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Compliance

Code of Conduct for Business Ethics

OHTORI Group’s Code of Conduct for Business Ethics

OHTORI CORPORATION
OKAMOTO ELECTRONICS CORPORATION

Introduction

It is thought that it is necessary and indispensable that Ohtori Corporation,
Okamoto Electronics Corporation and related companies acquire the posture of
"Observance of the law" and "Esteem of social ethics" to director and
employee's (the junior employee and the contract worker are included) each
one, and build and practice "Corporate ethics" widely accepted to the society.

This basic stance was assumed to be "Basic principles of Business ethics",
and "Compliance part" were installed based on this principle.

In addition, "Code of Conduct for Business Ethics" was enacted as follows for
all directors and employee (the junior employee and the contract worker were
included) of Ohtori Corporation, Okamoto Electronics Corporation and related
companies.

Moreover, the head of each post is assumed to be "Compliance leader" to
ensure "Code of Conduct for Business Ethics", all companies are given, and
"Education and Enlightenment" and "Consultation and Report", etc. are
promoted consistently.

It consults the head of the post, and it aims at the solution promptly when it
receives information etc. that seem that it is this "Code of Conduct for Business
Ethics" and the act in contradiction to being specified or the doubt exists it.

Still, it can consult "Compliance Hotline" in the compliance part directly when it
is difficult not to be convincing, and to consult the head of the post.

The employee who offered information via this "Compliance Hotline" by a proper
purpose never receives prejudicial handling all.

President Hiroshi Okamoto

Management Policy
1. To contribute to public welfare through business activities.
2. To achieve constant development, step by step, on the basis of sound
management.
3. To increase credit with sincerity, effort and cheer.

Action Guideline
We respect individuality, make the best use of the strong point of team work,
and aim at a brightly and lively business culture making.

We aim at the bountiful life with youth, zeal, and the dream, and make it to great
place to work.

We are positively interested also in what, deepen technical knowledge, and
heighten sensitivity.

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Code of Conduct for Business Ethics

Relation with Society

1. Respect for Human Rights
We violate neither discrimination nor privacy for which the reason is human
rights such as the race, the ethnic discrimination, the handicapped person
discrimination, and sexism.


2. Esteem of Environment
We follow our environment policies, and aim at the enterprise that considers
the global environment and natural environment enough.

3. Esteem of Fairness
We do not do undertaking activities biased to a specific political party, the religion,
thought, and those groups.

4. Relation Rupture with Antisocial Forces
We do not have a relation between the antisocial activity and power which
become a threat and an obstacle in civil society and economic activity at all.

5. Approach on Welfare Activity
We also work on welfare activity aggressively and make an effort toward a
community service.

Compliance with Lows and Regulations

6. Compliance with Lows
We observe related domestic and abroad decrees, regulations of a regulation and
equality industry and requests, etc. and make an effort toward proper
business activity based on a prescriptive social norm and business ethics.

7. Proper Accounting Procedure
We process the account properly with a related decree, an internal regulation
and the standard kinds and build the system in the company that an internal
check functions effectively.

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Relation with Customer

8. The Business Activity Sincere Justly
We execute business in order always to keep business activity justly and also
answer with the sincere posture with customer and get high trust from customer

9. Trading Company Function in Response to Trust
To achieve the quality which responds to the user needs, we conform to our
quality policy and are trusted from a client, and aim at the trading company
function which can admit the value.

10. Restriction of Present, Reception and Contribution
We are compared with a decree and a trade custom of the morality public of
ethics and a present, reception and the contribution in the reach beyond the
courtesy are not done, do not receive and do not request.

Information Management

11. Thoroughness of Information Management
We carry to manage and protect information from our company, customer and
third party and information about an individual appropriately without exception.

12. Defense to Threat on Computer Network
We devise a defense scheme to a threat on the computer network, and manage
so that we do not do harm to our company and other company.

Relation with Employee

13. Offer of sound and safe work environment
We obey labor laws, offer sound and safe work environment to employee and
maintain it.

14. Work Environment without Sexual Harassment
We do not approve sexual harassment to achieve sound work environment. When
a problem occurred, we deal and make an effort toward recurrence prevention
immediately.


Additional Clause

Coverage of Code of Conduct
This code of conduct is assumed to be the one applied to all employees of
Ohtori Corporation, Okamoto Electronics Corporation, and related companies,
the junior employee, and the contract worker.
About Establishment of “Compliance Hotline”
When we found a compliance violation in the company, using “Compliance
Hotline”, we make an effort toward self-purification of organization.


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