NIPPON SANSO (THAILAND) Co., Ltd.

Code of Conduct
We contribute to the creation of value of our customers in all industries through innovative gas solutions and to
the realization of affluent and sustainable society through creation of harmonious relationship between humanand the earth based on our corporate philosophy "Proactive. Innovative, Collaborative, Making life better throughgas technology."
We act honestly and fairly with high ethical values toward the goal as described below so that we can gain trustfrom the society and make continuous progress.
1. Responsibility and AwarenessThis Code of Conduct sets forth the standards of judgment and concepts of conduct to be observed by all officers
and employees in our group (including temporary employees and contract employees) in various aspects ofbusiness activities in accordance with the corporate philosophy and vision.
We are aware of corporate social responsibilities and comply with this Code of Conduct based on theunderstanding that the foundation of business activities of our group companies should be built on trust of ourcustomers and the society.
In addition, employees can present or report concerns through the internal reporting system of their company.
Retaliation is prohibited against employees who honestly report actual or likely violation of this Code ofConduct, laws, regulations, or corporate policies.
2. Accountability and Respect for Stakeholders
We are aware of the importance of accountability in corporate activities, where we reserve transparency. We
always maintain an open stance to internal and external stakeholders and endeavor to disclose information in an
appropriate manner. We are truly open to views and criticism concerning information disclosure and have goodfaith communication, which we optimize in corporate activities.
3. Legal Compliance
We always comply with laws, regulations, and international standards, and treat all stakeholders in a fair,equitable, and sincere manner.

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(1) We comply with the laws and regulations relevant to our products and services and ensure that wefollow the procedures including obtaining approval and licenses and notifying the authorities.
(2) For maintenance of security systems both domestically and internationally, we comply with regulations
under relevant laws and designated procedures under internal codes, confirm thoroughly the profile anddescription of our business partners in every export transaction, and ensure that no export
goods/technologies will be used for any development, manufacture, or other activities relating toweapons of mass destruction of any kind.
(3) If we come to know inside information of any of our group companies or of our business partners in thecourse of business activities, we do not buy or sell stocks of the company in question until suchinformation is made public. We do not communicate such information or recommend buying andselling to cause another person to make a profit or avoid making a loss. We comply with relevant laws,
regulations, and internal codes in trading stocks of our company.
(4) We accurately perform accounting processing in accordance with relevant laws, regulations andinternal rules. We do not make any false or fictitious entry, or hold unrecorded assets for the purpose ofmanipulating profit and loss or the like.
4. Respect for Human Rights
We support protection of internationally proclaimed human rights, are aware of corporate responsibilities torespect human rights, and respect dignity and rights of all people. We never make discrimination or give unfair
treatment for any reason whatsoever such as race, nationality, ethnic group, sex, religion, creed, disability, healthcondition, economic background, political opinion, personal preference, sexual diversity, social status, family
origin, or other positions.
5. Prohibition of Child Labor and Forced Labor
We support and implement effective elimination of child labor and abolition of forced labor in any form.
6. Better Working Environment
We respect employees' rights under labor relations acts and build a good relationship between the management
and employees through dialogue. The management at all levels respects human diversity, personality, and2

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individuality and create working environment where employees can exercise their abilities to the utmost in safeand physically and mentally healthy settings.
(1) We do not allow any act to infringe fundamental human rights, impede abilities of individuals, or
damage working environment such as engaging in discrimination, annoyance, abuse, or acts thatcompromise dignity of the employee, and excessive labor forced upon or harassment of a subordinate
by a manager using his/her position.
(2) We endeavor to create a workplace where each one of employees can work with a sense of job
satisfaction, motivation, and ambition and realize continuous growth of organizations and individuals
through realization of flexible working style and respect for diverse values.
7. Environment and Safety
We endeavor to reduce environmental impact and to harmonize with environment in all fields of corporate
activities through activities such as mitigation of and adaptation to climate change, reduction of volume ofresource usage and waste, appropriate management of chemical substances and prevention of pollution,
preservation of water resources, and preservation of biodiversity and also endeavor to ensure process safety andsecurity based on our motto of “Selling gas is selling safety” in order to realize preservation of global
environment and sustainable development.
(1) We are always mindful of safety in manufacture, development, import, storage, sales, transportation,
export, maintenance, and repair of products, fully understand and comply with laws and safety
standards concerning product safety, and aim to achieve a higher level of safety.
(2) If we obtain information on product safety, we immediately investigate the factual relevance of suchinformation. If any issue is identified, we notify relevant departments and sections and take appropriateactions.
(3) We understand and comply with laws, regulations, etc. concerning occupational safety and health. Incase of any occupational accident, we give priority to ensuring workplace safety and minimize theeffect of accident, and ensure that we take prescribed procedures such as an immediate reporting toprevent a recurrence of such accident.
(4) We grasp the materialized and potential risks concerning business activities, and ensure safety ofemployees and the society by proposing and implementing countermeasures to prevent accidents andoccupation injuries.
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8. Sincere and Fair Business Practices
We conduct corporate activities in a sincere and fair manner, adhere to ethical principles, refrain from being
involved in any form of corruption including bribery and anticompetitive acts, and contribute to sounddevelopment of social economy through fair and free competition in the market. We adopt a firm attitude toward
antisocial forces and groups and refuse to have any relationship with them.
(1) We not only give no bribe but also provide no unjust benefit, entertainment, or gifts to public officials,
officers and staff of public organizations, and other similar personnel.
(2) We do not commit an act that is considered as bribery or provision of benefit to make an unjust
business profit to foreign public officials, etc. including foreign public officers or staff of foreigngovernments.
(3)We do not commit any act that violates or may be deemed to violate the antimonopoly law such as
involvement in pricing cartels, bid collusion, and allocation of customers or regions, and conduct fairand free inter-enterprise competition.
(4) We adopt a firm attitude toward antisocial forces and refuse to have any relationship with them. If wereceive an unreasonable request from antisocial forces or other similar groups, we hold a firm attitude
toward them and do not resolve the issue by payment of money and the like.
(5) We act in accordance with sound business practices and social norms in connection with any
entertainment with or gift-giving to/from our business partners.
(6) We have transactions with our suppliers with common decency and good faith and have suchtransactions fairly and equitably in accordance with laws and regulations and contracts.
When conducting purchasing, we do not request unfair price discounts, services, money, or otherarticles through abuse of the purchaser's position. We observe commonly accepted social norms inconnection with entertainment with suppliers and gift-giving from them. In addition, we selectsuppliers based on rational criteria in terms of price, quality, delivery schedule, etc.
(7) We recognize that we must engage in best practice that will lead to the benefit of the company when
performing our duties and will not engage in acts that will or may create conflicts of interest usingbusiness position or authorization, or using information acquired through business.
(8) We do not use any assets or expenses of the company for any personal purpose.

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9. Customer Satisfaction and Quality Control
We comply with contracts, which are covenants with our customers, and endeavor to ensure safety and quality ofproducts and services we provide. We are truly open to our customers' feedback and address the development andimprovement for better products and services.
(1) We give full attention to quality of products we provide to our customers and meet the requirements
and quality standards under laws, regulations, etc.
(2) We endeavor to fully provide information on usage conditions and usage environment and otherinformation necessary for our customers to use and handle the products safely.
(3) In the case of any quality issue of product, we immediately investigate a cause and take appropriate
recurrence prevention measures, remedial measures, and other similar actions.
10. Information Management and Personal Information Protection
We appropriately handle the collection and management of all information concerning corporate activities inaccordance with laws, regulations, etc.
(1) We recognize the importance of protection of personal information and obtain, use, and provide
personal information appropriately in accordance with laws, regulations, etc. We endeavor to preventand remedy leakage, loss, or damage of personal information we handle by taking necessary andappropriate security measures.
(2) We strictly manage personal information that can identify a specific individual and information on
individual privacy that is obtained in the course of business to prevent external leakage.
(3) We appropriately manage corporate confidential information in accordance with laws, regulations, etc.,
and do not disclose or leak such information to any external party without complying with prescribed
rules nor use such information for any purpose other than those specified. We obtain confidential
information of others only from persons authorized to disclose such information and manage and use
such information appropriately in accordance with laws, regulations, etc. We handle such informationin the same manner even after retirement/resignation of a relevant employee.
(4) We use the company information system solely for business purposes and not for any personal purpose.
We place strict controls on IDs and passwords concerning the company information system and prevent
external leakage. We do not attempt any unauthorized access to any computer systems under thecontrol of other companies.
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11. Protection of Intellectual Property Rights
We recognize that the intellectual property rights of the company (such as patent rights, utility model rights,design rights, trademark rights, and copyrights) are important corporate assets, use them appropriately, endeavor
to preserve such rights, and respect intellectual property rights of others.
12. Contribution to Local and International Communities
In conducting corporate activities, we respect the history, cultures, religions, social norms, customs, etc. of eachcountry or region and endeavor to establish a relationship of mutual trust with each local community. We
endeavor to contribute to the development of local and international communities with an awareness of being agood corporate citizen.
13. Application/Revision and Abolition
1. This Code applies to all officers and employees of our group companies including temporary employees
and contract employees.
2. In this Code, our group companies mean our company and all domestic and overseas subsidiaries of ourcompany.
3. This Code may be revised or abolished by the Board of Directors of the Company. Each of our groupcompanies may make necessary amendments to the provisions of this Code in accordance with laws andregulations, practices, business forms, etc. of its country and region upon prior approval of our company;
provided, however, that no provision may be set forth against the intent of this Code.

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