T.RAD Code of Conduct

We believe that ensuring the implementation of the management principles of T.RAD fulfills our socially-expected responsibilities. In achieving the management principles, we must fully understand and place great emphasis on the T.RAD Code of Conduct as top priorities as a matter of compliance and conduct of necessary activities. By doing so, we are confident that T.RAD and its operational results will increase the corporate value and gain the trust of all stakeholders.

1.Compliance with Laws and Regulations

1) Compliance with Laws and Spirit of the Laws

  • We will properly understand and observe the laws and regulations in Japan and those in other countries, if applicable, and will refrain from illegal conduct in society.

2) Compliance with Competition Laws

  • In compliance with the competition laws in Japan and those in other countries, if applicable, we will not conduct any unlawful or illegal acts, such as private monopoly, the imposition of unreasonable transaction restrictions (e.g., the forming of cartels or the implementation of bid-rigging agreements . . .etc.), or the abuse of superior positions.

3) Anticorruption

  • We will abide by the applicable laws and regulations in Japan and those in other countries, if applicable, and will make political and other donations accordingly, and strive to create transparent and fair relationships with politicians, administrators, public institutions, and organizations.
  • We will not provide bribes and other unfair profits to government officials (including government officials overseas and other workers deemed to be public officials) or offer or receive entertainment, gifts, or money to or from anyone for the purposes of obtaining and maintaining unfair profits or incentives.

4) Management and Protection of Confidential Information

  • We will acquire confidential information on customers and third parties and personal information on our employees in a proper way, strictly manage and protect all information acquired, and use the information within the scope of proper purposes.
  • We will promote the proper and effective use of computers and other internal information systems and strictly manage them so that information leakage will not occur.

5) Import and Export Transaction Management

  • We will carry out proper import and export procedures and its management concerning the import and export of technologies, goods etc., regulated by the laws and regulations in Japan and those in other countries, if applicable.

6) Protection of Intellectual Property

  • We will protect all intellectual property rights belonging to or owned by the company and will not engage in the illegal acquisition, use, or infringement of third parties’ intellectual property or rights.

7) Awareness as Members of Company

  • All officers and employees have awareness as members of the company and will not divert the money, assets, or information of the company for personal benefits.

2.For Shareholders and Investors

1) Disclosure of Management Information

  • We will properly disclose the management policies, financial statements, business activity situations of the company to all shareholders and investors. Furthermore, we will value their opinions on the disclosed information seriously and will respond appropriately.

2) Appropriate Accounting

  • We will perform proper accounting procedures in accordance with the relevant laws and internal regulations and disclose the results.

3) Prohibition of Insider Trading

  • We will not trade shares based on undisclosed information on our company or its affiliates. Furthermore, we will strictly manage all undisclosed information and ensure that third parties will not conduct unlawful transactions based on the undisclosed information.

4) Risk Management

  • We will analyze risks related to corporate activities and aim at the permanent development of the company by implementing the company-wide risk management (including business continuity plan at times of disaster) to the company and its domestic and overseas affiliated companies.

3.For Customers

1) Securement of Product Safety and Quality

  • We will conduct activities to ensure product safety and quality at all stages (including the stages of product material procurement, manufacturing, customers’ product use, and product disposal).

2) Provision of Information on Products and Services

  • We will provide customers with appropriate information on products and services.

3) Pursuit of Customer Satisfaction

  • We will strive to accurately understand customers’ opinions and reflect them in our corporate activities.

4) Sincere and Prompt Responses to Any Problems

  • In the event of customer complaints or product defects in the market, we will strive to respond to and resolve the complaints or product defects in good faith and with promptness from customers’ point of view.

4.For Business Partners (Suppliers)

1) Appropriateness of Transaction

  • We will ensure sound relationships with all our business partners and make appropriate and fair deals.
  • We will partner with those who agree with the T.RAD Code of Conduct.

2) Entertainment and Gifts

  • We will not receive or offer entertainment or gifts beyond the scope of common sense.

3) Transparency and Fairness of Decision Making

  • We will make decisions on business partners, including the selection of such partners, based on the prescribed rules and regulations of the company. We will conduct ourselves within fair business acts, such as showing favoritism to specific business partners.

4) Collaboration and Mutual Prosperity

  • We will build strong, trustful and cooperative relationships with all business partners for business success together.

5.For Local Communities

1) Value Sharing with Each Country and Each Community

  • While respecting the culture and customs of each region, we will aim at corporate activities that share value with each community and develop together.
  • We will communicate with local communities and proactively promote social contribution activities.

2) Approach to Environmental Problems

  • We will position environmental efforts as an important management issue.
  • We will develop and produce more environmental contributing products and provide them for society.
  • We will reduce greenhouse gas emissions, reduce industrial waste, prevent atmospheric, water, and soil contamination, and properly manage chemical substances.

3) Elimination of Any Relationships with Anti-Social Forces

  • We will take a resolute attitude to antisocial forces and eliminate any relationships.

6.To Employees

1) Respect for Human Rights and Abolition of Discrimination

  • We will respect the human rights of all employees and not conduct discriminatory behaviors, based on personal attributes.

2) Prohibition of Forced Labor and Child Labor

  • We will not engage in forced labor or child labor regardless of any employment form.

3) Prohibition of Harassment

  • We will not tolerate any forms of harassment resulting from individual attributes, workplace relations, etc.

4) Wages and Working Hours

  • We will establish labor conditions, such as wages and working hours, in compliance with the relevant laws in Japan and those in other countries, if applicable.

5) Maintenance of Safety and Hygiene

  • We will develop a safe and clean workplace where everyone can work safely.
  • We will promote activities to prevent the occurrence of accidents and disasters in the workplace.
  • In the event of a disaster, we will conduct restoration activities with top priority on human live in mind.
  • Promote activities related to traffic safety.

6) Creation of Comfortable Workplace Conditions

  • We will aim at deepening mutual communication and creating a workplace with profound trust.
  • We will respect each person’s characteristics, abilities, and achievement, and will aim at creating a workplace where each person’s growth and self‐actualization will be possible.
  • We will strive to promote the physical and mental health of each worker on a daily basis, practice physical and mental health improvement measures, and maintain a comfortable working environment.

7.Lastly

In the event of a violation of the T.RAD Code of Conduct identified, the officers and employees of the company will take an initiative to resolve the problem, explain the details to stakeholders (including government agencies), formulate measures to prevent the recurrence of the problem, and punish severely all involved parties, including the management, if needed. Also, we will establish an internal whistle-blowing system to encourage self-corrective actions if violation is found. We will not tolerate any retaliation from Management or any other persons, in connection with those who report allegations under the Whistle Blower Policy.

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