• We aim to be an internationally respected and trusted company. The uncompromising commitment to integrity and discipline embodied in our "Right Path" management philosophy provides the foundation for this.
• We aim to develop and grow with each of our stakeholders as we pursue the continuous innovation and sustainable growth that will enhance our corporate value as well as foster an ethical corporate culture. Our goal is to be a company customers want to do business with, a company investors want to invest in, and a company people want to work for.
  

2. Our commitment to our customers, business partners, and competitors

• We will make customer value our number-one priority, delivering the best products and service.
• We will develop win-win relationships with our suppliers, guaranteeing impartial treatment as well as reasonable terms and conditions.
• We will compete in good faith and respect the principles of fair trade.
  

3. Our commitment to our stockholders and investors

• We will achieve solid profitability through transparent decision-making and effective management.
• We will increase corporate value through continuous innovation and sustainable growth.
• We will respect the rights of stockholders and investors and their expectations to profit from their investments. We will provide timely and full disclosure so they can make informed investment decisions.
  

4. Our commitment to our employees

• We will respect the creativity of each individual and provide equal work opportunities to create an environment where they can achieve their full potential.
• We will not discriminate on the basis of Nationality, alma mater, birthplace, gender, age, religion, or any other criteria unrelated to job qualifications.
• We will foster a win-win corporate culture built on mutual trust and understanding.
  

5. Our commitment to local, national, and global communities

• We will abide by all national laws and regulations as a socially responsible corporate citizen.
• We will respect the traditions and culture of local communities as we work to prosper and grow with them.
• We will comply with international conventions on human rights, the environment, culture, and trade as well as local laws and accounting standards in every country we operate in.
  

Rules of Conduct

1. Follow sound and fair trading principles

• Treat all business contacts with respect, ensuring that all dealings are performed fairly and equitably.
• Refrain from using your position of power to seek undue concessions.
• Avoid doing business with companies that have been convicted of tax evasion, accounting fraud, or willful environmental pollution.
  

2. Avoid conflicts of interest

• Refrain from peddling or misusing influence as well as borrowing from or lending to business contacts.
• Refuse to give or accept money or valuable gifts. The only exceptions are for souvenirs and small gifts exchanged under generally accepted social practices.
• Refuse requests for or offers of dining, entertainment, or other business courtesies beyond generally accepted social practices. In all cases, the policy and standards of the recipient’s organization must be fully respected.
  

3. Avoid misuse of company assets or information

• Refrain from using or sharing internal information for personal gain.
• Administer company funds responsibly and effectively.
• Avoid using company supplies and facilities for non-business purposes.
  

4. Protect confidential information

• Scrupulously protect confidential knowledge and information.
• Immediately forward important knowledge and information to appropriate personnel.
• Refrain from distorting facts or disseminating false information.
  

5. Create a culture of mutual trust and respect

• Avoid offensive verbal, physical or visual behavior.
• Respect individual privacy and avoid assaults on character.
• Break down organizational barriers and create an atmosphere that fosters cooperation.
  

6. Respect social norms and reputations.

• Set the example for volunteer service in local communities.
• Avoid any conduct that might damage the good name and reputation of the company or fellow employees.
• Refrain from using position to benefit a particular political party or non-profit organization.
  

7. Establish a culture of ethical excellence

• Adopt the Code of Conduct as your personal value and conduct standard.
• Immediately report violations of the Code of Conduct by yourself or others to your supervisor or the Corporate Ethics Team.
• Witnesses of ethical violations will remain confidential and be fully protected from possible retaliatory action.
• Code of Conduct standards may be clarified or added when necessary to address emerging issues.
  

Guidelines

Article 1 (Objective)

The objective of this guideline (hereinafter referred to as "Guideline") is to provide for the scope of benefits (including in the form of money and/or gifts, entertainment, and convenience) that a director or employee of the Company is allowed to take from the interested party(s), and also the behavioral standards they are required to comply with in the course of carrying out their duties to implement the Code of Conduct.


Article 2 (Definitions)

As used in this Guideline, the following terms and expressions shall have the meanings hereby assigned as follows: 

1. Money/Gift : Economic benefits in any form whatsoever, including money (e.g. cash, gift certificates, and memberships) or gifts.
2. Entertainment : Meals, drinks, golf, performances, amusements, etc.
3. Convenience : Transportation, accommodation, sight-seeing or any other form of support related to the event organized or sponsored by the Company, or its division, department, team, or any other unit.
4. Interested Party : Other director and/or employee, customer, supplier, subsidiary, outsourcing partner of the Company, and any organization outside the Company whose rights or interests may be directly or indirectly affected by the manner or results in which the director or employee of the Company concerned performs his/her duties.
5. Customarily Accepted Level (CA Level) : The level that is deemed, in the opinion of other directors or employees of the Company, or by the public, to be generally acceptable or reasonable within common sense to the extent that the recipient concerned may perform his/her duties in a just and fair manner.
   

Article 3 (Money/Gift)

1. No director or employee shall demand or take any form of Money/Gift from Interested Party for any reason whatsoever, except a gift marked with a logo of the Interested Party, or a gift generally provided to each of the participants in an event held by the Interested Party within the CA Level.
2. If a director or employee happens to take any form of Money/Gift unknowingly or against his/her own will, he/she shall immediately return the same to the giver, and, if it is not possible to do so, he/she shall report the details thereof to the Manager of his/her department ("Department Manager")
3. Upon receipt of such a report mentioned in Paragraph 2 above, the Department Manager concerned shall treat the form of Money/Gift transparently and fairly, and then report the results of such action to the Corporate Ethics Department ("CED").
   

Article 4 (Entertainment)

1. A director or employee shall receive entertainment within the CA Level from an Interested Party.
2. No entertainment exceeding the CA Level shall be received in any manner, and if a director or employee of the Company happens to receive such entertainment under certain unavoidable circumstances, he/she shall report the same to the Department Manager.
3. If a director or employee entertains any Interested Party or participates in any event exceeding the CA Level, it shall obtain a prior approval from the Department Manager.
   

Article 5 (Convenience)

1. No director or employee shall receive any form of convenience, including transportation and accommodation, as provided as the Interested Party's expenses, except such convenience that is generally provided to each of the participants in an event held by the Interested Party.
2. If a director or employee happens to receive entertainment exceeding the CA Level under certain unavoidable circumstances, he/she shall report the same to the Department Manager.
   

Article 6 (Pecuniary Transactions)

1. No director or employee shall involve himself/herself in any pecuniary transaction with an Interested Party, such as lending or borrowing of money, providing or being provided with a payment guarantee for a loan or a rental/lease of real estate.
2. If a director or employee is involved in any pecuniary transaction with an Interested Party due to personal relations, he/she shall report the same to the Department Manager.
   

Article 7 (Support for Events)

1. No director or employee shall be allowed to take any form of Money/Gift from an Interested Party to support any event organized or sponsored by the Company, such as department-level events or hobby club activities.
2. Any form of convenience (such as vehicles, venues, services, etc.) received from an Interested Party in relation to an event shall be regarded as having taken Money/Gift as well.
3. Any form of Money/Gift or conveniences taken or received from any Interested Party in relation to an event under certain unavoidable circumstances shall be reported to the Department Manager, or the manager of the sponsoring department.
   

Article 8 (Undue Application of Budgets)

1. No director or employee shall apply the Company's budgets (such as meeting expenses and business promotion expenses) to any personal use.
2. In executing any of the Company's expenditure, a corporate credit card shall be used, in principle, in conformity to the objective of relevant budgets, and also in compliance with the standards prescribed by law.
   

Article 9 (Department Manager’s Responsibility, etc.)

1. Each Department Manager shall train and advice the employees of his/her department to ensure that they fully understand this Guideline.
2. Each Department Manager shall take appropriate preventive measures to ensure that any employee in his/her department will not violate this Guideline.
   

Article 10 (Obligation to Report and Confidentiality)

1. If a director or employee becomes aware of any violation of this Guideline, he/she shall report the fact to the CED in the manner that is most expeditious and convenient.
2. Upon receiving the report of the fact that the Code of Conduct and/or this Guideline has been violated by one of the employees in his/her department, the Department Manager concerned shall immediately prepare the details of such violation in the prescribed form, as in the Appendix attached hereto, and submit the same to the CED.
3. With respect to the matters reported pursuant to Paragraphs 1 and 2 above, the CED has the authority to verify the relevant fact, whenever necessary, and the director and/or employee involved with the aforesaid matters shall actively cooperate with the CED in relation to such verification.
4. No director or employee shall treat a person ("Reporting Person") unfavorably after reporting such violation, or divulge the identity of the Reporting Person to a third party.
5. If a Reporting Person is likely to suffer any unfavorable treatment in terms of personnel management, proper measures, such as changing his/her position, shall be taken according to the person's wishes.
6. If a director has become aware of the aforesaid report in the course of his/her duties or by chance, he/she shall keep it confidential, and by failing, he/she may be subject to disciplinary measures.
   

Article 11 (Reward and Disciplinary Measures)

1. The Company may offer a prize or appropriate compensation to each director or employee who has contributed to the attainment of the objective of this Guideline.
2. Directors and/or employees who have violated this Guideline shall be subject to disciplinary measures according to the Company's regulations.
   

Article 12 (Interpretation)

1. The administrative guideline for reporting any unethical behavior, including taking any form of Money/Gift from an Interested Party, and compensation therefore shall be separately established, as attached hereto as Appendix II (Administrative Guideline for Reporting Unethical Practice and Compensation).
2. If any of the family members, relatives, or acquaintances of a director or employee violates the Code of Conduct or this Guideline by using the latter's name without authorization, it shall also be deemed done by the director or employee concerned.
3. Questions regarding the matters not specifically provided in the Code of Conduct and this Guideline shall be directed to the CED for interpretation.
   

Addendum (established as of August 25, 2006) : Article 1 (Effective Date) This Guideline shall come into effect, as of the established date of August 25, 2006.