Toyo Seikan Group Code of Conduct & Guidelines of Behavior

Preconditions of the Guidelines of Behavior

We must fulfill the following preconditions to implement the Toyo Seikan Group Guidelines of Behavior (the “Guidelines”).

• Comply with rules, including laws and regulations of the relevant countries/regions as well as policies and procedures of the Group and group companies.
• Act honestly with high ethical standards in accordance with common practice, good sense and good judgment.
• Perform duties as a team or an organization, and ensure that appropriate procedures that are authorized or formally approved are performed; not to perform duties in a way peculiar to a specific individual.

Scope of application

The Guidelines are the basic standards of behavior which all officers and employees working within the Toyo Seikan Group must implement and comply with.

• “The Toyo Seikan Group” refers to Toyo Seikan Group Holdings, Ltd. and its group companies.
• “Officers” as described herein include directors, auditors, operating officers and advisors.
• “Employees” as described herein mean all members who work in the Group, including employees and special employees as well as contract employees, part-time employees, temps dispatched from staffing agencies and temporary workers.

Countermeasures against violations of the Guidelines

Any violation of the Guidelines will be strictly punished based on provisions of the work regulations and other rules of the relevant group company according to the extent of the violation.

Item of the Guidelines

• 1. Sustainable economic growth and solutions to social issues

  Through innovation that transcends traditional ideas and existing perspectives, we will develop safe and useful products, systems and services to offer them to the society, thereby seeking sustainable economic growth and solutions to social problems.

  Creation of innovation

  • We pursue innovation in all operational areas, including the transformation of technologies, production and sales processes, and distribution channels and supply chains.
  • We seek open innovation opportunities via cooperation with third parties, other industries, universities and R&D institutions, as well as opportunities to work with various stakeholders, including governments, consumers, customers, local communities and NPOs/NGOs.

  Quality and safety assurance of our products, systems and services

  • In order to achieve a sustainable economic growth, we assure the quality and safety of our products, systems and services (collectively the “Products”) to gain trust and satisfaction of society.
  • We define clear standards and procedures for all operational processes from product development to sales activities, ensure that they are executed, verify their effectiveness and revise them as necessary.
  • In the event of a defect in the Products, we promptly collect, share and disclose the relevant information in an appropriate manner.
  • We properly manage and store the information on incidents of defects and utilize such information to prevent recurrence.
  • We provide Products that comply with and meet the requirements of laws and regulations and safety standards of the relevant countries.

  Utilization of data and protection of personal information

  • We create new value, including innovative products, through the use of various types of data to contribute to improving the quality of life for all people and finding solutions to social problems.
  • In using data, we properly manage and protect personal information in accordance with the relevant rules such as internal regulations.

  Utilization and protection of intellectual property rights

  • We create intellectual property and properly manage and use such intellectual property to develop and provide useful and innovative products for the society.
  • We pay close attention to avoiding infringement of other parties’ intellectual property rights, including patents, utility models, registered designs, trademarks and copyrights.
  • We properly manage confidential information associated with technologies and sales operations, including trade secrets, in accordance with the relevant rules such as internal regulations in order to prevent technology and information leakage.

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• 2. Fair business practices

  We will never forget our past mistakes. We do not pursue only short-term profits; we promote fair and free competition, conduct transactions properly, and engage in responsible procurement activities. We also maintain sound relationships with politicians and governments.

  Fair competition with competitors

  • We maintain fair relationships with our competitors in accordance with the applicable competition laws in Japan and other countries and regions where we operate.
  • Contact with competitors is allowed only when there is a legitimate business justification and with prior approval.
  • We never exchange information or make an agreement with competitors on matters related to competition, including prices, price estimates, price increases or reductions, sales territories, sales volume, production volume, cost, market share, customer allocation, supply and demand prospects and appetite for orders.
  • If we encounter an event that could result in suspected cartel formation at a meeting, party, golf event, etc. in which persons from our competitors also participate, we express a disagreement and leave the event, submit an internal report on the details of the event, and place the details of the event on record.

  Responsible procurement activities

  • In procurement activities, we pay attention to whether our suppliers are properly committed to legal compliance, quality, safety, environment preservation, information security, fair trade and ethics, health and safety, and human rights and labor conditions.

  Appropriate export control

  • In exporting products or transferring technologies abroad, in order to comply with laws and regulations related to export security control, we check in advance whether export regulations apply to such products and technologies. Regardless of whether or not such export regulations are applicable, we confirm in advance that there is no risk that such items are utilized for developing, producing or using weapons.

  Prohibition of bribery and corruption

  • Corruption is defined as the abuse of entrusted power or authority for private gain, financial or otherwise. We commit ourselves to prevent any form of corruption, including bribery involving domestic or foreign government officials, customers or suppliers, misappropriation and money laundering.
  • We do not offer to or accept from our customers, suppliers or other business partners entertainment, gifts, money, etc. in order to gain or retain illicit profits or preferential treatment.
  • We do not offer to politicians, domestic or foreign government officials, or other government-related parties (e.g. individuals who work at government agencies) entertainment, gifts, money, etc. that are provided, or could be considered to be provided, in order to gain or retain illicit profits or preferential treatment.

  Prohibition of conflicts of interest and mixing up public and private matters

  • Without the company’s consent, we do not engage in any activity to obtain benefit for ourselves or any third party related to us (family members, friends, acquaintances, etc.) against the interests of the company by, for instance, concurrently serving as an officer at another company or being involved in an activity that competes with our company’s business.
  • We draw a sharp line between public and private positions and refrain from bringing our personal interests into the workplace or taking advantage of our position at work for private interests.
  • We appropriately manage the company’s assets (e.g. both tangible and intangible assets including the Products, facilities and equipment, loaned equipment, money, data and know-how) and refrain from using these assets for any purpose other than work, including private use.
  • We clearly distinguish between statements of the company and personal comments on social networking services (SNS).
  • No political, ideological or other personal activities are allowed at the workplace.

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• 3. Appropriate disclosure of information and constructive communication with stakeholders

  For further improvement of corporate value, we proactively disclose corporate information in an effective and appropriate manner and hold constructive communication with our wide range of stakeholders.

  Transmission of corporate information

  • We actively disclose information to shareholders, investors and other stakeholders in an appropriate and timely manner in accordance with the relevant laws and regulations and internal regulations.

  Constructive communication with our stakeholders

  • We promote interactive communication with shareholders, investors and other stakeholders.
  • We sincerely respond to our stakeholders’ questions, comments and feedback on the information we provide.
  • We take the opportunities of open facilities and factory tours to gain wider support of local communities for our business activities.

  Prohibition of insider trading

  • We refrain from trading shares and other assets based on unpublished material information related to the Group and its interested parties such as customers and suppliers.
  • We conduct transactions of shares of a listed company in the Group in accordance with the relevant rules such as internal regulations.

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• 4. Respect for human rights

  We respect the human rights of all people.

  Respect for human rights

  • We understand and respect internationally recognized human rights, including freedom of association, the right to collective bargaining and the right to a minimum wage, as well as laws concerning human rights in countries where we operate.
  • We continuously monitor our business operations to check for human rights abuses not only within the group but also in the entire supply chain we belong to. In particular, we follow required standards and procedures to avoid using labor that is connected to human rights abuses, including forced or bonded labor, child labor and human trafficking.
  • In the event that human rights abuses are identified, such facts must be immediately reported to the workplace managers and the relevant departments.
  • We promote deeper understanding of challenges faced by socially disadvantaged people.
  • In the cases where national laws conflict with international norms, we seek to respect internationally recognized principles of human rights.

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• 5. Mutual trust with consumers and customers

  To gain the trust of consumers and customers and ensure their satisfaction, we provide appropriate information on our products, systems and services and communicate honestly.

  Provision and effective use of information

  • We provide appropriate and easy-to-understand explanations on the details and handling of the Products. We also voluntarily and proactively disclose environmental and safety information.
  • In the event that a defect in the Products that poses a danger to the health and lives of consumers and our customers is identified, such defect must be immediately reported to the workplace managers and the relevant departments.
  • We share information on inquiries and requests related to the Products from consumers, our customers and other parties with the relevant departments and effectively utilize such information.

  Response to diversified needs

  • In each phase of development, production, filling, consumption, collection and recycling, we demonstrate our integrated strength as a group and promote horizontal cooperation among group companies to meet diversified expectations of society.
  • We pursue the universal design of products that can be used by a wide range of people regardless of age, gender, disability, culture or language.

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• 6. Reform of work styles, improvement of work environment

  We make efforts to develop our abilities, respect diversity in the workplace and different personalities of colleagues, and carry out fair evaluation and treatment and appropriate personnel allocation. We also establish new work styles which allow us to strike a balance between work and personal life, while actively engaging in health and safety maintenance activities.

  Acceptance of diversity

  • We respect each other’s personalities and abilities and use the different perspectives and ideas of individual members as the common advantages of all group members.
  • We build mutual trust between each other by sufficiently fulfilling our respective duties and responsibilities.

  Prohibition of discrimination and harassment

  • We do not discriminate on the grounds of nationality, race, ethnic group, religion, belief, gender, age, disability or sexual orientation.
  • We do not tolerate harassment of any kind, including sexual harassment and abuse of authority in the workplace.

  Continuous growth and challenges

  • To be prepared for changes in society and work environment, each of us deepens our expertise regardless of the business areas with which the workplace or the company is associated. Through the individual efforts to achieve our own growth, we contribute to the growth of the Group.
  • We are always conscious that maintaining the status quo may eventually result in taking a step backward. With revolutionary thoughts and global perspectives, we continue to pursue new challenges in our operations.
  • Managers promote growth of their team members and conduct fair personnel evaluation and optimal human resource allocation, with an appropriate understanding of the individual personalities and abilities of each member.

  Promotion of work-life balance

  • To achieve a right balance between work and other aspects of life, including child-rearing, elderly care, medical treatment, learning and hobbies, we cooperate in creating and improving a workplace environment that allows everyone to work flexibly.
  • Managers take the initiative to maximize output while reducing work hours. They also cooperate in correcting working practices that have been associated with long work hours.

  Maintenance of health and safety

  • We actively engage in health and safety activities on a daily basis, including risk prediction and 5S activities*.
    * 5S activities refer to a five step process for organizing a working area to improve efficiency, including Sort, Set in order, Shine (clean), Standardize and Sustain (maintain through training).
  • Managers, together with their team members, take preventative measures against excessive work and implement mental health initiatives.
  • We promote the maintenance and enhancement of health, including the prevention of lifestyle-related and other diseases.

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• 7. Commitment to environmental issues

  We acknowledge that commitment to environmental issues is a critical issue common to all mankind and is also essential for our existence as a corporation and for our business activities. Based on this point of view, we proactively address environmental issues.

  Creation of a zero-carbon, zero-waste society that coexists with nature

  • We contribute to the creation of a sustainable society from the three key perspectives through the value chain of products, services and systems we provide.
  • We pursue energy conservation while increasing the ratio of renewable energy to total energy consumption, and significantly reduce our carbon footprint.
  • In order to deliver products, services and systems with lower environmental burden throughout their lifecycles, we pursue product design that allows for the use of recycled and renewable materials and the improvement of recyclability.
  • We reduce material input and waste generation and promote recycling for more effective use of resources.
  • We reduce the use and release of substances which could have an adverse impact on the environment, and promote switching to alternative substances.
  • We advance our efforts to prevent environmental pollution, seeking solutions to the global problem of marine plastic pollution.
  • We make efforts to understand the impact of business activities on the ecosystem, and perform our operations while respecting the biodiversity.
  • We engage in active communication on environmental issues with our stakeholders to build a mutual understanding.

  Certification of Eco-friendly Products

  At Toyo Seikan Group, we strive to promote sustainable consumption and production through the development and provision of products and services with superior environmental performance.
  Eco-friendly products are those that take into account environmental impact throughout the product's lifecycle, and are designed to reduce the environmental burden compared to conventional products.
  These products meet the certification criteria set by the group and have been certified internally.
  Certification of Eco-friendly Products

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• 8. Participation in the community and contribution to community development

  We, as good corporate citizens, actively participate in the community and contribute to community development.

  Active participation in the community

  • As a member of the Group, each of us understands the Group’s view on participation in the community, actively participates in the community and contributes to its development.
  • We actively join programs that promote healthy growth of children, who will be the next generation leaders.
  • To build mutual trust with the international society and local communities, we understand the social environment of countries and regions where we operate and respect their cultures, customs and religions in conducting our business operations.

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• 9. Comprehensive risk and crisis management

  We ensure that our crisis management system works effectively to prepare for potential risks, such as hazards to life and health, actions committed by organized crime groups, terrorism, cyberattacks and natural disasters.

  Preparation for risks and crises

  • We become more sensitive to risks in day-to-day operations, and when identifying any risk, we report the information to managers and relevant departments and consult with them for preventive and corrective measures to address the risk.
  • In the event of a disaster, accident or other emergency, we take necessary steps in a fair, honest and transparent manner following the instructions from managers and relevant departments and parties.

  Separation from organized crime groups

  • We do not have any connection with organized crime groups and similar organizations, which pose a threat to public order and security, or easily use our company names in a private situation, which could increase the risk of generating contact with such groups and organizations.
  • We do not attempt to deal with organized crime groups alone; any actions should be taken as a team, in consultation with managers and relevant departments. Engaging in a backdoor deal or cover-up is never acceptable.
  • We always make sure that our transaction counterparties are not organized crime groups.

  Preparation for threats of terrorism

  • Each of us raises awareness that we have to protect ourselves, whether we are in our own country or abroad. We voluntarily collect information and prepare safety measures so as not to be involved in an incident or accident such as terrorism and proactively share collected information with managers and relevant departments.

  Ensuring cyber security

  • We understand the importance of cyber security, and refrain from taking actions that are prohibited by the internal security rules. Delete suspicious emails and files without accessing them.

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