Compliance Policy of Competition Law
This policy is formulated for the purpose of the companies, officers and employees of theG-TEKT Group respecting and complying with the competition laws, related laws andregulations of each country and region (hereinafter referred to as "the competitionlaws").
We declare here not to accept any violation of competition law
Article 1 (Applicable target)(1) This policy is applied to all companies, which include subsidiaries and affiliates(hereinafter referred to as "each company"), officers and employees belonging to theG-TEKT Group (hereinafter referred to as "each officer and employee").
(2) Each company, officer and employee must carefully confirm the competition laws
and pay attention not to violate the laws.
Article 2 (Meeting with competitors)
Each officer and employee should not participate in meetings where competitors attend.
When participating in the meetings for reasonable reasons, it is necessary to give priornotice to the superiors and post-fact reports.
Article 3 (Prohibited matter)(1) Each officer and employee can’t discuss or exchange information to conduct thefollowing acts at the meeting where competitors attend.
① Act to restrict competition by negotiating sales price, supply quantity, etc.
② Agreement on pricing strategy, price composition, schedule of price change,
substitution condition, etc.
③ Agreement on restrictions on sales partners, sales region restrictions,manufacturing model restrictions, etc.
④ Act of restricting competition by negotiating business partners, transaction
volume, sales, market share, etc.
⑤ Other acts that may conflict with competition law.
(2) In addition to the preceding paragraph, each officer and employee shall not conduct
any act that violates the competition law.

1Article 4 (Prior confirmation of agenda and materials)
The person who designated to preside over a meeting where competitors attend(Hereinafter referred to as "chairperson") must confirm in advance that the agenda,materials, etc. at the meeting do not contain content that may conflict with competition
law.
Article 5 (Proceedings)
In the event of a situation that conflicts with competition law at the meeting wherecompetitors attend, each officer and employee do the following acts.
① The Chairperson takes measures such as calling attention to those who maderemarks that conflict with competition law. Nevertheless, if the speaker does notstop speaking, the chairman takes appropriate measures such as ordering to leave.
② At the meeting, if participants judge that there is a statement that may conflict withcompetition law, participants assist the proceedings of the chairperson by notifying
the chairperson of attention to the speaker. Nevertheless, if the speaker does notstop speaking, participants respond appropriately, such as leaving the meetingroom.
Article 6 (Preparation of minutes)
Each officer and employee who attend the meeting where competitors attend promptly
prepare the minutes of the meeting.
Article 7 (Organizational Structure)(1) The Compliance Officer, appointed from G-TEKT (headquarters in Japan)’s Officers,(hereinafter referred to as "the Compliance Officer"), supervises the G-TEKTGroup's compliance. The Compliance Officer constantly monitors for this policy to beproperly operated, and reports to the G-TEKT Board of Directors, in case of
discovering problems.
(2) Compliance managers are appointed from the management team at each company.
Each company establishes a committee to deal with compliance including
compliance of competition law.
(3) Each company establishes an internal reporting desk that can be reported
anonymously. Each company’s committee to deal with compliance actively conducts
educational activities of its existence.

2(4) In cases inappropriate acts are discovered in light of the competition laws, thispolicy and internal regulations, each company’s committee to deal with compliancepromptly reports the situation to the Compliance Officer and cooperates toinvestigate or deal with the problem.
Article 8 (Formulation of internal regulations)(1) Each company consults with lawyers or other experts as necessary to formulateinternal regulations that embody this policy, considering the competition laws andthe actual circumstances of the company. The internal regulations must be approvedby the Compliance Officer.
(2) Regardless of the position, officers and employees who committed inappropriate
conduct in light of the competition laws, this policy or internal regulations shall bestrictly punished in accordance with internal regulations.
Article 9 (Education)(1) Education of compliance of competition law is to be carried out continuously throughtraining etc.
(2) The contents of the education are practical contents including concrete examples,
based on the understanding of the competition laws, this policies and internal
regulations of each company.
Article 10 (Cooperation request to supplier)(1) Each company requests cooperation from suppliers so as not to commit
inappropriate conduct in light of the competition laws, this policy and internalregulations.
(2) In case violations of the competition laws, this policy or internal regulations bysuppliers are discovered, each company promptly requests correction and if
correction can’t be expected, considering measures including elimination of business
relations.
Article 11 (Audit)(1) The Compliance Officer audits the company's compliance with this policy andinternal regulations on a regular basis, and reports the results to the G-TEKTBoard of Directors.
(2) Each company strives to make audit results widely shared among officers andemployees.
3December.1.2017
G-TEKT CORPORATIONPRESIDENTNAOHIRO TAKAO

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