1 Business Practices

Mutual trust is at
the foundation of our work
We strive to continue the business growth of TEL Group,and this cannot be achieved without mutual trust.
Each officer and employee must earn the trust of others,
being committed to high ethical standards and fairness inall activities.

1｜Business Practices

1-1 Safety and Quality
We pursue safety in our businessactivities – development,
manufacturing, transportation,
installation and maintenance of ourproducts – and provide the highest
quality products and services thatmeet customer expectations.
■We achieve the above goals by meeting or exceeding
all legal and regulatory requirements and throughthe rigorous application of our safety and quality
management system and processes.

■

We implement effective and preventive processes,
and if appropriate, corrective actions to assure thatour business activities are conducted safely, andthat the highest quality products and services aredelivered by the Company.

For the TEL Group Safety Policy, please refer to the following
website at:https://www.tel.com/csr/safety/safety-management/
For the TEL Group Quality Policy, please refer to the following
website at:https://www.tel.com/csr/quality/quality-management/12

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1-2 Suppliers
We select suppliers based on
objective criteria and review theirqualifications by ensuring thatthey comply with laws andregulations as well as our businessethics.
■

We select our suppliers based on objective criteria,such as quality, technology, price, delivery times,compliance and other reasonable standards.

■

As a part of the global supply chain where we do ourbusiness, we consider the environmental, social andethical impacts of the Company s supply chain thatare critical in the industry.

■

We require our suppliers to comply with laws andregulations, including in relation to anti-bribery andcorruption, fair competition, forced labor, bondedlabor, child labor or modern slavery, and to respect
our business ethics. At the same time, we continue
to work respectfully with our suppliers and continue
to build strong partnerships with them.

■

We do not accept raw materials or materials that
contain conflict minerals which have been obtained
illegally by use of child labor or modern slavery, orthrough other abuses of human rights.
For the TEL Group Procurement Policy and ProcurementPolicy – Supplement, please refer to the following website at:https://www.tel.com/csr/procurement/procurementmanagement/13

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1-3 Export & Import
We are committed to upholding
all applicable laws and regulations,and our Company s internal rules
regarding the export and importof goods and technology.

■

In any countries or regions where we do business,
we comply with export/import (including re-export)
laws and regulations, licensing requirements,
embargoes and other restrictions that have been
approved by recognized national and international
authorities.

■

When importing/exporting our products ortechnology, we follow the import/export
requirements of the applicable government
agencies of countries or regions and provide
accurate, truthful and complete information about
our products, technology and other items tocustoms and other relevant authorities.

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Many countries where we do business have laws in place
which regulate the import/export of goods andtechnology. The United States has controls which
restrict the export of certain products (e.g. services,
technical data and software) to other countries, as wellas the re-exporting of those items from a country otherthan U.S.to another non-U.S. destination.

1｜Business Practices●●As for exporting, the classification and content ofproducts or technology, final destination, and end
user need to be confirmed in accordance with laws
and regulations in many jurisdictions.
Trade restrictions (e.g. sanctions, embargoes, anddenied-parties lists) seek to prevent or limit trade withspecific entities and, in some cases, entire countries.
TEL Group is committed to screening the parties withwhom we do business.

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1｜Business Practices

1-4 Fair and OpenCompetition

We strive to operate in a fair,open and competitivemarketplace.
■We are committed to complying with all competition
laws in the markets where we do business and do not
engage in illegal anti-competitive activities.

●●●Competition laws and regulations in the markets
where we do business, such as the U.S. and EU, haveextraterritorial application.
Investigations by competition authorities may resultin significant fines and costs, and incur damage to ourreputation. Criminal sanctions may also apply, andthe Company may be liable for civil damages.
The following are examples of conducts that arealways illegal:▶

Competitors agreeing or taking concerted actions
regarding:・prices or any price components, terms and conditions,・product or territory allocation or sharing,・boycotts, or・limits on production, sales, inventory or researchand development.

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1｜Business Practices▶

Employing unfair or deceptive trade practices or
methods that generally fall within the scope ofunfair competition laws, such as:・misleading advertising,・disparaging a competitor s product,・harassing a competitor, or・stealing trade secrets or other confidential

business information.

●The following are examples of conducts that may beconsidered illegal and may result in high fines in many
countries:▶

Dominant companies taking actions that appear tobe efforts to control a market, such as:・tying or requiring bundling of separate products,
・unfairly terminating dealers, distributors or suppliers,
・discriminating on price,・selling below cost (predatory pricing), or・imposing overly restrictive exclusive dealingarrangements.

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1｜Business Practices

1-5 Bribery and Corruption
We do not bribe anyone,
anywhere, for any reason
under any circumstances.
■

We are committed to complying with all applicableanti-corruption laws, rules and regulations, andnever offer or give a bribe or allow others to bribe onour behalf.

■

We do not make Facilitating Payments＊ even if allowed
under local law or if doing so is common in society.

■We follow the Company s internal rules when giving
or receiving gifts, meals, travel and otherentertainment.

■

We only do business with third parties who we know
do business with integrity, after conducting
appropriate due diligence. When third parties
engaged by TEL Group participate in misconduct orviolate the law, they put TEL Group at risk for legal
violations and reputational harm.

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Bribery occurs when anyone authorizes, offers, solicits,gives, receives or accepts anything of value, or any
financial or other advantage, in exchange for favorable
treatment by a company, government authority,
official or employee or relating to their duties. In China,for instance, we should understand that the local lawsalso regulates commercial bribery. It would be illegal
even if the recipients are their close relatives.

1｜Business Practices●●●●A "bribe" typically takes the form of cash, but also
includes entertainment (e.g. meals and beverages,attendance of sporting events and performances),
gifts, tours in connection with visits to Company
facilities, travel invitations (e.g. training trips lacking a
legitimate purpose), healthcare services, employment
including employment of relatives of Public Officials
and sexual services, etc. Payment made in disguise of
donations or sponsorships could also constitutebribes.
Most countries enforce laws prohibiting bribery andcorruption. Many of these laws apply even when thewrongful conduct is committed outside the country s
own borders and/or by citizens of other countries,
such as the UK Bribery Act 2010 and the US Foreign
Corrupt Practices Act 1977.
Violations of these laws can result in criminal andcivil liability, including prison sentences and fines forindividuals.
The Company will conduct periodic anti-corruption
training for all directors and officers, and, whereappropriate, employees, agents and business partners.

＊Facilitating Payment – a small payment paid to public officials to facilitate

non-discretionary actions or services such as obtaining an ordinary license,business permit or visas.

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1-6 Conflicts of Interest
We make fair and objective
decisions in the best interest of
the Company, and avoid any
action that puts our personal
interests ahead of those of theCompany s.
■

We have a responsibility to avoid activities whichconflict or appear to conflict with our professional
responsibilities. Even the appearance or perception ofa conflict of interest can place the Company at risk.

■

We should never allow personal gain or benefit toprevent us from doing what is in the best interest ofthe Company. Examples are:▶

Receiving personal privileges from a supplier;▶ Concurrent employment as a board member or as an
employee of another company or organization;▶ Business with a company that a close relative or friend
manages/owns;▶ Bringing an unjustifiable financial interest in any
company or a current or prospective customer, supplieror competitor of the Company or receiving improper
personal benefits or gifts;▶ Supervising the job performance or compensation of a
relative or romantic partner as a part of the day-to-day
job duties;▶ Engaging in an activity which competes directly orindirectly with the Company; and▶ Engaging in any transaction that involves a former
Company employee or officer or any close relative ofsuch ex-employee in providing goods and services.
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1｜Business Practices●●A conflict of interest occurs when a personal
relationship or activity exists that may influence ourjudgment or ability to perform our job objectively or
to uphold our duties to the Company.
It is our responsibility to disclose any actual or
potential conflicts of interest to the Company
voluntarily and proactively. In most cases, disclosed
conflicts can be cleared by an open and transparent
discussion.

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1-7 Political Activities

and Contributions
We do not, directly orindirectly, support or makecontributions to politicalparties or candidates using
Company finances or assets.

■

We are committed to complying with all applicablecampaign finance laws, rules and regulations.

■

While TEL Group does not support or contribute topolitical parties or politicians including candidates,
employees may offer support and contributions＊ topolitical groups in a personal capacity and on theirown time.

■We ensure that:▶

▶

Any contributions towards, and support for, politicalparties are clearly personal and give no impression of
being connected to TEL Group; andNo personal political support or contributions affectperformance or objectivity on the job.

＊Support and contributions include financial contribution, benefits in kind, gifts,sponsorships and use of any Company resources.

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1｜Business Practices

1-8 Money Laundering
TEL Group does not receive theproceeds of criminal activities,
as this can amount to thecriminal offence of money
laundering. Nor do we engage
in any relationships withantisocial organizations.
■

We are committed to complying with all applicableanti-money laundering laws, rules and regulations.

■

We look out for warning signs of money laundering,such as:▶

Supplier requests to:・Pay funds to a bank account in the name of a third partyor outside their country of operation;

・Make payments outside the normal form of business;
・Split payments to several bank accounts; or・Overpay.
▶

Customer payments to TEL Group:
・From multiple bank accounts or ones overseas when

not a foreign customer;

・Made in cash when normally made by checks orelectronically,

・Received from third parties; or・Made in advance when not part of normal terms ofbusiness.

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1｜Business Practices▶

Use of a paper company and P.O. Box as the third partyaddress▶

Transactions that do not make obvious commercial
sense

■

We do not do any business with antisocialorganizations and firmly refuse improper demands
from such organizations.

■

The Company conducts appropriate due diligenceon certain customers and vendors to identify
potential money laundering risks.

●If you suspect money laundering or transaction withantisocial organizations, please consult with yourLegal/Compliance Department immediately.
Money laundering – the illegal process ofconcealing the origins of money obtained illegallyby passing it through a complex sequence ofbanking transfers or commercial transactions.
Antisocial organizations – refers in Japan to gangs andother parties who hinder social order and safety ofcitizens and/or business activities by gaining economic
benefit with unfair demands through violence, threat,and fraud. Such organizations may disguise theirintentions to take advantage of innocent citizens
by masquerading as ordinary businesses ororganizations seeking donations or participation inbusiness, sending unsolicited publications anddemanding payment or subscription in return, etc.

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