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Exhibit 11.1 Code of Ethics for Senior Financial Officers and Professionals Article 1.
The CEO (Chief Executive Officer), CFO (Chief Financial Officer) and other
officers and/or senior professionals of the Company (categorized as Riji, MT
(Management) and/or MS (Managerial Staff) by the Working Regulations of the
Company) who serve in finance, treasury, accounting, tax and/or financial risk
management roles (collectively hereinafter called the Senior Financial
Officers and Professionals) shall comply with the ethical standards and
requirements set forth below, in addition to those required by the Code of
Conduct for all employees, officers and directors of the Company:  (1)
    
    Act with honesty and integrity, avoiding actual or apparent conflicts of
interest between personal interests and the interests of the Company;(2)
    
    Provide constituents with information that is accurate, complete,
objective, relevant, timely and understandable;(3)
    
    Comply with applicable governmental laws, rules and regulations, as well
as the rules and regulations of self-regulatory organizations (such as the
Tokyo Stock Exchange and NASDAQ) of which the Company and/or its
subsidiaries are members;(4)
    
    Act in good faith, reasonably, with due care, competence and diligence,
without misrepresenting material facts or allowing their independent
judgment to be subordinated;(5)
    
    Respect the confidentiality of information acquired in the course of
their work except when authorized or otherwise required by applicable
laws, rules, regulations or legal or regulatory proceedings and not use
any confidential - 1 -




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information acquired in the course of their works;(6)
    
    Share knowledge and maintain skills which are required for and relevant
to their work;(7)
    
    Proactively promote ethical behavior among subordinates and peers in the
work environment;(8)
    
    Achieve responsible use of and control over all assets and resources
employed or entrusted to them;(9)
    
    Produce full, fair, accurate, timely, and understandable disclosure in
reports and documents that the Company and/or its subsidiaries file
with, or submit to, the Financial Services Agency of Japan, the Securities
and Exchange Commission of the U.S.A. and other regulators, and in other
public communications made by the Company and/or its subsidiaries;(10)
    
    Not take any direct or indirect action to fraudulently influence,
coerce, manipulate or mislead the Companys and/or its subsidiaries
independent public auditors engaged in the performance of an audit of
their financial statements for the purpose of rendering the financial
statements of the Company or its subsidiaries materially misleading;(11)
    
    Observe the most stringent standards in the keeping of financial records
and accounts and reflect all components of transactions, as well as the
standard of insisting upon an honest and forthright presentation of the
facts on the books; and(12)
    
    Promptly report any possible violation of this Code of Ethics to the CCO
(Chief Compliance Officer) or any of the parties or channels listed in the
Companys - 2 -




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Code of Conduct. Article 2.
The Senior Financial Officers and Professionals who breach any of the ethical
standards and requirements set forth in the above Article 1 hereof may be
disciplined in accordance with the Working Regulations and others relevant
internal rules of the Company. Article 3.
All of the other directors, officers and employees of the Company than the
Senior Financial Officers and Professionals shall also respect the ethical
standards and requirements set forth in Article 1 hereof and make efforts to
comply with the same to the extent they relate to their assignments and
responsibilities. - 3 -