Asahi Kasei Group Code of Conduct

Asahi Kasei Group Code of Conduct
Overview of the Asahi Kasei Group Code of Conduct
The Asahi Kasei Group Code of Conduct consists of three parts.

1. Ensuring safety, environmental protection, and high quality
products and services to contribute to life and living

Part 1 concerns ensuring all aspects of safety in our business activities, and how
we should meet society’s expectations and requirements for safety, theenvironment, and quality [sections (1)–(4)]2. Maintaining sincere relationships with those around us

Part 2 concerns building and maintaining sincere relationships with various
related parties such as the general public, customers, shareholders, investors,
suppliers, competitors, and employees [sections (5)–(10)]

3. Utilizing management assets appropriately and effectively

Part 3 concerns the proper management and effective use of all management
assets [sections (11)–(15)]Format of the Asahi Kasei Group Code of Conduct
Each section of the Asahi Kasei Group Code of Conduct applies to all officers, managers,
and employees of the Asahi Kasei Group.
➢

The blue box at the beginning of each section represents the Asahi Kasei Group’s
public declaration with respect to the subject of that section.

➢

The individual items within each section indicate specific standards for action bymembers of the Asahi Kasei Group.

1Asahi Kasei Group Code of Conduct
1. Ensuring Safety, Environmental Protection, and High Quality Products and Services
to Contribute to Life and Living(1) Endeavor to Maintain Absolute Safety in All Aspects of our Business
The Asahi Kasei Group considers safe business practices to be a prerequisite to thesustainable development of operations. Accordingly, it conducts business throughout all
sectors in accordance with relevant safety management policies and endeavors toensure safety in every way.
a.

Complete Safety in our Business Activities
Our employees must perform our business activities with absolute safety.

b.

Understanding of and Compliance with Safety Rules
Our employees must understand and comply with laws, regulations, and internal
company rules related to safety management that apply to our business.

c.

Reporting, Informing, and Discussing Safety Matters
If any employee encounters a safety related accident or problem, becomesaware of any risk thereof, or has any concerns related to safety, the employee
must promptly report, inform, and/or discuss the matter to or with his/hersupervisor, relevant parties, and/or relevant department.

(2) Providing Safe and High-Quality Products and Services That Customers Can Rely On
The Asahi Kasei Group continuously strives to improve its quality management systemand quality assurance programs in order to provide safe and high-quality products andservices.
a.

Understanding of and Compliance with Safety and Quality Rules
Our employees must understand and comply with laws, regulations, and internal
company rules related to safety and quality standards that apply to our products
and services.

b.

Responding to Requirements and Expectations of Customers and Society
Our employees must reasonably ascertain the standards required by customers
and the constantly changing expectations of society and respond appropriately.
2Asahi Kasei Group Code of Conductc.

Placing Our Highest Priority on Customers’ Safety
Our employees must place their highest priority on customer safety and avoid
any accident associated with our products or services or any threat to the safetyor health of our customers.

Note: In this Code of Conduct, “customers” include not only those who directly purchasefrom Asahi Kasei Group companies, but also those who purchase through trading
companies, wholesalers, or distributors, as well as end users and consumers of final
products into which our products are incorporated.

(3) Carefully Managing Workplace Safety to Ensure a Safe and Comfortable Work
Environment
The Asahi Kasei Group endeavors to secure the safety of its employees by striving toprevent occupational accidents. The Asahi Kasei Group also endeavors to build
comfortable workplace environments and to promote the maintenance andimprovement of employee health.
a.

Understanding of and Compliance with Workplace Safety Rules
Our employees must understand and comply with laws and regulations related
to workplace safety and hygiene, with internal company rules related to the
management of workplace safety and hygiene, and maintain their own safety as
well as that of their colleagues.

b.

Complying with All Safety Procedures and Manuals
Our employees must maintain workplace safety and hygiene as well as maintainand improve the workplace environment by understanding and complying withthe content of our safety procedures and manuals related to our business.

c.

Maintaining and Improving Health
Our employees must pay attention to their own health and safety and the healthand safety of their colleagues, including undergoing health checkups whererequired by laws and regulations.

3Asahi Kasei Group Code of Conduct(4) Contributing to Environmental Protection and Harmony with Local Communities
The Asahi Kasei Group is committed to operating in harmony with the environment andwith local communities and to contributing to the development of local communities
through our business activities.
a.

Understanding of and Compliance with Environmental Rules
Our employees must understand and comply with laws, regulations and internal
company rules related to environmental standards that apply to our business.

b.

Reducing Environmental Burdens
Our employees must undertake to reduce the burden and impact of our business(product development, procurement, manufacturing, logistics, etc.) on theenvironment.

c.

Contributing to and Communicating with Local Communities
Our employees must contribute to our local communities through our businessactivities and actively participate in community fellowship activities. Our
employees must also gain a sufficient understanding of local culture to deepen
our communication with local communities.

2. Maintaining Sincere Relationships with Those around Us(5) Disclosing Corporate Information Timely and Appropriately to Society
The Asahi Kasei Group endeavors to disclose corporate information, where required bylaw, in a fair, impartial, accurate, and prompt manner to those around us such as ourcustomers, shareholders, investors, suppliers, employees, and local communities, and to
the general public.
a.

Public Communication
Our employees must strengthen our brand and heighten our corporate value
through proactive communication that fosters an accurate understanding of the
Asahi Kasei Group.

4Asahi Kasei Group Code of Conductb.

Understanding of and Compliance with Information Disclosure Rules
Before disclosing information related to our business, our employees must
confirm the content and obtain approval from relevant supervisors andcorporate communications department. In particular, our employees may only
engage the media on behalf of the company after receiving approval from thecorporate communications department.

c.

Prohibition of Insider Trading
If any employee comes to know non-public material information (insider
information) about the Asahi Kasei Group or another market-listed company, theemployee must not trade his/her shares prior to the information becoming
public (insider trading). Furthermore, no employee may divulge insider
information to third parties, including family members, nor recommend trading
shares based on insider information.

(6) Appropriate Descriptions to Customers, Provision of Safe and Reliable Products
and Services
The Asahi Kasei Group endeavors to provide descriptions of products and services tocustomers, including product labeling and advertisements, that are easy to understand,not misleading, and to provide safe and reliable products and services that meetcustomers’ needs.
a.

Understanding of and Compliance with Product and Service Description Rules
Our employees must confirm the content of descriptions and advertisements ofproducts and services at each stage from product development to introduction
to sale, and continuously check that there is no infringement of related laws,
regulations, or voluntary industry standards, and confirm that customers areable to properly use products and services safely and reliably.

b.

Accurate Description of Products and Services to Customers
Our employees must accurately convey the content and characteristics ofproducts and services to customers, and appropriately manage the various data
and materials that substantiate the content and characteristics. Our employees
also must comply with contractual obligations to give notifications to customers.

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Asahi Kasei Group Code of Conductc.

Appropriate Response to Contact from Customers
Our employees must swiftly respond to inquiries, complaints, requests, opinions,etc., on our products and services, understand the facts objectively, sincerely
respond based on the facts, and continuously improve our products and services.

d.

Documenting and Proper Processing of Transaction Terms
Our employees must document the transaction terms agreed with ourcustomers and perform proper processing of received orders, shipment,delivery, transfer, and service provision based on the orders received from ourcustomers.

e.

Compliance with Corporate Ethics in Transactions through Distributors, et
In cases where any employee sells through trading companies, distributors,
agents, etc., the employee must still adhere to the substance of Section II, Part 6,
paragraphs a. through d., above, make sure to confirm the purpose of use of our
products, and ascertain the final users of our products to the extent possible.

(7) Healthy Relationships with Customers and Government Officials
The Asahi Kasei Group maintains healthy relationships with customers in both the public
and private sectors, performs transactions with integrity, and expressly prohibits thebribery of government officials to obtain orders or to advance business operations.
a.

Maintaining Healthy Relationships with Customers
Our employees must not provide customers in either the public or private sector
with entertainment, gifts, money, travel expenses, donations, or any otherbenefit that exceeds the range permissible by laws and regulations or what is
generally considered reasonable.

b.

Prohibition of Bribery of Government Officials
Our employees must maintain healthy relationships with each country’s
government officials, and not only comply with laws and regulations regarding
the prohibition of bribery of government officials but also comply with any
related internal company rules. Our employees must avoid any act that would
raise suspicion of bribery or suspicion of illicit intent.

6Asahi Kasei Group Code of Conductc.

Prohibition of Bribery through Distributors, etc.
Our employees will require our business partners such as distributors, agents,
consultants, and contractors to maintain ethical behavior and to comply with thesubstance of Section II, Part 7, paragraphs a. and b. mentioned above, as well as
to comply with various related laws, regulations and contractual obligations
when working with us.

(8) Fair Relationships with Competitors
The Asahi Kasei Group thoroughly complies with the competition laws andantimonopoly laws of each country, maintains relationships of fair competition withcompetitors, and provides products and services in a fair manner.
a.

Prohibition of Cartels
Our employees will not take part in agreements with competitors or otherparties to impede fair competition. Our employees therefore do not makeunnecessary contact with competitors, share information that is important forcompetition, or act in any other way that would raise suspicion of a cartel.

b.

Prohibition of Private Monopolies and Exclusionary Transactions
Regarding products or services where we are dominant in the market, ouremployees will not unfairly restrict or exclude competitors in accordance withthe law.

c.

Prohibition of Other Impediments to Competition
Our employees must avoid any transaction that impedes fair competition by
circumscribing the resale prices of trading companies, wholesalers, or
distributors, attaching unfair conditions, etc.

7Asahi Kasei Group Code of Conduct(9) Optimized Procurement and Healthy and Appropriate Relationships with Suppliers
The Asahi Kasei Group sets rules related to procurement, pursues optimal procurement,
maintains healthy relationships with suppliers, and thoroughly follows proper
procedures for transactions and payments.
a.

Understanding of and Compliance with Procurement Rules
Our employees must select suppliers and determine prices based on appropriate
procedures and approvals. Our employees must adhere to our system of checks
and balances, including any and all requirements for supervision or assessments
by multiple employees, and not engage in speculative transactionsb.

Seeking Optimal Procurement
Our employees must seek optimal procurement by evaluating suppliers
comprehensively including aspects such as safety, quality, price, delivery term,
management condition, and environmental burden. The selection of suppliersmust be determined based on a rational judgment following the determinationof the suppliers’ actual condition and the proper examination of suppliers.

c.

Prohibition of Gift and Transactions Counter to Company Interests
Employees may not accept any offer of money from suppliers, nor any
entertainment, gifts, or other favors that exceed what is generally consideredreasonable. Employees may not perform any transactions that run counter tothe interests of the company.

d.

Documenting and Proper Processing of Transactions
Our employees must document all transaction conditions agreed with suppliers,
confirm proper processing of purchasing and procurement in compliance with
relevant laws and regulations, confirm the receipt and inspection of goods, andconfirm the actual receipt of services provided to us.

e.

Compliance with Corporate Ethics by Suppliers
To the extent possible, our employees must ensure our suppliers’ commitment
to compliance with relevant laws and regulations, particularly those that prohibit
bribery and the use of conflict minerals, that prevent human rights violations
such as compulsory labor, child labor, and slavery, and our employees will share
the Asahi Kasei Group’s policy on such matters with suppliers and request theircomplete compliance.
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Asahi Kasei Group Code of Conduct
Note: In this Code of Conduct, “suppliers” include not only direct vendors of materials tocompanies of the Asahi Kasei Group, but also counterparties from whom we procure any
goods or services such as providers of equipment or maintenance, contractors, andproviders of outsourced work.

(10) Respect for Human Rights and Diversity
The Asahi Kasei Group respects individuals’ basic human rights and diversity, andendeavors to provide a workplace that enables anyone to be actively engaged.
a.

Respecting Basic Human Rights and Diversity
Our employees must respect individuals’ basic human rights and diversity and,along with the basic policy of the Asahi Kasei Group regarding prohibition of
discrimination on any protected category under applicable law, such as
nationality, ancestry, race, ethnicity, religion, gender, ideology, age, physicalcharacteristics, sexual orientation, employment status, form of contract, etc.,
our employees must not condone such discrimination.

b.

Prohibition of Harassment
Our employees must maintain a workplace free of unlawful harassment,
whether moral, sexual harassment, physical or psychological, etc., and our
employees must not condone such words or deeds.

c.

Prohibition of Inhumane Labor Practices
Based on respect for basic human rights, our employees must not condone
inhumane practices such as compulsory labor, child labor, slavery, etc.
Furthermore, our employees must not condone such practices done by our
suppliers.

9Asahi Kasei Group Code of Conduct
3. Utilizing management assets appropriately and effectively(11) Performing Work with Integrity and Responsibility
The Asahi Kasei Group expects each individual employee to perform his or her work
independently with integrity and a sense of responsibility.
a.

Performing Work with Integrity
Our employees must comply with relevant labor laws and regulations, with any
relevant employment agreements, and must perform their work with integrity
and responsibility.

b.

Prohibition of Acts Counter to Company Interests
No employee may perform acts that run counter to the interests of the Asahi
Kasei Group.

c.

Clarification of Roles and Compliance with Reporting Lines
To maintain the reliability of work and to prevent work from becoming
dependent on an individual, employees are expected to comply with
documented segregation of duties, responsibility, authority, and reporting lines.

d.

Promotion of Workplace Communication
To facilitate the orderly progress of work and the timely ascertainment of risks,
employees must regularly report, inform, and discuss business activities as partof fluid daily communication in the workplace.

(12) Compliance with Accounting and Tax Rules, Protecting Company Property
The Asahi Kasei Group protects the value of tangible and intangible company property
by thoroughly performing proper accounting and tax treatment in conformity with thelaw and relevant regulations and appropriate management of company property.
a.

Understanding of and Compliance with Accounting and Tax Rules
Our employees tax must understand the accounting standards and tax laws that
apply to our company, and perform proper and lawful accounting and tax
treatment based on such laws, regulations, and internal company rules.

10Asahi Kasei Group Code of Conductb.

Compliance with Internal Procedures Related to Company Property
Management
When acquiring or disposing of company property or disbursing expenditures,
our employees must follow the proper procedures and obtain the necessary
approvals as specified by the relevant supervisor and/or department. Whenmaking donations, providing sponsorships, or giving gifts, our employees will
follow the company’s established process for examination and approval.

c.

Protecting Company Property and Prohibition of Personal Use
Our employees must manage tangible and intangible company property
appropriately and not use or consume such property for personal purposes.

d.

Maintaining the Company’s Reputation and Brand
Our employees must understand that the company’s reputation and brand areimportant intangible property and that they must not act in a way that would
jeopardize the company’s reputation and brand.

(13) Protecting and Managing Information
The Asahi Kasei Group thoroughly protects information security, including protection of
personal information and proper management of documents.
a.

Understanding of and Compliance with Information Security Rules
Our employees must comply with all laws, regulations, and internal company
rules related to information security, and appropriately manage information
assets. In the event that a breach or violation occurs, employees must
immediately contact the related department and follow the instructions theyreceive.

b.

Appropriate Management of Personal Information
Our employees must clearly specify the purpose for the collection and use of
personal information, and collect, store and use personal information in an
appropriate manner and within the scope of the specified purpose. Our
employees may not provide or disclose personal information to third parties
except as permitted by laws and regulations and/or with the consent of theindividual.

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Asahi Kasei Group Code of Conductc.

Appropriate Management of Documents and Data
All company information, documents, and data that employees produce or
receive in the course of their work belongs to the company, and employees are
expected to manage it appropriately in accordance with laws, regulations, andinternal company rules.

d.

Restriction of Information Dissemination
Our employees must not talk about confidential information related to ourbusiness in public, disseminate confidential information related to our businesson social networking systems (SNS) without permission, or disseminate
misleading information.

(14) Protecting and Respecting Intellectual Property Rights
The Asahi Kasei Group promotes the acquisition and protection of its own intellectual
property rights, and endeavors to respect the intellectual property rights of others.
a.

Protection of Our Intellectual Property
Our employees will protect our company’s intellectual property, including
technology information, by promoting the acquisition of intellectual property
rights and by maintaining the confidentiality of inventions, know-how, etc.,
whose rights are not yet acquired.

b.

Management of Information in External Announcements of Company
Technology
When publishing scientific papers, etc., and issuing external releases, ouremployees must confirm that no confidential information is included.

c.

Prevention of Infringement of Others’ Intellectual Property Rights
Our employees must perform thorough searches of prior work and exercise theutmost care to ensure that we do not infringe the intellectual property rights ofothers in any aspect of our business, including R&D, manufacturing, sales, etc.

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Asahi Kasei Group Code of Conductd.

Respecting Others’ Intellectual Property Rights
Our employees must take care to ensure that they do not use, directly or
indirectly, any intellectual property rights of others without permission, including
copyrights of literature, photographs, music, and computer programs, etc.

(15) Compliance with Laws and Regulations, Practicing Corporate Ethics
The Asahi Kasei Group endeavors to thoroughly comply with the laws and regulations ofeach country, and to prepare and appropriately apply internal company rules. When
judgment cannot be made based on laws, regulations, and internal company rules, eachaction must be based on the utmost integrity.
a.

Thorough Legal Compliance

Our employees must understand the laws and regulations that relate to their work andduties and confirm whether there is any violation. Our employees must also makecertain to obtain any license or approval and to perform any notification or reporting as
required by laws and regulations.
b.

Thorough Compliance with Internal Company Regulations

Our employees must understand the internal company regulations that relate to theirwork and not only thoroughly apply such rules but also continuously check to confirm
whether there is any amendment to such laws or rules that relate to their own work.
c.

Integrity in Work Based on this Code of Conduct

If any employee encounters a situation in the course of his/her work when judgment
based on laws, regulations, and internal company rules becomes difficult, the employee
must act with integrity based on the spirit of this Code of Conduct.

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