Guidelines for Corporate Behavior

The steel industry in Japan, which is the base material industry, is required to carry out the mission of contributing to the improvement of people’s lives anddevelopment of the Japanese economy and society, through constantly supplying steel products that are useful in wide-ranging applications to society.
Based on this mission and a strong awareness that it is a member of society, Sanyo Special Steel has established a trusting relationship with society, throughfaithful and fair business operations.
Business corporations should widely contribute to society and are expected to create added values through fair competition and develop the economy andsociety through generation of jobs. Sanyo Special Steel aims to respect human rights inside and outside Japan, abide by the relevant laws and regulations
and conform to and respect the spirit of international rules. We also aim to fulfill our social responsibilities regarding creation of a sustainable society, basedon high ethical standards.
To fulfill these missions, Sanyo Special Steel has established the“Guidelines for Corporate Behavior”that specify the expected actions in detail.
1. As a company belonging to the basic material industry, Sanyo Special Steel will make efforts to develop and supply high-quality special steel products
constantly, to satisfy customers and consumers and to earn their trust.
2. Sanyo Special Steel will ensure fair, transparent and free competition as well as fair trade. We will also maintain sound and proper relationship with
political parties and the government.
3. Sanyo Special Steel will make efforts to communicate with shareholders and society in general and disclose corporate information in a positive and fairmanner. We will pay careful attention to protecting and administrating information including individual information and customer information.
4. Sanyo Special Steel will respect the versatility, personality and individuality of employees to realize safe and comfortable workplaces with a relaxed andaffluent atmosphere.
5. Sanyo Special Steel will take the initiative in solving environmental issues, based on the notion that environmental measures should be implemented by
the entire human race and are essential for the existence and activities of business corporations.
6. Sanyo Special Steel will positively perform social contribution activities as a“sound corporation in society.”
7. Sanyo Special Steel will handle antisocial forces and groups which pose a threat to the social order and safety in a resolute manner and completely avoid
having relationships with such forces and groups.
8. Sanyo Special Steel will abide by the laws of each country and region and respect human rights and international rules in performing global business
operations. We will also give consideration to cultures and customs in performing business management, aiming to contribute to the development of therelevant country and region.
9. Top-level executives of Sanyo Special Steel will acknowledge that they are responsible for implementing the Guidelines and act as role models, while
making efforts to ensure complete implementation of the guidelines by the group companies and business partners. The executives will also listen
actively to the opinions of employees inside and outside the company and establish an internal control system to realize an effective system.
10. In the event of actions being made that go against the Guidelines, top-level executives will clarify the intention to solve the problem with regards topeople inside and outside the company and make efforts to identify the cause and prevent recurrence of the trouble. The executives will also provide
information promptly and properly and explain the situation, clarify authority and responsibilities, and severely punish the persons involved, including
themselves.

Code of Conduct

This Code of Conduct stipulates in concrete terms matters to be observed by
Sanyo Special Steel and all of its officers and employees (including Counselors,
Senior Advisors, Executive Officers, Executive Councilors, etc. Applies also to
those who work on the basis of a commission contract or temporary staffing
agreement) in each aspect of our business activities with regard to the ten
items set out in the Guidelines for Corporate Behavior. For matters notprescribed in this Code of Conduct, actions should be taken in adherence withthe spirit of the Code of Conduct and the Guidelines for Corporate Behavior.

I. In Business Activities
1. Timely and appropriate provision of excellent products and services
We will contribute to the society through providing excellent products andservices needed by the society in a timely and appropriate manner, andthereby gaining our customers’satisfaction and trust.
Recognizing that high quality and safety are the prerequisites for excellent
products, we will make every effort to achieve them.
(1) Accurate understanding of customer needs
We will constantly gather information as to what is demanded in themarket and grasp the needs and“seeds”of our customers. By doing so, we
aim to provide attractive products and services that meet our customers’
requests in a timely and appropriate manner and thereby improve customer
satisfaction.
(2) Enhancement of customer support system
We will provide after-sales support of our products and services withsincerity, which would help us gain new orders, not to mention successiveorders from existing customers. Each division will strengthen its customer
support system and improve information materials on products andtechnologies.
(3) Compliance with laws and regulations related to safety
We will pay attention to safety at all times throughout the stages
from development of products to manufacturing, storage, sales andtransportation, so that our customers can use our products without worry.
To this end, we will strictly comply with laws, regulations, standards andwork standards regarding product safety.
(4) Preparation of easy-to-understand catalogues and specifications
We will take into consideration the ease of understanding in terms ofindications and descriptions when preparing product catalogues andspecification documents, so as to prevent any accidents that may occur
from wrong usage of products or uses other than their designed use.
(5) Response to accidents, etc.
When we learn of any product defects or accidents caused by productdefects, we will take prompt and appropriate actions including informing
relevant divisions, investigating all facts, and taking measures to prevent
recurrence.
(6) Prevention of accident recurrence
We will investigate the cause of product defects or the accidents caused
by product defects. We will share information on such investigation among
persons involved by appropriately compiling and utilizing its records andstrive to prevent similar accidents in the future.
(7) Protection of personal and customer information
We will pay the closest attention to personal and customer information
during the entire process from collecting to using, storing and destroying,and ensure strict management of such information.

2. Healthy and favorable relationship with our buyers and suppliers
We will conduct sales and purchases with integrity, fairness and equitability
in our business transactions both in and outside of Japan. We will not offer
or demand any unreasonable benefits in the course of business transactions.
(1) Relationship with buyers
We will limit the offer of entertainment and gifts to our buyers within
the socially acceptable and minimum necessary level. We will not offer
personal or arbitrary discounts, commissions, or any other benefits, even
if it is to gain an order. Maintaining healthy and favorable relationship withour buyers and suppliers, we will abide by our corporate rules on internal
approval.
(2) Relationship with suppliers
We will select suppliers with fairness and equitability, basing on reasonable
criteria such as price, quality, delivery, and after-sales services. Whenchoosing a new partner, we inquire into the candidate’s credit standing
and other matters, in addition to applying the above criteria and with
fairness and equitability. We will, whenever possible, decline any offer
of entertainment or gifts from our suppliers. When it is not practicable
to decline, we will make a report to our superior and never leave theboundary of socially acceptable practice.
(3) Relationship with subsidiaries and affiliates
We deal with our subsidiaries and affiliates with good common sense andintegrity. We do not impose on them any conditions unreasonably different
form the terms of business that we apply to a third party in a fair and freecompetition. We will, whenever possible, refrain from offering or accepting
entertainment or gifts to and from our subsidiaries or affiliates. When it isnecessary to offer or accept such entertainment, etc., we will make a reportto our superior and keep it within the socially acceptable and minimum
necessary level.
 elationship with the government, public offices, local authorities and other(4) R
public organizations
We will not offer any benefits to foreign or domestic government officials or
their equivalents in relation to their execution of duties.
3. Promotion of fair and free competition
The aim of the Antimonopoly Act is to maintain and promote fair and freecompetition, and thereby secure the interest of consumers and promote
the democratic and wholesome development of the national economy.
The Subcontract Act aims to ensure fair transactions between main
subcontracting entrepreneurs and subcontractors. By complying with theselaws and related regulations, we will work to maintain and promote fair andfree competition.
(1) Compliance with Antimonopoly Act
We will not engage in cartels, bid-rigging, maintenance of resale prices,
abuse of superior bargaining position, or any other act in violation of the
Antimonopoly Act, and compete fairly and freely with other companies.
1) We will not engage in any unreasonable restraint of trade, such as
consulting or making agreements on prices, quantities, or production
facilities, or committing bid-rigging, among firms in the same industry or
in industrial associations.
2) We will not engage in any act that constitute unfair trade practices, suchas refusing to deal with specific firms (discount distributors, etc.) or new
entrants, or posing restriction on the buyer’s selling prices, in concert
with firms in the same industry or industrial associations.
(2) Compliance with the Subcontract Act

We do not use our superior bargaining position against our partners inmanufacturing contracts or repair contracts to request of them any unfair
trade practices or to delay our payments, or any other similar acts.
4. Protection of intellectual property rights
Intellectual property rights are the rights by which inventions, devices,manufacturing know-how, literary works and other creations of the mind, as
well as trademarks and other identification marks of business, are protectedby law. These include the industrial property rights covering patents, utility
models, trademarks, etc., copyrights on artwork, computer program, etc., aswell as trade secrets (technical or business information useful for businessactivities, such as manufacturing or marketing methods, that are kept secret
and that are not publicly known).
(1) Treatment of Sanyo Special Steel’s intellectual property rights
We recognize that the intellectual property rights of Sanyo Special Steelare important assets of the company, and will strive to properly exploit andpreserve such rights.
1) R egarding inventions arising from manufacturing and development
activities, we will file patent application without delay and take othermeasures to preserve our intellectual property rights.
2) R ecognizing that leakage of intellectual property rights and trade
secrets will harm the company’s interest and credibility, we will clearly
demarcate confidential information from the rest and make suchclassified management of information clear to third parties.
(2) Treatment of other firms’intellectual property rights
We will comply with the laws and regulations related to intellectual
properties and the Unfair Competition Prevention Act, and respect the
intellectual property rights owned by other firms as they were our own.
1) We will not for any reason obtain trade secrets owned by other firms
through theft or other illegal means, or exploit such secrets. Moreover,
we will never obtain or exploit them knowing that they have been, or
may have been, obtained through illegal means.
2) Even when we have rightly acquired information owned by other firms,
we will not implement any technologies published in the patent gazettewithout permission, make a copy of purchased computer software
without permission, or conduct any other act that infringes on theintellectual property rights of other firms.
3) We will conclude appropriate agreement before we exploit intellectual
property rights of other firms, and will not abuse them.

II. In relation with the Society
1. Ethical and legal compliance
As a member of the society, we will conduct business activities basedon social norms, social common sense, and, not to mention, laws andregulations. In particular, we will comply with laws and regulations in ourbusiness with regard to matters below, the violation of which would cause
serious consequences.
(1) Security Export Control
1) W e will not engage in exports of arms, weapons, or any relevant
technologies that would disturb the maintenance of world peace andsecurity.
2) With regard to export transactions, we will check the buyer’s corporate
profile and business activities, and confirm, based on our internal
regulations, that the products or technologies to be exported will not be
used in development or manufacturing of weapons of mass destruction.
As for export transactions and service transactions of products andservices that are controlled under relevant laws and regulations, we willtake necessary steps pursuant to relevant laws and regulations.
(2) Prohibition of insider trading
When we come to learn any insider information of Sanyo Special Steel,its subsidiaries, affiliates, or business partners while performing our work,
we will not buy or sell stock of those companies until such information
is officially made public. When buying or selling our own shares, we will
confirm in advance whether or not we are in possession of any insider
information.
(3) Treatment of acts of endowment and political contributions1) W hen making political contributions or endowments to variousorganizations, we will comply with the Public Offices Election Act, thePolitical Funds Control Act, and other relevant laws and regulations, andfollow legitimate procedures.
2) W e will obtain approval based on our internal regulations prior to
making political contributions or endowments.
3) W e will strictly avoid any act that may be mistaken to constitutecollusion with politics or public administration, or, not to mention,bribery, offer of illegal profit, or illegal political contribution.
2. Avoidance of relationship with anti-social forces
We will stay out of any relationship whatsoever with individuals ororganizations that adversely affect social order or impair sound corporate
activities. Moreover, we will take a firm stand against such antisocial forces
without fear.
(1) T o ensure that we do not get involved in any unlawful or antisocial
behavior, we will hold basic knowledge of the law, social common sense
and a sense of justice, and act according to good common sense at all
times.
(2) W e will stand firm against antisocial forces and refuse to have any
relationship whatsoever with such forces. In addition, if we receive any
unreasonable demands from antisocial forces or the like, we will face itwith a firm attitude and will not try to settle the situation by offering moneyor through provision of other unreasonable benefits.
(3) We do not make use of antisocial forces in order to gain benefit for thecompany or ourselves.
(4) W e will not engage in any transaction whatsoever with antisocial forces orwith any business partners that are associated with antisocial forces.

3. Disclosure of corporate information(1) We will disclose corporate information to our shareholders, investors,
customers, business partners, the local community and others in a timely
and appropriate manner and strive to communicate with the society at all
times and improve the transparency of our management. We will also pay
careful attention to protecting and administrating information including
personal information and customer information.
(2) When disclosing financial statements and other corporate information,
we will make every effort to streamline and enhance appropriate internal
control that secure the reliability of such information.
4. Environmental conservation and protection
Recognizing that we are drawing various benefits from the earth including
resources, energy and other factors needed in our business activities, we will
make every effort to preserve the global environment in a better possible
condition.
(1) We will strive to produce environmentally friendly products, control waste
generation, and ensure proper waste disposal, while fully recognizing theimportance of environmental protection and complying with conventions,laws and regulations related to the environment at all times.
(2) We will work to improve our environmental consciousness and actively
participate in environmental protection activities for energy conservation
and recycling, among others.
5. Social contribution
As a corporate citizen, we will serve our social role through businessactivities and also actively participate in social contribution activities
including support of culture and art, cooperation with local communities,
volunteer activities, among others, and thereby contribute to social
development.

III. In relation with employees
1. Respect of personality and individuality(1) R espect of personality and individuality
We will pay respect to the personality and individuality of each andevery person, and aim to foster personnel for expertise, creativity andindependence.
(2) R espect of human rights and prohibition of discriminatory acts
We will respect the human rights of each and every person, and do notdiscriminate anyone for their nationality, race, religion, gender, age, ordisabilities of any type, or any act that may lead to unjust discrimination.
 rivacy protection(3) P
We will respect the privacy of each and every person, and make every
effort towards proper management of personal information.
(4) Prohibition of harassment
We will achieve a fair and positive workplace that do not tolerateharassments.
 e will not commit unnecessary physical contact, sexual jokes, teasing,1) Wor any other act that constitutes sexual harassment.
2) We will not commit bullying, defamation, intimidation, or any other act
that constitutes power harassment.
2. Safe and healthy working environment
We will strive to secure a safe, worker-friendly, and sound workplace as wellas our mental and physical health.
(1) Safety and health in workplace
We will place the highest priority on securing safety and health, comply
with the laws, regulations and rules related to occupational safety andhealth, and endeavor to maintain a safe and healthy work environment.
Also, in performing work, we will train our sensitivity to predict hazard andto sense harm before it occurs, and react to them systematically.
(2) Compliance with laws and regulations related to labor
We will comply with laws and regulations related to labor and strive
to maintain and improve a safe, worker-friendly, and healthy work
environment.
(3) Disaster prevention
To prevent a disaster and stop the spread of damage, we will endeavor
to predict and gauge the scale of hazards that are forecast to occur in the
future, discuss countermeasures, develop manuals, and thereby maintainand improve our disaster prevention management system.
3. Prohibition of acts that impair the company’s interest
As corporate workers, we will perform our work with high ethical standards,
not to mention in compliance with internal rules.
(1) Compliance with working regulations
We will abide by matters set out in our working regulations and carry out
duties while maintaining order in the workplace. We will not commit any
unjust or dishonest act.
(2) Proper use of corporate assets
We will not make unjust use of corporate assets or mix private interest with
the interest of the company. We will not use corporate assets or expenses
for personal purposes.
(3) Proper use of information systems
We will closely protect IDs and passwords and watch out for theft,
manipulation, and breach of information, and, needless to say, we will not
use the company’s information systems for personal purposes.
(4) Prohibition of conflict of interest
We will give priority to the interest of the company and will not commit any
act that constitutes conflict of interest with the company.
End