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EAA COMPANY LIMITED COMPLIANCE CODECOMPLIANCE PRINCIPLES
1. Integrity
To ensure that independence, impartiality and integrity is maintained, no staff
member is to be pressured either externally or internally in any way that would
influence the quality of an inspection performed, or decisions relating to aninspection.
1.1 Guidance for Employees for dealing with clients who expect special treatment or
waiving of proper standards of business/services operation is as follows:
1.2 Staff member is to immediately inform the person from whom pressure is being
applied that, in accordance with the Company Compliance Code, this incident will
be documented and recorded.
1.3 The inspector is to immediately notify their supervisor who will direct the inspector
how to handle the situation.
1.4 The incident is to be documented by completing a corrective action request (CAR)
form and sent to the Technical Manager immediately. (see Appendix A for CAR
example form).
1.5 Reminder for all Employees of the need for strict adherence to contracted
requirements for inspection services and conduct.
2. Conflict of Interest
2.1 EAA Company Ltd employees or its Directors or any associated companies shall not
be associated with activities that may suggest or be deemed to conflict with ourinspection or certification services. Such conflicts include but not limited to repair
works, exportation, importation, shipping and freight logistics businesses.
2.2 EAA Company Ltd employees or its Directors or any associated companies shouldhave no conflict that may affect the quality, the responsibility or authority of his/herwork.
2.3 EAA Company Ltd employees or its Directors or any associated companies should
not directly or through relatives, friends or intermediaries, acquire an interest in asupplier, a client or a competitor of the Company.
2.4 EAA Company Ltd employees or its Directors or any associated companies should
not hold any position with a competitor or client.
2.5 EAA Company Ltd employees or its Directors or any associated companies should
not conduct any company business with any member of their family or with anindividual or organisation with which they or their family is associated.
2.6 EAA Company Ltd employees or its Directors or any associated companies shouldnot employ a member of their family without approval of EAA’s management.
3. Confidentiality and Data Protection
3.1 EAA requires each employee to sign a Non-Disclosure Agreement which prohibits
the disclosure of any confidential business information, obtained during his/her
employment, to other parties. (See Appendix B example attached).

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3.2 EAA will ensure that all intermediaries, joint venture partners, agents,
subcontractors, franchisees, contractors, and suppliers are made aware of theconfidential nature of business information that they may handle through theirdealings with EAA, and that they should not disclose confidential information toother parties. (See Appendix C attached as example letter to all above mentioned
parties).
4. Anti-Bribery
4.1 Compliance with Laws - EAA will ensure that the Principles and Rules of ourInspections Program meet the requirements of this Code and all local laws relevant
to countering bribery in all the jurisdictions that we operate. In the event that thelocal laws specify additional or different requirements, which are not covered by
our Programme, EAA will modify our Programme for the country(ies) concerned.
Records will be kept of countries where our Programme has been modified.
4.2 Analysis of Risks - EAA's Compliance Committee and/or our senior executive, or hisdelegate, in each country of operation must organise periodic reviews to assess
bribery risks and determine appropriate control measures. Such reviews will besystematically conducted:
i. Prior to the commencement of any new service or the start-up of operations in
a new country andii. Whenever a significant breach of EAA's Programme which warrants a review ofthe existing control measures occurs.
4.3 Business Principles for Countering Bribery – EAA will employ good businesspractices and risk management strategies in accordance with the Business Principles
for Countering Bribery as published by Transparency International and Social
Accountability International (see www.transparencv.orgj). These will address thefollowing areas:
4.3.1 Political contributions - EAA, its employees or agents will not make direct orindirect contributions to political parties, organisations or individuals engaged inpolitics, as a way of obtaining advantage in business transactions. EAA will accountfor all its political contributions in a separate ledger and consolidate all suchpayments made by any of the operations that form part of our organisation.
4.3.2 Charitable contributions and sponsorships – EAA will ensure that charitable
contributions and sponsorships are not being used as a subterfuge for bribery. We
will account for all charitable contributions or sponsorships in a separate ledger andconsolidate all such payments made by any of the operations that form part of ourorganisation.
4.3.3 Facilitation payments - Facilitation payments are defined as small payments madeto secure or expedite the performance of a routine or necessary action to which thepayer of the facilitation payment has legal or other entitlement. Recognising thatfacilitation payments are a form of bribery, EAA will work to identify and eliminatethem.

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4.3.4 Gifts, hospitality and expenses – EAA prohibits the offer or receipt of gifts,
hospitality or expenses whenever such arrangements could affect the outcome ofbusiness transactions and are not reasonable and bona fide expenditures.
5. Fair Business Conduct
5.1 EAA will provide guidelines to employees, agents and intermediaries to ensure thatthey understand and adhere to the Principle governing fair business conduct.
5.2 EAA maintains a Fair Business Conduct policy prohibiting:i. Making untrue statements about competitors, their operations, services or serviceofferings.
ii. Activities contrary to rules for fair competition, anti-trust or tenderingiii. Inciting, inducing or encouraging any person to breach its contractual obligations(including obligations of confidentiality)
iv. Commercial espionage and/or data theft
v. Negative or punitive reaction to ‘Whistle-blower’
5.3 EAA maintains a specific helpline/advice system to further encourage employees toreport any instances where a code of compliance breach has been observed. The
following email address has been created for such use: help@eaa-s.jp
5.4 EAA's presentations and publications will accurately and unambiguously reflect ournetwork and affiliations, resources/capabilities, experience, and services provided.
6. Health and Safety
6.1 EAA maintains a policy on Health & Safety that meets all legal requirements.
6.2 EAA will provide Health & Safety training to our employees appropriate for theactivities they are engaged in.
6.3 EAA will encourage employees to report Health & Safety related incidents, record
these incidents, investigate these incidents and if required, take correctivemeasures.
7. Fair Labour
7.1 EAA maintains a policy on fair labour.
7.2 EAA’s policy confirms our commitment to the following:i. Compliance with at least minimum wage legislation and other applicable wage andworking time laws.
ii. Prohibition of child labour - strictly prohibit the use of child labour.
iii. Prohibition of forced and compulsory labour - prohibit all forms of forced labour,whether in the form of prison labour, indentured labour, bonded labour, slave
labour or any kind of non-voluntary labour.
iv. Respect of equal opportunities in the workplacev. Zero tolerance of abuse, bullying or harassment in the workplace.

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8. Compliance Officer
EAA has nominated our Administration Officer as our Compliance Officer, who, irrespectiveof his/her other responsibilities shall have responsibility and authority for the co-ordinationof the implementation of the Compliance Programme throughout the EAA'sorganisation/company. The Compliance Officer may nominate delegates to perform someor all of his/her functions within specified parts of our organisation.
9. Compliance Committee
EAA has established a Compliance Committee to carry out periodic reviews of the progressof the Compliance Programme and provide policy guidance. Our Compliance Committee
consists of four members including the Chief Executive Officer, General Manager,
Compliance Officer, and Manager Administration.

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