NIPPON YAKIN KOGYO CO., LTD

1. We conduct our activities while complying with laws and regulations, respecting social rules, and upholding common decency.
2. We embrace change by deploying our intellect and an enterprising spirit.
3. We accomplish our goals with courage, regardless of any difficulties.
4. We respect diversity and differences, and demonstrate our comprehensive capabilities with a spirit of harmony.

In carrying out our business, we comply with laws and regulations inside and outside Japan, respect social rules, and conduct company activities with sound judgment.

1. Relationship with society
   1. Valued interactions with local communities

      As a good corporate citizen, we strive to make wide-ranging contributions to society by deepening our interactions with local communities and participating in activities with them.

   2. Compliance with business laws relating to the products and services we offer

      We comply with business laws relating to the products and services we offer, and dutifully conduct the procedures for obtaining licenses, filing reports, and so on.

   3. Proactive action to address environmental problems

      We fully recognize the importance of environmental protections in research, development, manufacturing, sale, and disposal of our products, and conduct our business activities with due regard for the environment in compliance with treaties, laws, regulations, etc. concerning the environment. We also proactively address environmental problems by promoting the efficient use of resources, energy efficiency, and green procurement.

   4. Healthy and transparent relationships with government and political officials

      We demonstrate prudent self-restraint so as not to engage in activities that could be misunderstood as being inappropriate close relationships with government or political officials, and strive to create healthy and transparent relationships. We do not engage in illegal political contributions, illegal provision of benefits, or bribery.

   5. Having no relationships with anti-social forces in an uncompromising manner

      We deal in an uncompromising manner with anti-social forces that threaten social order and sound corporate activities, and we have no relationships therewith. If we receive unjust demands from anti-social forces, etc., we respond to them in a stern manner and would not provide monetary payments or other appeasements thereto in order to resolve the issue.

   6. Transactions in compliance with import and export laws and regulations

      We perform the appropriate import and export customs procedures in accordance with relevant laws and regulations when exporting products and importing raw materials. We do not export or import prohibited goods.

2. Relationships with customers
   7. Providing safe and high-quality products and services

      Based on our advanced technologies and wealth of experience, we manufacture and provide customers with safe and high-quality products and services under our excellent quality management system. We maintain a robust understanding of product safety laws and safety standards, comply with them, and strive to achieve higher levels of safety.

   8. Proper description of products and services

      We accurately describe the products and services we offer to customers to convey their quality and details.

   9. Promptly handling any issues that arise with our products

      We promptly investigate the causes of any issues that arise with our products in cooperation with sales, manufacturing, and research divisions.

3. Relationships with business partners
   10. Fair competition in transactions

       Regarding business transactions, we do not engage in conduct that would violate the Antimonopoly Act regardless of the situation, and we engage in free and fair competition with other companies.

   11. No engagement in unfair competition

       We never engage in conduct designed to unfairly obtain and/or use the trade secrets of another company.

   12. Fair transactions with suppliers

       We engage with suppliers in good faith and with sound judgment, and conduct fair and equitable transactions. We engage with subcontractors with a robust understanding of the Subcontractor Act and do not engage in conduct such as delaying payments.

   13. Prudent relationships with business partners

       We do not give or receive gifts or entertainment that would be suspected of unfairness. We maintain prudent relationships with our business partners.

4. Relationships with shareholders
   14. Appropriate disclosure of company information

       We disclose company information as appropriate, including our financial information and information about our business activities, to our shareholders and investors in accordance with the relevant laws and regulations.

   15. No engagement in insider trading

       In the case that we learn of any internal information about our company, a related company, or a business partner in the course of business, we appropriately handle the information until it is officially released to the public and do not engage in any acts constituting insider trading.

5. Relationships with employees
   16. Compliance with labor laws

       We comply with labor laws and strive to maintain healthy and worker-friendly workplace environments. Managers regularly give attention to the mental and physical health and well-being of their subordinates.

   17. Compliance with employment rules and internal regulations

       We do not engage in any conduct in bad faith that would run contrary to our employment rules. In carrying out our business, we gain a strong understanding of the related internal regulations and conduct appropriate business activities.

   18. Healthy and safe workplace environments

       We strive to create healthy and safe workplace environments, ensuring that safety and health are our top priorities. We also gain an understanding of laws and regulations, etc. relating to safety and health in business, and strive to comply with them and create comfortable workplaces.

   19. Respect individuals’ identities and human rights

       We show mutual consideration and respect for individuals’ ways of thinking and positions. We do not engage in unjust discrimination based on sex, beliefs, physical attributes, social position, or other factors.

   20. Self-development efforts, aiming to create new value

       We engage in our work in good faith and make self-development efforts, aiming to create new value.

6. Relationship with the company
   21. We handle company assets with care

       We recognize that company assets are a source of creating corporate value and handle company assets with care, regardless of whether the assets are tangible or intangible. We do not use company assets or expenses for personal purposes.

   22. Appropriate management of trade secrets

       We strictly manage trade secrets of our own and of other companies, and do not leak them outside our company or use them for purposes other than business purposes.

   23. Protection of our intellectual property rights

       We strive to protect our intellectual property rights, including by promptly filing patent applications, for discoveries made through our manufacturing and development activities. We also exercise sufficient care so as not to unjustly infringe on the intellectual property rights of others.

   24. Appropriate use of information systems

       We use the Company’s information systems only for business tasks, and do not use them for personal purposes. We strictly manage IDs and passwords for the information systems.

   25. Proper accounting processing in compliance with relevant laws and regulations and internal regulations

       In recording entries in account books and creating vouchers, receipts, and slips, we carry out proper accounting processing and accurately record entries in accordance with relevant laws and regulations and internal regulations. We strive to build an effective system of internal controls.

[Supplementary Provisions] Established on January 30, 2004