April 1, 2024
Compliance Office, INOAC Group
Compliance Policy
INOAC Group's Compliance and Ethics Program and Compliance Management
Regulations are designed to guide the business activities of INOAC Group companies
around the world (“Group Companies"), with a commitment to ethical and lawful
practices.
To promote ethical and lawful practices in our business operations, the Compliance
Office affirms the following principles that Group Companies must comply with. It is
important that Group Companies familiarize themselves with this policy, and conduct
their business activities in accordance with this policy.
1

Human Resources, Employment and Workplace(1)

Prohibition of discrimination
We do not tolerate any unfair discrimination based on nationality, gender,age, creed, religion, race, ethnicity, sexual orientation, disability, marital orparental status, or any other personal attribute. We value and respect theindividuality of all people involved in our Group.

(2)

Prohibition of child labor
We prohibit and condemn child labor in any of our Group businesses,
including our factories.

(3)

Prohibition of slavery and forced labor
We prohibit and condemn any form of slavery or forced labor within theGroup. Every employee working for the Group must do so willingly without
coercion.

(4)

Prohibition of harassment
We maintain zero tolerance against harassment of any kind, including power
harassment, sexual harassment, and harassment related to pregnancy,
childbirth, childcare leave, family care leave.

(5)

Prevention of information leakage
We must appropriately manage personal information of employees involvedin the Group's business. Additionally, we must ensure and maintainappropriate safeguards so that retirees and mid-career hires do notunlawfully use trade secrets or leak confidential information.

2

Finance and Accounting.
(1)

Prohibition of embezzlement
We strictly prohibit embezzlement in relation to any of our Group operations.
Rigorous payment and billing processes as well as safeguards must be
established to prevent any such misconduct.

(2)

Taxes
We must comply with all relevant tax laws and regulations.

(3)

Accounting
We adhere to principles of proper accounting and closing of accounts.

(4)

Prevention of information leakage
It is imperative that we take due care in managing confidential accounting
and financial information that one may come to know in the course ofbusiness.

(5)

Management of documents and seals
It is important that we appropriately manage and store the Group’s official
documents and seals.

3Quality Assurance(1)

Prohibition of data falsification
We strictly prohibit and condemn the falsification of data or otherinformation related to our Group's products or services.

(2)

Quality assurance and specification
All product specifications and quality assurances must be designed optimallyfor practical mass production.

(3)

Change of appropriate materials and products.
If there are any changes that may impact the quality of the materials usedin production or of the finished products, we must follow the appropriate
procedure for quality assurance, including but not limited to obtaining thecustomer approval.

(4)Compliance with laws and regulations
We are dedicated to strict compliance with all laws and regulations
governing the quality of the Group's products and data, including but notlimited to legal metrology regulations.

(5)

Public accreditation and certification
We must manage applications to, and registration and maintenance of, allofficial accreditation and certification bodies in good faith.

(6)Internal and external information disclosure
In the event that a risk concerning the Group's products or services - which
could significantly impact our customers and markets - is identified,necessary information must be disclosed to appropriate entities to minimize
and prevent the escalation of damage. We must promptly assess themateriality of the situation, consider whether recalls and other actions arenecessary, and engage in dialogue with government authorities.

4

Environmental Matters(1)

Chemical substance management
We must manage chemical substances with utmost care and in accordancewith relevant laws, regulations, treaties, and any other legal requirements.

(2)

Prevention of water pollution
To prevent water pollution from our operations, we will strictly comply withall relevant laws and regulations.

(3)

Prevention of soil pollution
To prevent soil contamination from our operations, we will strictly comply
with all relevant laws and regulations.

(4)

Prevention of air pollution
To prevent air pollution from our operations, we will strictly comply with all
relevant laws and regulations.

(5)

Prevention of vibration and noise
To minimize vibration and noise pollution to our environment caused by ouroperations, to the best of our abilities, we will strictly comply with all
relevant laws and regulations.

(6)

Waste management
We must appropriately manage and dispose of all waste generated byoperations in accordance with relevant laws and regulations and withutmost care.

5Safety(1)

Prevention of occupational accidents
We are committed to achieving "Zero Occupational Accidents” throughcontinuously improving our workplaces and implementing preventive
measures.

(2)Accident response
To prevent the occurrence of accidents resulting from fire, floods, leakage ofraw material and other hazards, systems must be established in advance.
This includes measures to mitigate the spread of damage in the event such
accidents occur.

(3)

Working environment and workplace hygiene
Maintaining a healthy working environment that allows all employees toperform their duties effectively is of paramount importance. This includes
measures to prevent heat stroke, excessive noise, odor, lighting, among othermatters.

(4)

Natural disasters
We will diligently prepare for natural disasters such as typhoons, floods,
guerrilla rains, landslides, earthquakes, and snow damage. In planning fordisaster mitigation, it is prudent to always consider the greatest risk.

6Procurement(1)

Supply chain management
We are committed to maintaining integrity in our supply chains. To do so wemust ensure that our suppliers, subcontractors, and other entities associatedwith our Group do not engage in any illegal or unethical activities, including
human rights violations.

(2)

Building healthy relationships
We must not take advantage of our Group’s market position and accept
kickbacks or extravagant entertainment from suppliers, subcontractors or
any other entities, nor shall we solicit such benefits.

(3)

Information sharing and management
We must appropriately disclose information to suppliers and other entities
and also manage and store information disclosed to us by suppliers and otherentities.

(4)

Management of conflict minerals and prohibited substances
We are dedicating to excluding conflict minerals from our Group's products.
We will also ensure that appropriate chemical substances are used inaccordance with INOAC Group Green Procurement Standards.

7

Business Activities(1)

Fair competition
We must strictly adhere to all relevant domestic and foreign competition
laws. Contact with competing companies are generally prohibited and ifconducted, should be carried out in accordance with the Group's rules.

(2)

Anti-corruption
To prevent corruption, offering of gifts, providing for travel or entertainmentand other benefits to both domestic and foreign public officials are generallyprohibited. If doing so in exceptional cases, it must be conducted inaccordance with the rules of the Group and in compliance with theregulations specific to each country or region.

(3)

Prevention of misappropriation of trade secrets
We must appropriately monitor retirees and mid-career hires to ensure thatthey do not illegally use trade secrets or leak information.

(4)

Labeling, advertising, and premiums
Labeling, advertising, or offering of premiums must be conducted incompliance with all relevant laws and regulations.

(5)

Customer service
We are dedicated to responding sincerely and appropriately to all customer
inquiries, including those from general consumers.

8Information Management(1)

Prevention of malware infection and system development
We prioritize identifying network threats such as ransomware and businesse-mail fraud, and to creating a comprehensive system that includes
prevention and incident response.

(2)

In-house system management
We must properly manage and maintain various internal business systems.

(3)Internal and external network management
We must ensure proper management and monitoring of external andinternal networks.

(4)

Information management and data privacy
A robust system must be established to ensure that appropriate monitoring
and tracking can be performed and that unauthorized data removals do notoccur. Personal information shall be managed in compliance with all relevantlaws and regulations.

(5)External information management
To ensure the integrity and confidentiality of our data stored and managed
outside the Group, we must appropriately manage and supervise the Group'sinformation.

(6)

SaaS environment
When using business systems managed by external vendors, we must
maintain a manual for handling incidents and ensure appropriate use.

(7)

Hardware Management
We must properly manage hardware containing critical information.

(8)

Data tampering
A robust system must be put in place to prevent falsification of importantinternal information.

9Technology Management(1)

Monitoring of technical information
Technical information and intellectual property rights held by the Group
must be actively monitored to ensure that retirees and mid-career hires do
not illegally use trade secrets or leak confidential information.

(2)

Appropriate specification setting
All technical departments are mandated to set realistic specifications formass production and obtain approval from the quality assurance department.

(3)Compliance in Material Selection
In the process of selecting and reviewing materials used, we must strictly
comply with all relevant laws and regulations.

(4)

Prevention of Corruption
The Group actively engages in technological innovation with domestic andforeign public research institutions, and in doing so, offering of gifts, traveland entertainment to related public officials and other persons are generallyprohibited. If doing so in exceptional circumstances, it must be conducted inaccordance with the Group's rules.

10Export and Import(1)

Compliance with export regulations
We must operate in strict compliance with all relevant national and regional
import and export regulations, including security controls.

(2)Customs compliance
Customs laws and regulations in all relevant countries and regions must becomplied with.

(3)

Compliance with chemical substance regulations
Through collaboration across departments, we must strictly comply withregulations concerning chemical substances.

The officers and employees of the Group will work with the Compliance Officers who areresponsible for their respective areas.
INOAC Group is committed to promoting ethical and legal business practices. To do so,
our compliance policies, including this policy, will undergo periodic review and updates.