Inherited
ULVAC-Style

Corporate Governance

About ULVACULVAC’s Vision

ULVAC’s Strategy

Financial Data/
Corporate Information

CorporateGovernanceComplianceWith Our Stakeholders

We emphasize not only compliance with laws and regulations but also compliance with internal codes andethical codes. As well as conducting awareness-raising activities so that each person in the ULVAC Group actswith a spirit of compliance, we have established and are operating a range of institutions and regulations toensure thorough compliance.

In order to resolve social issues and co-create sustainable corporate value, we vigorously engage in dialogue
with stakeholders and respond in a timely manner to changes in the market and business environment in which
ULVAC operates.

Corporate Code of Conduct
In order to further promote fair and highly transparent corporate management, ULVAC
has established the Corporate Code of Conduct, to which all officers and employees
are required to adhere, and conducts education. In addition, booklets are distributed toGroup companies to raise awareness about the importance of compliance. We use thisCorporate Code of Conduct as guidelines for asking ourselves whether our businessconduct is “in the best interest of our customers,” “correct in light of laws and socialethics,” and “does not infringe human rights.”

We conduct company-wide education on compliance, prevention of insider trading,prevention of harassment, prevention of misconduct in research activities, etc., for all
employees of ULVAC, Inc. every year and the attendance rate is 100%. The education
is designed to raise awareness not only in terms of knowledge but also to enable ouremployees to act appropriately.

Whistleblowing System
In addition to a whistleblowing system operated via the Manager of the Internal Auditing Department for which
independence is secured in accordance with the Whistleblower Protection Act, we have also established an external
whistleblowing contact. The system is structured such that confidentiality is ensured throughout the process ofinvestigating the content of reports. By putting in place a whistleblowing system that allows whistleblowers to feelsecure in their reporting, we aim to detect any misconduct early and take appropriate corrective action.
After a whistleblower report has been received, the initial response is for the Compliance Committee of ULVAC,Inc. to conduct an investigation in order to establish the facts. This investigation is particularly mindful of fairness,and is conducted judiciously and thoroughly. If necessary, assistance may be sought from external specialists, andthorough interviews that are as wide-ranging as necessary are conducted and analyzed.
The president chairs the Compliance Committee and the members of the Committee observe a strict duty ofconfidentiality in carrying out their duties.

Handling of Violations
In the event that, based on the results of an investigation by the Compliance Committee, it is deemed that a violationof laws or regulations has been committed, then the opinion of an external specialists, such as a lawyer, may besought as necessary, steps will be taken to ensure that the violation ceases with immediate effect and improvement
measures will be implemented, and those involved in the violation will be dealt with after deliberation by theappropriate bodies. In addition, the root causes of the violation are also investigated in order to formulate effective
measures for preventing recurrence.
Corporate Code of Conduct
1Excellent Products, Services, and Safety

10

Assurance of Safe and Healthy Work Environment

2

Sound, Corporate Association with Business Partners
and Affiliated Companies

11

Compliance with Laws or Ordinances

3

Promotion of Maintenance of Fair and Free Competition

12

Insulation from Anti-Social Forces

4

Protection of Intellectual Property Rights

13

Disclosure of Information

5

Corporate Secrets

14

Global Environmental Protection

6

Client Information

15

Local Contribution

7

Respect for Employees’ Personality and Individuality

16

Global Business Activities

8

Respect for Privacy

17

Thorough Implementation of Corporate Ethics

9

Respect for Human Rights and Nondiscriminatory
Treatment

18

Pronouncements by Individuals

ULVAC VALUE REPORT 2023

Dialogue with Employees
At the start of a new fiscal year and at the New Year’s reception, video messages from the ULVAC president andsenior management are distributed to all Group companies in order to share ULVAC’s status and policies withemployees, including those overseas. A questionnaire survey is conducted coinciding with each such video message
to check the level of employees’ understanding and collect their opinions, which are then fed back to management
and reflected in the planning of the next video project.

Collaboration with Business Partners
Through various briefings and information exchanges, we strive to share information relevant to business and request
our business partners for their understanding and cooperation in enhancing communication on CSR procurement.

Compliance Education

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Message to OurReaders

For details

P.47 Procurement

For Customer Satisfaction
In order to enhance customer satisfaction, we strive to improve the quality of our products and services based on thequality management system in accordance with the ISO 9001 standard. ULVAC’s 31 Group companies obtained ISO9001:2015 certification for the integrated management system. Quality management is promoted by way of thoroughanalysis of nonconformities that occurred at a process within the process, implementation of recurrence prevention
measures, feedback of findings, implementation of preventive measures, and process standardization activities.
Furthermore, in order to achieve customer satisfaction in all phases from product delivery to disposal, we are working
to reduce running costs, shorten lead times, and provide prompt, high-quality customer support.
For details

Website >> Sustainability > Quality Assurance and Product Safety

For details

P.20 Customer Support

Dialogue with Shareholders and Investors
We strive to provide our shareholders and investors with timely, fair, and easy-to-understand information about theGroup’s mid-term management plan, growth strategy, and financial condition, in order to facilitate their understanding.
Regarding investor relations, in addition to quarterly financial results briefings, we actively offer opportunities for
dialogue by organizing technical seminars, taking part in conferences sponsored by securities companies both inJapan and overseas as well as seminars for individual investors, and holding road shows overseas, plant tours, andpersonal interviews.
We disclose financial results briefing materials and summaries of Q&A sessions, integrated reports, fact sheets,etc. on our website. We strive to enrich disclosure information and for swifter disclosure. From the viewpoint of fairdisclosure, we disclose information in Japanese and in English simultaneously to the extent possible.
Evaluations and opinions obtained through dialogue with shareholders, investors, and analysts are collected andsummarized on a regular basis and are reported to theIR activities
Results in FY 2022
Board of Directors and at the Management Council
Financial briefing
4 times
to share them with management, depending on theIRinterviews
withinstitutional
investors
importance and nature of such opinions, so as to reflect
Approx. 690 persons
and analysts
them in improvement of management measures, etc.
Participation in conferences for overseas
28 conferences
We will continue our efforts to strengthen
institutional investors
communication with shareholders and investors throughIR interviews on road shows overseas
20 interviews
Plant tours
9 timesvigorous IR activities, with the aim of realizing soundSeminars for individual investors3 times
corporate management and maximizing corporate value.

Dialogue with Local Communities
In addition to contributing to society through our core business, we strive to make social contributions that
benefit local communities, focusing on “Local Communities,” “Environment” and “Education Support for the Next
Generation.”
For details

Website >> Sustainability > Social Contribution Activities

ULVAC VALUE REPORT 2023

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