associated with ourbusiness activities, we contribute to the construction of a carbon-free society
through those business activities.
・We contribute to the formation of a recycling-oriented society by promoting
the 3 R’s and evaluating the impact on the environment in the entire productlife cycle- from the procurement of parts to disposal- striving to develop anddesign environmentally friendly products.
（3）Preserving Biodiversity
・We conduct business activities that minimize the impact on the ecosystem topreserve biodiversity.

6 Cooperation with and Contribution to Society
As a member of the international community, moreover as a member of
local communities, we maintain a global perspective of respecting local
cultures and customs and develop business activities while striving forcooperation and harmony in each region.

・We actively participate in local communities and contribute to their sustainable
development by conducting active, two-way communication with various
stakeholders.
・We support our officers and employees’voluntary and independent activities
which contribute to society.

77 Information Management
We protect all information assets handled in business activities fromthreats such as disasters, accidents, crimes, and negligence.

・We endeavor to prevent incidents and accidents such as information leaks,tampering, theft, and loss by maintaining and improving information management.
・We comply with the legal regulations of countries and regions where we conductbusiness activities, and appropriately manage and protect all personal information
we handle in our business activities such as that on employees, business partners,and customers.
・We take necessary measures to address cyber-attacks.

8 Appropriate Disclosure of Information
We disclose our corporate information in a timely and appropriatemanner according to the rules of laws and regulations, etc.

・We endeavor to eliminate risks that may result in the loss of stakeholders’trust byreadily disclosing non-financial information.
・We bolster mutual understanding with stakeholders and engage in the resolutionof societal issues.
・In order to deter insider trading, we closely manage undisclosed information whichwould have a significant impact on shareholders’investment decisions.

9 Risk Management
We identify and evaluate all risks associated with business activities
and establish company-wide, cross-sectional systems for appropriately
controlling these.

・We build systems to address situations such as natural disasters, terrorist attacks,and cyber-attacks under normal circumstances, as well to provide a business
continuity plan in the case that a threat to business continuity occurs.

810 Responsibility of Top Management
Top management recognizes the realization of this Code of Conduct’s
intention to be its own responsibility. They make every effort to establish
a governance of effectiveness within the Company and Group, as well as
to operate business in accordance with this Code of Conduct.
In the event of a violation of this Code of Conduct, top management
fulfills their responsibilities by taking the initiative to endeavor to resolve
the problem and prevent any recurrences.

Top management, with their responsibility to actualize the intention of the Meiden
Group Corporate Code of Conduct in mind, engages in the following matters.
・Creation and operation of effective corporate systems of governance.
・Measures are taken to ensure this code of conduct is instilled throughout the entire
Meiden Group and is established as the basis of day-to-day business activities.

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