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Our Assets &Property

Responsible disclosure andguarding of information
We disclose financial and accounting details whenappropriate, and have the responsibility to guard
important information assets and intellectual property.

2｜Our Assets & Property

2-1 Accounting/Tax/

Financial Reporting
We prepare financial documents
in a timely, accurate and appropriatemanner, disclosing all accounting andfinancial reports in accordance withrelevant laws and regulations,and generally accepted
accounting principles.

■

We document and reflect the Company s businessactivities and economic information including
financial statements, expense reports, contracts,
internal & external reports and tax filing in a timely,
accurate and complete manner based on facts andevidence and accordance with related laws andregulations, accounting principles and internal rules.

■

We keep business records in accordance with applicablelaws and regulations, and the Company s own internal
rules regarding the preparation of such documents.

●We assure that documents and records related tointernal and external investigations or audits, as well as
pending or potential litigation, be retained properly
upon request from our Legal Department
and/or any other relevant departments.
For the TEL Group Tax Policy, please refer to thefollowing website at:https://www.tel.com/csr/related-policy/28

2｜Our Assets & Property

2-2 Insider Trading
We do not use material
non-public or non-disclosed
inside information about TELGroup or any other company,
including suppliers and customers,
to buy, sell, or otherwise transact
in securities of TEL Group or any
other publicly traded company.
■We do not make profits by trading securities usingmaterial non-public or non-disclosed insideinformation.

■

We do not recommend or suggest to others to buy,sell, or otherwise transact in securities using material
non-public or non-disclosed inside information.

■

We do not communicate regarding material non-public
or non-disclosed inside information to others who
might trade on the basis of such information, tip theinformation to others, or otherwise misuse theinformation, whether verbally or by any other means.

●Examples of inside information include the following:▶

Business results or forecasts for a company▶

Changes in management or board of directors orother governing body of a company▶

Major new product, product claim or productincident/issue29

2｜Our Assets & Property●●▶

Loss, delay or gain of significant contract, sale or order▶

Acquisition, merger or divestment▶

Major developments in litigation cases or indealings with regulators or governments▶

Revisions in dividend policy▶

Issuance of stock and stock acquisition rights, stockbuy-back, and stock split▶

Changes in or dispute with a company independent auditor▶

Default in debt or bankruptcy filing

Trading or encouraging others to trade on material
non-public or non-disclosed inside information, orgiving it to unauthorized parties, is a criminal offense
in many jurisdictions. A breach of the applicable laws
can lead to fines and/or imprisonment against theindividual who passed the information even if he/she
does not personally gain.
Trading securities through third parties such as family
members, friends, and/or agents, is also not allowed.
Insider Trading – the buying or selling of a security(e.g. shares, equities and related derivatives) of alisted company by investors (individuals or legalentities) with access to non-disclosed material
information (inside information) about thecompany. This is prohibited by laws, and theCompany is committed to complying with allapplicable insider trading laws, rules and regulations.

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2｜Our Assets & Property

2-3 Intellectual Property
We respect intellectual
property and protect,manage, and utilize it
appropriately.
■

We are committed to complying with all applicable
intellectual property laws, rules and regulations, andwe secure and protect the use of these valuable assets.

■

We take precautions to protect our intellectual
property and confidential business information.

■

We do not use TEL Group intellectual property andconfidential business information outside of theoffice without permission.

■

We respect and do not misuse intellectual property
and confidential business information of others. We
do not use other s intellectual property andconfidential business information withoutauthorization or an appropriate license.

●

Below are some examples of intellectual property rights:
・Patent Right ・Utility Model Right ・Design Right
・Trademark ・Copyright・Trade secret●

We do not discuss or share TEL Group or third party
intellectual property and confidential businessinformation in public places, such as airports andrestaurants.

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2｜Our Assets & Property

●●●

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We do not bring to TEL Group any intellectual
property and confidential business information of aformer employer or other third party, or utilize for the
benefit of or disclose to TEL Group any intellectual
property and confidential business information of any
former employer or third party, without prior written
authorization from the former employer or third
party and unless necessary to further a businesspurpose.
We immediately notify the Company, in thedesignated manner, when in the scope of our work
we create an innovation, invention, idea, design using
the physical or technical assets of TEL Group.
We consult with the designated department before
using TEL Group intellectual property, such as
trademark or copyright, outside the Company.

2｜Our Assets & Property

2-4 Information Security
We protect TEL Group confidential
business information as well as
any confidential businessinformation that is entrusted tothe Company by our customers
and business partners, andprevent information leakage bymaintaining a reasonable andappropriate information
management framework andcomplying with rules concerning
the handling and protection ofconfidential business information
including personal information.
■

We appropriately protect and manage confidential
information such as technical and sales information,and only use TEL Group confidential businessinformation for legitimate business purposes or asrequired by law.

■

We do not misuse or improperly obtain confidential
business information from third parties.

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2｜Our Assets & Property

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●

●

●

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We define the classification of information and scopeof disclosure, control such information, and only
disclose confidential business information on anas-needed basis and in accordance with company
policy. Examples of confidential information are:detailed sales information, business performancetargets, key performance indicators, productstrategies, new product and technology, pending
personnel announcements, manufacturing processes
and equipment designs, and contracts withcustomers.
We take care not to disclose confidential businessinformation in public places, including taking allnecessary steps to protect documents and IT devices
away from the workplace.
We do not disclose confidential information beyond its
authorized limits while employed at the Company.
Upon the end of employment, we must erase, destroy
or return electronic files and material objects that
contain confidential information, and shall sign written
acknowledgement of such action. It is absolutely
impermissible to keep the confidential information after
the end of employment.

2｜Our Assets & Property

●

●

●

Below are some examples of methods to prevent
information leakage and loss:▶

Do not open an attachment and/or URL when you
receive a suspicious email;▶

Do not let others know or use your password;▶

Pay close attention to the companies devices withconfidential information; especially when outside
the Company, in transit, etc.;▶

Ensure any removable TEL Group IT equipment,
including devices, are secured when left in the officeovernight and are locked away or out of sight whenleft unattended off premises; and▶

Do not install software without Company s approval.

The Company may monitor, record or use any
communication made by using the Company s
information system (e.g., email and internet) to theextent permitted by local laws and regulations.
Officers and Employees must immediately report theloss or theft of any TEL Group equipment, or any
personal device used to store TEL Group informationor any actual or potential incidents of information
leakage to the information security department.
For the TEL Group Information Security Management,
please refer to the following website at:https://www.tel.com/about/riskmanagement/35

2｜Our Assets & Property

2-5 Personal Data
We respect the privacy of all
individuals and confidentialityof Personal Data and handle
Personal Data with utmost
care and take measures topromote the appropriate
handling of Personal Data.
■

We comply with each country/region s law,regulations, and internal Company rules regarding
Personal Data protection. We collect, use and retain
Personal Data on a minimum basis to the extent ourbusiness needs and dispose it when no longer
necessary.

■

We always consider the privacy risks before wecollect, use, or retain or disclose Personal Data, suchas in a new system or part of a project.

■

We endeavor to keep Personal Data accurate andup-to-date.

■

We protect the Personal Data we hold by ensuring
we have effective safeguards in place so it does not
fall into the wrong hands.

■

We are transparent with individuals about how weuse, disclose or transfer their Personal Data. We also
make it easy for individuals to access and correct
their information.

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2｜Our Assets & Property●●Personal Data is information about any existing
individual including the following:▶

information that can identify a specific individualsuch as name, date of birth or other descriptors▶

information that can be collated with otherinformation and can identify a specific individual

Many of the laws and regulations related to Personal
Data are extraterritorially applied; therefore, whenhandling personal information, it may be necessary tounderstand and follow not only the laws and regulations
in your country, but also the other country/region.
For the personal information protection policy,
please refer to your market s specific policies.
If you receive any contacts from outside parties
regarding the usage of personal information of
TEL Group or data breach, immediately consult withyour local Legal/Compliance Department.

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2｜Our Assets & Property

2-6 Company Assets
We do not improperly use
company assets for ourown personal benefit.
■

We rely on company assets to support our work
every day. We use computers, mobile devices,
information technology hardware and software,vehicles, facilities, intellectual property, supplies
and other assets with our care and for legitimate andappropriate business reasons.

■

We do not use, waste or take the property of
TEL Group out of the Company s facilities without
the Company s permission regardless of whether it istangible or intangible.
●●●

We may not install software that the company purchasedon a home PC, or use a company PC for personal purposes.
Improper usage of company assets (as above) would
not only be a violation of the internal rules but could
also constitute a criminal offense.
Below are some examples of assets that areconsidered company assets.
Tangible

Intangible

Facilities

SoftwareEquipment(customer information, market share information etc.）

Raw materials
Office supplies

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Confidential Information

Intellectual property rights
such as patent rights

2｜Our Assets & Property

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