EM Devices Code of Conduct
We (*) recognize that the key to enhancing the corporate value of EM Devices is fulﬁlling our corporate social responsibility in our day-to-day work as a member of society, in line with the EM Devices Charter of Corporate Behavior. (As amember of society, we will faithfully comply with the stipulated cooperate code of EM Devices Charter of Corporate
Behavior , based on the recognition that always fulﬁlling our corporate social responsibilities in the execution of ourdaily operations that lead to the enhancement of the corporate value of EM Devices) Therefore, we will faithfully
observe the provisions of this EM Devices Code of Conduct (this Code).
* “We” refers to the Ofﬁcers (including directors, corporate auditors, and certain other personnel) and Employees(including temporary and part-time employees regardless of their employment status) of EM Devices and its subsidiaries (collectively “EM Devices”).
This Code shall be applied to the Ofﬁcers and Employees of each company in the EM Devices Group subject to the1

Basic Stance(1) We will comply with all applicable laws, rules, regulations, and in-house regulations, including this Code, in every
aspect of our corporate activities at all times. We will strive to ensure that all corporate activities are in compliancewith fair business practices and social ethics.
(2) We will respect the fundamental human rights of all people. Moreover, we will not act in such a way that may
offend the individual dignity unjustly. This also includes complying with requirements stipulated by local laws
and regulations as well as treaties and international organizations.
(3) We recognize privacy as a fundamental human right and will respect the privacy of individuals, including customers, business partners, and Employees.
(4) We will maintain fair, impartial and highly transparent relationships with all stakeholders while seeking the interests of the company. We will not engage in any act that is contrary to the above, for the beneﬁt of ourselves or athird party, or that damages the credibility or reputation of the company.
(5) We will accurately and fairly maintain all accounting and other records in accordance with applicable laws, rules,regulations, and internal regulations, and properly execute our duties. We will not carry out any unlawful accounting transactions or actions that may result in losses for the EM Devices Group.

2Accountability for Adherence to This Code(Responsibility for compliance with the Code)With an awareness of our position as a member of society, act in accordance with social decency based on highmorals and ethics, and all of us will faithfully carry out the items stipulated in this code in our respective positions.
We recognize that a violation of this Code may result in disciplinary action under and in accordance with applicablelaws, rules, regulations, and/or internal regulations.

3Establishment and Revision of This Code(1) The provisions and revisions of this Code will be deliberated on by the management conference of EM Devices
Corporation and reported to its board of directors.
(2)Each company in the EM Devices Group may modify any part of this Code, provided that such modiﬁcations do notdeviate from the provisions of this Code.

I Relations with Society
Being a Good Corporate Citizen

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Building a sustainable society(1) To preserve the global environment and contribute to building a sustainable society, we will not only observe allapplicable laws and regulations but also constantly reduce any adverse impact on the environment that results toany stage of a product’s lifecycle.
(2) We will manage the amount of energy and water resources used in our processes, as well as the amount of pollutants and waste generated, based on annual numerical targets, and take thorough measures to reuse, minimize,and reduce the amount of waste generated.
(3) When handling chemical substances or other substances that may affect human health or the environment, we will
maintain safe and environmentally friendly handling methods, equipment, and environments that are appropriate
for these substances.

2

Protecting personal information and privacy

We will respect the privacy of individuals, including customers, business partners, and Employees and Recognize the importance of
personal information and the need to protect it. To protect personal privacy and information, will take appropriate action in compliance with said internal regulations as well as related laws and regulations, including the regulations of international organizations.

3

Contributing to local communities

As a good corporate citizen, we will respect local cultures and comply with all provisions of this Code of Conduct, relevant laws and regulations, and requirements and regulations agreed upon between countries and by internationalorganizations, as we strive to grow together with local communities.

4

Contributions and political funds

We will make contributions only after careful consideration of the necessity, appropriateness, and scale. We will complywith laws and regulations concerning political activities.

5

Policies on entertainment and gifts(1) We will conduct ourselves according to sound business practices and social norms when we provide or receive
entertainment or gifts with business partners or others.
(2) We will maintain highly transparent relationships with government and government agencies. We will not bribe
politicians or public ofﬁcials (including deemed public ofﬁcials) regardless of whether they are domestic or overseas, and we will not engage in entertainment that is considered to be the provision of beneﬁts or conveniences,the provision of gifts, or the provision of beneﬁts in order to obtain illicit business proﬁts. We will not take any
actions that are considered to be inappropriate or prohibited by laws and regulations.

6

Prohibition of involvement in anti-social activities

We will take determined action against anti-social inﬂuences and groups that threaten public order and safety
and sever all contacts and relations between such entities and the company or Employees throughout our operations. We will not involve ourselves in any acts that would promote the activities of anti-social groups.

7

Whistleblowing

We will notify a superior, corporate ofﬁcer, or other appropriate ofﬁcial if we become aware of any violation or possible violation ofthis Code by a company ofﬁcial. We understand that we can also anonymously report such violations to the Compliance Hotlineand that, in either case, whistleblowers will not be subject to retaliation or be disadvantaged in any way for reporting violations.

II Relations with Customers
Meeting Expectations as a Producer

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Providing products and services customers can count on(1) We will always focus on customer satisfaction, observe all applicable laws and rules, and give full consideration tothe quality and safety of our products and services.
(2) We will not be satisﬁed with the current state of our technology, but will work to further improve efﬁciency, suchas improving its effectiveness and reducing costs, and aim for a higher level of manufacturing.
(3) We will sufﬁciently control the chemicals used in our manufacturing processes and make sure that our products,services, and emissions do not contain objectionable substances.
(4) When procuring raw materials containing conﬂict minerals, we will respect the basic human rights of people
around the world and comply with international agreements. We conﬁrm the appropriateness of the supplierthrough due diligence by a neutral third party as necessary.

2Free competition and fair commercial transactions(1) We will always keep relations with customers, business partners and competitors transparent and fair. In addition,
we will carry out all commercial transactions with integrity by adhering to social ethics.
(2) We will not engage in any conduct that is contrary to fair and free competition, nor will we engage in any illegal
or unfair acts or means, including criminal acts, for the purpose of obtaining an advantageous business positionor economic beneﬁts. We will conduct fair transactions in compliance with relevant laws and regulations, such as
the Antimonopoly Act, and will not engage in bid rigging, cartel formation, or any other activities that may be construed as such.

3Policies on transactions with suppliers of materials and services(1) We will carry out commercial transactions with suppliers of materials and services in a fair and equal manner
while being compliant with applicable laws and contracts. We will not engage in unfair or unjust acts against oursuppliers, such as exclusion, unfair or discriminatory treatment, or restraint of business activities.
(2) We will not allow our suppliers to engage in illegal or ethically unacceptable behavior in any aspect of their operations in order to do business with our company. We will also ask our suppliers to establish and operate a management system that will enable them to maintain the same standards set forth in this Code of Conduct in every
aspect of their operations, and will audit their initiatives as necessary.
(3) We will not seek any personal gain, such as beneﬁts or special conveniences, in connection with performing ourduties.

4Policies on import-export transactions

We will carry out the import and export of products, technology, and services in compliance with all applicable
domestic and international laws, rules, regulations, and internal regulations.

5Policies on publicity and advertising

We will avoid displays and expressions that are not based on facts or that are misleading to customers with respect tothe quality, performance, or speciﬁcations of our products or services in publicity, advertising, and other sales-relatedactivities.

III Relations with Shareholders and Investors
Proper Management of Assets and Information

1Accuracy and timely disclosure of corporate information

We will always ensure the accuracy of our corporate information and will disclose information such as management
policies and business activities to shareholders and investors in accordance with applicable laws, rules, and regulations.

2Management and proper use of company’s assets

We will properly manage our company’s assets, whether tangible or intangible, in accordance with internal regulations and will not use them for private purposes or any other purpose unrelated to the company’s business operations.

3

Prohibition of insider trading

We will not use non-public information obtained from the EM Devices Group or other companies through the execution of our duties or business transactions for the sale or purchase of marketable securities, including the trading ofstocks.

4Handling of confidential information(1) We will strictly manage our company’s conﬁdential information. That is, we will not disclose such information in amanner that violates the procedures stipulated in internal regulations, both during and after employment at thecompany.
(2) We will not use information about customers, suppliers, etc. or information held by them that was obtained
through the execution of our duties for any inappropriate purpose. Moreover, we will strictly manage such information in order to ensure that it is not leaked.
(3) We will not access or obtain conﬁdential information on customers, distributors, suppliers, competitors, etc. or
information held by them by improper means.

5

Protection and utilization of intellectual property rights(1) We will protect and maintain intellectual property rights such as the patents, utility models, design rights, trademarks, and copyrights that are obtained through our R&D or other intellectual activities and will try to actively
utilize them. Any licensing of these rights must be processed in compliance with internal regulations.
(2) We will not use our company’s conﬁdential information improperly or inappropriately for our own beneﬁt, both
before and after employment at the company.
We respect the legitimate intellectual property rights of third parties and do not intentionally infringe or misuse
them. (Translate the original sentence from Japanese, the current sentence is not translated from Japanese)IV Employment

Lasting Satisfaction for Employees(1) As we pursue our economic interests, we will recognize that creating a work environment with a commitment to
HSE (health, safety, and environment) leads to increased labor productivity.
(2) We will comply with local labor-related laws and regulations regarding working age, working hours, etc. We will
make wage calculation and payment procedures transparent and ensure that wages paid as compensation forlabor will not fall below the minimum established level.
(3) We will place no unreasonable limits on the use of company-provided beneﬁts. We will also make certain to inform andeducate Employees about their rights, company obligations, and prohibitions in accordance with relevant laws, regulations, and agreements with the company. In order to maintain these conditions, we will make status assessments as wellas continuous improvements.
(4) In order to ensure employee health as well as prevent ﬁres and disasters, we will clearly indicate, as much as possible, sources of workplace health and safety hazards and incidents as we strive to eliminate or minimize themwhile taking into account potential risks. We will also ensure that the machinery and equipment we use is safeand employ appropriate protective equipment as needed in order to ensure the safety of workers.
(5) We will strive to improve working environment, and assess the physical condition and motivation of each worker,
with an eye to preventing industrial accidents and diseases from occurring. In the unlikely event of an incident,
we will take appropriate action in a timely manner that beﬁts the situation.

V Implementation System
Toward Effective Operations

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Implementation System(1) The Human Resource and General Affairs Department of EM Devices Corporation, which is responsible for the management of this Code, will promote the implementation of the rules in this Code in cooperation with its Group companies
and the related divisions of EM Devices Corporation.
(2) We will conduct awareness raising activities, training, etc. to thoroughly implement the policies stipulated in this Codeacross the company and make appropriate amendments to ensure that they are relevant to the needs of the times andsociety. In addition, we will monitor the implementation of the Code of Conduct from time to time and ensure that,rather than being written in stone, it is applied appropriately and lawfully in areas of compliance, the environment, labor
practices, health and safety, and risk management.
(3) We will develop and implement an ongoing, systematic training program for all Employees, including Ofﬁcers, to ensure thateveryone across the company uses this Code of Conduct as a foundation when making decisions and taking action in their work.
The Human Resource and General Affairs Department will conduct audits of the observance of this Code.
(4) The basic policies concerning the management and application of this Code will be deliberated on by the management conference of EM Devices Corporation and, where necessary, reported to the board of directors of EM Devices Corporation.

2Inquiries

Inquiries related to the provisions in this Code should be directed to the Human Resource and General Affairs Department, EM Devices Corporation.