Noritz Group
Code of Ethics
Important things to remember to achieve
the Noritz Group's mission.

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会社名
社員番号
氏名

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Top message
With "The Simple Comforts of Life," the Noritz Group aims to offer value that inspires
customers in daily life and create many smiles. Achieving this mission requires not only theCompany's sustainable growth but also the development of society as a whole. The Noritz
Group strives to carry out its business activities based on its four important values, respondto demands from stakeholders to solve issues facing society, improve its corporate value,and contribute to achieving a sustainable society. Through these efforts, the Noritz Group
continues to provide "The Simple Comforts of Life" for stakeholders around the world as acorporate group trusted by society.
To achieve the sustainable growth of both the Company and society as a whole, we mustprioritize our response to environmental, social, and corporate governance (ESG) initiatives.
The Noritz Group aims to further improve its corporate value by promoting "Q + ESG," byadding "Q (quality)" to "ESG," as the basis for all of its corporate activities. In order for theentire Noritz Group to work as one towards achieving these goals, it is required for each
employee not only to comply with laws and regulations but also broaden their horizons andtake actions based on the "Q + ESG" perspective, while complying with the corporate ethics
expressed in our mission and value.
In other words, all our Group members must take actions by understanding stakeholders'
expectations and demands for us and considering how we should respond to ourstakeholders' expectations and demands from the perspective of Q + ESG.
Each and every one of our employees isrequired to build up actions with a high level of
ethics and responsibility to create trust with all
our stakeholders, and thereby contribute to the
President and CEO
Noritz Group's value creation and SDGs, aswell as achieving the Group's mission.

Today's
issuesChallenges
facingJapan
Challenges
facing the
NoritzGroup

How the Noritz Group
creates value

R&D

Quality
Manufacassurturing
ance

Realizing our mission

AfterSales sales
service

Basis for all business activities

Quality

The Simple
Comforts of Life
Relevant Sustainable
Development Goals for
the Noritz Group

Environment Society GovernanceGroup
Response to
expectations anddemands

Shareholders

Customers

Trust
Business partners

Employees

Global environment

Stakeholders surrounding the Noritz Group-1-

Community

Noritz Group Code of Ethics
The Noritz Group Code of Ethics (hereinafter, the "Code of Ethics") was established as a
guideline for the actions that each of the Group members should take in order torealize our mission. The Group's important values are specified in the Code of Ethics sothat each employee can put them into practice from the perspective of "Q + ESG." The Group
has also established the segment policies and rules that define specific policies, rules, andprocedures for executing daily operations in accordance with the Code of Ethics.
While the vision and medium-term management plan specify which direction to take, thevalue and Code of Ethics show what actions to take. If either of these is missing, ourmission "The Simple Comforts of Life" cannot be achieved. Please read the contents of thisCode of Ethics carefully, understand them correctly, and put them into practice in your daily
operations.
You may sometimes need to make decisions that are not defined in the Code of Ethics. In
such a case, review our mission, value, and vision to maintain a high level of ethics and act
responsibly as an employee of the Noritz Group while being fully aware of stakeholders'
expectations and demands.

Basic action concept

Mission, value, and Code of Ethics
Which direction to take

What actions to take

Response to stakeholders'
expectations and demands

Compliance withcorporate ethics

VisionMedium-term
management plan

Compliance withlaws, regulations,and social norms

Single-year policy
and targets

Segment policies,
guidelines, and rules

Break down

Department
Mission

Noritz Group
Code of Ethics

Our Mission

Personal
targetDaily

The Simple Comforts of Life
The Noritz Group supplies products that are friendly to theglobal environment and greatly satisfy and impress our customers.
The Noritz Group aims to contribute to people around the world and the global environment.
Our mission is to offer value that inspires customers in daily life and create many smiles.

Value

Our important values

We set our highest priority on quality, and provide the products and service by staying
one step ahead.
We act on justice, fairness, and transparency.
We develop ourselves with our employees, and contribute to the society.
We keep changing, challenging, and creating with our passion.

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TABLE OF CONTENTS
1. Respect for Human Rights

S

01. Respect for human rights --------------------------------------

P. 04

2. Improvement of Job SatisfactionS

02. Promoting individual growth and strong teams -----------03. Healthy and safe workplace environments ------------------

3. Providing High-Quality Products and Services

Q

P. 05
P. 06

E

04. Ensuring safety and security ----------------------------------05. Initiatives to improve manufacturing quality ----------------06. Initiatives to improve customer satisfaction -----------------

S
P. 07
P. 08
P. 09

4. Fair and Equitable Transactions

G

07. Free competition and fair transactions ----------------------08. Sound importing and exporting --------------------------------

P. 10
P. 11

5. Transparent Business Activities

G

09. Appropriate disclosure of corporate information ----------10. Prevention of insider trading ----------------------------------11. Prevention of corruption -----------------------------------------

P. 12
P. 13
P. 14

6. Crisis Management
12.
13.
14.
15.

G
Disaster countermeasures -----------------------------------Protection of information --------------------------------------Protection of intellectual property rights -------------------Elimination of antisocial forces -------------------------------

7. Harmony with the Global Environment and Local Communities
16. Preservation of the global environment --------------------17. Social contributions and harmony with local
communities -------------------------------------------------------

P. 15
P. 16
P. 17
P. 18

E

S
P. 19
P. 20

How to use the Noritz Group Code of Ethics
Each chapter indicates the stakeholders and social
requirements (Q + ESG) involved.
To deepen understanding of the contents of the Code of Ethics,
Please read through this document with team members and consider and discuss
stakeholders' expectations and demands of us by using case studies.
The Noritz Group Code of Ethics should be used in daily business practices as a guide tohelp the Noritz Group members take appropriate actions to achieve the Group's mission.

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Chapter 1 Respect for Human Rights

Customers

Shareholders

Employees

Business partners Local community Global environment

We support international human rights standards and respect all humanrights related to our corporate activities.

01. Respect for human rights(1) We do not discriminate based on race, gender, religion, political views, country oforigin, age, disability, sexual orientation, or any other reason.
(2) We do not engage in any form of harassment (actions that hurt the dignity of
individuals or impair the working environment and people's job performance),
including sexual harassment and power harassment.
(3) We do not use, tolerate, or benefit from any forced, child, or inhumane labor.

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Chapter 2 Improvement of Job Satisfaction

Customers

Shareholders

Employees

Business partners Local community Global environment

We grow together with the Company by contributing to our teams, while
maximizing our individual abilities.

02. Promoting individual growth and strong teams(1) We act proactively to achieve the goals of individuals, teams, and companies,
recognizing that the Noritz Group's interests are our employees' own interests.
(2) In order to achieve high performance, we take advantage of opportunities todevelop skills and knowledge and take on challenges without fearing failure.
(3) We create new value by acknowledging the diversity and differences in values ofindividuals and by inspiring each other.

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Chapter 2 Improvement of Job Satisfaction

Customers

Shareholders

Employees

Business partners Local community Global environment

03. Healthy and safe workplace environments(1) We strive to maintain and improve our own health as well as the health of otherworkplace members to realize our maximum potential.
(2) We discuss the creation of safe and hygienic workplace environments, andcontinue to improve them to prevent workplace accidents.
(3) We understand the diverse working needs of workplace members, andcooperate to securing and maintaining an employment environment where
everyone can work comfortably.
(4) We work to promote communication between employees and management inorder to create a better workplace.

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Chapter 3 Providing High-Quality
Products and Services

Customers

Shareholders

Employees

Business partners Local community Global environment

We strive to improve the quality of our entire value chain and deepen
our bonds of trust with our stakeholders.

04. Ensuring safety and security(1) We ensure the safety of our products and services by complying with the laws,
regulations, and rules of each country and region, as well as our internal
standards.
(2) We strive to maintain and improve our quality control systems, while ensuring
quality at every stage of our business activities.

(3) If a problem that may harm customers is found, we promptly take appropriate
measures in accordance with our internal rules.

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Chapter 3 Providing High-Quality
Products and Services

Customers

Shareholders

Employees

Business partners Local community Global environment

05. Initiatives to improve manufacturing quality(1) We develop products and services to solve the issues facing society byunderstanding the diverse needs of our customers.
(2) We strive to develop products and services that are easy for everyone to use,always from the perspective of customers.

(3) We strive to develop, manufacture, and promote environmentally friendly
products, technologies, and services.

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Chapter 3 Providing High-Quality
Products and Services

Customers

Shareholders

Employees

Business partners Local community Global environment

06. Initiatives to improve customer satisfaction(1) We make sure to display accurate information about our products and services
in an easy-to-understand way to prevent misunderstandings by customers.
(2) We respond to inquiries and complaints from customers quickly, properly, andpolitely, as well as in a fair and equitable manner.
(3) We take customers' feedback about our products and services seriously andstrive to improve the quality.
(4) We properly obtain and manage personal information, an important asset of ourcustomers, in accordance with the laws, regulations, and guidelines set by eachcountry and region, as well as our internal rules.

-9-Chapter 4 Fair and Equitable Transactions

Customers

Shareholders

Employees

Business partners Local community Global environment

We ensure fair, equitable, and free transactions, and build relationshipsthat allow us to grow together with our business partners.

07. Free competition and fair transactions(1) We comply with the Antitrust Law and other related laws and regulations of eachcountry and region, and conduct transactions on an equal and fair basis.
(2) When conducting transactions, we fairly select our business partners according torational criteria.
(3) We conclude contracts with the approval of the authorizer based on our internal
rules, and comply with the agreed contract terms and conditions.
(4) We do not provide our business partners with or solicit them for entertainment or
gifts that go beyond the acceptable range of social norms.

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Chapter 4 Fair and Equitable Transactions

Customers

Shareholders

Employees

Business partners Local community Global environment

08. Sound importing and exporting(1) When engaging in import and export transactions, we comply with the trade laws
and regulations of each country and region.
(2) We do not engage in any transaction which may impede the maintenance ofinternational peace and security.

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Chapter 5 Transparent Business Activities

Customers

Shareholders

Employees

Business partners Local community Global environment

We carry out transparent business activities to improve the credibility ofthe entire Noritz Group.

09. Appropriate disclosure of corporate information(1) The Noritz Group strives to proactively disclose information so that our
stakeholders can fairly obtain information.
(2) We never hide any information that could have a significant negative impact on
our stakeholders.

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Chapter 5 Transparent Business Activities

Customers

Shareholders

Employees

Business partners Local community Global environment

10. Prevention of insider trading(1) We do not use non-public information obtained in the course of duties, whether
inside or outside the Company, to buy or sell stock.
(2) If we buy or sell Noritz stock, we make a prior application as prescribed in theinternal rules.

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Chapter 5 Transparent Business Activities

Customers

Shareholders

Employees

Business partners Local community Global environment

11. Prevention of corruption(1) We maintain sound and normal relationships with politics and government, andwill not engage in any forms of corruption, including the bribery of public officials.
(2) When making political contributions and other donations, we will make themproperly in accordance with the laws and regulations of each country and region,
as well as our internal rules.

- 14 -Customers

Chapter 6 Crisis Management

Shareholders

Employees

Business partners Local community Global environment

We thoroughly implement organizational crisis management against
risks in order to continuously carry out business activities.

12. Disaster countermeasures(1) In order to minimize damage in the event of a disaster, we make preparations andconduct training on a routine basis.
(2) In the event of a disaster, we give top priority to protecting human life and focus
our efforts on relief and recovery support in the disaster-affected areas, while
ensuring continuity and early restoration of our business activities.

- 15 -Customers

Chapter 6 Crisis Management

Shareholders

Employees

Business partners Local community Global environment

13. Protection of information(1) We thoroughly manage information to prevent its exposure in a data breach andunintended use by treating all information, including technical and business
confidential information, as assets.
(2) To ensure information security, we comply with our internal rules regarding thehandling of IT equipment.
(3) If information is stolen or exposed in a data breach, we promptly report it to therelevant departments and immediately take action, including measures to preventa recurrence of the incident.

- 16 -Customers

Chapter 6 Crisis Management

Shareholders

Employees

Business partners Local community Global environment

14. Protection of intellectual property rights(1) We recognize the importance of our intellectual property rights and manage themappropriately to prevent their unauthorized use by others.
(2) We respect the intellectual property rights of others and do not use such rights inany unlawful manner that would constitute an infringement of intellectual property
rights.

- 17 -Customers

Chapter 6 Crisis Management

Shareholders

Employees

Business partners Local community Global environment

15. Elimination of antisocial forces(1) We take a resolute attitude toward antisocial forces such as organized crimegroups and will never have any relationships with them.
(2) If there is no choice but to respond to antisocial forces, we will respond as anorganization, not as an individual, while working closely with our superiors and thepolice.

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Chapter 7 Harmony with the Global
Environment and Local Communities

Customers

Shareholders

Employees

Business partners Local community Global environment

We strive to fulfill our responsibility to achieve a sustainable society
through our business activities.

16. Preservation of the global environment(1) We strive to reduce environmental risks and prevent environmental pollution bycomplying with environmental laws, regulations, and standards.
(2) Based on our medium- to long-term policies and goals, we actively work to build acarbon-free society and a resource-recycling society.

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Chapter 7 Harmony with the Global
Environment and Local Communities

Customers

Shareholders

Employees

Business partners Local community Global environment

17. Social contribution and harmony withlocal communities(1) As a member of society, we engage in activities that contribute to thedevelopment of local communities.
(2) We understand the social circumstances and give due consideration to the culture,religion, and customs of each country and region where we conduct our businessactivities.

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MEMO

Noritz Group Code of Ethics (NB-02000)

Applicable to: Noritz Corporation and Noritz Group companies
Permission for revision and abolition: Resolution by Noritz Corporation's board of directors(Noritz Corporation Planning & Administration Headquarters Head for minorchanges)
Date of issue:
July 2003, First edition
Revision history: November 2006, Second edition
January 2010, Third edition
April 2014, Fourth edition
January 2022, Fifth edition
Department responsible for issuance: Noritz Corporation Planning & Administration
Headquarters, Human Resources & General Affairs Division