Coca-Cola Bottlers Japan Holdings Group

Code of Business Conduct & Ethics

Coca-Cola Bottlers Japan Holdings IncJ

October 2023

Code of Business Conduct & Ethics
Contents
1J Why We Have a Code JJJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 1

5J Conflicts of Interest JJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 10(1) What Is Expected of Everyone JJJJJJJJJJJ 1(1) Determining Conflict of Interest…JJ 10(2) What Is Expected of Managers JJJJJJJJJJ 2(2) Gifts, Meals and EntertainmentJJJJJJ 10(3) When Written Approval Is Required J 2(3) Outside Employment, Speeches and(4) COBCE and Laws, etcJ JJJJJJJJJJJJJJJJJJJJJ 2Presentations JJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 12(5) Raising Concerns JJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 2(4) Relatives and Friends JJJJJJJJJJJJJJJJJJJJJJ 12(5) Outside Service as an Officer or

2J Right ConductJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 4

Director JJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 13(1) Business and Financial Records JJJJJJJJ 4(6) Outside Investments JJJJJJJJJJJJJJJJJJJJJJJJ 13(2) Company Assets JJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 4
Use of Time, Equipment and Other
Assets(3) Use of Information JJJJJJJJJJJJJJJJJJJJJJJJJJJJJ 5
Nonpublic Information
Insider Trading
Privacy, Personal Information
3J Respect of Human Rights JJJJJJJJJJJJJJJJJJJJJJJ 7
4J Dealing with Stakeholders JJJJJJJJJJJJJJJJJJJJJ 7(1) Relationship with customers, key
accounts, suppliers, shareholders,
and the community JJJJJJJJJJJJJJJJJJJJJJJJJJJJ 7(2) Dealing with Administrative Bodies J 8
Bribes Are Prohibited(3) Dealing with Competitors JJJJJJJJJJJJJJJJJJ 9
Competitive Intelligence

1J Why We Have a Code
What makes Coca-Cola one of the most admired brands in the world? It is not just our
productsJ It is also how we do our work and the integrity of our actionsJ
Ingrained in our culture, integrity inspires our work and strengthens our reputation as a
Company that does extraordinary things and always does what is rightJ Integrity is theessential ingredient to our successJ We value actions performed with integrityJ
The Code of Business Conduct & Ethics (“COBCE”) serves as the guide to act righteously
and defines how the employees should conduct themselves as the representatives of theCompanyJ
Our responsibilities to the Company, fellow employees, customers (consumers), key
accounts, vendors (suppliers), shareholders and public administration are also described in
COBCEJWe must observe all laws, regulations, and COBCE, act righteously with integrity andhonesty at all times under any circumstances, and be accountable for our actionsJ
You might face a situation where the right thing to do is not obviousJ
That is where our COBCE can helpJ It is always here as your guide to preserving our
reputation and living our valuesJ While the Code cannot answer every question, it can show
you where to go for guidance when the answer is not clearJ(1) What Is Expected of Everyone
All the employees in the Company are expected to:Comply with laws and regulations, COBCE, and all the Company rules and workplace
disciplines, including the Employment RegulationsJ
Observe all laws, regulations, and COBCE at all times under any circumstances, use good
judgment and avoid taking any actions that may appear to be improper behaviorJ
Draw a line between public and private affairs, and focus on sensible behaviorJ Never takeany action that may disgrace the Company or damage its interest, even in private livesJ
Think through before taking an action and seek guidanceJ If in doubt, engage in selfquestioning before taking an actionJ
If ever in doubt about what the right conduct may be, ask yourself the following questions:・ Will it be a violation of any laws and regulations?
・ Is it in line with the corporate philosophy and vision?
・ Is it consistent with COBCE?
・ Is it ethical?
・ Is it supported by customers and people in the society?
・ Is it an action that is considerate of other people's positions?
・ Is it an action that you will not feel ashamed of even before your family?
・ Is it an action that will not be embarrassing to you nor to your Company and its
reputation?
・ Is it an action that will cause no inconvenience even when reported in the newspaper？
If the answer is “No” to any of these questions, don’t do itJ
If you are still uncertain, ask for guidanceJ COBCE tries to capture many of the situations
that the employees may encounter, but cannot address all of themJ If you are unsure of yourjudgment or have any questions, you should seek guidance from any of the following:• Your manager• Legal Compliance Department
1(2) What Is Expected of Managers① Promote a Culture of Ethics and ComplianceManagers should at all times be the model of appropriate behaviors and put the following
into practiceJ• Ensure that the subordinates you supervise understand their responsibilities
stipulated in COBCE and other Company policiesJ• Make opportunities to discuss about the contents of COBCE and reinforce theimportance of ethics and compliance with themJ• Create an environment where they do not feel hesitant to raise concernsJ• Consider conduct in relation to COBCE and other Company policies when evaluating
your subordinatesJ• Never encourage or direct them to achieve business results at the expense of ethicalconduct or compliance with COBCE or any lawsJ• Always act to stop your subordinates from violating COBCE or any lawsJ② Respond to Questions and Concerns
If approached with a question or concern related to COBCE, listen carefully to what yoursubordinate wants to convey to youJ Ask for clarification or additional information when
you feel necessaryJ Answer the questions as much as you can, but do not feel obligated togive an immediate responseJ If you cannot respond immediately, consult your supervisor or
relevant department to gain guidanceJ If your subordinate raises a concern that may
require investigation under COBCE, contact the Legal Compliance DepartmentJ(3) When Written Approval Is Required
Certain actions referenced in COBCE, such as, the use of Company assets for purposes not
related to work, and certain situations where conflict of interest arises require prior written
approval (including the use of electromagnetic system) from managers, officers in charge oflegal affairs or Legal Compliance DepartmentJ
If you are in a situation where you need a written approval, contact your manager who canhelp you seek the necessary approvalJ(4) COBCE and Laws, etcJ
Employees are expected to comply with COBCE and all applicable laws, rules andregulationsJ If an act is prohibited by COBCE or law, the provisions of the law take precedence
over COBCEJ
If you are uncertain which laws apply to you, or if you believe there may be a conflict
between applicable laws, consult Legal Compliance Department before taking actionJ(5) Raising Concerns
If you observe a behavior that concerns you, or that may represent a violation of COBCE,
raise the issue promptlyJ Doing so will allow the Company an opportunity to deal with theissue and correct it, ideally before it becomes a violation of law or a risk to health, security or
the Company’s reputationJ① Where to inform or consult
As to where you should inform or consult about issues or concerns, you have several optionsJ
You can contact any of the following:• Your manager• Legal Compliance Department• Internal reporting hot line2

② Anonymity and Confidentiality
When you make a report to Legal Compliance Department or through the department
responsible for the whistleblowing system, you may choose to remain anonymous, although
you are encouraged to identify yourself to facilitate communicationJ If you make your identity
known, the department responsible for the whistleblowing system and the investigating
department will take every reasonable precaution to keep your identity confidentialJ To help
maintain confidentiality, avoid discussing about these issues, or any investigation, with other
employeesJ Because these departments strive to maintain strict confidentiality in allinvestigations, they may not be able to inform you of the outcome of an investigationJ③ Investigations
The Company takes all reports of possible misconduct seriouslyJ We will investigate thematter confidentially, determine whether COBCE or any law has been violated, and takeappropriate corrective actionJ If you become involved in such investigation, cooperate fully andanswer all questions completely and honestlyJ④ No Retaliation
The Company values the help of employees who identify potential problems that theCompany needs to addressJ Any retaliation against an employee who raises an issue honestly
is a violation of COBCEJ The fact that an employee has raised a concern honestly, or
participated in an investigation cannot be the basis for any action that adversely affects
his/her employment, including dismissal, demotion, loss of benefits, threats, harassment or
discriminationJ
If you work with someone who has raised a concern or provided information in an
investigation, you should continue to treat the person with courtesy and respectJ If you believe
someone has retaliated against you, report the matter to Legal Compliance Department or
department responsible for the whistleblowing systemJ⑤ Making False Accusations
The Company will protect any employee who raises a concern honestly, but it is a violationof COBCE to knowingly make a false accusation, lie to investigators, or interfere or refuse tocooperate with such investigationJ Honest reporting does not mean that you have to be rightwhen you raise a concern; you just have to believe that the information you are providing isaccurateJ3

2J Right Conduct
Acting righteously begins within the Company, and includes how we deal with Company
records, assets and informationJ(1) Business and Financial Records① Ensure the accuracy of all Company business and financial recordsJ These include
not only financial accounts, but other procedural records such as quality reports,
working hours, expense reports, benefits claim forms and resumesJ
Ensuring accurate and complete business and financial records is everyone’s
responsibility, not just a role for accounting and finance personnelJ Accurate
recordkeeping and reporting reflects on the Company’s reputation and credibility, andensures that the Company meets its legal and regulatory obligationsJ・ Always record and classify all accounting treatments in the proper accounting period
and in the appropriate account and departmentJ Do not delay or accelerate therecording of revenue or expenses to meet budgetary goalsJ・ Estimates and accruals must be supported by appropriate documentation and be basedon your best judgmentJ・ Ensure that all reports to regulatory authorities are full, fair, accurate, timely andunderstandableJ・ Never falsify any documentJ・ Do not distort the true nature of any accounting treatmentJ・ Never assist others to evade taxesJ For this reason, payments should be made directly
to the person or firm that actually provided the goods or servicesJ Also, payments
should be made in the supplier’s home country, where it does business, or where thegoods or services were provided, unless the supplier legitimately designate a payee orsold its accounts receivable to another entityJ Exceptions must be approved bymanagers or in accordance with the Company rulesJ② Strive for Accuracy
Employees must always strive to be accurate when preparing any information for theCompany, but honest mistakes occasionally happenJ Only intentional efforts tomisrepresent or improperly record transactions, or otherwise to falsify a Company
business record, will be deemed as violation of COBCEJ(2) Company Assets① Protect the Company’s assets, and use those assets in the manner intendedJ
Do not use Company assets for your personal benefit or the benefit of anyone other thanthe CompanyJ Use, protect, and manage the Company assets under the responsibility ofeach of the employeesJ・ Apply the common senseJ For example, in case of emergency, you may make atelephone call from your workplace or send emailJ Excessive use of private telephone
calls and email is a misuse of assetsJ
Theft of Company assets, whether it is physical theft such as unauthorized removal ofCompany product, equipment or information, or theft through embezzlement or intentionalmisreporting of time or expenses, may result in dismissal and criminal prosecutionJ The
Company treats workplace theft of assets belonging to other employees the same way it treats4

theft of Company assetsJ
The use of Company assets outside your work, such as using the Company’s businessachievements outside the Company or using Company materials or equipment for personal
interests, requires prior written approval from your manager or from the relevant department
through your managerJ You must have this approval renewed annually if you continue to use
the asset outside the workJ② Use of Time, Equipment and Other Assets• Do not engage in personal activities during working hours that interfere with your job
responsibilitiesJ Ensure time management and strive to achieve the maximum results
within the limited timeJ• Using Company computers and equipment for outside businesses, or for illegal orunethical activities such as gambling, pornography or other offensive subject matter isprohibitedJ• Taking any opportunity for personal gain that you learn through your position in the
Company, or through the use of Company property or information is prohibitedJ③ Examples of Company Assets• Company money（sales proceeds, change, etcJ）• Company products and promotional materials• Call• Wireless communication devices• Vehicles• Computer systems and software• Photocopiers• Employees’ working hours and deliverables from their work
• Tickets to concerts or sporting events• Proprietary information• Company trademarks(3) Use of Information
The Company’s nonpublic information must not be disclosed to anyone unrelated to theCompanyJ This includes everything from contracts and pricing information to marketing
plans, technical specifications and employee informationJ① Nonpublic Information
Do not disclose nonpublic information to anyone outside the Company, including tofamily and friends, except when disclosure is required for business purposesJ Even then,take appropriate steps, such as execution of a confidentiality agreement, to prevent misuseof the informationJ
Do not disclose nonpublic information to anyone outside the Company, except whendisclosure is required for business purposesJ Employees are obligated to protect theCompany’s nonpublic information at all times, including outside of the workplace andworking hours, and even after employment endsJ
Retain or discard Company records in accordance with the Company’s record retention5

policiesJ Company legal counsel occasionally may issue notices regarding retention ofrecords in the case of actual or threatened litigation or government investigationJ
Employees must abide by the directions contained in these notices, as failure to do so could
subject the Company and employees to serious legal risksJ② What Is Nonpublic Information?
It is any information that the Company has not disclosed or made generally available tothe publicJ Examples include information related to:• Information on new products prior to release or new campaigns prior to
implementation• Raw materials of products and production method• Pricing of products and production costs• The Company’s business results, business policies, and strategies• Content of contracts• Personal information of employees, customers, and vendors• Financial data
• Major management changes• Mergers and acquisitions• Technical specifications• Inventions• Proposals③ Insider Trading
Trading in stocks or securities based on material nonpublic information, or providing
material nonpublic information to others so that they may trade or using such information
for your own trading, is illegal and may result in prosecutionJ④ Privacy, Personal Information
The Company respects the privacy of all its employees, business partners and consumersJ
We must handle personal data responsibly and in compliance with all applicable privacy
lawsJ Employees who handle the personal data of others must:• Act in accordance with applicable law;
• Act in accordance with any relevant contractual obligations;• Collect, use and process personal information only for legitimate business purposes;• Limit access to the information to those who have a legitimate business purpose forseeing the information; and• Take care to prevent unauthorized disclosureJ

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3J Respect of Human Rights
Respect for human rights is the foundation of corporate activities, and we must ensure suchrespect in order to realize the sustainability of the Company and the community in which we
do businessJ In addition, we need to accept diverse value and lifestyles and develop an
environment in which each of the employees can use his/her maximum potential and qualityJ
We will strive to create a workplace in which each of the employees is respected as a person
and can be motivated to workJ・ We will respect each other’s ways of thinking and positions so that everyone in theworkplace can work activelyJ・ We will strive to maintain a workplace that is free from discrimination andharassment due to race, gender, color of the skin, nationality, origin, religion, age,disability, sexual orientation, and/or gender identityJ・ We will never commit or tolerate any violence, sexual harassment, power harassment,maternity harassment, and/or other abuseJ・ We will strive to maintain and continue improving the workplace to be a place that issafe, healthy and easy-to-workJ

4J Dealing with Stakeholders
The Company’s relationships with stakeholders are critical to our successJ We must deal
fairly and lawfully with everyone and every organization we encounterJ(1) Relationship with customers, key accounts, suppliers, shareholders, and thecommunity
The Company values its partnerships with customers, key accounts, suppliers,
shareholders, and the communityJ Treat these partners in the same manner we expect to betreatedJ• Always deal fairly with customers, key accounts, and suppliers, and treat themhonestly and respectfullyJ• Do not engage in unfair, deceptive or misleading practicesJ• Always present Company products in an honest and forthright mannerJ
We expect that our suppliers will take no action contrary to the principles of our COBCEJ
When we deal with the suppliers, we must make sure that we comply with the“Fundamental Principles of Suppliers”J① Relationship with customers
Everything we do begins with the purchase of our products by the customersJ It is mostimportant that we think about what we need to do to be chosen by customers and act fromtheir point of viewJ We will offer quality goods and services at all times and ensure to
pursue customer satisfactionJ• We will offer safe products that customers can use with a sense of securityJ• We think about what may be the valuable goods and services for customers, listen to
their voices, and understand what they desireJ• We will respond to customers' inquires and complaints in a prompt, faithful,appropriate, and sincere mannerJ We will also review our actions, ensure to evaluatethem, and reflect in the next action in a flexible mannerJ• We will not use any representation or indication on products or in advertisement that7

may be misleading to customersJ• We will appropriately manage the vending machines and other sales equipment so thatthey are kept clean and safe for use at all timesJ② Relationship with key accounts
It is essential to have trust and cooperation from our key accounts to perform ourbusiness activitiesJ We need to understand the sense of value of each key account andprovide them with necessary information to address their issues so that we can aim for
mutual prosperityJ• We will remain interested in customers and act with passion and sincerityJ• We will pay attention to our attire, use cheerful expression and kind words, and offer
friendly attitudeJ• We will proactively understand customers' issues and solve/improve them togetherJ• We will not commit any action that may hinder free and fair trade and competitions in
the course of performing our business to build relationship with key accountsJ③ Relationship with suppliers
We will develop the relationship of trust with suppliers through fair and equal transactions
and strive to coexist with them as a good partnerJ• We will not have any discussions or agreements as to trade terms that may hinder freecompetitionJ• We will not force our suppliers to accept any unfair terms by using our advantageous
position in the business or restrict suppliers not to do any business with third partiesJ④ Relationship with shareholders
We will strive for sound and transparent business operations and raise the corporate
valueJ We will also provide appropriate information in a timely manner and enhance thecorporate value through sound and transparent Company activities, thereby fulfilling the
expectations and trust of shareholdersJ⑤ Relationship with the community
We must strive to sustainably grow and prosper with the community so that we canbecome a trusted and necessary member of the communityJ We will fulfill our social
responsibility through our business activities and contribute to the realization of further
enriched societyJ• We will aggressively support the community through sports, culture, education,
welfare, environmental preservation activities, etcJ
• We will try to work on resource saving, energy saving, and recycling in order topromote environmental preservationJ• We will have no relationship whatsoever with any anti-social forces or groups thatthreaten the order and safety of civil society and will take the approach in a firm
attitudeJ• We will strive to improve the corporate image and product image of our groupJ(2) Dealing with Administrative Bodies
Transactions with administrative bodies are not the same as conducting business withprivate parties, and must be handled with careJ Be aware that there are certain
restrictions applied to the transactions with administrative bodies, and consult with Legal
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Compliance Department if you have any questions regarding these restrictions to becertain that you clearly understand them and can fully comply with themJ
As a principle, you must not offer anything to a government official directly or
indirectlyJin return for any favorable treatmentJ If offering anything of value to agovernment official becomes necessary for any reason, be sure to obtain prior approval from
Legal Compliance Department in accordance with CCBJI group regulations for the divisionof authorities (“Regulations of Administrative Authority”)J Also, ensure that any suchpayments are properly recorded in the appropriate Company accountJ① Bribes Are ProhibitedA bribe is giving or offering to give anything of value to a government official to influencea discretionary decisionJ Examples of bribes include payment to a government official toencourage a decision to award or continue business relations, to influence the outcome of apublic administration audit or inspection, or to influence tax or other legislationJ Other
payments to government officials also may constitute bribery in some countries andregionsJ② “Anything of Value”
This phrase literally means anything that might have value to a government official,including cash, gifts, meals, entertainment, business opportunities, Company product, andmoreJ There is no monetary threshold; any amount could be construed as a bribeJ③ Certain Payments May Be Acceptable
Special payments to a government official may be allowable under certain narrow
exceptionsJ Obtain approval from Legal Compliance Department before making any suchpaymentJ In some circumstances, Legal Compliance Department may be able to provide
blanket approvals for certain well-defined interactions with government officialsJ④ Improper Payments by Third Parties
The Company may be held liable for bribes paid by a third-party agent or consultant
acting on the Company’s behalfJ Take particular care when evaluating a prospective third
party who might interact with public administrative organizations on behalf of theCompanyJ You must not engage a third-party agent or consultant if there is reason tobelieve that the agent or consultant may attempt to bribe a government officialJ(3) Dealing with Competitors
Employees may sometimes need to collect, share and use information about ourcompetitors for business reasonsJ But even in such cases, they must do so only in a legal
and ethical mannerJ We must also respect the nonpublic information of other companies inthe same way the Company values and protects its own nonpublic informationJ J① Competitive Intelligence
Employees are encouraged to collect, share and use information about our competitors,
but to do so only in a legal and ethical mannerJ Just as the Company values and protects its
own nonpublic information, we respect the nonpublic information of other companiesJ② Acceptable Intelligence Gathering9

It is acceptable to collect competitive intelligence through publicly available informationor ethical inquiriesJ For example, you may gather and use information from sources suchas:・ Publicly available filings with public administrative organizations
・ Public speeches of Company executives
・ Annual reports
・ News and trade journal articles and publications
You also may ask third parties about our competitors, or accept competitive intelligenceoffered by a third party, as long as there is no reason to believe that the third party isunder a contractual or legal obligation not to reveal such informationJ③ Prohibited Activities
The following basic restrictions apply to our ability to gather competitive intelligence:・ Do not engage in any illegal or illicit activity to obtain competitive informationJ This
includes theft, trespassing, eavesdropping, wiretapping, computer hacking, invasion ofprivacy, bribery, misrepresentation, coercion, espionage or threatsJ・ Do not accept, disclose or use competitive information that you know or have reason tobelieve was disclosed to you in breach of a confidentiality agreement between a third
party and one of our competitorsJ

5J Conflicts of Interest
Act in the best interest of the Company while performing your job for the CompanyJ A
conflict of interest arises when your personal activities and relationships interfere, orappear in the eyes of those around you that you are prioritizing your personal interest overthe interest of the CompanyJ
This section of COBCE provides rules for some common conflict of interest situationsJ
COBCE cannot address every potential conflict of interest, so use your conscience andcommon senseJ When you are unsure, consult with your manager or Legal ComplianceDepartment to seek guidanceJ
Take particular care if you are responsible for selecting or dealing with a supplier onbehalf of the CompanyJ Your personal interests and relationships must not interfere, orappear to interfere, with your ability to make decisions in the best interest of the CompanyJ
When selecting suppliers, always follow applicable Company procurement guidelinesJ(1) Determining Conflicts of Interest
When faced with a situation where conflict of interest may arise, ask yourself:• Could my personal interests interfere with those of the Company?
• Might it appear that way to others, regardless of whether they are those who are inside
the Company or outsiders?
When unsure, seek guidanceJ(2) Gifts, Meals and Entertainment
Do not accept gifts, meals or entertainment, or any other favor from customers or
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suppliers if doing so might compromise or appear to compromise your ability to makeobjective business decisions that meet the best interest of the CompanyJ
We must not commit bribery or exchange any entertainment or gift that deviates from asocial common senseJ Acceptance of any gifts, meals or entertainment that exceed thefollowing limitations must be approved by your managerJ① Gifts• Do not accept gifts in exchange for doing, or promising to do, anything for a customeror supplierJ• Do not ask for gifts from a customer or supplierJ• Do not accept gifts of cash or cash equivalents, such as gift cardsJ• Do not accept gifts of more than modest valueJ• Gifts of symbolic value, such as trophies and statues that are inscribed in recognitionof a business relationship, may be acceptedJ• Gifts or discounts offered to a large group of employees as part of an agreement
between the Company and a customer or supplier may be accepted and used asintended by the customer or supplierJ② Meals and Entertainment• Do not accept meals or entertainment in exchange for doing, or promising to do,anything for a customer or supplierJ• Do not ask for meals or entertainment from a customer or supplierJ• You may accept occasional meals and entertainment from customers and suppliers if
the event is attended by the customer or supplier, and the costs involved are in linewith local custom for business-related meals and entertainmentJ For example, ordinary
business meals and attendance at local sporting events are generally acceptableJ③ Travel and Premium Events
If you are invited by a customer or supplier to an event involving out-of-town travel orovernight stay, or to a premium event, such as the Olympics or World Cup, consult yourmanager to determine if there is adequate business rationale for your attendanceJ If there
is, the Company should pay for your travel and attendance at the eventJ Be sure to takenecessary procedure to receive that payment according to the Regulations of
Administrative AuthorityJ④ Refusing Gifts, Meals and Entertainment
Make efforts in informing people in advance that you will not accept any entertainment
or giftJ If you are offered a gift, meal or entertainment that exceeds the limits noted
above, politely decline and explain the Company’s rulesJ If returning a gift would offend thegiver, or the circumstances under which it was given preclude its return, you may accept
the gift but should notify your manager and report to the Company by taking the necessary
procedure predefined in the Regulations of Administrative AuthorityJ⑤ Gifts, Meals and Entertainment for Customers and Suppliers
Gifts, meals and entertainment for customers and suppliers must support the legitimate
business interests of the Company and must be reasonable and appropriate under thecircumstancesJ Always be sensitive to the customers’ and suppliers’ own rules and policies
on receiving gifts, meals and entertainmentJ
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⑥ Tickets and Housing for Personal Use
Tickets to sporting events or other entertainment venues that are offered by a customeror supplier for your personal use, without attendance by the customer or supplier, areconsidered giftsJ They should not be accepted, unless offered to a large group of employees
as part of an agreement between the Company and the customer or supplierJ The same
applies to the personal use of a condominium or vacation homeJ(3) Outside Employment, Speeches and Presentations
Employees may not be employed by, or otherwise provide services for or receive payment
from, any customer, supplier or competitor of the CompanyJ
You must have prior approval in accordance with the Regulations of Administrative
Authority before speeches or presentations you have done outside the Company, which
include the following cases:• When you are giving the speech or presentation as part of your job with the Company(except when it is part of the official duties such as Public Relations);• When you are giving the speech or presentation describes your work with theCompany;• When you are formally identified as the employee of the Company in the speech orpresentation(4) Relatives and Friends
Some employees have family members who are employed by or investing in thecustomers or suppliers of the CompanyJ These financial interests do not constitute a conflictof interest except in the following cases:• When you have discretionary authority in dealing with any of these companies as partof your job with the Company; or• When your relative deals with the Company on behalf of the other companyJ
In any of the above situations, you must gain approval from an officer in charge,
manager, or Legal Compliance DepartmentJ
You may have friends who are employed by or investing in the customers or suppliers of
the CompanyJ If you deal with such a customer or supplier, make sure that your friendshipdoes not affect, or appear to affect, your ability to act in the best interest of the CompanyJ If
you are uncertain whether your friendship may create an issue, consult your manager orLegal Compliance DepartmentJ
In addition, personal relationships at work must not influence your ability to act in thebest interest of the Company, and must not affect any employment relationshipJ
Employment-related decisions must be based on qualifications, performance, skills andexperienceJ① Who Is My “Family” Under COBCE?
Your spouse, parent, sibling, grandparent, child, grandchild, mother- or father-in-law, orsame or opposite sex partner that you live with are all considered a part of your familyJ Also
included is any family member who lives with you or is financially dependent on you, or onwhom you are financially dependentJ Even when dealing with family members beyond this12

definition, make sure that your relationship does not interfere, or appear to interfere, withyour ability to act in the best interest of the CompanyJ(5) Outside Service as an Officer or Director
In general, you must obtain the necessary approval in accordance with the separately
defined Regulations of Administrative AuthorityJ(6) Outside Investments
Avoid investments that could affect, or appear to affect, your decision making on behalf of
the CompanyJ Specific guidelines apply to ownership of stock of a customer, supplier orcompetitor of the Company:• If you have discretionary authority in dealing with a company as part of your job, you
may not have any financial interest in that company without prior written approval
from Legal Compliance DepartmentJ• If you do not have discretionary authority in dealing with a company as part of yourjob, you may own up to 1% of the stock of that companyJ• You may own more than 1% of the stock of any customer, supplier or competitor onlywith the prior written approval of Legal Compliance DepartmentJ• You must renew approval from Legal Compliance Department if you continue to own
the stockJ① Mutual Funds
These restrictions on outside investments do not apply to mutual funds or similar
investments in which the employee does not have direct control over the particularcompanies included in the fundJ＊ Glossary
Employees – Corporate Officers (Directors, Executive Officers, Auditors), permanent
employees, contracted employees and employees of companies under contract with
the Company, also included part-time employees and non-regular employees in
COBCEJ
Customers (consumers) – All those who purchase or may purchase our products
Customers (consumers) – All those who purchase or may purchase our products
Key accounts (customers) ― Wholesalers, shops, and vending machine locations whocarry our products
Suppliers (vendors) – Contracted parties who transport, deliver, or manufacture our
products or from whom we purchase raw materials and other materials【HP】

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