SIIX GroupCSR Procurement Guidelines（1st Edition）

1st June 2022
SIIX Corporation

1

Introduction

With the globalization of corporate activities and the complexity of the supply chain, we, the SIIX Group,
respect human rights and comply with laws and regulations throughout the supply chain.
We believe that it is important to actively work on CSR, “Corporate Social Responsibility,” to realize asustainable society.
However, this cannot be achieved without working together with our business partners, so we have establishedthe SIIX Group CSR Procurement Guidelines as one of the means to promote our activities.
In order to fulfill the social responsibility of the supply chain, we, as one of the suppliers, would like to ask
our business partners for understanding and support of our activities, and to inform your business partners ofthese guidelines.
We appreciate your cooperation toward the realization of a better society.

Procurement & Logistics Department
SIIX Corporation

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SIIX Group CSR Procurement Guidelines

Table of contents

1

Respect for Human Rights and Labor

1-1

Respect for Human Rights ........................................................................................................................ 6

1-2

Prohibition of Forced Labor and Respect of Freely Chosen Employment .............................................. 6

1-3

Prohibition of Child Labor and Consideration for Young Workers......................................................... 6

1-4

Working Hours, Day Off, and Annual Leaves ......................................................................................... 7

1-5

Wages and Benefits ................................................................................................................................. 7

1-6

Humane Treatment.................................................................................................................................... 7

1-7

Elimination of Discrimination and Harassment ....................................................................................... 8

1-8

Freedom of Association and Collective Bargaining ................................................................................. 8

2

Occupational Safety and Hygiene

2-1

Occupational Safety .................................................................................................................................. 8

2-2

Emergency Preparedness .......................................................................................................................... 9

2-3

Occupational Injury and Illness ................................................................................................................ 9

2-4

Industrial Hygiene ..................................................................................................................................... 9

2-5

Attention to Physically Demanding Work.............................................................................................. 10

2-6

Machinery and Equipment Safeguarding ............................................................................................... 10

2-7

Sanitation, Food and Housing ................................................................................................................. 10

2-8

Health and Safety Communication ......................................................................................................... 10

3

Environment

3-1

Environmental Permits and Reporting.................................................................................................... 11

3-2

Pollution Prevention and Resource Conservation Activities.................................................................. 11

3-3

Hazardous Substances ............................................................................................................................. 11

3-4

Solid Waste.............................................................................................................................................. 11

3-5

Air Emissions .......................................................................................................................................... 11

3

3-6

Chemical Substances Management ........................................................................................................ 12

3-7

Water Management ................................................................................................................................. 12

3-8

Energy Consumption and Greenhouse Gas Emissions .......................................................................... 12

3-9

Conservation of Biodiversity .................................................................................................................. 12

3-10 Establishment of Environmental Management System ......................................................................... 12

4

Corporate Ethics and Compliance

4-1

Prohibition of Corruption, Bribery, etc. .................................................................................................. 12

4-2

Prohibition of the Offer or Acceptance of Improper Advantages .......................................................... 13

4-3

Disclosure of Information ....................................................................................................................... 13

4-4

Respecting Intellectual Property Rights of Others.................................................................................. 13

4-5

Fair Business, Advertising and Competition .......................................................................................... 14

4-6

Protection of Whistleblowers and Elimination of Retaliation ................................................................ 14

4-7

Responsible Sourcing of Minerals .......................................................................................................... 14

4-8

Privacy ..................................................................................................................................................... 14

4-9

Appropriate Export and Import Management ........................................................................................ 14

5Management Systems

5-1

Company Commitment ........................................................................................................................... 15

5-2Management Accountability and Operational Responsibility................................................................ 15

5-3

Legal and Customer Requirements ......................................................................................................... 15

5-4

Risk Assessment and Management ........................................................................................................ 15

5-5

Education and Training ........................................................................................................................... 15

5-6

Worker Feedback and Improvements ..................................................................................................... 15

5-7

Regular Review ....................................................................................................................................... 16

5-8

Communication, Cooperation Request and Confirmation to Suppliers................................................. 16

4

6

BCP・Supply Chain

6-1

Formulation and Management of BCP (Business Continuity Plan) ...................................................... 16

7

Information Security and Protection of Personal Information

7-1

Prevention of Information Leakage ........................................................................................................ 16

7-2

Protection against Threats on Computer Network ................................................................................. 17

8

Quality and Safety

8-1

Establishing Quality Management System ............................................................................................. 17

8-2

Providing Precise Information on Products and Services ...................................................................... 17

8-3

Ensuring Product Safety.......................................................................................................................... 17

9

Corporate Citizenship

9-1

Contributing to Society and Local Community...................................................................................... 18

5

1

Respect for Human Rights and Labor

1-1

Respect for Human Rights● Suppliers shall respect the human rights in compliance with international laws, regulations, and norms, and shall not
violate them.

1-2

Prohibition of Forced Labor and Respect of Freely Chosen Employment● Suppliers shall not engage in forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative
prison labor, slavery, or trafficking of persons.
● Suppliers shall not impose unreasonable restrictions on workers’ freedom on entering or exiting workplace or dormitories.
●In the case of foreign workers, suppliers shall provide them a formal contract in their native language, containing adescription of their working conditions, prior to the departure from the worker’s home country.
● Once the contract has been concluded with the foreign worker while at his or her home country, suppliers are prohibitedto make any unfair changes to the contract after his or her arrival at the working country.
● Suppliers shall permit workers to terminate their employment freely.
● Suppliers shall not retain any government-issued identification card, passport, work permit (unless such holdings are
required by law), immigration application, and other similar documents.
● Suppliers, temporary employment agencies, supply companies, and staffing agents shall not collect any recruitment feesfrom workers.
● Suppliers shall request and confirm that temporary employment agencies, supply companies, and staffing agents comply
with all the above items.

1-3

Prohibition of Child Labor and Consideration for Young Workers● Suppliers shall not employ any children (a child refers to a person under the age of 15, or under the completion age ofcompulsory education, or under the minimum employment age in the country, whichever the greatest).
● Suppliers shall not have workers under the age of 18 (Young Workers) perform the work which may jeopardize theirhealth and growth and expose them to danger, including any night shifts and overtime work.
● Suppliers shall ensure the appropriate support and education of student workers, and protect their rights, in accordancewith applicable laws and regulations.
● In the absence of the applicable local laws and regulations, the wage rate for student workers, interns, and apprentices
shall be at least the same wage rate as other workers performing equal or similar tasks.

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1-4

Working Hours, Day Off, and Annual Leaves● Suppliers shall ensure that the workers’ working hours, day off, and annual leaves are appropriately managed incompliance with local laws and regulations.
● If overtime work is performed even within the limits of relevant local laws and regulations, it shall be done upon theagreement with workers under the direction of their superior.
● Suppliers shall allow workers at least one day off every seven days.
● Suppliers shall entitle workers annual paid leave, maternity leave, parental leave, and time to rest as stipulated in relevant
local laws and regulations.

1-5

Wages and Benefits● Suppliers shall pay workers at least the statutory minimum wages and shall not unreasonably deduct from wages as
stipulated in relevant local laws and regulations.
● Suppliers shall comply with all applicable wage-related laws and regulations, including those relating to minimum wages,
overtime work, and legally mandated benefits. Compensation shall be paid without any delay.
● Suppliers shall not collect operational fees and costs from workers.
● Suppliers shall not deduct from nor reduce wages for the purpose of disciplinary action unless permitted by local laws
and regulations.
● Suppliers shall provide workers understandable and accurate wage statements that include sufficient information to verify
compensation for work performed by the date of payment.
● Suppliers shall provide workers with all social insurance stipulated in relevant local laws and regulations.

1-6

Humane Treatment● Suppliers shall respect the human rights of workers and shall not treat workers in harsh and inhumane manner, including
violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion,
bullying, public shaming, or verbal abuse of workers.
● Suppliers shall clearly define disciplinary policies and procedures and communicate to workers. In order to grasp the factof inhumane treatment, suppliers shall establish a consultation and whistleblower desk.

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1-7

Elimination of Discrimination and Harassment● Suppliers shall eliminate discrimination in recruitment and employment, and ensure equal opportunities and fairtreatment in application, recruitment, promotion, compensation, education, business grant, wage, welfare, punishment,
dismissal, retirement, etc. Suppliers shall not engage in discrimination or harassment based on race, color, age, gender,
sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, politicalaffiliation, union membership, covered veteran status, protected genetic information or marital status.
● Suppliers shall accommodate the needs of workers within a reasonable extent for religious practices.
● Suppliers shall not conduct any medical examination or physical examination that could be used in a discriminatory way.

1-8

Freedom of Association and Collective Bargaining● Suppliers shall allow the rights of workers to organize and join a labor union, as a means for workers to realize discussions
between labor and management such as working environment and wage level, in accordance with local laws.
● Suppliers shall not conduct any discrimination, reprisal, intimidation, or harassment against workers and/or theirrepresentatives.
● Workers and /or their representatives shall be able to communicate with management regarding working conditions andviews on management practices.

2

Occupational Safety and Hygiene

2-1

Occupational Safety● Suppliers shall identify potentially hazardous locations in the workplace (chemicals, electrical and other energy sources,
fire, vehicles, and fall hazards) and shall implement preventive maintenance and safe work procedures (including
lockout/tagout) and conduct training continuously.
*Lockout: Monitor hazardous points with sensor and shut off power sources of machine or equipment by locking thepower sources.
*Tagout: Indicate with a tag or other similar things that the operation of a power-blocked device is prohibited during thepower shut-off.
● Suppliers shall provide workers with appropriate personal protective equipment, such as eye protectors, safety hats, andgloves, and working environment, such as appropriate ventilation.
● Suppliers shall encourage workers to raise any unsafe areas.
● Suppliers shall provide safety and health related information (operation procedures, warnings, etc. of production
machinery), as well as safety and health training, in the worker's native language.

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● Suppliers shall remove pregnant women and nursing mothers from dangerous working condition and reduce any
workplace where contains health and safety risks for pregnant women and nursing mothers.
● Suppliers shall take reasonable care for nursing mothers, such as providing safe and clean place to breast-feed and store
milk.

2-2

Emergency Preparedness● To protect lives and personal safety, suppliers shall prepare emergency measures for possible disaster or accident andkeep everyone in the workplace informed.
● Suppliers shall install fire detectors and fire extinguishers appropriately.
● Suppliers shall display the evacuation route and evacuation shelters in the workplace.
● Suppliers shall remove any obstacle around or in front of the exits to secure the evacuation route for emergency.
● Suppliers shall develop the recovery plans in case of emergency.
● Suppliers shall provide evacuation education and drills either once a year, or as required by local relevant laws andregulations, whichever is more frequent.

2-3

Occupational Injury and Illness● Suppliers shall provide appropriate medical treatment in case of occupational injury and illness, investigate the root case,
implement measures, and keep records.
● Suppliers shall establish the procedures to facilitate the workers with occupational injuries and illness cases to return to
work.

2-4

Industrial Hygiene● Suppliers shall identify the biological and chemical substances, noises, offensive odors, etc. in the workplace that areharmful to the human body. The appropriate measures and workers’ health management shall be implemented.
● Suppliers shall provide medical examinations to workers pursuant to laws and regulations for the prevention and early
detection of illness.
● Suppliers shall also pay enough attention to prevent health damage and mental illness caused by long working hours or
overwork.

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2-5

Attention to Physically Demanding Work● Suppliers shall identify physically demanding work and appropriately control such work to prevent injury and illness
caused by them.
● Suppliers shall identify, evaluate, and control hazards and physically demanding tasks including manual material
handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks.

2-6

Machinery and Equipment Safeguarding● Suppliers shall take appropriate safety measures for machinery and equipment used at their own company.
● Suppliers shall take safety measures, such as physical guards, interlocks, and barriers, and perform appropriate
maintenance, where machinery and equipment could pose a hazard to workers.

2-7

Sanitation, Food and Housing● Suppliers shall appropriately ensure the health and safety of facilities (including dormitories, canteens, and toilets)
provided to workers for their livelihood.
● Suppliers shall provide workers with clean toilet facilities, potable water, and food cooked and stored in a clean
environment and canteens.
● Suppliers shall provide workers with individually secured accommodations for storing personal and valuable items, andreasonable personal space.
● Suppliers shall conduct evacuation drills for dormitories and clarify the evacuation route to secure workers’ safety.

2-8

Health and Safety Communication● Suppliers shall provide workers with appropriate workplace health and safety information and training.
● Suppliers shall display hazardous areas of the workplace and health and safety information in the facility by using thelanguage the workers can understand.
● Suppliers shall provide health and safety training with all workers prior to the beginning of work and regularly thereafter.
● Suppliers shall establish the process to enable workers to raise issues and concerns related to workplace health and safety.
Measures for improvement shall be taken promptly.

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3

Environment

3-1

Environmental Permits and Reporting● In accordance with local relevant laws and regulations, suppliers shall obtain approvals from the government office ifnecessary and comply with the required operation and reporting.
● Suppliers shall obtain all required environment permits, approvals, and registrations, keep them current, and follow theiroperational and reporting requirements.

3-2

Pollution Prevention and Resource Conservation Activities● Suppliers shall engage in resource conservation activities by reducing the usage of natural resources and using recycledresources and parts.
● Suppliers shall implement activities to reduce pollutants and wastes.

3-3

Hazardous Substances● Suppliers shall identify chemicals, waste, and other materials posing a hazard to humans or the environment and control
them properly as stipulated in relevant local laws and regulations.

3-4

Solid Waste● Suppliers shall implement rules regarding the identification, classification, storage, movement, and disposal of waste andmaintain them properly.
● Suppliers shall set voluntary reduction targets for waste and implement a systematic approach to responsibly dispose ofor recycle solid waste.
● Suppliers shall periodically evaluate whether the outsourced disposal company/carrier of hazardous waste is processing
according to the contract conditions.

3-5

Air Emissions● Suppliers shall comply with relevant laws and regulations and act appropriately to reduce harmful substances emitted
into the atmosphere.
● Suppliers shall analyze hazardous substances before they are discharged to the atmosphere. Based on the analysis results,
suppliers apply necessary treatments before they are discharged.
● Suppliers shall control ozone depleting substances in accordance with the Montreal Protocol and applicable regulations.

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3-6

Chemical Substances Management● Complying with related laws, regulations, and customer requirements, suppliers shall manage chemical substances(eliminate, reduce, label, etc.) and shall not use prohibited substances in products and manufacturing processes.
● Suppliers shall report appropriately to the government office based on laws and regulations.

3-7

Water Management● Suppliers shall comply with relevant laws and regulations and take necessary treatment before draining or disposing ofwastewater.
● Suppliers shall work to conserve water resources by taking measures to minimize water consumption.
● Suppliers shall be aware of water risks such as floods and water pollution.

3-8

Energy Consumption and Greenhouse Gas Emissions● Suppliers shall establish voluntary greenhouse gas reduction targets to improve energy efficiency and continuously
reduce energy consumption and greenhouse gas emissions.
● Suppliers shall grasp, record, and document the amount of energy consumption and related greenhouse gas emissions.

3-9

Conservation of Biodiversity● Suppliers shall evaluate the impact of business activities on the ecosystem and make efforts to minimize the negative
impact.
● In order to minimize the negative impact of business activities on biodiversity within the community, suppliers shallidentify risks to the ecosystem inside and outside the production bases and implement biodiversity conservation activities
properly.

3-10 Establishment of Environmental Management System● Suppliers shall establish Environment Management System, such as ISO14001.

4Corporate Ethics and Compliance

4-1

Prohibition of Corruption, Bribery, etc.

● Suppliers shall formulate and maintain policies that prohibit any bribery, corruption, extortion, and embezzlement.
● Suppliers shall establish a system for corporate ethics and legal compliance, disseminate and raise awareness toemployees, and monitor compliance status.
● All commerce should be transparent and accurately reflected in the company's accounting.

12● Suppliers shall provide in-house education to prevent corruption, corruption, bribery, etc.

4-2Prohibition of the Offer or Acceptance of Improper Advantages● Suppliers shall maintain a healthy and normal relationship with politics and administration, and not make bribes or illegal
political contributions.
● Suppliers shall neither directly nor indirectly entertain stakeholders, give gifts or money, nor receive them fromstakeholders for the purpose of acquiring or maintaining unreasonable profits or preferential treatment.
● Suppliers shall not act to provide inappropriate benefits to antisocial forces (antisocial individuals or groups).
● Suppliers shall not engage in insider trading based on important non-public information regarding customers and business
partners.
● In order to comply with the laws and regulations related to the prevention of bribery, suppliers shall educate and train
workers and monitor the status of compliance.

4-3

Disclosure of Information● In compliance with related laws and regulations, or general industry practices, information regarding business activities,
products, and services shall be transparently and appropriately disclosed to stakeholders.
● Suppliers shall not falsify records or disclose false information to stakeholders regarding business activities, financial
status, business performance, ESG information, etc.
● Suppliers shall not tolerate any falsification of information or misrepresentation in the supply chain.
● Suppliers shall disclose accurate information on the substances contained in materials and parts used in their products.
● Suppliers shall keep records of management indicators of environmental conservation activities, achievement of goals,
and other important environmental matters, and disclose information, as necessary.

4-4

Respecting Intellectual Property Rights of Others● Suppliers shall protect their intellectual property and respect the intellectual property rights of others without infringement.
● When developing, producing, selling, providing, etc. products and services, suppliers shall thoroughly investigate theintellectual property rights of others and do not use them without permission.
● Suppliers shall not allow customers’ and suppliers' intellectual property to be taken out when workers resign from thecompany.
● Suppliers shall not illegally or improperly acquire, use, disclose or leak confidential information.

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4-5

Fair Business, Advertising and Competition● Suppliers shall conduct fair business, advertising, and competition in compliance with international standards andindustry rules, and do not abuse dominant bargaining positions.
● Suppliers shall not engage in unfair transactions such as cartels, bid rigging, discriminatory pricing, discriminatorytransaction conditions, and unfair bargaining such as dumping and purchasing at an unreasonably expensive price.
● Suppliers shall not make false or misleading statements about their products or services.
● Suppliers shall not engage in unfair competition, such as making false or misleading indications regarding othercompanies' products.

4-6

Protection of Whistleblowers and Elimination of Retaliation● Suppliers shall establish rules to ensure and protect the confidentiality and anonymity of whistleblowers.
● Suppliers shall provide a means of reporting that allows workers to raise concerns without fear of retaliation.

4-7

Responsible Sourcing of Minerals● Suppliers shall formulate policies regarding responsible minerals procurement, and reasonably and continuously assurethat the tantalum, tin, tungsten, gold, and cobalt in products they manufacture does not directly or indirectly finance or
benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or its
neighboring countries.
● Suppliers shall conduct due diligence on the origins and distribution area of minerals and disclose the results of the due
diligence upon the request of customers.

4-8

Privacy● Suppliers shall act appropriately in consideration of the privacy of personal information of all relevant persons, including
suppliers, customers, consumers, and employees. When collecting, storing, processing, transferring, and sharing personal
information, suppliers shall comply with the requirements of laws and regulations regarding privacy and information
security.

4-9

Appropriate Export and Import Management● Suppliers shall follow proper export and import procedures, in compliance with international consensus and regulations.
● Suppliers shall establish a management system for import and export of technologies and goods (parts, products,
technologies, equipment, software, etc.) regulated by laws and regulations, and carry out appropriate import and export
procedures.

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● Regarding the import and export of technologies and goods regulated by international agreements (Wassenaar
Arrangement, etc.), suppliers shall perform the procedures for obtaining permits from regulatory agencies, as necessary.

5Management Systems

5-1

Company Commitment● Suppliers shall formulate corporate social responsibility policies endorsed by executive management and display it in thefacility in the local language.
● Suppliers shall disclose accurate information about company policies and activities to customers, suppliers, and workers.

5-2

Management Accountability and Operational Responsibility● Suppliers shall clarify and review regularly the operational status of the management system and the officer in charge.
● Suppliers shall conduct management reviews at least once a year.

5-3

Legal and Customer Requirements● Suppliers shall identify and manage laws, regulations, and customer requirements related to the guidelines, and maintainand update internal rules, as necessary.

5-4

Risk Assessment and Management● Suppliers shall establish a process to identify risks over these guidelines.
● Suppliers shall properly manage identified risks.

5-5

Education and Training● Suppliers shall conduct trainings for managers and workers to promote to follow these guidelines.
● Suppliers shall keep records of education and training and verify their effectiveness.

5-6

Worker Feedback and Improvements● Suppliers shall construct a system to effectively deal with problems and make continuous improvements, by assessing
the workers’ understanding, and obtaining feedback or report on violations of these guidelines.
● Suppliers shall appropriately address and make improvements on the issues raised.

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5-7

Regular Review● Suppliers shall prepare improvement targets and implementation plans for these guidelines and evaluate achievements
on a regular basis.
● Suppliers shall appropriately, and promptly correct deficiencies identified by internal or external evaluations, inspections,investigations, and examinations.
● Suppliers shall prepare documents and records based on relevant legislation as well as their internal management
requirements.

5-8

Communication, Cooperation Request and Confirmation to Suppliers● Suppliers shall communicate the requirements of these guidelines to their suppliers, request cooperation, and confirm
their compliance status.

6

BCP・Supply Chain

6-1

Formulation and Management of BCP (Business Continuity Plan)● To prepare for the large-scale natural disasters, accidents, and contingency situations, suppliers shall create BCP andbuild measures for stable supply (such as multi-sourcing and securing inventory).
● To ensure appropriate delivery time and stable supply, suppliers shall conduct investigations on their suppliers (such as
the country of origin of materials and emergency contact) throughout the supply chain.
● In the event of natural disasters, accidents, and contingency situations, suppliers shall establish a system to promptly
communicate to their business partners the damages confirmed to their production equipment, buildings, and workers, aswell as the impact on their production and procurement.
● Suppliers shall notify the EOL of parts within the period agreed in the contract.

7

Information Security and Protection of Personal Information

7-1

Prevention of Information Leakage● Suppliers shall provide education on information security to their employees on a regular basis.
● Suppliers shall establish organizational structure and procedures for the occurrence of information security incidents.
● When collecting, storing, processing, transferring, and sharing personal information, suppliers shall comply with laws
and regulations related to privacy and information security, and properly manage and protect confidential information.

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7-2

Protection against Threats on Computer Network● Suppliers shall implement protective action against threats on computer network to avoid any harm to their suppliers,
customers, consumers, and employees.

8

Quality and Safety

8-1

Establishing Quality Management System● Suppliers shall work to establish a quality management system and endeavor to acquire the ISO 9001 certification orother third-party certifications concerning the quality management system.

8-2

Providing Precise Information on Products and Services● Suppliers shall provide customers with precise information on specifications, quality, and handling procedures of theirproducts and services.
● In catalogues, advertisements, and other promotional materials of products and services, suppliers shall not use
expressions that are factually incorrect or may cause misunderstandings to customers. They shall not include any content
that defames other companies or individuals or infringes on their rights.
● Suppliers shall promptly report any changes in Man, Machine, Method, and Material (commonly called “4M changes”)
to their products.

8-3

Ensuring Product Safety● Suppliers shall comply with the requirements stipulated by laws and regulations regarding product safety.
● Suppliers shall establish management systems, including the following:・Ensuring traceability (taking records of materials, parts, and processes)
・Ensuring process to promptly respond to solve problems

Footnote: If the local laws and regulations in each country / region or customer requirements are stricter than the guidelines
above, those local laws, regulations, or customer requirements shall be followed.

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9

Corporate Citizenship

9-1

Contributing to Society and Local Community● Suppliers shall positively engage in activities that contribute to the sustainable development of international and local
communities.
● Suppliers shall work to reduce negative factors such as waste, taking care not to have a negative impact on the local
community.

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