Corporate Code of Conduct for Pacific Metals Co., Ltd. and its Group Companies
Established April 20, 2007
Revised January 11, 2008
Revised October 10, 2012
The Corporate Code of Conduct gives shape to the Corporate Code of Ethics in the corporate activities of PacificMetals Co., Ltd. (“the Company”) and its Group companies and sets forth matters that should be put into practicein daily work activities. Officers and employees of the Company and Group companies will comply with thisCorporate Code of Conduct in the execution of their duties.
I. Responsibility to Society
1. Compliance with laws and regulations
The Company and its officers and employees will comply with the Financial Instruments and Exchange Act,
Political Funds Control Act, Public Offices Election Act, and laws and regulations prohibiting bribery, etc., andwill conduct themselves based on compliance, social norms, and social decency.
2. Contributions to local communities
We will coordinate and cooperate closely with local communities and maintain favorable relations with them.
3. Conservation of the global environment
We will comply with treaties, laws, and regulations for the protection of the global environment and strive forenvironmental conservation. We will also promote the conservation of energy, reduction of waste, and recycling.
4. Insulation from antisocial forces that threaten social order and safety
We will have no association whatsoever with any individuals or groups that would adversely affect social orderor sound corporate activities.
(1) We will not give simplistic responses, such as paying money, to antisocial forces.
(2) We will be duly cautious of any advances by antisocial forces disguised as business transactions.
5. Information disclosure
In accordance with the relevant laws and regulations and as otherwise required, we will make timely disclosuresof the Company’s financial details, the state of its business activities, management plans, and other relevant
information to shareholders, investors, and other stakeholders, with the exception of trade secrets and informationthat is subject to contractual obligations of confidentiality.
6. Prohibition of insider trading(1) The Company will not cause its officers, representatives, employees, or other workers to engage in insider
trading on the Company’s account.
(2) The Company will strive to establish the necessary information control structures to prevent insider tradingby its officers, representatives, employees, or other workers themselves.
II. Business Activities
1. Provision of valuable products
The fact that the products provided by the Company are needed by society is the foundation of the Company’s
existence. To ensure the strength of that foundation, we will strive to improve product development andmanufacturing technologies.
(1) Consumer relations
We will provide products of high quality that meet consumer needs.
(2) Compliance with relevant laws and regulations
We will provide safe products in compliance with the Product Liability Act and other relevant laws andregulations.
2. Sound, amicable relations with business partners and other associates
We will strictly forbid the provision or receipt of undue advantage in our transactions.
Officers and employees must make correct decisions and be temperate in their actions, to ensure that there are no
misunderstandings or unwarranted judgments made by the community.
(1) Customer relations

Business entertainment and gifts extended to customers must be within the bounds of social decency andanything that exceeds such bounds must be refused or returned. In addition, no favors, such as personal rebates
or commissions must be given or received.
(2) Supplier relations
Selection of suppliers will be based on reasonable (economically rational) criteria such as price, quality, anddelivery times. Any business entertainment or gifts received from suppliers must be within the bounds of socialdecency. Anything that exceeds such bounds must be refused or returned.
(3) Relationships with associated companies, partner companies, etc.
Transactions with associated companies (subsidiaries and affiliated companies) and partner companies, etc.
will not be given unfairly special treatment compared with the terms of fair and transparent competitivetransactions with third parties. In addition, business entertainment and gifts will be prohibited in principle.
3. Maintenance and promotion of fair, transparent, and free competition
We will observe the antitrust laws of both Japan and the various overseas countries in its business activities.
Further, the purchasing and contracting departments will not use their superior bargaining position to commit acts
such as forcing unfair transactions on business partners.
(1) Compliance with Antimonopoly Act
We will comply thoroughly with the Act on Prohibition of Private Monopolization and Maintenance of Fair
Trade (Antimonopoly Act).
(2) Compliance with Subcontractors Act
We will comply thoroughly with the Act against Delay in Payment of Subcontract Proceeds, Etc. to
Subcontractors (Subcontractors Act).
4. Protection of intellectual property rights
Intellectual property rights generate value in the economy and society and have a bearing on company survival.
Officers and employees will engage in the creation and protection of the Company’s intellectual property rightsand will not unjustly infringe upon the intellectual property of other individuals or companies.
(1) Handling of the Company’s trade secrets
The Company’s trade secrets will be managed strictly to ensure that they are not leaked outside the Company
via communication not only in documents but also by electronic media, commodities themselves, and verbally.
Trade secrets will not be disclosed for any reason other than for operational purposes.
(2) Handling of other companies’ intellectual property rights
We will respect the intellectual property rights of other individuals and companies in the same way as we doour own.
III. Company-employee Relations
1. Respect for employees’ character and individuality
We will strive to maintain and enhance human resources systems and working conditions that respect employees’
character and individuality.
2. Respect for privacy
We will respect the privacy of employees and, in the spirit of the Act on the Protection of Personal Information,
handle their personal information appropriately with careful and meticulous caution.
3. Respect for basic human rights and prohibition of discriminatory treatment
We will ensure sound workplace environments in which no person will be subjected to discrimination on thegrounds of race, religious beliefs, gender, etc.
4. Ensuring safe and healthy workplace environments
We will respect the intent of the various labor-related laws and regulations and strive to maintain safe and healthy
workplace environments.
The establishment, amendment, and abolition of this Corporate Code of Conduct requires a resolution of the Boardof Directors.
The contents of the Code will be reviewed at least once a year by the Internal Control Committee.