Action Guideline

Tokyo Seimitsu Co., Ltd. (here in after referred as “ACCRETECH”) has adopted the basic policy to build WIN-WIN relationships with its customers, shareholders, investors, employees, suppliers, governments, and other stakeholders and together achieve long-term sustainable growth. To this end, ACCRETECH shall do the right thing so that it is well accepted in communities in which it operates.

ACCRETECH Group (ACCRETECH, its subsidiaries and its affiliated companies) established this ACCRETECH Group Code of Conduct (here in after referred as “Code of Conduct”) to provide a set of guiding principles which are to be observed by all directors, auditors and employees of ACCRETECH Group (collectively referred to as “ACCRETECH Officers and Employees”). ACCRETECH Group shall meet the highest ethical standards and establish transparency in management systems to promote compliance.

Through the promotion of education to all ACCRETECH Officers and Employees, ACCRETECH Group shall raise their awareness to observe this Code of Conduct.

ACCRETECH Group shall make sincere efforts to obtain understanding and cooperation from all stakeholders in its compliance activities.

Code of Conduct shows “Action Guideline” to ACCRETECH Officers and Employees as follow;

• ACCRETECH Group shall abide by all applicable local and international laws, including import and export laws, respect local custom, culture and social norms, and acts with honesty and the highest ethical standards in its business activities to meet the expectations of all stakeholders.
• ACCRETECH Officers and Employees should be aware of their responsibilities as a good citizen and act with honesty and the highest ethical standards.
• ACCRETECH Group shall establish internal policies, regulations, procedures and rules (internal rules), and provide education and training to ensure that ACCRETECH Officers and Employees should comply with laws, international rules, and social norms.
• ACCRETECH Group has a whistleblower system in place that allows ACCRETECH Officers and Employees to report any act against this Code of Conduct or other compliance rules and regulations, without going through their usual chain of command. The whistleblowers are to be protected and kept free from any disadvantages or unfavorable treatments.

• ACCRETECH Group shall respect basic human rights. ACCRETECH Officers and Employees should not discriminate nor offend others by any form of harassment.
• ACCRETECH Group shall comply with labor laws, respects the basic rights of workers, and shall not infringe them.

• ACCRETECH Group continuously seeks to ensure safety and quality of its products and services and implement environmental measures, while complying with international and local laws and regulations.
• ACCRETECH Group shall abide by industrial safety and health laws, and laws to prevent industrial accidents. Additionally ACCRETECH Group shall create, maintain, and improve for a safe and healthy work environment for employees.
• To contribute to the protection of the global environment and sustainability of the society, ACCRETECH Group shall control energy consumption, reduce waste, and promote recycling, thereby preventing global warming and pollutions.

• ACCRETECH Group shall deal with its stakeholders such as customers, suppliers or business partners in compliance with laws according to sound business practices and social norms, and shall not make any unreasonable request by taking advantage of its dominant position.
• ACCRETECH Group shall comply with laws related to competition such as “The Antimonopoly Act” in areas where it operates, and conduct fair sales activities according to sound business practices and social norms. ACCRETECH Group shall provide proper indication on the quality and price of its products and services and shall not make any indication that may mislead customers or suppliers. No defamation, false or misleading advertisement may be used.
• ACCRETECH Group always shall consider technology, products and services which customers need by hearing what they want and acts with fairness and honesty to gain customer satisfaction.

• ACCRETECH Group shall act with great care in receiving/giving entertainment, gifts or donations according to sound business practices and social norms.
• ACCRETECH Group shall not demand entertainment, gifts, donations, or any other favorable arrangements or benefits. ACCRETECH Group shall not grant unreasonable rebate or discount even if so demanded.
• ACCRETECH Group shall not offer any bribery to public officers. ACCRETECH Group shall not support any particular political parties or organizations, politicians, or political candidates. ACCRETECH Group complies with laws and regulations and may not give any entertainments, gifts, donations or any other favorable arrangements or benefits in violation of such laws.

• ACCRETECH Group continuously makes efforts to communicate actively with its stakeholders and discloses its corporate information in intelligible manner to obtain understanding and trust from them.
• ACCRETECH Group shall make timely, fair, and accurate information disclosure on its management policy, financial records, business situations, products and services to gain trust from its stakeholders.

• ACCRETECH Group recognizes the value of intellectual property. ACCRETECH Group shall properly protect and manage its own intellectual property rights while respecting the rights of others. ACCRETECH Group shall not knowingly misuse the intellectual property of others or violate such rights. ACCRETECH Group takes prompt and resolute measures to any infringement or misuse cases of its intellectual property rights.

• ACCRETECH Group should manage and protect any confidential or personal information according to local laws and internal rules. ACCRETECH Group should not use such information for any reason other than legitimate purposes and should not take out, use, or disclose such information without permission.
• ACCRETECH Officers and Employees should not take out, use, or disclose any confidential or personal information without permission even after they leave ACCRETECH Group.

• ACCRETECH Group shall prohibit ACCRETECH Officers and Employees from insider trading by themselves, or through their family, friends, or other acquaintances. ACCRETECH Group shall prohibit ACCRETECH Officers and Employees from disclosing any insider information to any other people such as their family, friends, or other acquaintances

• ACCRETECH Officers and Employees should not engage in any act that involves, may involve, or may appear to involve a conflict of interest of ACCRETECH Group for the benefit of themselves or related third parties (such as customers, suppliers, business partners, competitors, or etc.) without legitimate reasons or permission.
• ACCRETECH Officers and Employees should not engage in any act that benefits themselves or related third parties using their position or authority in business without legitimate reasons or permission.

• ACCRETECH Officers and Employees are responsible for properly managing company assets and protecting them from any loss, damage, misuse, theft, sabotage, or falsification.
• ACCRETECH Officers and Employees shall not use company assets for their own personal benefit, for any reason other than legitimate purposes, knowingly damaging, misusing, losing, sabotaging, falsifying or stealing them, or taking them out without obtaining prior permission of ACCRETECH Group.

• Any information that could be interpreted as an official ACCRETECH Group comment should be provided to the press (news media, research organizations, reporters, websites, social media, etc.) only by the corporate communications, investor relations, or other departments given the authority to deal with the press.
• ACCRETECH Officers and Employees should not disclose any information related to ACCRETECH Group or its business to the press without obtaining prior permission of ACCRETECH Group to protect confidential or personal information.

• ACCRETECH Group shall sever and refuse to have any relations with antisocial organizations or elements such as organized crime groups that threaten the order and safety of society. ACCRETECH Group shall refuse to accept any demand from antisocial organizations or elements, and never offers money or favorable arrangements to them for any reasons.
• ACCRETECH Group shall work as one to take action against antisocial organizations or elements. ACCRETECH Group shall take a resolute attitude to antisocial organizations or elements in collaboration with external specialized agencies, including taking legal measures.

• ACCRETECH Group shall never engage in any trade that may impair international security, human rights protection, or environmental preservation.
• For export and import of goods (including services) and provision of technologies (including technical information, cooperation and assistance, and software) to foreign countries, ACCRETECH Officers and Employees should understand the objectives of international and local laws and regulations on security and abide by them as well as internal rules and regulations in order to prevent the development and manufacturing of weapons of mass destruction or conventional weapons and their use as assistance to terrorists.
• From the viewpoints mentioned in above, ACCRETECH Group shall conduct strict control such as conducting proper examination, going through a procedure to obtain approval or license from regulatory authorities if necessary, avoiding trade if approval or license is not obtained.
• ACCRETECH Group shall not use any minerals which are a source of money for armed insurgents who may abuse human rights or destroy the environment (so-called conflict minerals).

• ACCRETECH Group shall keep sound, transparent and proper relations with politics and religions. ACCRETECH Group shall not support or oppose any particular politics or religions.
• ACCRETECH Officers and Employees may engage in political activities or religious propagation activities only in a private capacity using their own private times and resources, but not in the facilities or premises of ACCRETECH Group.

• ACCRETECH Group shall establish, maintain and improve its internal control system.