Organo Group Company Code of Conduct

Objective

Organo Group’s Code of Conduct sets forth the guidelines to be observed by all directors and employees of Organo Group. We aim to achieve our sustainable growth, fulfill our corporate social responsibility to build a sustainable society, that means constantly working to help industry, human being and environment coexist in harmony by acting in line with the following guidelines.

Management Philosophy

Organo serves as a valuable partner company by leveraging its advanced technologies cultivated through long experience with water treatment, by contributing to the industries that create the future, and by playing a key role in the development of societal infrastructure.

Organo Group Company Code of Conduct

Ⅰ.Building Trust by Meeting Expectation of Customers, Business Partners, and Stockholders

1. Quality and Safety Control of Our Products
1)We will work in light of consumer and customer needs to develop and provide socially beneficial products and services that are conducive to the sustainable development of the society. 2)We will build and maintain adequate 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 do everything possible to make sure 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 with 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.
2. Fair Business Transactions Standing on Free 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 do anything that might violate anti-trust laws or other relevant regulations. 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 look to see that our suppliers and contractors have CSR initiatives aimed at ensuring legal compliance, environment, and human rights so that we all can fulfill our corporate social responsibilities. 4)We will comply with the Subcontract Act, Construction Business Act, and other relevant laws and will not abuse our dominant bargaining position, etc. to the detriment of our suppliers or contractors.
3. Intellectual Property Rights Policy
1)We will retain the results of R&D, etc. as intellectual property and make the most use of the rights to such intellectual property. 2)We will not use any others’ intellectual property rights without proper authorization and will sign a legally binding agreement before using any such rights. 3)We will not infringe upon any others’ intellectual property rights in any way, including illegally copying computer software or other copyrighted materials.
4. Confidential Information Management
1)We will strictly safeguard confidential company information (including the confidential information disclosed to us by other companies), and will not disclose or provide such information to a third party without permission, use it for personal gain, or make use of it for any other unauthorized purposes. 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 obtain, use, disclose, or leak other companies’ trade secrets by unjustifiable or fraudulent 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.
5. 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.
6. Compliance with Import and Export Laws and Regulations
We will export and import products in strict accordance with applicable laws and regulations with government approval as necessary using established customs procedures.
7. Gifts and Entertainment Control
1)We will not give or receive entertainment, gifts, money, or other economic benefits to/from our customers, suppliers, contractors, and other business partners with the aim of securing or keeping undue gains or preferential treatment. 2)All expenses we give or receive related to business entertainment and gifts to/from our customers, suppliers, contractors, and other business partners shall fall within accepted social or international norms.
8. Bribery and Corruption Prevention
1)In either domestic or overseas market, we will not give any entertainment, gifts, money or other economic benefits to public officials, or those in similar positions, in order to gain an improper business advantage or in return for business favors. 2)We will comply with Japan’s National Public Service Ethics Act and other related laws, and will not give any entertainment or gifts to public officials, or those in similar positions, even if they have no business relationship with us in Japan.
9. Political Donation Control
We will comply with applicable laws, including Japan’s Public Offices Election Act and Japan’s Political Funds Control Act, when making donations to politicians, political parties, or any other political organizations.
10. Timely and Appropriate Information Disclosure
We will disclose relevant 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. And we do interactive communication with our stakeholders in order to deepen mutual understanding.
11. 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.
12. Financial Integrity and Records Management
1)We will process all business transactions based on proper accounting procedures in accordance with applicable laws, regulations, and internal rules, to ensure the integrity of our financial reports. We will not engage in the fraudulent accounting such as issuing false slips and listing off-the-balance assets or liabilities. 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.
13. 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.
14. Compliance with Non-Competition Duty
Organo employees may not be employed by other entities nor engage in any kind of business that would compete with Organo without express permission from the company.

Ⅱ.Ensuring a Comfortable Workplace Where All Employees Can Realize Their Full Potential

15. Compliance with Laws, Regulations, and Social Norms
In 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 local and international laws, regulations and internal rules, and keeping eyes to maintain genuine and fair business activities. We will not act in any way that could undermine the company’s credibility or integrity.
16. Compliance with Rules of Employment and other Internal Regulations
Organo employees will comply with the Rules of Employment and related regulations.
17. Protecting Human Rights and Preventing Discrimination
1)We will respect diversity, rights and individual personalities of all employees and will not discriminate against any person based on his or her nationality, gender, region, physical characteristics, social status, etc. 2)We will not be party to any kind of child or forced labor, or any other unlawful forms of labor that violates human rights.
18. Preventing Harassment
1)We will not condone any form of sexual harassment, power harassment, violence, or bullying. 2)We will not engage in or condone the use of abusive words or behavior.
19. Ensuring a Healthy Workplace
1)We will comply with all relevant labor laws and strive to maintain and improve the work environment. 2)We properly control working hours, holidays and vacations of all employees in accordance with the relevant laws and regulations. 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.
20. Workplace Safety and Health
1)We will comply with all laws and regulations concerning occupational safety and health, strive to improve the workplace environment in safety and health, and prevent occupational accidents. 2)We will work to enhance employees’ physical and mental health by implementing measures designed to prevent overworking and foster mental health.
21. Protecting Personal Information
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.
22. Proper Use of Corporate Assets
1)We will utilize the company’s assets, both tangible and intangible, in the most efficient manner possible, 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 for personal expenses or benefit.
23. Proper Use of IT Systems
1)We will use the company’s IT systems only for business purposes and not for personal use. 2)We will safeguard IDs and passwords that are used for our business operations and will not disclose them to unauthorized persons. 3)We will not make fraudulent use of user IDs or passwords belonging to other persons, and not hack into other persons’ computer systems.

Ⅲ.Contributing the Sound Development of Society

24. Environmental Conservation and Protection
1)We will place great value on environmental conservation and protection, and comply with all applicable environmental laws and regulations, including chemical substance controls, and implement necessary 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.
25. 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.
26. Top Management’s Role
1)Top management recognizes 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 and its affiliates. The executive management team will continually keep their ears to the ground as they set up an effective mechanism for implementing this Code of Conduct throughout the organization. 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 between top management and employees. 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.

*This Code of Conduct is quoted from Charter of Corporate Behavior and its Implementation Guidance of KEIDANREN (Japan Business Federation).

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