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Business Conduct & Social Ethics

1. Legal Compliance

1.1 Basic Attitude
The Company recognizes that the most important code of conduct for the Company to continue businesses in the society is compliance and shall demand the Directors and Employees to comply with and practice not only the laws and regulations but also morals and corporate ethics behind them.
1.2 Legal Compliance/Appropriate Judgment Process Implementation
The Directors and Employees recognize not only the appropriateness of the results but also the importance of the process leading to the results, and the decision-making shall always require sufficient discussions and consideration based on the facts and appropriate approval procedures. In addition, the Company shall organize the rules and procedures for the Employees to take appropriate procedures.

2. Promotion of Social Communication

2.1 Social Communication and Information Disclosure and Information Protection
The Company recognizes that the Company bears social responsibilities for a broad range of stakeholders including the clients, their customers, cooperating companies, Employees, shareholders, regional communities and authorities. Upon occurrence of events that may significantly affect the stakeholders, the Company shall take responsibilities for appropriate explanations at appropriate timing and shall make efforts for resolution of the joint challenges through two-way communications.
2.2 Responses to Globalization
The Company shall respond to the globalization of the business activities, conduct management taking into consideration the legal regulations, cultures and customs of each country and region where the business is conducted and contribute to the development of economy and society of the said country and region by providing new values

3. Social Relationships

3.1 Social Contribution
The Company recognizes that addressing the social challenges and issues directly or indirectly is a requirement from the stakeholders to take its social responsibilities, identify the challenge areas to be addressed in priority in view of the managerial ideals and promote its social contribution activities.
3.2 Regional Contribution
The Company shall contribute to the local revitalization such as creation and promotion of employment by inviting business projects, actively participate in the various regional efforts, make efforts for the harmony with the regional societies and contribute to the realization of the abundant and comfortable regional societies.

4. Contribution to Environmental Conservation

4.1 Social Contribution
The Company recognizes that the Company bears social responsibilities for a broad range of stakeholders including the clients, their customers, cooperating companies, Employees, shareholders, regional communities and authorities. Upon occurrence of events that may significantly affect the stakeholders, the Company shall take responsibilities for appropriate explanations at appropriate timing and shall make efforts for resolution of the joint challenges through two-way communications.

5. Acquisition of Trust of Customers

5.1 Service Development and Provision and Securing Quality
The Company shall develop and provide socially useful services to respond to the needs of the clients and their customers, make efforts for securing quality and realize client values.
5.2 Transmission of Service Information
The Company shall always provide correct and appropriate information in the sales activities for the clients, transmission of information by websites and PR and advertisements activities through seminars, lectures and other media.
5.2 Response to Inquiries, Quality Improvements and New Service Development
The Company shall quickly and sincerely respond to the requests form the clients and their customers and awareness from the Employees, not only improve the proprietary services but also actively provide advice that may be useful for the development and improvement of the products and services of the clients.

6. Establishment of Trust Relationships with Business Partners

6.1 Fair, Transparent and Free Competitions and Appropriate Transactions
The Company shall not be engaged in the acts that inhibit fair, transparent and free competitions by unfair transaction methods and abuse of dominant bargaining position.
6.2 Restrictions on Gifts and Entertainment
The Company shall not give or receive entertainment, money, gifts and other profits beyond the scope socially considered appropriate and for the purpose of obtaining illicit profits between the clients and cooperating companies.
6.3 Implementation of Appropriate Indication
The Company shall not place false, incorrect or misleading indications for the services provided by the Company and make efforts for realizing fair and transparent competitions.
6.4 Purchase Activities
The Company shall establish the appropriate outsourcing and purchase transaction principles, fully evaluate the cooperating companies upon their selection and execute appropriate agreements. In addition, the Company shall follow the written order placement and payment date provided for in the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors and make efforts to maintain and establish the long-term trust relationships with the cooperating companies by eliminating unfair transactions by abusing the dominant bargaining position.
6.5 Appropriate Agreements
The Company shall correctly understand risks and costs for agreements with the clients and cooperating companies and execute the agreements that state correct and clear terms and conditions.
6.6 Compliance with Agreements
The Company shall always comply with the agreement contents in developing and providing services and make efforts for achieving the SLA promised with the clients. In addition, the Company shall not alter KPI or make false reports
6.7 Relationships with clients (1) - Compliance with Rules
The Company shall determine the rules required for businesses with the clients and cooperating companies, establish the common rules and checking structures and mutually make best efforts for the compliance with the rules.
6.8 Relationships with Clients (2) - Making Proposals and Advice for Improvements
The Company shall recommend the best methods to improve the relationships between the clients and their customers to the clients.
6.9 Relationships with Clients (3) - Communication
The Directors and Employees shall always behave well for the clients and cooperating companies during or outside the business hours to establish the mutually respectful relationships.
6.10 Protection of Personal Information
The Company shall take every precaution possible in the overall process of information collection, use, storage and disposition in accordance with the personal information protection principles and improve the management systems continually to maintain the best conditions at all times.
6.11 Protection of Confidential Information
The Company shall appropriately protect its proprietary information and information of the clients, their customers and cooperating companies held as the information managed as confidential and shall not obtain or use the confidential information by illicit or unjust method. The Directors and Employees may not refer to any information of the Company, clients, their customers or cooperating companies made known in the course of business outside the businesses and shall be prohibited to write about the said information on the Internet.
6.12 Protection of Proprietary Intellectual Property Rights
The Company recognizes that the tools and applications developed for implementing the businesses or manuals and produced materials are the important intellectual properties and shall appropriately protect the proprietarily owned intellectual property rights.
6.13 Protection of Intellectual Property Rights of Third Parties
The Company shall respect the intellectual property rights of third parties and shall not act to violate them.
6.14 Appropriate Record of Accounting at Appropriate Timing
The Company shall fairly treat accounting and prepare appropriate accounting records by establishing the business processes that incorporate multiple confirmations and approvals.
6.15 Business Continuation at Disasters
The Company shall previously discuss the responses in accordance with the conditions of disasters with the clients and cooperating companies, and in case of actual disasters, the Company shall make the best efforts to continue businesses through close communications.

7. Establishment of Pleasant Working Environment

7.1 Compliance with Labor related Laws and Regulations
The Company shall comply with the labor related laws and regulations including the Labor Standards Act and make efforts for maintaining and improving the work environment that is pleasant to the Employees.
7.2 Establishment of Safe Environment
The Company shall comply with the various related laws and regulations including the Fire Service Act and the Industrial Safety and Health Act and make efforts for maintaining and improving the working environment that is safe and pleasant.
7.3 Compliance with Company Policies incl. Work Regulations
The Company shall prepare the Work Regulations and rules in accordance with the various laws and regulations and fully notify the Employees of them and encourage them to comply with the said rules.
7.4 Safety Confirmation at Disasters
The Company shall organize the structures and systems to promptly confirm the safety of the Employees and evacuate them in case of disasters.
7.5 Prohibition of Child Labor and Forced Labor
The Company shall not employ the school children under the minimum working age determined in the countries or regions or force the labor against the will of the workers.
7.6 Prohibition of Political and Religious Activities
The Company shall not conduct any political activities or religious activities in the business activities for the clients and cooperating companies. In addition, the Company shall not solicit the purchase of or sell goods and services not related to the businesses in any case.
7.7 Respect for Diversity
The Company shall make efforts for making an open workplace where the Employees with various values actively exchange opinions, respect each other and work pleasantly. In addition, the Company shall eliminate discriminations based on sex, age, hobbies, education, nationality, race, religion or disabilities and any discriminations on account of unreasonable events in solicitation, hiring, promotion, etc.
7.8 Addressing Human Resources Development and Career Development
The Company shall organize the system to objectively evaluate the abilities of the Employees and the ability development structure, give opportunities for the willing and skillful Employees to fully perform their tasks and support the human resources development and career development.
7.9 Workplace Communication
The Employees shall consult the managers without fail when unsure of judgment, and the managers shall always make the best efforts to establish the workplace environment where it is easy for the Employees to consult the managers and make efforts for the organizational resolution.
7.10 Prohibition of Various Harassments incl. Power Harassments and Sexual Harassments
The Directors and Employees shall respect mutual human rights and shall not conduct any acts that harm the dignity of others, disturb the healthy environment, morals and orders of the workplace and inhibit business implementations or deliver or take any misleading words or behavior including sexual words and behavior (sexual harassment) or harassment based on positions or authorities (power harassment).
7.11 Promotion of Work-life Balance
The Company shall establish the personnel and treatment system to allow work in very diverse ways to promote the work-life balance of the Employees. The managers shall take care not to place excessive burdens on the Employees and reduce overtime work and promote acquisition of holidays by supporting planned business implementations.
7.12 Compliance with Social Rules and Manners
The Directors and Employees shall observe social orders and morals and be responsible as the members of the society and the Employees of the Company to behave honorably in the society.
7.13 Conservation of Corporate Assets
The Directors and Employees shall appropriately manage the corporate assets managed by the individuals or divisions in accordance with the rules determined by the Company so that the assets shall not be damaged.
7.14 Appropriate Use of Corporate Assets
The Directors and Employees shall use the corporate assets managed by the individuals and divisions only for the business purposes and shall not use them for private or illicit purposes.
7.15 Prohibition of Conflict-of-interest Transactions
The Directors and Employees shall not conduct acts to obtain profits in sacrifice of the profits of the Company by conducting businesses that are competing with the businesses of the Company by themselves or having transactions with the Company through the companies in which they or their relatives are involved.
7.16 Insider Transactions
The Directors and Employees shall not obtain important information in relation to the Company or the business partners of the Company for obtaining personal profits and make efforts for preventing insider transactions.
7.17 Media Relationships
The Directors and Employees shall follow the instructions of the PR division in responding to various media, shall not contact media without permission of the PR division and shall not make statements actively or potentially representing the Company. In addition, the Employees shall appropriately submit opinions at appropriate timing in accordance with the methods and routes determined by the Company and shall not make false accusations on the Internet when they have opinions on the management policies, businesses, personnel, organization and management structure of the Company.

8. Sound Relationships with Politics and Authorities

8.1 Relationships with Politics and Authorities
The Company shall maintain sound and transparent relationships with politics and authorities and shall not conduct acts that are dubious of collusive relationships and others such as bribery, illegal profit provision and excessive entertainment and gift giving.

9. Response to Anti-social Forces

9.1 Blocking of Relationships with Anti-social Forces and Groups
The Company shall respond to the anti-social forces and groups that are threatening to the social orders and safety with resolute attitudes and shall have no relationships whatsoever including transaction relationships.

10. Compliance with Code of Conduct

10.1 Roles of Top-level Executives
The top-level executives shall be aware that their own sincere attitudes are the basis of legal compliance and the establishment of corporate ethics, take initiatives to fully notify internally and make efforts for fulfilling the corporate social responsibilities.
10.2 Establishment of Compliance Structure
The top-level executives shall establish the structure to promote corporate ethics and risk management and take initiatives so that the said structure effectively functions. In addition, they shall organize the reporting, notification and consultation structure to promptly and appropriately obtain various types of internal information and continuously improve the corporate activities.
10.3 Full Notification
The top-level executives shall implement education and training in relation to the full notification of the compliance with the Code of Conduct and vigorously promote the corporate ethics by continuously improving the contents of the said education and training. In addition, they shall make efforts so that not only the Directors and Employees but also the cooperating companies provide cooperation that is necessary for complying with the Code of Conduct.
10.4 Measures for Active or Potential Violations
The top-level executives shall clearly display the attitude of resolving any matters in violation of the Code of Conduct by themselves internally and externally, make efforts for clarifying reasons and taking preventive measures, promptly and appropriately disclose information to the stakeholders and fulfill explanation responsibilities.
10.5 Handling in Case of Violation
The Company shall strictly handle the violator, Directors or people in the senior position having management and supervision responsibilities in accordance with the internal rules for the act that violates or is in conflict with the internal rules in relation to punishment.