Tamron Group
Standards of Business Conduct

Tamron Group Standards of Business Conduct
Overview■Purpose●Tamron Group Standards of Business Conduct (hereinafter the “Standards of Conduct”)
describe the conduct that every member of the Tamron Group must understand andpractice every day in order to implement the Tamron Group Corporate Mission andCorporate Vision.
■Scope of Application of the Standard of Conduct●The Standards of Conduct apply to the officers and employees (including such fixed-term
employees as contract, part-time and temporary employees) of all companies of the
Tamron Group.
●The Standards of Conduct are adopted by a resolution of the Board of Directors of
Tamron. Tamron Group companies resolve to develop the measures necessary to ensurethat the Standards of Conduct are upheld in good faith.
■Points to Remember and Responsibilities in Implementation●Tamron Group companies do not order officers or employees to disregard the Standards ofConduct. In addition, Tamron Group companies ensure that no officer or employee isadversely affected due to complying with the Standards of Conduct.
●We will closely monitor for fraud and/or violations of laws and regulations and/or theStandards of Conduct in the workplace and in business. We will consult with appropriate
superiors or report to or consult with the liaison appointed for each Tamron Group
company concerning facts that are problems or are believed to be problems in light oflaws and regulations and/or the Standards of Conduct. Tamron Group companies willsecure the personal information of and protect the privacy of any person making a reportor consultation and ensure that such reporting is not used to the detriment of such
person.
●The top management of Tamron Group companies should recognize their own roles incomplying with the Standards of Conduct and set an example of compliance. In addition
to setting an example, top management should ensure compliance within their companies
and regularly incorporate opinions from both inside and outside their companies in orderto establish effective internal systems.
●When there is a major infringement of the Standards of Conduct, such as a violation of alaw or regulation, the top management of Tamron Group companies is expected to makeclear to stakeholders their stance on resolving the issue and to take the needed steps todetermine the cause and prevent any recurrence.

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Tamron Group Standards of Business Conduct■Basic Policy●To realize our mission, we remain aware that we are a part of society and give priority toobserving laws and regulations, respecting fair social rules, and conducting businessactivities with high ethical standards.
●We support the United Nations Global Compact.
The United Nations Global Compact
Human Rights
Principle 1: Businesses should support and respect the protection of internationally proclaimed
human rights.
Principle 2: Ensure that business practices are not complicit in human rights abuses.
Labor
Principle 3: Businesses should uphold the freedom of association and the effective recognition of
the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labor;
Principle 5: the effective abolition of child labor; andPrinciple 6: the elimination of discrimination in respect to employment and occupation.
Environment
Principle 7: Businesses should support a precautionary approach to environmental challenges;
Principle 8: undertake initiatives to promote greater environmental responsibility; andPrinciple 9: encourage the development and dispersion of environmentally friendly technologies.
Anti-Corruption
Principle 10: Businesses should work against corruption in all its forms, including but not limited
to extortion and bribery.

１. Resolving Social Issues (Achieving SDGs) ThroughCorporate Activities
Tamron will contribute to the realization of a fulfilling society by focusing on
resolving social issues and creating new value through corporate activities toachieve economic growth and solutions to social issues.
1.1 Resolving Social Issues Through Corporate Activities
1.1.1 We are aware that our business has an impact on society in various ways andendeavor to do everything within our control to help solve the issues facing
society through our business activities.

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Tamron Group Standards of Business Conduct
2．Quality and Product Safety
Tamron impresses and reassures customers by combining creativity, technologicalprowess and consideration for safety and the environment to provide high quality
products that ensure customer confidence.
2.1 Marketing activities
2.1.1 We investigate customer needs, and develop and provide products and services
which will be chosen by customers.
2.1.2 Before providing products and services, we fully research the market and listen
to customer opinions with the aim of increasing customer satisfaction.
2.2 Provision of very unique, high quality products and services
2.2.1 We continue to develop key technologies and refine proprietary technologies toprovide very unique, high quality services.
2.3 Product quality system
2.3.1 We strive to maintain and improve our quality assurance system in order todeliver safe and secure products to our customers.
2.3.2 We comply with laws, regulations, and appropriate quality standards related tothe safety of our products and services. Whenever there is a concern that our
product or service may not meet quality standards, we take immediate steps to
identify the cause of the problem and prevent reoccurrence.
2.3.3 If a problem occurs with the quality of a product or service we provide tocustomers, we provide accurate information related to the product or service
and respond promptly in order to limit any negative impact. Furthermore, we
make every effort to determine the cause of the problem and prevent its
recurrence.
2.4 Information regarding our products and services
2.4.1 We disclose information regarding our products and services as necessary and ina timely manner. We listen sincerely to the suggestions and opinions of ourcustomers and respond in good faith.
2.4.2 We take care to properly describe and label our products and services and toensure that such descriptions and labels are easy for consumers to understand.
2.4.3 With regard to advertising and communication with customers, we use
appropriate and truthful expressions and avoid expressions that could cause
misunderstandings related to the features and qualities of our products.

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Tamron Group Standards of Business Conduct
2.4.4 We ensure that we do not give customers or business partners false information
about the products or services of other companies. We do not act in a mannerthat may discredit other companies. In particular, when making comparisons
between our own products and services and those of other companies, we arecareful not to intentionally damage the reputation of the other companies.

3．Environment
With the understanding that environmental problems are important matterscommon to all mankind, Tamron works to reduce environmental impacts andprotect the environment, contributing to the creation of a sustainable society inharmony with the environment.
3.1 Ensuring that our business activities contribute to the environment
3.1.1 We maintain awareness of global and local environmental issues at all times as
we engage in our day-to-day work, and we constantly work to improve ourenvironmental performance.
3.1.2 We not only meet customer needs, but also meet social expectations bycontributing to the environment, including caring for biodiversity andecosystems and using resources and energy more efficiently. To accomplish thisgoal, we consider environmental factors in every stage of our operations—fromresearch and development, through procurement, production, and sales, to theconsumption, disposal and recycling of our products and services.
3.1.3 We are to adhere to all applicable laws, regulations and customer requirements
regarding prohibition or restriction of specific substances in products andmanufacturing.
3.1.4 We must manage to ensure their safe handling, movement, storage, use,
recycling or reuse and disposal for Chemicals and other materials posing a
hazard to humans or the environment.
3.1.5 We look for opportunities to save water and manage water resources. We
comply with wastewater regulations through indication of characteristics,
monitoring, management and treatment as required prior to discharge anddisposal.

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Tamron Group Standards of Business Conduct
3.2 Communicating about the environment
3.2.1 We stay abreast of the latest developments in environmental regulations ineach country and region of the world, as well as relevant international
standards, and we ascertain the environmental impact of our business
operations. We do these things in order to minimize the impact that ourbusiness has on the environment.
3.2.2 We cooperate and collaborate with a diverse array of stakeholders including
government and specialized agencies, customers, business partners, NGOs,
NPOs, and local residents to ensure that we have a positive impact on the
global environment and the communities where we do business.

4．ComplianceTamron is aware that it exists together with society. We place a priority on
observing laws and regulations while respecting social rules, and carry out our
corporate activities with a high sense of ethics.
4.1 Complying with laws
4.1.1 We conduct business in a reasonable manner, striving to be fair andtransparent in all our dealings and recognizing those we deal with as business
partners.
4.1.2 As part of the Tamron Group, which has a global presence, we endeavor to
fully understand and comply with laws and regulations concerning competition
in all countries in which we operate.
4.1.3 We make sure to obtain business licenses and permits and carry our
registration and other procedures in compliance with business laws governing
the products and services we handle.
4.2 Complying with antitrust and related laws
4.2.1 We take steps to ensure compliance with antitrust laws, competition laws andother laws and ordinances intended to ensure fair competition in each country
where we do business, as well as with related internal guidelines, whilepursuing free and fair transactions.
4.2.2 We implement policies to avoid collusion with competitors to arrange prices orsales/production volume, etc., and do not engage in behavior to limit
competition (including participating in cartels) or in bid-rigging.

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Tamron Group Standards of Business Conduct
4.3 Practicing appropriate socialization
4.3.1 We do not engage in conduct such as offering inappropriate gifts,
entertainment or money to customers or business partners for the purpose ofbuilding or maintaining business relationships. We do not engage in conduct
such as asking business partners for gifts, entertainment or money for our
personal benefit.
4.4 Prohibiting bribery and corruption
4.4.1 We do not provide gifts, entertainment, money or other benefits that could beconsidered bribes to domestic and foreign public or quasi-public officials,
regardless of the means.
4.5 Avoiding any involvement with organized criminal elements
4.5.1 We prohibit involvement with organized criminal elements.
4.5.2 We take a resolute attitude against organized criminal elements, and refuse toentertain any inappropriate and/or illegal request.
4.5.3 We cooperate with relevant organizations working to eliminate organizedcriminal elements.
4.6 Prohibiting insider trading
4.6.1 We do not use internal corporate information or confidential information frombusiness partners for personal gain. We do not engage in illegal activity suchas insider trading, which includes trading in stocks or other investment vehicles
using non-public information regarding publicly listed Tamron Group companies
and/or publicly listed business partners.
4.6.2 We follow the prescribed company procedures when buying or selling shares orother securities of Tamron or other listed Tamron Group companies.
4.7 Managing corporate assets
4.7.1 We appropriately manage and protect tangible and intangible corporate assets
in accordance with the internal regulations and rules of the Tamron Group.
4.8 Protecting intellectual property rights
4.8.1 We recognize that our brands and intellectual property (including patents,
utility model rights, copyrights on registered designs, trademarks, copyrights,
and trade secrets) are important corporate assets and use these in an
appropriate and correct manner according to laws and regulations and therules of the Tamron Group.

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Tamron Group Standards of Business Conduct
4.8.2

We respect the intellectual property rights, such as trademark and patentrights, of third parties and we do not use them without permission. We do notdamage or infringe on these assets.

4.8.3

We recognize that intellectual property laws and regulations differ by country
and pay special attention in each country to the registration, disclosure,transfer, and use of intellectual property.

4.8.4

We endeavor to protect company intellectual property including promptly filing
patent applications for inventions resulting from our manufacturing anddevelopment activities.

4.9

Prohibition of conflicts of interest
4.9.1 We take steps to ensure that the interests of employees, including theirfamilies, and the interests of Tamron Group companies do not conflict. In theworkplace, we are conscious at all times of the fact that we are members of
the Tamron Group, follow corporate rules, and conduct ourselves responsibly.

4.10 Compliance with import and export laws and regulations
4.10.1 In conducting global business activities, we understand and comply with theimport- and export-related laws of each country where we do business.
4.10.2 We do not export products to countries that do not sanction the use or
prohibit the import of such products, nor do we export products from countries
that prohibit the export of such products.
4.11

Security trade control

4.11.1 We do not engage in exports of arms, military equipment or technology which
would pose a threat to the maintenance of international peace and stability.
4.11.2 In all our export transactions, we carry our thorough checks on those we deal
with and their business activities and confirm that exported goods andtechnologies cannot be used in the development or manufacture of weapons.
4.11.3 Taking the international situation into account, we carefully consider whether
or not to engage in transactions involving the export of goods or technologies
services or the rendering of services which are regulated by relevant laws andregulations, and we carry out any necessary procedures in accordance with
relevant laws and regulations.

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Tamron Group Standards of Business Conduct
5．Information disclosure
Tamron strives to enhance its corporate value through active, effective and fair
information disclosure and constructive dialogue with its various stakeholders.
5.1 Properly disclosing information
5.1.1 We implement policies to ensure that no information that should be disclosed
to shareholders and investors is concealed or otherwise improperly withheld.
5.1.2 We take seriously our obligation to proactively disclose information concerning
the environment, and we carry out appropriate environmental communications
to respond to the expectations and trust of our stakeholders.
5.1.3 When disclosing information, we strive not only to disclose the information
stipulated in disclosure-related laws, but also to meet the expectations of ourdiverse stakeholders by disclosing information that is useful to them.

６．Occupational safety and health
Tamron does everything possible to ensure the safety of each employee andmaintain and improve the workplace environment so that everyone can work in asafe and healthy environment.
6.1 Creating safe and comfortable work environments
6.1.1 We seek to understand and comply with all laws and regulations related tosafety and sanitation.
6.1.2 We do everything possible to ensure the safety of each employee and maintainand improve the workplace environment so that everyone can work in a safeand healthy environment. We also make every reasonable effort to prevent
disasters, accidents and incidents, and establish internal systems, including
employee training programs and safe equipment, to respond appropriately andcreate an efficient and comfortable work environment.
6.1.3 We never impose unnecessary work on others, including forcing them to doexcessive work or overtime work.

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Tamron Group Standards of Business Conduct
7．Social contributions
Tamron aims to create a spiritually enriching society by taking part in activities
that contribute to the development of photography and film culture as well as inlocal community activities as a good corporate citizen contributing to local
community development.
7.1 Social contributions
7.1.1 We engage in meaningful and appropriate donations and support activities, asa form of social contribution, seeking to respond to social issues andcommunity.
7.1.2

In conducting donations and support activities, we thoroughly consider theirnecessity and appropriateness and comply with all related laws andregulations.

7.1.3 We continuously strive to understand and respect the cultures, customs andtraditions of local communities, aiming for harmonious co-existence withsociety everywhere we do business.

8．Human resources/human rights
Tamron makes every effort to provide employees with opportunities to develop
and demonstrate their abilities in ways that respect their diversity, character andindividuality. We embrace a global perspective, value teamwork and endeavor tocultivate human resources who harness creativity.
8.1 Human resource development
8.1.1

We as a company work together to analyze all location, subject, andcircumstances to improve our products, services, and operations.

8.2 Human resource development
8.2.1 We support international human rights standards, including the Universal
Declaration of Human Rights, the ILO Declaration on Fundamental Principles
and Rights at Work and its Follow-up, the United Nations Guiding Principles on
Business and Human Rights, and the United Nations Global Compact.
8.2.2 We work to avoid any complicity in the violation of human rights.

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Tamron Group Standards of Business Conduct
8.3 Prohibiting discrimination
8.3.1 We respect the laws and culture of each country and region and prohibit
discrimination against anyone on the basis of race, ethnic group, nationality,
religion, belief, birthplace, gender, age, sexual orientation, disability, or any
other characteristic.
8.3.2 We do not discriminate in hiring or employment.
8.3.3 We continuously strive to understand and respect the cultures, customs andtraditions of local communities, aiming for harmonious co-existence withsociety everywhere we do business.
8.4 Prohibition of political and religious activities
8.4.1 All employees engage in political activity only as individuals taking a personal
stance and not on behalf of or in the name of the company, doing so only
during non-working hours and outside company facility grounds.
8.4.2

We do not solicit religious groups, impose creeds, request donations, or
distribute solicitation brochures during business hours.

8.5 Upholding basic principles and rights related to labor
8.5.1 We respect the basic rights of our employees regarding freedom of associationand collective bargaining.
8.5.2 We prohibit the use of forced or coerced labor in any form.
8.5.3 We understand the harmful effects of child labor and do not use, in any form,
labor by persons who have not reached the minimum age for employment.
8.6 Prohibiting harassment
8.6.1 We prohibit sexual harassment in the workplace, including any kind of
sexually suggestive language or behavior.
8.6.2 We prohibit the exploitation of a job position to abuse the human rights ofothers in the workplace.
8.6.3 We prohibit all forms of harrassment.

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Tamron Group Standards of Business Conduct
9．Information management
Tamron establishes protection from threats such as information asset incidents
and crimes, and lives up to the trust placed in it by customers and society.
9.1 Appropriate use of information systems
9.1.1 We use the company information system for business purposes only and not for
personal purposes.
9.1.2 We strictly manage IDs and passwords related to information systems andprevent them from being leaked outside the company.
9.2 Management of trade secrets
9.2.1 We never engage in conduct by which confidential information about ourcompany or competitors is acquired in an illegal manner.
9.2.2 We understand the importance of confidential information, including that
related to business, technology, research, product development, sales, financeand personnel related information, and rigorously and confidentially manage
this information. In addition, we do not use internal information for any nonbusiness purpose, whether or not the information is confidential.
9.2.3 After retirement, we will not leak confidential information about the company
or confidential information obtained from outside the company or use it for any
purpose.
9.3 Protecting personal information
9.3.1 We recognize the importance of protecting personal information and obtain,
use and provide personal information in an appropriate manner. We rigorously
control the handling of personal information in order to prevent it from being
used for anything other than its original purpose and to prevent information
leaks. We do not disclose personal information obtained in the workplace orbusiness operations to others without the consent of the individual, unlessrequired by law.
9.3.2 We respect one anotherʼs privacy.

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Tamron Group Standards of Business Conduct
10．CSR procurement
Tamron engages in sound trade practices, and works with its business partners
to promote procurement activities that consider social responsibility including
human rights, labor standards and the environment.
10.1 Ensuring fair purchasing transactions
10.1.1 We do not engage in conduct that results in any disadvantage to our business
partners by abusing our dominant position in purchasing transactions.
10.1.2 We respect free and fair competition at all times in purchasing transactions. We
provide fair business opportunities and select our business partners based on
general and just evaluations of price, quality, service, and other factors.
10.2 Sustainable procurement
10.2.1 We take steps to raise environmental awareness within our company as well as
in the broader society while pursuing environmental initiatives in all of ourbusiness activities—from procurement of raw materials to provision of products
and services to customers.
10.2.2 In purchasing transactions, we procure sustainable materials wheneverpossible.
10.3 Responsible procurement
10.3.1 We make clear to our business partners what we expect with regard to humanrights, labor, the environment, anti-corruption, and other matters. We
collaborate with them to ensure that these policies are put into practice.

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Tamron Group Standards of Business Conduct
11．Risk (crisis management)
Tamron prepares against risks that could threaten civic life or corporate
activities, and does the utmost to prevent such risks from occurring. Should any
such crisis occur, we will make every effort to minimize damage and loss, effecta swift recovery, prevent recurrences and fulfill our social responsibility.
11.1 Preventive activities
11.1.1 We identify and assess potential emergency situations and events. We
endeavor to minimize their impact by implementing emergency plans andresponse procedures including but not limited to: emergency reporting,
employee notification and evacuation procedures, worker training and drills,
appropriate fire detection and suppression equipment, clear and unobstructed
egress, adequate exit facilities and recovery plans.

12．Corporate governanceTop management works to build up sustainable corporate value by establishinggovernance to engage in fair, transparent and swift decision making in response
to a changing business environment. In addition, top management will makethe Tamron Group aware of the corporate mission system.
12.1 Sound management
12.1.1 We aim to realize our corporate mission by building a well-organizedorganizational structure so that we can take responsibility for all stakeholders.
12.1.2 We make every effort to employ sound management practices, to provide
appropriate returns to shareholders, and to increase corporate value.
12.1.3 We maintain, operate and evaluate effective and appropriate internal control
systems for financial reporting in accordance with Financial Instruments andExchange Act and other laws to ensure the credibility and accuracy of financial
reports.

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