OSG Company Ethics Pledge
Foreword
The OSG Company Ethics Pledge (hereinafter “Company Ethics Pledge”) is established for all senior
management and employees (hereinafter “all employees”) who work in OSG Inc. (hereinafter “OSG”)
or OSG group companies (hereinafter “OSG group”) to perform business activities based on social
common sense while complying with laws and social standards.
The Company Ethics Pledge consists of two sections, “Business Ethics Norms” and “Corporate
Action Standards.”
1. Business ethics norms: To establish a respectable and universal way of thought for the OSG
group and all employees for business activities.
2. Company action standards: To establish detailed codes of conduct for the OSG group and all
employees to observe the business ethics norms while performing business activities.

By following the Company Ethics Pledge, all employees in the OSG group shall fulfill the corporatesocial responsibilities, have pride and joy as employees of the OSG group while also being aware of the
responsibility that entails, and always perform their duties in accordance with the “Business Ethics
Norms” and “Company Action Standards.”

Business Ethics Norms
The OSG group’s basic business policy is as follows:
・The company will always be aware of it being a public institution of society, and will provide
products that customers appreciate.
・The company will provide employees with proper workplace postings and work for the
betterment of their lives.
・The company will work to provide steady dividends to the stockholders.
・The company will elevate its social trust, while securely running the company to develop
globally.
The OSG group has established 10 rules to follow and practice the basic business policy toobserve the Business Ethics Norms (hereinafter “the Norms”).
The OSG group and all employees will independently act inside and outside the country, and will
respect human rights and related laws based on the following 10 norms for creating a sustainable
society.
1. To win the trust and satisfaction of consumers and customers, we will develop and distribute
goods and services useful to the public while paying attention to safety and private customer
information.
2. We will perform transactions under fair, transparent, and free competition. We will also
maintain a normal and sound relationship with the government and administrators.

3. We will communicate not only with the stockholders, but also with the general public, andwill actively and fairly post company information.
4. We will respect the diversity, personality, and individuality of the employees, and will provide
an environment that is safe and easy to work in to realize flexibility and prosperity.
5. Efforts to solve environmental problems are common to all of humankind. We will recognize
this as crucial to the existence of the company and its activities, and will independently andactively work on this subject.
6. As “model corporate citizens,” we will actively make positive contributions to society.
7. We will stand firmly against any and all anti-social powers and groups that would harm thesecurity and stability of the general public.
8. Regarding international business activities, we will not only respect and abide by internationalrules and local laws, but we will respect local cultures and customs, and will seek to performbusiness that contributes to local development.
9. Senior management will recognize that their purpose is to implement the spirit of the company
standards, and in addition to setting an example worth following, they must be aware of allgroup companies and customers. Also, we must always take notice of all voices inside andoutside of the company, and be thorough in standardizing the company ethics while making
the company structure effective.
10. When an incident that goes against the existing standards occurs, senior management will
announce to the whole company that they will take part in solution of the problem, discover
the cause, and take measures to prevent future reoccurrences. Also, they will promptly andaccurately release information to the public, and understanding their own responsibility andauthority, they will decide on the appropriate punishment for the action, which may also apply
to them.

Corporate Activity Standards
To realize the “Business Ethics Norms” in the company’s activities, we have proposed thefollowing “Corporate Activity Standards” (hereinafter “the Standards”). The “Business Ethics Norms”
determine a respectable way of thought when the company plans its actions. The standards are based on
the norms, and establish the basis on how the OSG group, employees, and supervisors can apply this in
their daily work.

1.

To win the trust and satisfaction of consumers and customers, we willdevelop and distribute goods and services useful to the public while paying
attention to safety and private customer information.

1.1 Concerning distribution and safety of quality goods and services
There is no doubt that the goods and services distributed by the OSG group, are demanded by
the general public, and this, needless to say, is the foundation of the OSG group. To strengthen
this foundation, we will create value for customers by striving to increase our development andproduction skills.

Also, to have products and services with superior value, the system itself must be safe, and mustnot be harmful to life, health, and property. The OSG group will put forth maximum efforts toattain this goal.

1.1.1 Knowing the exact needs of the client
Each individual employee will pay attention to the movement of the markets, and must be
prepared to quickly respond to the clients’ needs. This especially concerns the OSG group
because there are few products geared toward the general consumers, and this makes it
necessary to precisely and actively understand the needs of the clients.

1.1.2 Laws concerning safety, and following the guidelines
There must not be any damage to the customer’s life, health, and property due to any flaws in
our products. To secure our products’ safety, we must consider the safety of our products
from the development stage, and continue to do so through design, production, distribution,and finally the sales stage. Also, when laws and public guidelines are present, they are to bestrictly obeyed.

1.1.3 Strictly following the self imposed standards
In any areas that have neither imposed laws nor public guidelines, we will plan new standards
for the safety of the respective products, and will follow those rules.

1.1.4 Damage control
When a flaw is discovered in a product, we must act quickly to prevent the losses fromincreasing. We must quickly report this to the users of the product, and must follow therequired recall procedures. The OSG group’s responsibility is to prevent damage fromspreading, and we must embrace that responsibility.

1.1.5 To prevent reoccurrence
When a flaw occurs in a product, we must discover the cause and eliminate it, or the error
may be repeated. Finding the cause of the accident/flaw and appropriately storing the records
will prevent similar accidents in the future. Each supervisor in their respective departments
must work to have quick access to such records.

2.

We will perform transactions under fair, transparent, and free competition.
We will also maintain a normal and sound relationship with the government
and administrators.

2.1 To preserve and promote fair and free competition
The antitrust laws will preserve free competition, protect the consumers’ profits, and secure thesafe development of the national economy. Through cartel actions such as price and sales
control between corporations, the damage the company takes by such violations is incalculable,
not only from the federal sanctions, but also from the damage to the reputation of the company.
When concerning business, the OSG group will abide by domestic and foreign antitrust laws.

Also, the procurement division must not abuse its advantageous position and force any unfair
transactions onto their customers, as is forbidden by subcontracting laws.

2.2 To have a sound and favorable relationship with the customers and allother related personnel
The OSG group will severely punish anyone that obtains or provides any unfair advantages.
Each employee must act using proper judgment and common sense, as misunderstanding anddisapproval is not desired in any case.

2.2.1 Relationship with customers
All entertainment and gifts for customers will be done within the bounds of social common
sense. Also, any and all selfish rebates (ex: discounts) and commissions are forbidden. Anycompany rewards given out must fall within the company rules.

2.2.2 Relationship with vendors
When deciding on vendors, we must base this on rational factors such as price, quality, andpunctuality. Any gifts from the vendors must be within the boundaries of social common
sense, and anything exceeding those limits must promptly be denied and returned.

2.2.3 Relationship with related companies and allied companies
When dealing with related and allied companies, third parties must see this as afair and transparent transaction. We must make every effort to make sure these
relationships do not differ from the norm. Also, any business entertainment must
be within social common sense.

2.2.4 Prohibition of anti-profit behavior
We will not let an employee’s profit conflict with the company’s profits, or perform any
activity that may cause a conflict. If there is a possibility of such event occurring, or if an event
has occurred, it will be reported to management or related divisions.

2.3 Protection of intellectual property rights
Intellectual property rights are rights related to anything associated with products created from
intellectual activity and business operations. Aside from any patents, new practical ideas,
designs, industrial trademarks, copyrights related to artistic works, and computer software thatare specifically defined by law, also included in the OSG company are the know-how,
technology, and management information that companies maintain privately.
Intellectual property rights are the source of all company value, and are protected worldwide.
All of our employees must do their best to create and protect the OSG group’s intellectual
property rights. Also, we must be cautious in not interfering with the intellectual property
rights of others.

2.3.1 The OSG group’s treatment of related company secrets
There are some company secrets that may or may not have physical value, but the OSG
group’s profits and trust can be lost when company secrets are leaked. This applies whether it
be solid goods, electrical data, or by word of mouth. The most important point of managing
company secrets is to decide what information is necessary to be stored as classified
information, and to display the level of classification in a way that is understandable to any
third party.

2.3.2 Handling intellectual property rights of others
The OSG group will treat the intellectual property rights of others with the same respect astheir own. Also, when any illegally obtained outside company secret is used, it is not only inviolation of intellectual property laws, but there is a possibility of going against the Unfair
Competition Act and other civilian laws. Therefore, taking great caution is necessary.

2.3.3 Securing of company property
We must not illegally use the company’s internal information system and tangible andintangible company property. Also, when an employee retires, the employee will return allcompany property, and all business-related classified information and documents. The
employee must not display or leak any business classified information obtained during
employment without permission from the company.

2.4 Foreign exchange and foreign trade laws
All employees associated with the export business must be thoroughly acquainted with the trade
rules manual, act accordingly to it, and must perform business without any foreign exchange andforeign trade rule violations.

2.5 Relationship with the government and administrators
2.5.1 Laws against bribery
Whether government employees work inside or outside the country, it is forbidden tocontribute any illegal provisions to them.

2.5.2 The Political Financial Adjustment Act and the Public Office Election
Act
We will respect and follow the Political Financial Adjustment Act and the Public OfficeElection Act, and will assure company fairness in political activities.

3.

We will communicate not only with the stockholders, but also with thegeneral public, and will actively and fairly post company information.

3.1 The Financial Products Transaction Act
We must follow internal company act no. OES3501 “Rules on timely release of important
information and prevention of insider trading.” It is forbidden to sell or buy any related stocks
before the release of important company information that might affect the decisions of investors.

3.2 Posting of information
The OSG group must release the information the public truly desires in a timely and appropriatemanner, excluding classified company information and classified obligations designated bycontract. We will maintain constant communication with the public, will not go beyond thebounds of social common sense, and company activities will stay fair and transparent. It goes
without saying that the information the public wants does not exactly correspond with theinformation that is required by law. The customers, clients, employees, stockholders, investors,
and local organizations must perform their duties related to the OSG group, and must openly
release all necessary information. The employees must confirm what information certain people
need through daily communication, and must treat them with respect.

4.

We will respect the diversity, personality, and individuality of the employees,
and will provide an environment that is safe and easy to work in to realize
flexibility and prosperity.

4.1 Respecting the employee’s personality and individuality
The OSG group will respect each employee’s personality and individuality, and will do its best to
construct a personnel system and labor standard that will provide prosperity and sense ofachievement. Also, we will judge employees fairly on results and achievements alone, and willgrow talent full of creativity and proficiency.

4.2 Respecting privacy
The OSG group will respect employees’ privacy, and when handling personal information, it will
follow internal company act OSG3502 “Private Information Protection Act.” When conducting
business activities, properly handling and keeping information is the basis of company trust. We
must understand the importance and usefulness of this information, and we must give our utmost
care administering this.

4.3 Respecting human rights and abolishing all types of segregation
The OSG group will assure a work environment that will neither offend nor discriminate by race,
belief, skin color, sex, religion, nationality, language, physical appearance, wealth, or birthplace.
We must especially pay attention to sexual harassment, which we strongly disapprove of as acompany. When such problems occur, we must quickly investigate the case, provide aid to thevictim, and work for resolute prevention.

4.4 Guaranteeing a safe and healthy work environment
The OSG group will place worker health and safety first in all business activities, beginning withproduction machinery, to parts, to usage of materials, and up through disposal. Therefore, wemust organize the internal company rules, manuals and production standards, and observe allrespective laws.

4.4.1 Elimination of work accidents
The safety and health of the people are irreplaceable. To eliminate work accidents, we must
not only issue the respective acts, but also observe the rules of safety supervision. Also, when
performing daily work, we must periodically conduct education programs to detect andeliminate danger and possible harm, and must organize these actions at a group level.

5.

Efforts to solve environmental problems are common to all of humankind.
We will recognize this as crucial to the existence of the company and its
activities, and will independently and actively work on this subject.

5.1 Earth environmental safety
The OSG group has been receiving many benefits from this Earth, including the resources andenergy needed for its business activities, thus we must understand that it is our duty to maintainthe Earth’s environment in good condition, and make this one of our chief management subjects.
Therefore, while observing the environmental laws, we must do our best to make our products
and services affect the environment as little as possible, and will continue and strengthen ourenvironmental conservation activities.

5.1.1 Environmental protection and hazard countermeasures
Observance of environmental laws is an obligation for a company to the regional
community. We will use the company standards for environmental conservationin our business activities for the safety of both the OSG group’s and local area’s
environment. Each individual worker will once again check the hazard
countermeasure procedures related to their work, in order to prevent damage
from spreading if an actual disaster occurs.

6.

As “model corporate citizens,” we will actively make positive contributions
to society.

6.1 Contributing to the local community
We will closely cooperate with the local community, and will maintain good relationships. Also,
to interact with the community, we will perform sports activities, and other volunteer programs,

and will actively strive to be a “model corporate citizen.”7.

We will stand firmly against any and all anti-social powers and groups thatwould harm the security and stability of the general public.

7.1 No presence of ties with anti-social powers
The OSG group will have absolutely no ties with any individuals and groups that will affectsociety and the company’s well-being. Also, all employees and managers will not fear thesegroups, and will face them resolutely.

8.

Regarding international business activities, we will not only respect andabide by international rules and local laws, but we will respect local culturesand customs, and will seek to perform business to contribute to local
development.

8.1 Pertaining to overseas business activities
While economic globalization and elimination of economic borders progress, for the OSG
group to conduct business smoothly overseas, it must observe international rules and local laws,
and must contribute to the development of the local area. Also, not only must we research therespective country’s laws and observe them, the local companies must understand the Unfair
Competition Prevention Law (illegal to offer profits to overseas government officials), anddomestic laws such as overseas exchange laws. The OSG group will understand the social
situation and its problems, and will act upon fair knowledge of the local culture and customs. In
addition, by having the company locally supply its materials and parts, and throughtechnological guidance and technology transfers, we will work to develop the local industry.
We will also work to localize management.

9.

Senior management will recognize that their purpose is to implement thespirit of the company standards, and in addition to setting an example worth
following, they must be aware of all group companies and customers. Also, wemust take notice of all voices inside and outside of the company, be thoroughin standardizing the company ethics, and make the company structure
effective.

9.1 Internal and external awareness and institution
We will post the Company Ethics Pledge on the intranet, and will make it known to all. We will
also post it on the OSG group’s homepage, and make it available universally through theInternet. Also, when needed, we will execute the proper training regarding compliance with

laws and regulations accordingly.

9.2 Enforcement plan
Whenever the Company Ethics Pledge must be enforced, employees are urged to confer with
their superiors and thoroughly discuss how to resolve any issues. The superiors must actively
take in this advice, clarify the root of the problem, and must quickly improve on it. Also, when aproblem cannot be solved within the division, or cannot be solved by discussion with superiors,
we will create a special branch for queries, and will take questions directly from the employees.
When an immediate solution is needed, the risk and compliance supervision team will actively
pick this up.

9.2.1 The risk and compliance supervision teamIn the case of a serious violation, the risk and compliance supervision team is given the power
to report to the board of directors. The division risk management leader must report theCompany Ethics Pledge’s present situation in writing separately, and must periodically reportto the risk and compliance management office.

9.2.2 The division/subsidiary risk management leader
A risk management leader (division leader/center leader/room leader) will be placed in eachdivision to plan to effectively execute the Company Ethics Pledge. A subsidiary risk
management leader (the manager of the subsidiary) will supervise the subsidiary’s risk
management. If any problems concerning the Company Ethics Pledge occur, thedivision/subsidiary risk management leader will discuss with the risk and compliancesupervision committee, and will perform the appropriate improvements.

9.2.3 Ethics advisory branch
When a problem cannot be solved within the division alone, or when it would not beappropriate to discuss it with one’s superiors, we will create an “Internal Report Helpline” in
the OSG company for all the employees to discuss directly with the risk and compliancemanagement committee.

9.2.4 Establishing, amending, and abolishing Company Ethics Pledge
The establishment, amendment, or abolishment of the Company Ethics Pledge shall be inaccordance with a resolution from the OSG board of directors.

10. When an incident that goes against the existing standards occurs, senior
management will announce to the whole company that they will take part insolution of the problem, discover the cause, and take measures to prevent
future reoccurrences. Also, they will promptly and accurately release
information to the public, and understanding their own responsibility andauthority, they will decide on the appropriate punishment for the action,
which may also apply to them.
10.1 Involvement with senior management
When a violation of the Company Ethics Pledge occurs, senior management must show
strong leadership to prevent damage from spreading and to maintain social trust. Also,
they must take the lead and quickly investigate the cause, take preventive measures, andshow appropriate actions as a responsible company. If the health or lives of any
employees are in danger, they must quickly and accurately announce an explanation.
Also, the position of responsibility will also be quickly identified, and they will issue
punishment on themselves.

10.2 Company Ethics Pledge violator punishment
Any violation of the Company Ethics Pledge through ill intentions or gross negligence will bestrictly punished in accordance with employment regulations of the OSG group, and lawsuits
demanding reparations for any economic damage may occur.
2008.03.28 Newly established