CODE OF CONDUCT OF YAMADA

This Code of Conduct is a set of specific guidelines that serves as the fundamental policy for compliance shared within the group companies of YAMADA Group. It outlines the actions that all officers and employees working within the YAMADA Group should practice in their daily activities.

Compliance

YAMADA is continually enhancing compliance in an effort to gain deeper trust from society.
I, as a member of YAMADA, shall comply in good faith with the applicable laws and regulations, internal company rules, and social norms of the countries and regions where we conduct business.

1．Compliance with Laws and Regulations and Internal Company Rules

（1）Accurate Understanding
I shall accurately understand and comply with the provisions and the spirit of the relevant laws and regulations and internal company rules (internal regulations, standards, manuals, etc.), and take appropriate actions when there is a revision made to any of them.

（2）Handling of Unclear Interpretation
If there is an ambiguity concerning the interpretation of the laws and regulations and internal company rules, I shall seek clarification from the legal affairs department or the department responsible for establishing the rules to gain accurate understanding of the provisions.

（3）Handling of Violation
If any action is discovered that is or is likely to be in violation of the laws and regulations and internal company rules, I shall immediately make a report or suggestion to, or consult with my immediate manager, the Legal Affairs Department, or the hotline help desk for reporting.

（4）Report and Notification
I shall make a report and/or notification as required by the laws and regulations and the internal company rules in an appropriate and timely manner.

2．Adherence to Social Norms

I shall conduct myself sensibly as a member of society.

3．Sound Relationship with Government

I shall always maintain transparent and sound political and governmental relationships and shall not provide to domestic and foreign politicians and government officials any benefits such as political contribution, gifts and entertainment that are prohibited by laws, regulations, or the internal regulations.

4．Integration with Community

I shall respect the culture and customs of the countries and regions where we conduct business and act accordingly.

Traffic Safety

As a model company for traffic safety, YAMADA is actively engaged in activities to promote safe driving.
I, as a member of YAMADA, shall follow all traffic and safety rules to ensure safe driving.

Protection of Environment

YAMADA is working to preserve the global environment to contribute toward realization of sustainable society.
I, as a member of YAMADA, shall understand the importance of environmental protection and act accordingly.

1.Reduced Effects on Environment
In performing my tasks, I shall observe the laws and regulations, company regulations, and internal company standards pertaining to the environmental protection, and shall reduce adverse effects on the environment by promoting resource and energy saving and recycling.

2.Prevention of Environmental Pollution
I shall identify and safely control all chemicals and other substances that may potentially pollute the environment.

Corporate Social Responsibility

As a community-based company, YAMADA is making contributions to society through its business activities and also engaged in social activities as a corporate citizen.
I, as a member of YAMADA, shall actively perform activities to contribute to society.

1.Social Contribution through Business Activities
I shall contribute to society by providing compelling products to our customers.

2.Interaction with Community
I shall contribute to the development of community through participation in community events, volunteer work, and other activities.

Corporate Assets

YAMADA preserves and manages tangible and intangible corporate assets as management resources in order to achieve its business objectives.
I, as a member of YAMADA, shall properly handle corporate assets and shall not engage in any conduct that is not for the benefit of the company.

1.Management of Corporate Assets
I shall properly manage the facilities, equipment, jigs, products, issued items, money, software, intellectual property, as well as all other corporate assets in accordance with the internal regulations, and shall not use said assets without authorization or for personal purposes.

2.No Conflict of Interest
I shall not engage in any conduct that gives priority to my personal interest or the interest of the business partners or a third party, to the detriment of the interest of the company.

Information Management

YAMADA is taking appropriate measures to protect and manage confidential and personal information to ensure proper business operation.
I, as a member of YAMADA, shall properly manage the internal confidential information of the company, business partner information as well as personal information of our customers and employees.

Intellectual Property

YAMADA seeks to create value by thinking out-of-the-box in order to deliver value beyond customer expectations.
I, as a member of YAMADA, shall comply with the laws and regulations and internal regulations pertaining to intellectual property.

1.Protection and Use of Intellectual Property
I shall aggressively create and properly protect intellectual property, and put it to good use for the business activities.

2.Prevention of Infringement on Intellectual Property
I shall conduct a thorough research on intellectual property and its associated rights throughout the processes of development and production activities, and shall take appropriate preventive measures if there is potential infringement.

3.Prohibition of Unauthorized Use of Intellectual Property
When using intellectual property owned by other person or entity, I shall obtain permission from the holder of the rights to such intellectual property.

Respect for Human Rights

As an honest and fair company, YAMADA has deep respect for human rights.
I, as a member of YAMADA, shall not engage in any conduct that may be harmful to an individual’s dignity.

1.Prohibition of Forced and Child Labor
I shall not allow any forced and child labor under violence, threat, etc.

2.Prohibition of Discrimination and Respect for Diversity
Based on the principle that all people are equal, I shall respect diversity and make no unfair and discriminatory statements based on attributes of individuals such as nationality, race, sex, religion and gender identity.

3.No Harassment
I shall not engage in any form of harassment, whether it is sexual harassment or power harassment. Further, I shall not overlook any such harassment whatsoever by others.

Health and Safety

As a workplace where all those who work for YAMADA can work with peace of mind, YAMADA pays attention to the physical and mental health of the employees and creates a safe and clean workplace.
I, as a member of YAMADA, shall comply with the laws and regulations and internal regulations pertaining to health and safety, and shall work toward maintaining and improving such workplace environment.

1.Creating Safe and Clean Workplace Environment
I shall fully implement the practice of sorting, organizing, and cleaning after ourselves in our workplace, and create a safe and clean environment.

2.Disaster Prevention
I shall observe the workplace rules and improve unsafe behaviors or conditions.

3.Reporting Anomaly and Problem
I shall immediately report any anomaly or problem detected or discovered in the workplace to my immediate manager.

4.Disaster Procedure
I shall be knowledgeable about the response procedures and contacts in an emergency at all times, and shall stop the damage from spreading when a disaster occurs while giving utmost priority to human lives.

Product Quality

YAMADA is committed to build the best possible quality control system at all times in order to deliver products that will satisfy our customers.
I, as a member of YAMADA, shall be sincerely committed to comply with the internal company rules to maintain and improve the product quality. Further, in the event there is an issue with the product, I shall immediately report it to my immediate manager, identify the root cause, and implement measures for prevention of recurrence as well as improvement.

Business Transaction

As a fair-minded company, YAMADA strives to make progressive business transactions with its business partners while maintaining a relationship of trust.
I, as a member of YAMADA, shall maintain fair and robust relationship with the business partners.

1.Compliance with Laws and Regulations and Internal Regulations Pertaining to Business Transactions
I shall comply with the laws and regulations and internal regulations to protect the integrity of our business relationships and transactions.

2.Prohibition of Gifts and Entertainment
I shall not give or receive any gift or entertainment to or from our business partners that is prohibited by laws, regulations or the internal regulations.

3.No Abuse of Position or Authority
I shall not take advantage of my position or authority to give or receive unjustifiable facilities to or from interested parties.

4.Compliance with Competition Laws
I shall comply with competition laws (Antimonopoly Act) applicable in Japan and overseas, exclude any pursuit of profit by unfair or unauthorized means, and engage in free and fair competition.

Exclusion of Anti-Social Forces

YAMADA is completely committed to block any relationship with the anti-social forces (such as organized crime syndicates, terrorists, drug rings, other criminal organizations) in order to conduct healthy and sound business activities. Further, it shall respond to any unreasonable demand with a firm and resolute attitude.
I, as a member of YAMADA, shall have no involvement whatsoever with the anti-social forces.

Communication

To remain a highly transparent company, YAMADA seeks to exercise appropriate communications practices with stakeholders such as customers, business partners, shareholders, and communities.
I, as a member of YAMADA, shall exercise appropriate and smooth communication practices in and outside the company.

1.Timely Disclosure of Right Information
If I am involved with a disclosure of information to external parties, I shall follow the laws and regulations and internal regulations to ensure an appropriate disclosure.

2.Dialogue with Stakeholders
I shall honestly respond to opinions and inquiries from the stakeholders.

3.Communication in Workplace
I shall seek to create an open workplace environment and promote smooth communication in the workplace.