Group’s Code of Conduct

1.Law and Ordinance Compliance and Corporate Ethics

1.1.

With self-consciousness as an independent member of society, we behave faithfully on the basis of a high sense of ethics.

1.2.

We comply with all laws, ordinances and internal rules on our own tasks in all business activities.

1.3.

We refrain from behavior for the benefits of ourselves or third parties contrary to reasonable benefits to the company.

1.4.

As a member working at an enterprise, we assume responsibility for our roles, keep promises without fail, and behave trustworthily.

2.International Business Activities

2.1.

In international business activities, we not only comply with international rules and laws and ordinances of respective nations and respective regions, but also develop business activities based on mutual confidence fully considering respective cultures and customs.

2.2.

We refrain from giving gifts to or entertaining foreign country officials for unfair business benefits in international commercial transactions.

3.Improvement of Customer Satisfaction

3.1.

Constantly keeping customer satisfaction in mind, we develop and supply products and services (meaning all values Yamaichi Electronics Group supplies to customers) based on customer needs.

3.2.

We secure safety of products and services and endeavor for quality improvement to win customer support and confidence.

3.3.

We provide customers with adequate information on products and services.

3.4.

We respond faithfully to inquiries from customers.

4.Sound Corporate Activities

4.1.

We comply with all laws and ordinances on monopoly inhibition, fair competition and fair trade.

4.2.

We comply with all laws and ordinances on export and import in international transactions.

4.3.

We comply with laws and ordinances on procurement activities and procure necessary materials of adequate quality, price and delivery time from global markets.

4.4.

We behave in line with sound commercial practice and social common sense in entertainment and gift receiving from and giving to business partners.

4.5.

We refrain from making donations that may come under favor giving or illegal payment.

5.Information Disclosure

5.1.

We comply with laws and ordinances on accounting and perform proper account processing and financial reports.

5.2.

We disclose to shareholders and investors timely and adequately corporate information including contents of management and state of business activities of the company.

6.Respect for Human Rights and Workplaces Easy to Work

6.1.

We respect basic human rights, characters and privacy of individuals, and commit no disregarding acts of individuality such as bullying, contempt or moral harassment.

6.2.

We deny child labor and compulsory labor.

6.3.

We will not discriminate based on race, religion, gender, nationality, age, physical or mental disorder and sexual orientation.

6.4.

We commit no sexual harassment acts such as sex-related words or deeds offending a person and people nearby.

6.5.

We endeavor to maintain and improve safe and comfortable workplace environment and also to build our own health.

7.Global Environment Conservation

7.1.

We acknowledge that global environment conservation is the most important task common to human beings, behave considering global environment conservation in all respects of corporate activities, and contribute to sustained development of society.

8.Management of Company Property and Company Information

8.1.

We adequately manage property (including tangible assets and also intangible assets such as intellectual property rights) of the company and use them only for business task purposes.

8.2.

Whether during employment or after retirement, we do not disclose nor divulge company information without going through designated internal proceedings.

8.3.

Whether during employment or after retirement, we do not use company information improperly or unduely.

8.4.

We comply with internal rules on information security and use company information properly.

8.5.

We refrain from trading company shares before information publication (insider trading) using internal information (information with grave effects on share prices of the company) obtained in relation to tasks. Further, we do not supply internal information to third parties with no business relations.

8.6.

We pay close attention to and manage adequately the gathering, keeping, use, disclosure, discard and other handling of personal information.

9.Harmony with Society

9.1.

We practice social contribution activities as a good corporate citizen.

9.2.

We flatly reject relations with antisocial forces and organizations.

Management of Yamaichi Electronics Group Conduct Code

1.Management System

1.1.

This code, after approval by board of directors at respective Yamaichi Electronics Group companies, applies to officers and employees of the respective companies.

1.2.

Respective Yamaichi Electronics Group companies are committed to familiarizing employees with the contents of this code continuously through education, training programs and others.

1.3.

Yamaichi Electronics Group officers and employees who learnt such acts that breach or may breach this code shall report the information to intelligence windows through internal intelligence systems established at respective Yamaichi Electronics Group companies. Officers and employees reporting for faithful and proper purposes shall not be treated unfavorably for reasons of the reporting.

1.4.

Acts in violation of this code are subject to disciplinary disposition in accordance with provisions of pertaining laws, ordinances and work regulations.

2.Supervision

2.1.

The supervision division for this code is Yamaichi Electronics Co., Ltd. General Affairs Department.

2.2.

Inquiries about interpretation etc. of provisions of this code shall be accepted at Yamaichi Electronics Co., Ltd. General Affairs Department.

2.3.

State of compliance with this code shall be evaluated by the internal audit division or the general affairs division of respective Yamaichi Electronics Group companies.