NIDEC GLOBAL APPLIANCECOMPLIANCE
CODE OF CONDUCT

01 January 2020

The Nidec GA Code Of Conduct

Dear Global Appliance team,Nidec Corporation sets the “royal road of business management” as one of its
philosophies to grow healthily while contributing to a better society. To achieve it,
all divisions, including Nidec Global Appliance, must maintain a deep relationshipof trust with its stakeholders while conducting business with the highest standardsof ethics, integrity and compliant with laws and regulations worldwide.
In this sense, I invite you to invest time reading and understanding theCompliance Code of Conduct, a document that responds to the increasing
demand for compliance with Nidec’s globalization by giving guidance for all
executives and employees to make decisions and choices keeping the royal roadof business management.
As a Nidec Global Appliance employee, you have the responsibility to perform
your work activities in a transparent, open, respectful and honest manner. In case
you are aware of a potential or confirmed ethical issue, it’s your responsibility todisclose it through the Hotline, a channel provided to receive inquiries andconcerns on a confidential basis, or other resources listed in the next few pages.
By Nidec Global Appliance side, I can ensure that retaliation against thosereporting misconduct or concerns will not be tolerated.
I count on your commitment to keeping upholding our Code in everything we do.
Sincerely,

Valter Taranzano
CEO Nidec Global Appliance Division
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The Nidec Group’s business philosophy is to grow healthily and contribute to theglobal society (the “royal road of business management”). Our reputation forhonesty and integrity among our customers, shareholders, investors, and otherstakeholders is a key to the growth and prosperity of the Group. We will notachieve any results through violations of laws or regulations or throughunscrupulous business transactions.
This Nidec Group Compliance Code of Conduct (this “Code of Conduct”) alongwith Nidec Global Appliance Compliance Policies provides for specific guidance
for all Nidec Global Appliance executives and employees to comply with not only
domestic/foreign laws, rules and regulations but also social rules, ethics, etc. inthe Company’s daily business activities, in order to keep the royal road ofbusiness management and in response to the increasing demand for compliancewith Nidec’s globalization.
This Code of Conduct will apply to Nidec Corporation, its consolidated companies,
and all of their executives and employees after undergoing these companies’
required procedure.

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THE BASIC PHILOSOPHYThe Seven Compliance Principles
We hereby establish the following “Seven Compliance Principles” as the basic
philosophy of this Code of Conduct, and, as the global society’s legal, regulatory,
and corporate requirements change with the times, we will always keep in mind
the spirit of the Principles, promote healthy business activities, and stay on the“royal road of business management” as a global manufacturer that contributes
to establishing a sustainable society.

1. We will comply with all laws and regulations and act based on noble businessethics.
2. We, as a global manufacturing company, will ensure we produce defect-freeand quality products.
3. We will ensure we disclose timely and accurate information.
4. We will ensure we properly manage and use Company information andassets.
5. We will ensure we keep our work environment safe and comfortable.
6. We will compete freely and fairly, and we will not engage in any
anticompetitive conduct.
7. We will ensure we create and maintain a compliance system that is necessary
and sufficient to comply with the Nidec Group Compliance Code of Conduct.

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1. COMPLIANCE WITH ALL LAWS, REGULATIONS, AND BUSINESS ETHICS

We will comply with all laws and regulations and act based on noble businessethics.

Staying on the “royal road of business management”
We must recognize ourselves as members of the international society, comply
with each country’s domestic and international laws and regulations, fulfill theCompany’s social responsibilities based on high business ethics and stay on the“royal road of business management.”
We will avoid acts that can be misunderstood by society as improper or against
corporate ethics.

Respecting basic human rights and banning discriminatory
treatments
In all of our business activities, we must respect basic human rights, and not
engage in any discriminatory treatment.

Ban on bribery, etc., and maintaining transparent political andgovernmental relations
We must maintain healthy and transparent political and governmental relations.
Inside or outside our country, we do not provide or promise any improper money,goods, or any other economic profit to any government officials or thoseequivalents.

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Ban on insider trading
We do not engage in any act that violates insider trading regulations, such as
trading in the Company’s securities while in possession of material non-public
information regarding the Company and/or tip or pass on inside information toany other person.

Environmental protection
We realize that global environmental protection is a social responsibility of a
global company, comply with individual countries’ environmental regulations, use
resources proactively and effectively, and make sure to conserve energy.

Securing self-correcting functions
If we identify any violation of laws, regulations, internal rules, etc. by ourexecutives or employees, we will correct such violation immediately, and strictly
handle such violation.

Compliance with this Code of Conduct
We recognize that we must comply with this Code of Conduct and that any
violation of this Code of Conduct may result in a disciplinary action, etc. basedon applicable laws, regulations, internal rules, etc.

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2. SECURING PRODUCT SAFETY AND QUALITY

We, as a global manufacturing company, will ensure we produce defect-free andquality products.

Securing product safety
To secure the safety of our products, we must comply with each country’srelevant laws, regulations, rules, etc. on product safety, quality and reliability, andotherwise properly ensure the safety of all of our products.

Prevention of misrepresentation, accidents and disputes
We will not present or advertise any information in any misleading way to ourcustomers, and we will do our very best to prevent accidents and disputes by
preparing easy-to-understand specifications, user manuals, etc.
If a defect is found or suspected in any of our Company’s products, we must
report it to an appropriate senior officer and must consider the product user’sinterest as the first priority. We must also immediately take all actions tominimize negative consequences such as quickly communicating the defect tothe product’s users.

Providing high-quality products
To respond to society’s and our customers’ expectations, we will ensure that we
efficiently produce and supply high-quality products.

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3. PROPER INFORMATION DISCLOSURE

We will ensure we disclose timely and accurate information.

Timely disclosure of Company information
To ensure our business management’s transparency, we will disclose ourCompany information to our shareholders, investors, and other stakeholders
proactively, timely, properly, and coherently as a listed company.

Accurate recording and document filing
We will properly record all work-related information based on laws, regulations,internal rules, etc., ensure that no misleading or false statement or error will be
on internal documents, and comply with the rule of keeping such documents fora specific period of time.

Proper accounting and account reporting
We must always ensure accuracy of our Company’s accounting reports basedon the proper accounting in compliance with relevant laws, regulations, andstandards.

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4. PROTECTING AND PROPER USE OF COMPANY INFORMATION ANDASSETS
We will ensure we properly manage and use Company information and assets.

Treating confidential information
Company information and assets includes all Nidec Group Companies’
information and assets.
We must strictly manage personal information and other confidential informationof the Company both during and after employment, based on internal rules, etc.
to prevent improper disclosure or leak of such information, and we will not use
such information either improperly or unfairly.
We will not unfairly obtain any information on our customers, suppliers or any
other business partners, etc., and will use such information we properly obtainedin the course of business only for fair purposes.

Appropriate management of Company property
We must promote the reasonable management and use of the Company’sassets and ensure that they are used efficiently and for legitimate businesspurposes, and must not use any Company assets, tangible or intangible, forpersonal purposes, or lose or damage any of such assets unfairly.

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Appropriate use of intellectual property rights and non-violationof intellectual property rights of others
The creation of intellectual property rights such as patent rights, trademarks,copyrights, and similar rights, is actively sought, and such rights will be used in
an appropriate manner. Violation of the intellectual property rights of others is nottolerated.
If intellectual property is created during the course of professional duty,
employees shall cooperate with the patent application process of the company,
conduct appropriate patent maintenance, and ensure its integrity.

Ban on acts that cause conflict of interest
We will not tolerate any personal act of our executives or employees that resultsin detriment to the Nidec Group’s corporate activities, or that interferes orconflicts, or has the potential to interfere or conflict, with the interests of theNidec Group.

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5. SAFE AND COMFORTABLE WORK ENVIRONMENT

We will ensure we keep our work environment safe and comfortable.
We will give first priority to the respect of human rights, comply with labor-related
laws and regulations, and realize safe and comfortable work environments.
Based on the understanding that the most important management resource of acompany is its employment force, we endeavor to create comfortable work
environments, in which all Nidec Group executives and employees can fully
exercise their abilities.

6. BAN ON UNFAIR COMPETITION

We will compete freely and fairly, and we will not engage in any anticompetitive
conduct.

Fair trade and free competition
We comply with all individual countries’ competition and anti monopoly laws, andengage in fair business transactions.
We do not engage in cartel, price fixing, bid-rigging, market allocations, or any
other act that impedes fair and free competitions, or engage in any act thatwould cause suspicion for such act.

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Ensuring transparency in transactions with customers andvendors
When selecting vendors, a fair and transparent evaluation, based on the strict
observance of the applicable law, with such selection standards as safety,quality, environmental aspects, price and delivery time, is conducted. There is nodifferentiation between domestic and non-Japanese service providers, and ourattitude and approach is that of a company open to the entire world.

Ensuring transparent relations with stakeholders
When communicating with our stakeholders, we will be open, honest, andmoderate.
We do not offer our private customers any personal rebates, commissions, or
any other conveniences.

Prohibition of illegal acquisition of information andattentiveness towards wrongdoing of customers and vendors
Information about other companies must be obtained by appropriate methods
and handled carefully. Due care with regards to wrongdoing of customers orpartner companies is exercised.

Prohibition of acts causing obstruction of business
Acts aimed at other companies that create barriers to their conducting business,
as well as misleading representations of products and similar unfair businesspractices, are prohibited.

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7. DESIGNING A COMPLIANCE SYSTEM

We will ensure we create and maintain a compliance system that is necessary
and sufficient to comply with the Nidec Group Compliance Code of Conduct.

Maintenance and operation of a compliance system
In order to continuously maintain and improve our compliance system, (i) theprincipal executive officer shall maintain and operate the compliance system
based on the basic framework for internal control as established by the board ofdirectors, and assume the responsibility for its evaluation, and (ii) managementlevel employees shall be responsible for maintaining and operating acompliance system with regards to the sections and duty assignments under
their control.
We will prepare and maintain a detailed compliance manual and systems, andensure our ability to appropriately address various situations in our daily
business activities.
The Compliance Committee, the Compliance Office as well as the compliancemanagers who shall be responsible for compliance in each department and ateach business unit shall perform a central role at their respective stage in thesystem.

Utilization of a whistle-blowing system
When it is discovered that one’s own actions or the actions of any otherexecutives or employees are in actual or possible violation of legal
requirements or Company policies or procedures, we will immediately report tothe Compliance Office or the Nidec Global Appliance Ethics Hotline available atour website.
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Any executive or employee who is reporting any possible violation via thewhistle-blowing system (Hotline available at our website) may choose to remain
anonymous in reporting such possible violation. We prohibit retaliatory action
against anyone who, in good faith, reports a possible violation.

Systematic response to illegitimate organizations
If we are approached by illegitimate organizations, we will promptly takenecessary actions including notifying the proper authorities. Illegitimate claims
and requests for illegal transactions shall be met with a firm response as anorganization.

Awareness-raising for executives and employees
Parallel to informing and teaching about this Code of Conduct througheducational and training activities, executives and employees should also deeplyinternalize the principles embodied in this Code of Conduct, and carry out theirproper compliance duties on a daily basis.

Effective monitoring and evaluation
The Internal Audit Department will conduct monitoring and evaluation of thecompliance system through systematic operational audits, and, in the event it
identifies significant concerns and problems, it will recommend improved
corporate controls or other practices to eliminate those concerns and problems.

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Responsible conduct in a crisis
In the case of socially-prohibited behavior, for example illegal or other improper
activities occurring within the Company, or if there is a valid suspicion of such
behavior, we will immediately take appropriate action, such as informing, andfully cooperating with any investigation by the competent authorities.

Amendments of this Code of Conduct
Any amendment of this Code of Conduct will be made only by the Board ofDirectors and will be disclosed as required or indicated by law or stock exchange
regulations.

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WHISTLE-BLOWING SYSTEM
Nidec Global Appliance HOTLINE:
COUNTRYACCESS CODE

PHONE NUMBER

United States
BrazilChina
Italy
MexicoSlovak Republic

800-172-444
0-800-000-101

8444-709-3988
0800-892-0456
4006612256
844-709-3988
0001-844-867-9176
844-709-3988

Nidec Corporation Compliance HOTLINE EMAIL:
HQ (Japan) nidec_hotline_hq@nidec.com• Americas nidec_hotline_americas@nidec.com• China nidec_hotline_china@nidec.com• Europe nidec_hotline_europe@nidec.com• Southeast Asia nidec_hotline_asia@nidec.com

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Business Ethics Policy Acknowledgement

I have carefully read the Nidec Global Appliance Compliance Code of Conduct

I understand and agree to comply with its purposes and provisions.

Signature of Employee ____________________________________________

Employee Number _______________________________________________

Typed or printed name of employee _________________________________

Date __________________________________________________________Name and address of business unit (Company) ________________________

Please complete and return this acknowledgment form to your Human
Resources Department to be included in your employee personnel file.

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