The JSR Group
Principles ofCorporate Ethics
Corporate Code of Conduct

Table of Contents
Message from the CEO
Corporate Code of Conduct
─ Introduction ─

1
2

JSR Groupʼs Essential Elements

3"Responsibility to Our Stakeholders" andCorporate Code of Conduct

5

1. Responsibility to Our Customers/
Business Partners
2. Responsibility to Our Employees
3. Responsibility to Society
4. Responsibility to Shareholders
5. Responsibility to All Our Stakeholders

7
9
11
14
15

JSR Groupʼs Sustainability Advancement Structure
17
United Nations Global Compact

fromMessagethe CEO
The JSR Groupʼs commitment to operating responsibly and ethically is a cornerstoneof our culture, and of who we are as a company, and we stand on our management
policy to always fulﬁll our responsibility to stakeholders.
Our Corporate Code of Conduct, which is speciﬁed in the JSR Group Principles ofCorporate Ethics, serves as a set of guidelines for all employees. It speciﬁes
responses, actions and procedures for our daily interactions with fellow employees,
customers, suppliers and other business contacts.
As JSR continues to grow and evolve, we will work to establish a resilient organization that can gather knowledge globally, from both inside and outside the company,and quickly execute optimal strategies for the present moment, even in uncertain
times like now when unpredictable events are unfolding to adapt ourselves todynamically changing environments. But we will never lose sight of who we are, of
our commitment to society, or of our responsibility to stakeholders.
The primary responsibility we have to our stakeholders is to create value and this is
the foundation of our sustainability activities.
To this end, we are focusing on the concept of sustainability, which is to create value
for all stakeholders, based on this code of conduct.
The fundamental rule is to follow laws and rules as well as social norms. My sincere
hope is that each Group company and organization will use these Principles as a
guideline to develop its own resilient system.
Jan. 1, 2021

JSR Corporation
Representative Director, CEO
Eric Johnson-1-Corporate Code of Conduct- Introduction -PurposeWe have established this Code of Conduct as the basic rules that all JSR Group companies, their directors andemployees (full-time, contract, part-time, and temporary employees as well as employees on short-term
contracts) should comply with, in order to execute the management policies “Our Responsibility to our
Stakeholders” in engaging in business activities. We shall not require our directors or employees to act inviolation of the Code of Conduct. Additionally, we shall not disadvantage any director or employee who refuses
to execute an order to perform an act that is in violation of the Code of Conduct for the reason of said refusal.

Contents Construction
This Code of Conduct contains the principles to be followed to execute our responsibility to individual
stakeholders: “Responsibility to Our Customers/Business Partners,” “Responsibility to Our Employees,”“Responsibility to Society,” and “Responsibility to Shareholders.”
In addition to the above, the common principle is provided to fulﬁll responsibility to all our stakeholders.

Scope of Application
The group companies listed on the Web sites below fall under the scope of application of JSR Group
Principles of Corporate Ethics.
Within Japan: https://www.jsr.co.jp/jsr_e/company/group.html
Overseas:

https://www.jsr.co.jp/jsr_e/company/group̲oversea.html* Among the companies listed on the Web sites, group companies for which JSRʼs capital ratio is 50%
or more are applicable.
* With regard to applicable group companies, there are some that possess independent guidelinesthat take into account local rules, based on the JSR Group Principles of Corporate Ethics.

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JSR Group’s Essential Elements
Corporate Mission
Materials Innovation
We create value through materials to enrich society,people and the environment

Management Policies
JSR’s Fundamental Pillars of Management
Continuous creation of businesses
As society evolves, so does the demand for specialized materials and advanced products.
JSR continuously evolves to anticipate and responds to changing marketing needs and, in
doing so, achieve dynamic growth.

Enhancement of corporate culture
As society evolves, so will our organization. JSR will build on its existing positive corporate
culture to create an organization and management style with the vitality to keep evolving.

Increase in corporate value
JSR will position itself to increase our overall corporate value by creating businesses
through materials with focuses on customer satisfaction and the fulﬁllment of employees.

Responsibility to Our Stakeholders
Responsibility to our customers / business partners
When interacting with our business partners and customers, the JSR Group will:■ Constantly evolve to meet the demand for new materials■ Always strive to increase customer satisfaction■ Act in good faith and maintain fair and equitable business relations■ Continue to be socially and environmentally conscious throughout the supply chain

Responsibility to our Employees
All employees should expect:■ To be evaluated and rewarded based on fair standards■ Continuous opportunities to grow by challenging themselves■ Acceptance of the diversity of fellow colleagues and to be provided a place
where all employees can work together as a team

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Responsibility to Society
All members of the JSR Group will honor our responsibility to both the local
and global communities through:■ Responsible and respectful business practices (Responsible Care) that consider
the environment and safety■ Support of environmental conservation by providing eco-friendly products■ Reduction of our environmental impact throughout the entire product lifecycle■ Active contribution to conserving biodiversity throughout its business activities andthe entire product lifecycle

Responsibility to Shareholders
The JSR Group will maintain its responsibility to its shareholders by:■ Aiming to increase corporate value by creating business opportunities through materials■ Constantly enhancing its management efﬁciencies■ Inspiring trust by being highly transparent and conducting sound corporate
management practices

Course of Action：4C
Challenge
All employees of the JSR Group should share a common,
global focus and desire to succeed. Employees should feel
conﬁdent to autonomously take on new challenges,
learning from successes while viewing setbacks
as opportunities to learn, grow and improve.
Communication
All employees should feel comfortable and conﬁdent maintaining open lines ofbi-directional communication at all levels within the JSR Group. Employees should strive
for organizational transparency through direct conversations
as the best means to share value and achieve common goals, especially in the face ofgrowth and diversiﬁcation.
Collaboration
Employees will work together in the spirit of cooperation valuing common, corporate
goals over internal or departmental barriers. Employees will also be encouraged toactively collaborate with external resources and not be bound to conventional ideas.
Cultivation
All employees will cultivate an environment that supports bi-directional communication
between managers and subordinates and provides opportunities to develop together as
individuals and as members of productive, supportive teams.

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"Responsibility to
Our Stakeholders" andCorporate Code of Conduct
An explanation of the relationship between "Responsibility to Our Stakeholders"
and the 15 rules in the Corporate Code of Conduct.

Corporate
MissionManagement
Policies

Materials Innovation
We create value through materials to enrich society,people and the environment

Continuous creation of businesses
Enhancement of corporate culture

JSR’s
Fundamental
Pillars ofManagement

Increase in corporate value
Responsibility to Our Customers / Business Partners▶P.7

Responsibility to
Our Stakeholders

Responsibility to Our Employees▶P.9

Responsibility to Society▶P.11

Responsibility to Shareholders▶P.14

Responsibility to All Our Stakeholders▶P.15

Challenge
Course of Action：4C

Communication
Collaboration
Cultivation

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Corporate Code of Conduct
Code of Conduct for Product Safety▶P.7

Code of Conduct for Fair and Proper Transactions▶P.8

Code of Conduct for Gifts and Entertainment▶P.8

Code of Conduct for Providing a Comfortable Work Environment▶P.9

Code of Conduct for the Environment and Safety▶P.11

Code of Conduct for Respecting Human Rights▶P.12

Code of Conduct for Risk Management▶P.12

Code of Conduct for Corporate Social Responsibility▶P.13

Code of Conduct against Antisocial Forces▶P.13

Code of Conduct for Coexistence with International Society▶P.13

Code of Conduct for Proper Recording of Information and Disclosure ▶P.14
Code of Conduct for Preventing Insider Transactions▶P.14

Code of Conduct for Fair Fulﬁllment of Daily Duties▶P.15

Code of Conduct for Use of the JSR Group’s Assets and Intellectual Properties ▶P.16
Code of Conduct for the Control of Information

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▶P.16

Responsibility to Our Customers/
Business Partners

Management Policies-Responsibility to Our Stakeholders

Responsibility to
Our Customers /Business Partners

Responsibility to Our Employees

When interacting with our business partners andcustomers, the JSR Group will:■ Constantly evolve to meet the demand for new materials■ Always strive to increase customer satisfaction■ Act in good faith and maintain fair and equitable business
relations

Responsibility to Society■ Continue to be socially and environmentally conscious
throughout the supply chain

Code of Conduct

Responsibility to Shareholders

Code of Conduct to fulﬁll Responsibility to
our Customers / Business Partners

1

Responsibility to
All Our Stakeholders

It's important toprovide relevant informationin addition to a safe product.

Code of Conduct for
Product Safety

When performing business activities, weshall abide by the law in relation to productsafety, proactively provide adequate product information to our customers andprevent accidents that may be attributed toour products. Through these eﬀorts, we
strive to maintain and improve relations withcustomers.

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Code of Conduct for Fair
and Proper Transactionsald❶We shall observe laws regulating transactions,such as competition laws, in Japan and otherrelevant countries where such laws are applicable to our business operations.
❷In transactions with small-size subcontractors, weshall not perform unfair practices such as
delayed payment to subcontractors.
❸To prevent our technologies and products from being used for harmful aﬀairs
and actions which may threaten international peace and safety, we shallobserve laws and regulations in relation to import and export, including foreignexchange and foreign trade control laws.
❹With regard to purchase transactions, we shall conduct transactions that are
fair, transparent, and based on economic rationality, as well as consider our
responsibility to society, such as compliance with laws and ordinances, protection of resources, environmental conservation, safety and human rights.

3

Code of Conduct for Gifts
and Entertainment

We will not give or accept
improper gifts or entertainment.

❶Whether inside or outside the country, we shallnot give gifts to and/or entertain politicians,
government oﬃcials or other relevant parties
in a manner that may generate proﬁts throughillegal means or violate bribery regulations.
❷When making contributions to politicalﬁgures/parties or other organizations, we shalldo so in a proper manner and observe all applicable laws and regulations,such as the Political Funds Control Law.
❸We shall not give or receive gifts and provide or receive entertainment to orfrom customers, suppliers and other stakeholders, which may be regarded asbribery or unfair acts. We shall not be involved in the exchange of gifts orentertainment that may go beyond the accepted social norms.
❹Within the JSR Group, we shall not give and/or receive gifts and/or provide
entertainment.

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Responsibility to Our Customers/
Business Partners

Management Policies-Responsibility to Our Stakeholders

Responsibility to
Our Employees

Responsibility to Our Employees

All employees should expect:■ To be evaluated and rewarded based on fair standards■ Continuous opportunities to grow by challenging themselves■ Acceptance of the diversity of fellow colleagues and to be provided
a place where all employees can work together as a teamResponsibility to Society

Code of Conduct

Code of Conduct to fulﬁll Responsibility
to our Employees

Responsibility to Shareholders

Code of Conduct for Providing
a Comfortable Work Environment

Responsibility to
All Our Stakeholders❶We shall ensure the fair treatment of
employees, based on each person stasks, roles, and level of commitment.
❷We shall respect the diversity of ourworkforce and make eﬀorts to createaworkplaceenvironmentthat
enables every employee to make thebest use of their abilities and to ﬁnd arewarding sense of satisfaction in
their work.

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Ensuring a good working
environment.

❸We shall respect the human rights and diverse characteristics of all
individuals, and shall not discriminate against gender, age, nationality,
race, ethnic group, origin, religion, beliefs, social status, physical disability,
sexual orientation, or other relevant conditions when determining employment status and/or working conditions.
❹We shall not force religion and/or belief on others.
❺We shall provide a workplace free from sexual harassment and any
harassment arising from positions of power. In addition, we will not engage
in or make verbal comments withsexual connotations that will makeWe will not allow
counterparts feel uncomfortable.
power harassment or❻We shall strive to maintain andsexual harassment!
improve safety and hygiene levels for
all relevant parties, based on our belief
that safety is of utmost importance toeveryone working in manufacturing
and the bedrock of business activities.
Additionally, we shall pay
suﬃcient attention to the maintenanceof the mental and physical health ofourselves and those we work with.

Our secure hotline isalways open.

❼In the event that a staﬀ member reports
the violation or possible violation of thelaw and/or the Principles of Corporate
Ethics to his/her superiors and/orinternal/external hotline, we shall fully
protect the said staﬀ member s identityand protect him or her from unfavorable treatment.
❽We will provide a work environment thatfacilitates ﬂexible work life management for employees, and strive toimprove both productivity and employee satisfaction.

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Responsibility to Our Customers/
Business Partners

Management Policies-Responsibility to Our Stakeholders

Responsibility toSociety

Responsibility to Our Employees

All members of the JSR Group will honor our
responsibility to both the local and global
communities through:■ Responsible and respectful business practices (Responsible Care)that consider the environment and safety■ Support of environmental conservation by providing eco-friendly
products

Responsibility to Society■ Reduction of our environmental impact throughout the entire
product lifecycle■ Active contribution to conserving biodiversity throughout its
business activities and the entire product lifecycle

Code of Conduct
Responsibility to Shareholders

Code of Conduct to fulﬁll Responsibility toSociety1

Code of Conduct for
the Environment and Safety

Responsibility to
All Our Stakeholders❶We will seek to form a symbiotic relationshipwith society by promoting accident-free anddisaster-free operations and securing thesafety of our employees and local commu-

nities.

We value the environment.

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❷We will strive to conserve the environment by reducing environmentalloads/impacts throughout the life cycle of a product, from development todisposal.
❸We will comply with all relevant domestic and foreign laws and regulationsin using chemical substances in our business activities.
❹To help prevent global warming and promote eﬀective use of valuable
resources, we will make active eﬀorts in our business activities, such as
resource saving, energy conservation, waste reduction, and recycling ofused products.
❺We will pay utmost consideration to the maintenance, conservation andsustainable use of biodiversity that supports our daily lives and ourbusiness activities.

We respect basic human rights.

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Code of Conduct for
Respecting Human Rights❶We will respect and uphold basic human rights, suchas the Universal Declaration of Human Rights,
declared internationally and protected under constitution and legal precedents of respective countries,
and will not infringe basic human rights.
❷We will abide by national and international labor codes
and respect workers right of association and rightfor collective negotiation in the realm of basic laborrights.
❸We shall never allow child labor or forced compulsory
labor, whether at the JSR Group or in the workplacesof business partners and collaborating companies.

3

Code of Conduct for
Risk Management

Thoroughly ascertaining risk
and preventing accidents.

We will keep track of imminent or potential risks
we may face, and prevent such risks before they
happen. Should any risk become evident, we will
strive to minimize its adverse eﬀects on ourbusiness activities and society.

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Responsibility to Our Customers/
Business Partners

4

Code of Conduct for Corporate
Social Responsibility

Working to be acompany that
contributes to
L E S S O Nsociety.

Responsibility to Our Employees❶As a responsible member of society, we
will make active eﬀorts to meet societal
demands and address social challenges,
as well as to contribute to society
through our business activities in conformity with our corporate mission.
❷We will pursue sustained eﬀorts in corporate social contribution activities bytaking full advantage of the chemical and technological knowledge on
which the business foundation of the JSR Group has been built.
❸We will actively encourage our employees to be involved in society andvoluntarily join activities that beneﬁt society.

Responsibility to Society

5

Responsibility to Shareholders

We refuse to workwith antisocial forces.

Responsibility to
All Our Stakeholders

6

Code of Conduct against
Antisocial Forces

Our basic policy, upheld by our top executive
and company as a whole, is to reject any
relation with antisocial forces including any
business transactions, and ﬁrmly reject any
demand with collaboration from police andexternal organizations specialized in security
issues.

Code of Conduct for Coexistencewith International Society

In our international business activities, we shall abide by internationalrules and local laws, respect local culture and customs, and conductbusiness operations in a manner which will contribute to the developmentof local communities.

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Management Policies-Responsibility to Our Stakeholders

Responsibility to
Shareholders
The JSR Group will maintain its responsibility to its shareholders by:■ Aiming to increase corporate value by creating business opportunities through materials■ Constantly enhancing its management eﬃciencies■ Inspiring trust by being highly transparent and conducting soundcorporate management practices
Code of Conduct

Code of Conduct to fulﬁll Responsibility to Shareholders

1

Code of Conduct for Proper Recording ofInformation and Disclosure❶When evaluating business activities, we shall focus not only on ﬁnal results
but also on business processes that deliver those results. We will strive toaccurately and explicitly record our business activities.
❷We shall disclose information on management and business activities in atimely and appropriate manner.

2

Code of Conduct for
Preventing Insider Transactions

Under no circumstances
will we commit
insider trading.

❶We shall not use, for our private interests, undisclosed material
information which we have come to know through conducting
our business and which concerns the JSR Group and/or othercompanies in which we engage.
❷In the case that we have and hold any undisclosed material information, we shallnot release such information until it is disclosed oﬃcially. Additionally, we shall notsell and/or purchase JSR s and/or other relevant companies shares or relevant
ﬁnancial products until oﬃcial disclosures are made.

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Responsibility to Our Customers/
Business Partners

Management Policies-Responsibility to Our Stakeholders

Responsibility to
All Our Stakeholders

Responsibility to Our Employees

The JSR Group will maintain its responsibility
to all of its stakeholders by:■ Striving to prevent any loss of reputation for the company or its
corporate values, including intangible values such as social
credibility and dignity.

Responsibility to Society

Code of Conduct

Code of Conduct to fulﬁll Responsibility toall our Shareholders

Responsibility to Shareholders

1

Code of Conduct for
Fair Fulﬁllment of Daily Duties

Responsibility to
All Our Stakeholders❶We shall not perform any dishonest transactions with the aim of securing unfair private
gain through commercial transactions orother business practices.
❷We shall accurately record job duties andshall not record anything falsely and/or
ﬁctitiously.
❸The directors and employees of JSR Group
companies must not act in a way that creates,or potentially creates a conﬂict of interest for
the JSR Group. If such a situation occurs, theperson(s) concerned must report it to theBoard of Directors or their superiors.

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We will enter data andcreate records accurately.

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Code of Conduct for Use of the JSR Group s
Assets and Intellectual Properties❶We shall eﬃciently use the JSR Group facilities, machines, equipment and any othercommodities. We shall not use the JSRGroup s properties for private interest.
❷We shall protect the know-how, patents,
utility models, industrial designs, trademarks and other relevant intellectual property that the JSR Group has and holds.
Additionally, we shall not infringe on othercompanies intellectual property without
justiﬁable reason.

3

Code of Conduct for theControl of Information

We will not use corporate
assets for private interest.

We will not leak or misuse
conﬁdential information.

Information Informatio❶We shall not obtain information necessary fornour business activities by any illegal means.
Information❷We shall strive for thorough control of
conﬁdential information concerning the JSRGroup, and/or third parties, including customers of, or suppliers to, the JSR Group. We shallalso prevent such information from unauthorized disclosure, and from being leaked or used illegally.
❸While being employed or after leaving a company, we shall not provide toothers, without rightful authority, conﬁdential information which has beenobtained in the course of company duties. We shall not use such information
for private interest.
❹We shall observe the Act on the Protection of Personal Information and strive
to prevent illegal acquisition, use and disclosure of personal information on
directors and employees of the JSR Group and on third parties, including
customers of, or suppliers to, the JSR Group we have come to know while
conducting our business.

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JSR Groupʼs Sustainability Advancement Structure
Board of Directors
Representative Director and CEO
Representative Director and President
Sustainability Promotion Committee

Chairperson: President
Office: Sustainability Promotion Dept.

・Formulates basic policies for promoting sustainability
・Supervises and guides the four committees andpromotes JSR Group's sustainability-related activities

Sustainability
Planning
Committee

Environment,
Safety andQuality Committee

Risk Management
Committee

Corporate Ethics
Committee

Chairperson: Officer in charge of
Sustainability Promotion
Office: Promotion Dept.

Chairperson: Officer in charge of
Safety and Environmental
Affairs
Office: Environmental Dept.

Chairperson: Officer in charge ofCorporate Planning
Office: Sustainability Promotion
Dept.

Chairperson: Officer in charge ofGeneral Affairs
Office: General Affairs Dept.

・Formulates guidelines for
dealing with risks
confronting JSR Groupand makes continual
improvements to them・Promotes JSR Group's
corporate ethics-related
activities
・Veriﬁes legal complianceand provides follow-up
・Promotes respect for andsafeguarding of humanrights・Promotes sustainabilityrelated activities andsocial contributionrelated activities
expected of JSR Group・Formulates JSR Group
Policies concerning
safety, environment,
quality, product safety,
and chemical
management; promotes
related activities; anddiscloses relevant
information

United Nations Global Compact
On April 2009, the JSR Group became a participant in the Global Compact policy advocated by theUnited Nations. Amidst increasing calls for corporate social responsibility, further consideration isrequired of ﬁrms engaged in business activities on a global scale in respect to human rights, labor, theenvironment and anti-corruption, as expressed in the ten principles of the Global Compact. We consider
joining the Global Compact to be a proclamation for acting responsibly in the international community,
and we intend to work hard to proactively execute our “corporate social responsibility.”
The 10 Principles of the United Nations Global Compact❶Businesses should support and respect the protection of internationally proclaimed human rights.
❷Businesses should make sure that they are not complicit in human rights abuses.
❸Businesses should uphold the freedom of association and the effective recognitionof the right to collective bargaining.
❹Businesses should uphold the elimination of all forms of forced and compulsory labour.
❺Businesses should uphold the effective abolition of child labour.
❻Businesses should uphold the elimination of discrimination in respect of employment and occupation.
❼Businesses should support a precautionary approach to environmental challenges.
❼Businesses should undertake initiatives to promote greater environmental responsibility.
❾Businesses should encourage the development and diffusion of environmentally friendly technologies.
❿Businesses should work against corruption in all its forms, including extortion and bribery.

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