Preventive Guidelines for Cartels
The subjects of these Guidelines are those persons who engage in the business
operations of the Company, such as the officers and employees, loaned employees,
contract employees, dispatched employees, etc., of the Company, its subsidiary companies
and affiliated companies.

1. Behavioral criteria (Matters to be observed as an individual)
1-1. Prohibition of illegal cartel behavior
Irrespective of whether in writing, orally, by email or otherwise, it shall be prohibitedto exchange with a competitor such information that may constitute a breach of theAntitrust Law in terms of pricing, customers, competitive information, etc. Informationexchanges that may constitute a breach of the Antitrust Law shall include, but are notlimited to, the following:
Information exchange that may be deemed to constitute a breach of the Antitrust
Law-Price information, such as prices, price ranges, price adjustments, pricepredictions and price trends;-Price elements, such as deductions, margins, extra charges and pricecalculation methods;-Matters concerning quantities, such as production capacities, production
volumes, production plans, sales volumes and market share;-Sales information about the terms of transactions with customers and saleschannels;

Bidding conditions and intentions to participate in bids or not.

Definition of competitorsa.

A company that provides the same or similar goods and/or services as those of
the Company to the same user as that of the Company;b.

A company that is provided the same or similar goods and/or services by thesame supplier as that of the Company.
* The definition of competitors may be interpreted broadly, and therefore shallnot be limited to a and b above.

-1-(In the case of the above chart, a seat manufacturer and a bearing
manufacturer are mutually competitors.)
1-2. Prior approval for contact with a competitor
It shall be prohibited, in principle, to contact a competitor irrespective of whether
formally or informally, or at a get-together or by playing golf together. However, provided
that prior approval has been obtained from the relevant responsible person, suchcontact with a competitor shall be allowed.
1-3. Management of the contents of contact with a competitor
A person who has contacted a competitor (including those who obtained priorapproval or had unintended contact with a competitor) shall, after such contact, record
the date and time, place, counterparty, persons present, purpose of contact, informationexchanged, etc., and conduct appropriate management thereof.
1-4. Steps to be taken in case of any problem in contacting a competitor
While contacting a competitor, provided that a topic has been raised in terms of theinformation set out in 1-1 above, after asserting that such discussion should besuspended, a request shall be made to the effect that said assertion should be enteredin the minutes. When the topic continues to be discussed in spite of such assertion, therelevant person shall immediately leave the place of the meeting and report the relevant
fact to the relevant responsible person and the division in charge of legal affairs orcompliance.

-2-1-5. Measures to be taken in case of violation
In the case of a violation of these Guidelines or the laws and regulations of eachcountry, a penalty may be applied based on the internal rules or the relevant laws andregulations. In addition, when having actually identified a violation or recognized an act
suspected of a violation, a prompt report shall be made to the division in charge of legal
affairs or compliance of the relevant company of the Company Group.

2. Matters to be addressed by the Company
2-1. Records management
Each company of the Company Group shall record such information as the contact
history with competitors and endeavor to establish and maintain a system for theappropriate preservation thereof.
2-2. Enlightenment activities
Each company of the Company Group shall provide education and training for theprotection against cartels as may be necessary to improve the understanding of therelated laws and regulations and these Guidelines.

3. Other
3-1. Relationship between these Guidelines and the Regional Guidelines
The guidelines specifically established by a region or each company may not
conflict with these Guidelines and in the event of any inconsistency with the contents ofthese Guidelines, these Guidelines shall prevail.
3-2. Revision of these Guidelines
Revisions of these Guidelines shall be drafted by the General Manager of theGeneral Affairs Department of the Company, and after approval by the Compliance
Officer of the Company, such revisions shall be enacted through a decision by the RiskManagement Officer of the Company.

Established on March 25, 2016

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