Kyokuto Kaihatsu Group Code of Conduct
Department in Charge: CSR Department
Established: April 1, 2021
Revised: April 1, 2024
1. Basic stance toward our social responsibilities
Corporate activities of the Kyokuto Kaihatsu Group are supported by all stakeholders
including our customers, suppliers, shareholders, local communities, and employees.
In order to realize sustainable society, we respect, and sincerely respond to, thesestakeholders’ needs and expectations through our sound and ethical corporate
activities in compliance with laws/regulations, social norms, international rules, ourmanagement philosophy, and our internal rules.
We will provide information required by stakeholders in timely, appropriate, andeffective manners, and also endeavor to disclose such information fairly andtransparently to fulfill our accountability:① promoting corporate activities toward realization of sustainable society;② respecting all kinds of human rights;③ preventing and alleviating any harmful impacts from the Company;④ endeavoring continuously to improve the corporate performances as well as theperformance of our entire value chain;⑤ promoting fair and transparent information disclosure; and⑥ contributing to development of the Company and society through our continuous
improvement efforts.
2. Basic stance toward our customers
The Kyokuto Kaihatsu Group regards our customers’ safety and sense of security as
our top priority and provides quality products and services. We will also endeavor tocreate new values through our incessant R&D initiatives to meet not only thecustomers’ explicit needs and expectations but also those implicit in society, so that
we can contribute to realization of sustainable society:①ensuring that our customers can feel safe and secure in all aspects of productdesign, production, and after-sale services;②

providing universally user-friendly products;③

preventing environmental pollution generated from manufacture, use, anddisposal of products, including procurement of components, to reduce
environmental loads; and1

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not being engaged/involved in any product uses that may end up in acts
threatening social order, including conflicts and military struggles.

3. Basic stance toward human rights
For diverse stakeholders with different values and ways of thinking to cooperate witheach other to create common value toward realization of a sustainable society, it iscrucial to respect each other’s differences: recognizing and accepting differences willlead to mutual understanding, and ultimately realize development and advancementof the entire society;in all aspects of our business activities, the Kyokuto Kaihatsu Group respects
internationally recognized norms concerning human rights, including “the Universal
Declaration of Human Rights” and “the UN Guiding Principles on Business andHuman Rights”:① respecting basic human rights in all corporate activities, including recruitment
and treatment of workers, and eliminating all discriminatory words and deeds
toward socially vulnerable groups of people, including discrimination due tosexes, ages, family backgrounds, races, creeds, religions, social status,
nationality, races, sexual preferences, sexual identity, and handicaps;② acknowledging diverse individual senses of value and respecting privacy of eachperson;③ prohibiting any kind of harassment;④ prohibiting any kind of forced labor, without a worker’s consent, etc.;⑤ prohibiting any kind of child labor involving children younger than the legallyprescribed minimum age of employment, established by each country/region;⑥ incorporating due diligence systems for human rights and properly managing
risks associated with human rights; and⑦ endeavoring to establish systems that can prevent infringement on humanrights; if any human-right violation occurs, taking prompt actions to correct andalleviate the situations through internal, external contact offices, etc.
4. Basic stance toward workers(*)
Abiding by the fundamental principle that protection of safety and health precedes
everything else, the Kyokuto Kaihatsu Group strives to create a safe and healthy
work environment for everyone working for the Group.
We also promote a work style based on the work-life balance by creating a workplacein which each person can work with self-initiative and a sense of fulfillment:①

promoting creation of safe, healthy, and rewarding working environments by2

assessing and appropriately managing occupational health and safety risks andimprovement opportunities;②

eliminating hazards and reducing occupational health and safety risks;③ providing equal opportunities for autonomous career development and skill
development of employees;④ making fair and impartial evaluations;⑤ promoting efforts toward work-life balance; and⑥ collaborating with workers to resolve problems through constructive discussions.
(*) Workers here mean those working, or engaged in labor-related activities, under themanagement of the Kyokuto Kaihatsu Group.
5. Basic stance toward handling of environmental issues
The Kyokuto Kaihatsu Group’s corporate activities, products, and services affectnatural environment in many ways, as they use diverse resources and energy.
We believe that environmental protection is a corporate responsibility and an
important management issue, and will, in all of our business situations, voluntarily
and energetically promote activities aimed at passing on a better global environment
to the future generations:① actively addressing environmental issues and pursuing a recycling-orientedsociety;② aiming at development of technologies conducive to global environmentalconservation;③ making proper arrangements for pollution prevention, contamination avoidance,and energy conservation;④ striving to reduce environmental impacts throughout entire product lifecycles;⑤ striving to implement proper management of chemical substances and otherenvironmentally hazardous materials used in business activities;⑥ striving to maintain a sustainable global environment in consideration ofbiodiversity; and⑦ identifying, and responding to, risks and opportunities from climate change.
6. Basic stance toward fair and lawful corporate activities
The Kyokuto Kaihatsu Group complies with laws, regulations, and corporate ethics
in all our business activities, both domestically or overseas, and responds fairly andequitably to all needs of the stakeholders. Furthermore, as a member of society, westrive to be always trusted by society through fair corporate activities:① observing social norms and corporate ethics;② complying with all relevant laws and regulations, including antitrust laws,
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import-export laws, and competition-related laws;③ abiding by rules established by relevant industries and local communities;④ complying with internal regulations;⑤ prohibiting provision of entertainment and gifts to public officials (includingsemi-public officials) and maintaining sound relations with them;⑥ not making illegal political donations;⑦ eliminating all relations with anti-social forces and rejecting all unfair demands
and illicit transactions;⑧ respecting intellectual property rights of others, including patents, copyrights,and trademarks; and⑨ making efforts to correct any violations as soon as possible, and taking strictmeasures.
7. Basic stance toward tax matters
The Kyokuto Kaihatsu Group conducts its accounting operations in accordance withgenerally accepted accounting principles, understands tax laws and regulations ofeach country, and processes tax-related work in accordance with laws/regulations andinternational standards:①

complying with accounting standards and tax laws applicable in each country
and properly disclosing the Group’s tax-related affairs and business activities;②

making efforts to improve efficiency of our tax-related work by utilizing
available tax benefits;③

employing external experts, including tax accountants to respond properly todifferences in opinions and simultaneously minimize taxation-related risks;④

not engaging in tax avoidance without economically justifiable reasons,
including transferring profits to light-taxation countries and tax-haven regions;and⑤ using prices based on the arm’s length principle for international transactions
between Group companies.
8. Basic stance toward preservation of corporate assets
The Kyokuto Kaihatsu Group conducts corporate activities by utilizing not only its
own assets but also various tangible and intangible assets that it retains throughcontracts with customers, suppliers, and business partners. The Kyokuto Kaihatsu
Group strives to protect these various assets from external attacks and threats,
including natural disasters, as well as damages, losses, and leakages in our daily
operations:①

actively and effectively utilizing company assets;4

②using company assets only for business execution and justifiable causes, andprohibiting any unauthorized uses; and③managing corporate assets properly so as not to erode their values.

9. Basic stance toward information management
Leakage of personal information, customer information, technical information,
management information, information about other companies, etc. obtained throughbusiness activities, to external parties, whether intentionally or negligently, willcause substantial harm to the relevant stakeholders. The Kyokuto Kaihatsu Groupendeavors to manage information properly while assuming all conceivable situations:① recognizing the importance of personal information, complying with laws andregulations applicable to its management for collection, use, and disposal, andhandling it properly;② prohibiting activities intended only to bring personal gains, including insider
trading based on publicly undisclosed information obtained through job-related
circumstances; and③ recognizing the importance of intellectual properties, and striving to protect andutilize them.
10. Basic stance as a corporate citizen
Each company must play a role as a member of society. Recognizing its role as a publicentity, the Kyokuto Kaihatsu Group actively engages in social contribution activities
as a good corporate citizen, and fosters a corporate culture that values those activities.
We will also actively engage in activities to deepen mutual understanding and build
trust with society in order to achieve harmonious coexistence with society:① respecting various historical and cultural implications and customs of society;② promoting activities that contribute to cultural and economic development ofsociety; and③ striving to develop harmonious coexistence with local communities.
Any revision of these provisions in whole or in part shall be decided at the Management
Meeting.
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