Organo Group Code of Corporate ConductOrgano Group Code of Corporate ConductOrgano Group Code of Corporate ConductOrgano Group Code of Corporate Conduct

I. Trusting Relationships with Customers

1.Quality and Safety Control of Our Products

• 1) We will grasp consumer and customer needs to develop and provide socially beneficial products and services that contribute to the sustainable development of society.
• 2) We will build and maintain appropriate quality management systems, such as ISO-compliant systems, and follow prescribed procedures with an eye to continuously improving the quality and reliability of our products and services.
• 3) We will comply with laws, standards, and other regulations aimed at ensuring safety and work to ensure that the quality and safety of our products and services conform to all prescribed requirements.
• 4) We will provide relevant information about our products and services to consumers and customers.
• 5) We will respond to inquiries from consumers and customers promptly, sincerely and appropriately. In the event of an accident or problem, we will take necessary measures to prevent any recurrence.

II. Fair Transactions and Competition

2.Appropriate Business Transactions Standing on Fair and Open Competition

• 1) We will compete fairly and openly in domestic and global marketplaces. That includes refraining from forming a cartel with our competitors for the purpose of regulating prices, production/sales volumes, etc., engaging in bid-rigging schemes where we would collude with other bidders to fix public tender bids, or doing anything that might violate competition laws (Antimonopoly Act, Unfair Competition Prevention Act, etc.) or other relevant regulations in countries and regions.
• 2) We will clearly specify all terms and conditions of transactions when buying raw materials, goods, services, etc. and select our suppliers and contractors in a fair and reasonable manner on the basis of pricing, quality, delivery terms, and other conditions.
• 3) We will work to ensure that our suppliers take an interest in social responsibility initiatives for legal compliance, the environment, human rights, safety and health, etc., in order to fulfill the respective social responsibilities of both parties.
• 4) We will comply with laws and regulations related to competition laws (the Proper Transactions Act, Construction Business Act, Unfair Competition Prevention Act, etc.) in countries and regions and will not conduct unfair transactions with suppliers or take actions to the detriment of our suppliers by using our dominant bargaining position.
• 5) We will comply with laws and regulations related to anti-corruption in countries and regions and refrain from all involvement in corruption.

3.Respect for Intellectual Property Rights

• 1) We will retain the results of R&D, technology development, etc. as intellectual property and make effective use of it.
• 2) We will respect others’ intellectual property rights and refrain from improper use of them.
• 3) We will not infringe upon any others’ intellectual property rights in any way, including illegally copying computer software or other copyrighted materials.

4.Security Export Control

• We will export our products and related technologies only in accordance with applicable laws, regulations, and internal rules to prevent them from being used for arms and weapons.

5.Compliance with Import and Export Laws and Regulations

• We will export and import products and provide technologies in strict accordance with applicable laws and regulations in countries and regions with government approval as necessary using established customs procedures.

6.Bribery Prohibition and Gifts and Entertainment Control

• 1) We will not give, offer or promise any gifts, entertainment, money, or other economic benefits to domestic or overseas government officials (or those in similar positions) or to any related party, including private-sector business partners, for the purpose of undue gains or acquiring or maintaining preferential treatment or in exchange for business favors. In addition, requesting or receiving these is also prohibited.
• 2) All business entertainment, gifts, etc. provided as a matter of business etiquette shall strictly comply with applicable laws and regulations in the country or region and with internal rules and shall be limited to that which is transparent and which falls within the scope deemed valid by society. We will not take any action with respect to the public or private sectors that could be construed as bribery or offering benefits from the perspective of laws, regulations, and social norms.

7.Political Donation Control

• We will comply with applicable laws (Public Offices Election Act, Political Funds Control Act, etc.) established in countries and regions when making donations to politicians, political parties, or any other political organization and will refrain from inappropriate involvement in political activities.

8.Avoiding Contact with Antisocial Forces

• We will resolutely confront any antisocial forces or organizations that pose a threat to the order and security of civil society, and sever any relationship with such concerned individuals and organizations.

III. Disciplined and Healthy Workplace

9.Compliance with Non-Competition Duty

• Organo employees may not be employed by other entities nor engage in any kind of business that would be detrimental to the interests of Organo without express permission from the company.

10.Compliance with Laws, Regulations, and Social Norms

• In all our business activities, including construction, production, sales, research and development, we will continually work with integrity and responsibility as a member of society, complying with social norms as well as applicable laws and regulations in countries and regions and internal rules, and strive to maintain genuine and fair business activities. We will not act in any way that could undermine the company’s credibility or integrity.

11.Compliance with Rules of Employment and Other Internal Regulations

• Organo employees will comply with the Rules of Employment and related regulations. We will also comply with the relevant labor laws in countries and regions that form their basis.

12.Ensuring a Healthy Workplace

• 1) We will comply with all relevant labor laws and strive to maintain and improve a comfortable workplace environment.
• 2) We will properly control working hours, holidays and vacations of all employees so as not to exceed legal limits.
• 3) Organo employees may not engage in political or religious activities in the workplace, including solicitation on behalf of political or religious groups as well as electioneering, except in specific situations with proper, advance corporate authorization.
• 4) We will foster a culture of taking on challenges and a desire to learn, and promote the creation of a workplace that is fulfilling and vibrant.
• 5) We will work to enhance communication between management and employees through a variety of means.

13.Workplace Safety and Health

• 1) We will comply with all laws and regulations concerning occupational safety and health in countries and regions, strive to improve the workplace environment in safety and health, and prevent occupational accidents.
• 2) We will comply with all laws and regulations concerning occupational safety and health in countries and regions and work to enhance employees’ physical and mental health.

14.Proper Use of Corporate Assets

• 1) We will efficiently utilize the company’s assets, both tangible and intangible, ensuring appropriate controls and maintenance procedures to limit the possibility of damage or loss.
• 2) We will acquire, sell, and dispose of company assets only in accordance with the company’s internal rules.
• 3) We will not use company assets or expenses for personal benefit.

IV. Fair Information Disclosure

15.Timely and Appropriate Information Disclosure

• We will disclose important and credible information in a timely and appropriate manner to a wide range of stakeholders, including stockholders, investors, consumers, business partners, employees, and local communities. We will also engage in interactive communication with our stakeholders in order to deepen mutual understanding.

16.Proper Accounting Procedures and Records Management

• 1) We will conduct proper accounting procedures in accordance with applicable laws and regulations in countries and regions and with internal rules to ensure the reliability of financial reports and pay taxes appropriately.
• 2) We will appropriately manage and maintain all records of our business transactions and activities in accordance with applicable laws and regulations as well as relevant internal rules.
• 3) We will cooperate with any internal and external audits as well as investigations by public authorities and will not discard, conceal, or tamper with records with an aim to obstruct an audit, investigation, lawsuit, etc.

V. Respect for Human Rights

17.Respect for Human Rights, Prohibition on Discrimination

• 1) We will respect the dignity, rights, and diversity of all people and prohibit all forms of discrimination.
• 2) We will not abuse human rights through improper labor practices, such as child labor and forced labor.

18.Prohibition on Harassment

• 1) We will not commit any human rights violations, including all forms of harassment such as sexual harassment, power harassment, and maternity harassment, as well as acts of violence and bullying.
• 2) We will not engage in any inappropriate speech or conduct that causes discomfort to others, nor will we make defamatory or slanderous remarks about others.

VI. Sustainability Initiatives

19.Sustainability Initiatives

• We will actively promote sustainability activities to achieve a sustainable society and global environment.

20.Environmental Conservation and Protection

• 1) We will sufficiently recognize the importance of environmental conservation and protection, comply with all applicable environmental laws, regulations, and internal rules, etc., including chemical substance controls, and create and implement internal standards.
• 2) We will actively work on conserving resources and energy, recycling, and reducing waste throughout all our operations.
• 3) We will develop environment-friendly products and technologies as well as products and services that will help solve environmental problems.
• 4) We will actively work on protecting biodiversity and the natural environment.

21.Corporate Citizenship

• 1) We will actively undertake CSR activities as a “good corporate citizen.”
• 2) We will make efforts to coexist with the local communities where we do business for mutual prosperity.
• 3) We will appropriately disclose company information, engage in dialogue with a wide range of stakeholders, and work to raise corporate value.

VII. Strict Information Management

22.Prohibition of Insider Dealings

• If we should discover some non-public material information about Organo, its affiliates, or business partners during the course of our duties, we will keep that information strictly confidential and will not sell or purchase the relevant company’s stocks, etc. (i.e. engage in insider trading) until said non-public material information is disclosed publicly.

23.Management of Company Secrets

• 1) We will appropriately manage the company’s confidential information (including confidential information disclosed to us by other parties) and will not improperly or unfairly disclose or leak such information to another party or use the information for our own benefit. Furthermore, we will not improperly or unfairly acquire the confidential information of other parties.
• 2) We will sign a nondisclosure agreement when we need to disclose confidential company information to a third party for business purposes.
• 3) We will not acquire, use, disclose, or leak the trade secrets of another party while knowing that information was acquired or potentially acquired through improper or unfair means.
• 4) We will take appropriate technical and physical security measures to protect computer systems, data, etc. in order to properly manage confidential company information throughout the entire process from obtaining information to using, storing, and disposing of it.
• 5) We will not disclose or use confidential company information that we have obtained during our tenure of office once we leave the company.

24.Protection of Privacy

• 1) We will implement strict confidentiality controls for personal information about our directors and employees, obtained or disclosed during the course of business operations, and will use such information only for the purpose of performing relevant operations.
• 2) We will implement strict confidentiality controls for personal information about individuals working for parties other than Organo, obtained or disclosed to us in the course of business operations, and will use such information only for purposes authorized by the party or individual.

25.Proper Use of IT Systems

• 1) We will use the company’s IT systems only for business purposes and not for personal use.
• 2) Authentication information such as IDs and passwords used for business shall be strictly managed and shall not be disclosed or divulged to any unauthorized third party.
• 3) No unauthorized access of IT systems shall be conducted regardless of the means.

VIII. Top Management’s Role

26.Top Management’s Role

• 1) Top management will recognize its obligation to serve as a role model as it takes the lead in embracing this Code of Conduct and implementing it throughout the organization. The executive management team will continually keep their ears to the ground for internal and external feedback as they set up an effective mechanism for implementing this Code of Conduct throughout the organization. Organo’s top management will also work to implement this Code of Conduct throughout its Group companies.
• 2) Top management will create a workplace environment that fosters employees’ independence and creativity so that individual employees can fulfill their potential while nurturing an open corporate culture where employees can freely speak their mind.
• 3) In the event that this Code of Conduct is violated, top management will make it known both internally and publicly that it will do everything possible to resolve the situation, as it determines the cause of infringement and makes efforts to prevent similar violations from occurring in the future. At the same time, top management will act quickly to make a full public disclosure, to achieve accountabilities, and, upon determining authority and accountability, will impose strict disciplinary action against those responsible, including top management itself if found culpable.