ROHM GROUP

BUSINESSCONDUCTGUIDELINESPlease note that this is English translation of the original Japanese version. Should
the words and/or contents differ from the original Japanese version, or conflict withlaws and/or customs of your country, please feel free to contact ROHM Co., Ltd.
Compliance Committee.

To the People of ROHM

October 2022

The ROHM Group strives to solve social issues through electronics, and based on
the Company Mission, Basic Management Policy, Basic Quality Assurance Policy,
Basic Goals for Education and Training, and Basic Policy for Education and Training,
the ROHM Group works on contributing to society through our business activities.
In order to continue to make such an effort, it is necessary for each employee of
the ROHM Group to continue to be trusted by stakeholders, including customers,
business partners, and local communities. With that in mind, we established theBusiness Conduct Guidelines (“BCG”) in 1999 that serve as the specific guidelines
of conduct for all employees .
In order to respond to social demands, BCG outlines the basic guidelines
for employees to understand and comply with laws and regulations and the BCG
provides guidelines for compliance with business ethics. BCG plays an importantrole in ROHM Group’s legal and ethical responsibilities. BCG will be updated
from time to time to align with changing societal demands, updated laws andregulations, and business ethics.
Nowadays the business environment in the electronics industry is constantly
changing. It is important for all ROHM Group employees to make an effort to breakthe mold and continually take on challenges to find a way to meet these demands.
The Company Mission is our founding spirit, and we need to steadily inherit theseprinciples and take actions that are in line with what we should be.
In order to maintain the trust that the ROHM Group has established, I
expect each employee of the ROHM Group to fully understand BCG and use it
as a guideline in our daily work. I further expect that all ROHM Group people, byusing the highest standards of ethics and lawful spirit, will build strong trusted
relationships with stakeholders and play a key role in our future success.
Sincerely Yours,

ROHM Co., Ltd.
President, CEO
Isao Matsumoto

CONTENTS
To the People of ROHM
Company Mission, Basic Policy and Basic Goal • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 1
ROHM Group Sustainability Policy• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 3
The Concept of the Guidelines• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 4
ROHM Group Business Conduct Guidelines• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 5
Chapter1 OUR BASIC OBLIGATIONS • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 6
1-1 Compliance with Laws, Business Ethics and In-house Rules, and Respect for •International Standards • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 6
Chapter 2 RELATIONS BETWEEN THE COMPANY AND SOCIETIES• • • • • • • • • • • • • • • • • • • • 8
2-1. Preservation of the Global Environment• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 8
2-2. Disclosure and Publicities• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 9
2-3. Social and Cultural Activities • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 10
Chapter 3 OUR BUSINESS ACTIVITIES • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 11
3-1. Research and Development •• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 11
3-2. Production • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 13
3-3. Sales • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 14
3-4. Procurement • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 15
3-5. Brand and Public Relations (PR)•• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 17
3-6. Safety of Our Products• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 18
3-7. Management of Confidential and Individual Information • • • • • • • • • • • • • • • • • • • • • • • • 19
Chapter 4 RESPECT FOR HUMAN RIGHTS AND DEVELOPMENT OF HUMANRESOURCES •• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 21
4-1. Respect for Humanity and Personality • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 21
4-2. Development of Human Resources and Company •• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 23

Company Mission, Basic Policy and Basic Goal

COMPANY MISSION
Quality is our top priority at all times. Our objective is tocontribute to the advancement and progress of culture
through a consistent supply, under all circumstances, of highquality products in large volumes to the global market.

BASIC MANAGEMENT POLICY
Secure reasonable profit through a concerted company-wide effort for
a comprehensive quality assurance program.
Develop globally leading products by improving upon technologies
held by each department for continued advancement of thecompany.
Maintain healthy and vigorous lifestyles and refine intellect andhumanitarianism, hence contributing to society.
Search extensively for capable human resources and cultivate themas cornerstones for building long-term prosperity.

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BASIC QUALITY ASSURANCE POLICY
1. Promote internal standardization for the whole company andestablish structures for QC management by data.
2. Conduct comprehensive and continuous research for thedevelopment of new technologies and products.
3. Proactively utilize methods of statistical control for all areas ofcompany activities.
4. Establish quality assurance structures for all manufacturing processes.
5. Exert effort for cost reductions of each product by continualmodernization of manufacturing systems.
6. Secure quality assurance programs of raw materials andcomponents with our suppliers through contracts.

BASIC GOALS FOR EDUCATION AND TRAINING
1. Develop personnel at all levels to constantly strive to obtain new
knowledge and to acquire empirical reasoning ability from a
broad perspective.
2. Train staff to be dedicated as leaders in their field by utilizing theirknowledge and experience.
3. Develop personnel who can overcome any adversity and strive
towards achieving targets.
4. Train staff to place the highest value on teamwork, resulting fromthe combined efforts of all individuals.

BASIC POLICY FOR EDUCATION AND TRAINING
1. All employees will use every available opportunity to enhanceself-development.
2. Those in leadership positions will exemplify model behavior at all times.
3. The emphasis of education is on-the-job training led by thesupervisors through daily operations. Supplementary training off
the job is also provided.
4. Each head of all management levels will appraise staff fairly andconduct effective training programs periodically and consistently.
5. Appraisals for each head of all management levels is based, as a
general rule, on the success of staff education and training.
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ROHM Group Sustainability Policy
We will conduct sincere, fair, and transparent business activities from a global perspectivein accordance with objectives and policies such as Company Mission and basic Policy,
and work to achieve the Sustainable Development Goals (SDGs*) to contribute to
the sustainable development of society. In addition, we will build good relationships
through communication with all stakeholders as follows, gain trust from society, andachieve continued growth of our company.

Customers
ROHM seeks to obtain customer satisfaction and confidence by continuing to supplyof high quality products and services in a timely and appropriate manner. ROHM is also
open to customer feedback and suggestions, and will evaluate them internally. ROHM
places the highest priority on the safety of its products and strives to disclose relevant
information as necessary.

Business Partners
ROHM selects its business partners according to equitable and rational criteria.
ROHM values the relationship with its business partners and conducts equal and fairtransactions for mutual prosperity.

Employees
ROHM strives to ensure a safe and pleasant working environment, respect human values
and individuality, and create a fair and appropriate workplace where each employee may
demonstrate individual initiative.

Shareholders and Investors
ROHM seeks to continuously improve corporate value and secure appropriate profits
in order to provide a steady return to both shareholders and investors. ROHM offers
financial information in order to keep shareholders and investors actively informed.

Local Societies and Communities
ROHM aims to deepen exchanges with each country and local community, respect theircultures and customs, and create relationships that can develop together with society
and local communities. In addition, ROHM will carry out social contribution activities,
cultural and artistic activities, etc., support activities, and actively engage in global
environmental conservation activities through our business activities.
*SDGs: SDGs is the abbreviation for Sustainable Development Goals, set up by United Nations, indicating the 17 goals and
169 targets the world is to achieve by 2030.
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The Concept of the Guidelines
Societal demands andinternational standards

Stakeholders
Clients

Company
mission

UNGC
10 principles

Basic management policy
Basic quality assurance policy
Basic goals for education and training
Basic policy for education and training

RBA code of
conduct

Industrial
association

Government
and local
community

Local societies
and regions

Employees

Shareholders
and investors

Customers

Business
partners

Students

Familiesofemployees

Dia

log

ue

Business conduct Various policies*
guidelines

ISO26000

nds
ma
De

Responsible
procurement* Various Policies mean a basic policy in order to achieve the Company Mission and acquire customer satisfaction(ex.ROHM Group Sustainability policy).

Since its foundation, the ROHM Group continues sustainable development and has
contributed to sound development of society by building relations of mutual trustwith its stakeholders guided by our company policies, such as Company Mission, BasicManagement Policy.
Various Policies including ROHM Group Sustainability policy are established inorder to define our Business Continuity concepts and to guide our business activities
conscientiously from a global perspective and thereby contribute to sustainable
progress of society based on Company Mission and Basic Management Policy. ROHM
Group Business Conduct Guidelines are established as the basic ethical rules each
employee of the ROHM Group must observe.
Company Mission and Basic Management Policy remain unchanging, but Various
Policies and ROHM Group Business Conduct Guidelines will be updated in line withchanging societal demands and the latest standards, such as the United Nations Global
Compact (UNGC), ISO26000, and Responsible Business Alliance (RBA) Code of Conduct,
so that we may better meet stakeholder expectations.

United Nations Global Compact (UNGC):An international initiative whereby companies and other organizations cooperate topursue the sustainable growth of society. In May 2011, ROHM signed the UNGC.

ISO26000:
A guidance standard concerning social responsibility (SR) published by the International
Organization for Standardization (ISO). Considered a guide for all types of organizations
to fulﬁll their SR.

Responsible Business Alliance (RBA):
A code formulated by an organization composed mainly of electronics manufacturers
and additionally of automotive, toy, aircraft and IoT technology companies. The code iscomposed of standards related to Labor, Health and Safety, the Environment, Ethics anda management system for these areas.
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ROHM Group Business Conduct Guidelines
1. Purpose of Establishment
These Business Conduct Guidelines aim to maintain and improve society’s trust
toward the business activities of the ROHM Group, by manifesting the ethical ruleswith which directors, officers and employees of the ROHM Group should comply
when practicing company polices such as Company Mission and Basic Management
Policy.

2. Scope of the Guidelines
These Business Conduct Guidelines are applicable to any and all directors, officers
and employees of the ROHM Group. For overseas subsidiaries, however, necessarychanges should be made to the Guidelines in accordance with the law, rules, customs
and business structure of each country and district. The concept and policy of theseBusiness Conduct Guidelines must be maintained despite any changes.

3. To the Directors, Officers, and Employees
Every director, officer and employee is accountable not only to the company policiesof the ROHM Group (Such as Company Mission and Basic Management Policy), butalso accountable to the laws and the rules of society.
Directors, officers, and employees of the ROHM Group are expected to abide bythese Business Conduct Guidelines with the following attitude:(1) Maintain a responsible and proactive attitude(2) Maintain dignity as a member of society with sincerity, integrity and courage(3) Maintain a basic understanding of respect for other people’s honor, dignity andopinion(4) Extend gratitude toward customers, business partners, shareholders, investors,
local societies and communities

4. Internal Disciplines
IIn case any of the directors, officers, or employees violates these Business Conduct
Guidelines, disciplinary action may be taken based on the company’s disciplinary
procedure, which is described in the “Working Regulation” and other human resource
management rules of each ROHM Group company.

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Chapter 1 OUR BASIC OBLIGATIONS
1-1. Compliance with Laws, Business Ethics and In-house Rules,
and Respect for International Standards
We conduct our business observing the laws, business ethics and in-house rules
in order to continue to gain the trust of various stakeholders as a company incompliance with the laws.
We also respect the United Nations Global Compact (UNGC), ISO26000,
Responsible Business Alliance (RBA) Code of Conduct and other international
standards of behavior.

1-1-1. Fair Action
We act with virtue and fairness based on good social sense. We are fully conscious of
our social responsibility, that the company is a public entity of society, and with theawareness that we as individuals represent the company.

1-1-2. Compliance with Laws and Business Ethics
We always conduct our business faithfully in strict compliance with the laws andbusiness ethics. We continually work to collect, manage and understand the laws
and regulations of each country that are relevant to our business.
We will also introduce and organize in-house rules corresponding to relevantlaws and regulations.

1-1-3. Elimination of Unreasonable Demands
We will show fortitude against anti-social powers and/or groups and will not bow to
unreasonable demands.

1-1-4. Correction, Prevention of Recurrence and Strict Action against Law
Violation
In the event where we suspect that our business activity may be in violation of thelaw or of any business ethics, we will report this to each superior or to the appropriate
related division (e.g. compliance hotline). Moreover, in case the violation or possible
violation of the law is discovered, we will promptly correct the condition, plan for theprevention of recurrence (or occurrence) and deal strictly with the act of violation.
Accordingly, we will not tolerate any negative treatment against any person orgroup who reports possible illegal activity, violation of the law and/or of business ethics.

BUSINESS CONDUCT GUIDELINES6

1-1-5. Prevention of Bribery and Corruptions
We understand and agree with the importance and necessity of preventing
corruption, as dictated by international agreements and standards, such as theUnited Nations Global Compact (UNGC), ISO26000, or Responsible Business Alliance(RBA) Code of Conduct, etc.
As result, we do not engage in any form of bribery or action, which may beotherwise deemed as bribery or invite suspicion, to any country’s governmental
agency, to members in official positions, nor to politicians for the purpose of gaining
improper benefit or advantage. Any corruption, extortion, and/or embezzlement arealso strictly prohibited.

1-1-6. Prohibition of Providing or Receiving Excessive Entertainments
We observe the company policies and regulations and do not provide gifts, meals orother channels of financial advantage to our customers or other business associates
beyond the bounds of what is socially acceptable.
Furthermore, we are most cautious with any offer of entertainment or gifts fromour suppliers and will not accept anything which may result in personal profit.

1-1-7. Maintenance of Company’s Assets
We effectively use and maintain the company’s tangible and intangible assets.
We do not commit any acts, illegal or personal, that may otherwise damage ordiminish the value of our assets.

1-1-8. Prohibition of Conflicts of Interest
We will not commit any act that may bring conflicting interests between thecompany and individuals.

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Chapter 2 RELATIONS BETWEEN THE COMPANY

AND SOCIETIES

2-1. Preservation of the Global Environment
We recognize that the materials, energy and other resources that are necessary forour production activities are greatly blessed with various gifts from the Earth andits biodiversity.
With this thought, at all of our business locations, we strive for the conservationof biodiversity and conduct environmental activities in harmony with natural
surroundings, to ensure a better environment for the next generation.

2-1-1. Preservation of the Global Environment
In order to preserve the global environment and contribute to achieve a sustainable
society, we develop our business activities, products and services based on a series ofinternational environmental management standards (ISO14000).
We also openly disclose information regarding our environmental activities andmaintain open communications. Should any environmental problem occur, we willtake appropriate action to minimize any impact on the environment.

2-1-2. Pursuit of Cyclical Operation
We aim to avoid waste of limited resources and energy, and try to reduce and recycle
waste in our business activities such as procurement of materials, development,
production, and sales.
We also aim to have factories and offices environmentally friendly andcomfortable for people working there, and make energy-saving efforts.

2-1-3. Development of Environmental Friendly Technologies
We strive to develop helpful technologies, such as energy-saving technologies,that aid in the preservation of the global environment. We also make use of thesetechnologies in our products, process and facilities.
Furthermore, we appropriately control chemical substances used in our
production processes as defined by laws and regulations and cease or reduce the useof hazardous substances.

2-1-4. Duty as One Citizen
We attempt to preserve the global environment not only in our business activities but
also in our private life as citizens of society.

BUSINESS CONDUCT GUIDELINES8

2-2. Disclosure and Publicities
We strive to disclose timely, appropriate, effective, and extensive information
regarding the business operations of the ROHM Group to our stakeholders.
Additionally, we collect information from the public and take input and opinions
seriously in order to gain public trust as a “transparent company”.

2-2-1. Disclosure of Information
We disclose timely, fairly and actively our corporate information in accordance withboth legal requirements and our company policies.
This includes relevant information on corporate principles, management policies,
business activities and social contributions of the ROHM Group to our stakeholders.

2-2-2. Dialogue with Society by Public Relations
We aim to enhance transparency in management and obtain trust from the public byproperly informing the ideas and substance of the management of the ROHM Group.
At the same time, we take the opinions from the public seriously, and incorporate
the feedback into our business activities to enhance our corporate value.

2-2-3. Accurate and Truthful Records and Reports
We appropriately record and report information based on fair and valid accounting
principles and facts. Accordingly, we pay tax obligations in compliance with theapplicable tax laws.
We aim to pay attention to the interests of all stakeholders and hold in highesteem the other party’s position. Our aim is to establish and foster a relationship ofmutual trust through the disclosure of information.

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92-3. Social and Cultural Activities
We contribute to community through our business. Moreover, as good corporate
citizens of society, we actively conduct community-related and cultural activities, aswell as lend support to those activities, in order to help the development of a civilized
and sound society.

2-3-1. Harmony with the Local Community
We aim to contribute to social development and soundness as good corporate
citizens by harmonizing with the local community.
Moreover, we actively participate in --and support volunteer activities--, building
close relationships with the local community, in turn, activating the community andcreating a better social environment.

2-3-2. Cultural Activities and Support
We contribute to the promotion and progress of art and science through our culturalactivities and support for such activities.
We also support cultural activities through support of public institutions, such as
foundations.

2-3-3. Contribution and Sponsorship
In responding to the community as well as social needs, we support contribution andsponsorship of solving social issues, social development, progress, and improvementof culture.

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10Chapter 3 OUR BUSINESS ACTIVITIES
3-1. Research and Development
Always considering quality as our top priority, we will manufacture world competitive
products by making a greater effort toward creative invention, discovery, andimprovements, and through our manufacturing activities, we aim to contributeto the advancement and progress of our culture as well as the enhancement ofcorporate value.
Furthermore, we promote dialogue with our stakeholders, and strive to develop
new products, which reduce and resolve various societal challenges, including
environmental issues.

3-1-1. Research and Development of World-Leading Products
We always maintain the standpoint of our customers, make every effort to grasp theirneeds, and strive to provide them with solutions. We endeavor to develop worldleading products, and aim to make our new technologies the industry standard.
In addition, we make every effort that these products can achieve customer
satisfaction, and that the goods incorporating our products can be environmentallyfriendly and help contribute to the further development of mankind.

3-1-2. Improvement of Technology and Respect for Intellectual Property
We strive to improve our own technology in every division. We establish andaccumulate the results of our development as our intellectual property, and utilize
these effectively in growing our business.
We hold great value for intellectual property rights. As such, we will not use third
parties’ rights without their permission, nor abuse our own rights.

3-1-3. Global Promotion of Development
We establish development facilities at the best location from a global perspective.
Moreover, we efficiently solve any problems we face in the course of our development
activities in cooperation with these facilities all over the world.

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3-1-4. Promotion of Fair Research and Development Activities andAppropriate Management of Public Research Expenditures
We will comply with research ethics and will not engage in fraudulent activities in
research and development activities such as forgery, falsification, theft, or any otheracts that violate laws and regulations in research and development activities. We
also recognize that many of the public research expenditures are funded by valuable
taxes and that their improper use is an act that significantly impairs the trust ofsociety. When receiving public research expenditures, we will conduct appropriate
management in compliance with laws and regulations, internal rules, the terms ofreceipt of each public research expenditure, and their contract provisions.

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3-2. Production
We strive for production activity according to our Company Mission: To keep quality
as our top priority, to manufacture products efficiently, to supply sufficient volume atfair prices and contribute to society through quality manufacturing.
We also aim to select the best location for our manufacturing facilities based ona global perspective.

3-2-1. Production Activities Keeping Quality as Top Priority
Throughout every process, to ensure product quality we establish strict standards
and procedures and perform production activities in accordance with the establishedstandards and procedures.
We will never be satisfied by the status quo. We will strive to continuously
achieve increased competitive and efficient production and reduce costs while
maintaining our policy of “Quality is our top priority at all times.”

3-2-2. Production for Customers’ Trust and Expectation
We always strive to consider our customers’ point of view and produce products
following changes in customers’ needs.
Therefore, we strive to achieve customers’ satisfaction in quality, performance,
safety, and price.

3-2-3. Business Continuity Management (BCM) System
In order to meet supply obligations to our customers, we globally establish andmaintain our Business Continuity Management (BCM) system, so that under any
difficulty in supplying our products due to natural disasters or any other reason, we
can continue our business and, if it is disrupted, we can strive to get the business backto normal as fast as possible.

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3-3. Sales
We aim to obtain satisfaction and trust of customers at all times by providing
excellent products and appropriate services.
Our intent is to contribute to society through fair and free competition.
Accordingly, we perform fair sales activities based on a solid social sense and decency
toward our customers.

3-3-1. Customer Oriented Sales Activities and Network Building
We strive to understand our customers’ needs and demands as well as the market
trends precisely and to actively propose our high-value-added products andservices accordingly. To accomplish this, we will make every effort to acquire
broad knowledge -- not only of our products and services, but also of the market,
to inform customers of the function and performance of those products, and to
pursue the development of those products and services that better serve ourcustomers. We also establish global sales and distribution networks in order tosupply the products effectively.
Through all of these activities, we aim to contribute to reducing and resolving
various societal challenges.

3-3-2. Customer Satisfaction and Trust
We seek to obtain customer satisfaction and confidence by continuing to supply
our high-quality products and services in a timely and appropriate manner. We
also strive to interact with customers with solid social sense and decorum, and tohave customers understand the view of the ROHM Group while paying attention tocustomers’ opinions and providing feedback internally.

3-3-3. Implementation of Fair Sales Activities
In line with the globalization of business, we value free-market competition andpractice fair sales activities. We pursue neither sales nor profit unless we comply withthe law, social ethics, and contractual obligations. We will not violate any law, social
ethics or contractual obligations nor engage in any unlawful or unethical conduct,such as anticompetitive behavior (cartel), collusive bidding, fictitious transactions,
restraining of selling prices, etc.
Moreover, we comply with import/export laws and regulations in order tocontribute to a peaceful and safe international community.

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3-4. Procurement
Our business relies on the cooperation and support of those engaged in various roles/
fields. This includes the supply of necessary materials, components and equipment.
Upon procurement of necessary materials, components and equipment or
subcontracting our work, we appreciate a mutual trust with our suppliers fromvarious countries, and strive to prosper together.

3-4-1. Equal and Fair Dealings
We will conduct procurement activities for suppliers with fairness, equal footing, andmodesty during purchasing material, component and equipment etc. and getting
any type of service. We will never enforce unfair trading with a superior position.

3-4-2. Fair Selection of Suppliers
We will globally and broadly open a trade opportunity to realize an equal business
opportunity. During the processing of suppliers’ selection, we will consider
many aspects including quality, technology, delivery, and price. Additionally,
we will consider factors like enthusiasm, management, ethics, human rights,
risk management, environment protect, health and safety, removal of anti-social
forces etc.

3-4-3. CSR Procurement
We will make an effort to penetrate CSR procurement with mutual understanding
between suppliers and ROHM in order to promote CSR procurement based on ROHM
Group Supply Chain Management Guidelines. We will also make an effort to secureenvironmentally friendly procurement based on Green Procurement Guidelines.

3-4-4. Responsible Minerals Procurement
We strive for the protection of human rights, as such, we will make an effort not to use
conflict minerals that benefit armed groups in designated regions whose activities
are linked to human rights violations as raw materials. Further, we will disseminate
the ROHM Group’s policy to suppliers and request them to promote actions so thatthey can observe such policy.

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3-4-5. Promotion of Human Rights Due DiligenceWe purchase materials, semi-products, and equipment and outsource operations
from our business partners who comply with the human rights laws and regulationsof each country. In addition, we will periodically check the status of compliance withlaws and regulations with our business partners and request compliance with thelaws and regulations as necessary.

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3-5. Brand and Public Relations (PR)We understand the management policy, and throughout each employee’s actions
and business activities, we aim to build a brand trusted and needed by every
stakeholder. Through our public relations (PR) activities, by internally and externallypublicizing our technology, products, and other corporate activities, we will enhance
the publicity and value of our corporate brand (ROHM).

3-5-1. Value of the Corporate Brand
The Corporate Brand represents the existence of our company and is an importantbusiness resource that can provide trust to stakeholders. We comprehend andpractice the philosophy of the management policy and aim to enhance the valueof the corporate brand.

3-5-2. Fair and Appropriate Content
We release fair and appropriate content in our public relations activities based on
accurate, fact-based information in accordance with applicable laws and regulations.
We observe public order and morality and do not express anything unjust which
may lead to falsehood, slander, social discrimination, infringement of human rights,
and so on.

3-5-3. Enhancement of Trust and Name Recognition
We aim to enhance trust in our technology, products, and brand recognition throughour public relations efforts and activities and improve the corporate brand value.

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3-6. Safety of Our Products
We strive to secure the safety of our products in all aspects of our business activities.
One of our top priorities is the security and safety of our customers (including theend users) who use our products.

3-6-1. Safety of Our Products
We strive to conduct our development, production, and sales activities with full
attention to quality and safety as our top priority in accordance with the legal
requirements, contract terms of our customers, and our internal rules and standards.
We strive to secure high functioning, high performance and reliability while
assuring no product liability issue can arise.

3-6-2. Provision of Correct and User Friendly Information
In order to prevent misuse, improper use and accidents, we provide our customers
with “information about safety” including usage environment and usage patterns
using comprehensible displays and explanations.

3-6-3. Our Action when an Accident Occurs
If we receive information concerning the safety of our products, we will immediately
conduct an investigation to uncover the facts.
In the event we discover problems in the safety of our products, we will faithfully
and promptly investigate the root cause and will act to prevent the expansion andrecurrence of the problem.

BUSINESS CONDUCT GUIDELINES18

3-7. Management of Confidential and Individual Information
We appropriately protect and thoroughly manage information including confidential
information of the ROHM Group stakeholders, privacy information, and personal
information of stakeholders as an important foundation for conducting our global
business activities.

3-7-1. Appropriate Information Management
We hold the appropriate management of information in line with international standards(ISO27001). These include confidential information as well as management data.
We acquire information by lawful means and handle it with necessary care, toprevent leakage, and/or illegal use of the information.

3-7-2. Management of Confidential Information of the Other Party
We thoroughly consider the necessity of obtaining the other party’s confidential
information and will not receive third party confidential information beyond thenecessary extent. We also strictly protect and establish safeguards designed toprevent any leakages ofsuch confidential information.

3-7-3. Prohibition of Insider Trading
We will never engage in insider trading, using unannounced or confidential
information obtained through our business dealings. We will never convey suchinformation to others within or outside the company, including to our immediatefamilies, relatives and/or friends.

3-7-4. Handling of Individual Information
We consider the importance of individual information acquired throughout ourbusiness, and will acquire, record, use, and discard it with the appropriate method sothat there will be no loss, falsification, or leakages.

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3-7-5. Correspondence to the Information Security
We strive to transmit and receive appropriate information effectively and efficiently
via the system of information networks. When using the information network system,
we pay close attention to potential plagiarism and/or falsification of information by
third parties, as well as the leakage of information. By doing so, we make efforts toprevent any damage to the third parties. Further, we recognize that cyber-attacks
are threats that may significantly affect our business activities and we make efforts
to ensure cyber security in ensuring business continuity and preventing loss of trust.

3-7-6. Private Use of Social Media
When we use social media privately as an individual, we do so with moral integrity
and in compliance with the law and in-house rules. Through the use of social media
or other exchange, we will not send any confidential information or individual
information obtained via our business.

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Chapter 4 RESPECT FOR HUMAN RIGHTS AND

DEVELOPMENT OF HUMAN RESOURSES/CAPITAL

4-1. Respect for Humanity and Personality
We respect the individuality and personality of each employee and ensure sound andstable lives of our employees.
In addition, we comply with international standards of conduct, related laws, andthe regulations of each country and region. Further, we understand the diversity ofcultures, customs, and other values of each country and region. We work to create
an ideal and comfortable work environment as well as preserve and promote ourphysical and mental health.

4-1-1. Maintenance and Improvement of Labor Conditions
We value the individuality of each and every employee. We aim to build diversified
systems to handle personnel and employment as well as improve working conditions,in order for employees to feel affluent and comfortable.

4-1-2. Safe and Comfortable Office Environment
We strive to prevent work-related accidents by implementing managerial measures
based on the identification of hazard sources in our workplace and their severity.
We also comply with relevant laws and regulations, and in line with international
standards (ISO 45001), make every effort to maintain occupational health and safety
management programs.
If any accident occurs in the workplace, we will promptly take appropriate
measures, and strive to prevent the expansion and recurrence.

4-1-3. Realization of Work-Life Balance
We realize that there are diverse working styles. We support work-life balance andstrive to maximize possibilities in promoting job satisfaction.

4-1-4. Respect of Privacy
We respect the privacy of individuals. We pay close attention when dealing withpersonal data and ensure the appropriate management of it.

4-1-5. Respect of Human Rights and Prohibition of Discrimination
We respect human rights and other rights of everyone. We do not allow discriminatory
words, behavior or treatment.
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4-1-6 Understanding of Diversity
We respect the diversity of cultures, customs and other values of each country andregion.

4-1-7. Maintenance of Good Human Relations
We will not tolerate or overlook any harassment, including unacceptable behaviors andpractices, or threats that result in physical, psychological, sexual, or economic harm.
We also will maintain good human relations and strive to make ourworkplace fair.

4-1-8. Prohibition of Child Labor and Forced Labor
We comply with labor laws and regulations related to employment, wage, and otherlabor conditions. We will prohibit labor of children and will not engage employees
under the age of eighteen (18) in jobs that may endanger their health and safety. We
understand that all work will be voluntary, and will not allow any forced or unfair labor
unwanted by employees.

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4-2. Development of Human Resources and Company
We always strive to acquire new knowledge and become a leader in the field.
We aspire to becoming a company sharing its spirit with employees andconducting its business in close cooperation of every level of employees. We
encourage mutual development of the company and its employees.

4-2-1. Development of Human Resources
We consider the development of human resources as a foundation for permanent
prosperity of our company. Any person in the position of leadership will serve asa model of good behavior and positive attitude. He/She will make every effort toencourage colleagues, toward professional growth as employees and positive
growth as individuals of society.
Accordingly, we continue to seek capable human resources and look for means
to foster their humanitarianism, intellect, broad knowledge, deep insight, specialty
and an international sense.

4-2-2. Self-Development
We always behave with decency, perform our responsibilities with the utmost
integrity, continuously work to develop ourselves, and strive for self-improvement
through every opportunity.

4-2-3. Prevention of Increased Risks
We assume and analyze every risk in our business activities and strive to prevent theirincrease on a daily basis.

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ROHM Group Business Conduct Guidelines
Japanese Original

The First Edition: January 1, 1999
The Second Edition: April 1, 2006
The Third Edition: April 1, 2010
The Fourth Edition: October 1, 2013
The Fifth Edition: October 1, 2022

English Translation

The First Edition: April 1, 2007
The Second Edition: April 1, 2010
The Third Edition: October 1, 2013
The Forth Edition: October 1, 2022

Edit: Legal & Intellectual Property Division ROHM Co., Ltd.
Copyright © 2022 ROHM Co., Ltd. All rights reserved.