HOKKAN HOLDINGS LIMITED

Compliance

Bylaws of the “Code of Conduct” for executives and employees

1. Respect human rights and do not discriminate and harass.

  • Do not discriminate against people by race, skin color, creed, religion, sex, nationality, age, descent, physical or mental disabilities, and diseases, for any reason whatsoever.
  • Do not sexually harass.
  • Correctly understand and recognize human rights issues, such as Dowa issues (discrimination against people from or living in certain communities), and do not discriminate.
  • Respect the cultures/customs/languages of each country/region, and try to blend in with the global community and regional communities.

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2. Observe environmental treaties, laws, and regulations, and take global environment-friendly actions.

  • Observe environmental treaties, laws, and regulations, and conserve the environment.
  • In pursuing corporate activities, take influences on natural environments and ecosystems into consideration.
  • Use resources and energy efficiently, and try to reduce waste and increase recycling.

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3. In fulfilling business, observe all laws, regulations, and ordinances, and make it a principle to act fairly.

  • Observe laws and regulations related to trading products and services, and make thorough arrangements for the acquisition of permission and licensing, the submission of various notices, and other procedures, in order to eliminate omissions.
  • Do not engage in any unfair restraint of trade with companies in the same trade or trade group, such as consultation and making agreements on price, production amount, production facilities, and market allocations.
  • Do not decline or terminate business with specific business operators (including discount dealers) and new entrants by conspiring with companies in the same trade or trade group. Moreover, do not join collusive bidding.
  • Do not carry out any action that may unfairly infringe upon the interest of subcontractors.

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4. Adequately handle not only corporate information, but also the information obtained outside the company and third party rights, including intellectual property rights.

  • Strictly control the confidential information of the company, and do not leak it nor use it for non-business purposes.
  • When it is necessary to disclose the confidential information of the company to a person outside of the company because of business necessity, take heed to prevent information leaks by, for example, concluding a non-disclosure agreement beforehand.
  • Even after retirement, do not leak the confidential information of the company nor use it.
  • When the departments that handle inquiries from outside are designated, do not handle the issues using your own judgment, but instead, relay the information to the appropriate department.
  • Do not infringe upon any intellectual property rights of third parties, including unauthorized copies of computer software.

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5. Do not perform any unfair trading of stocks and bonds (insider trading).

  • Do not purchase or sell our company’s stock or other financial instruments if you learn any “important facts” of the company that would have a notable influence on investment judgment, until such facts are disclosed to the public.
  • Do not purchase and sell any client company’s stock or other financial instruments when you learn any “important facts” of a client company that would have a notable influence on investment judgment, until such facts are disclosed to the public.

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6. Do not act contrary to the interests of the company. Draw a line between public and private affairs.

  • Do not unfairly use the tangible and intangible assets of the company.
  • Do not use the property and expenses of the company for personal purposes.
  • Do not use the information system of the company without authorization.
  • Do not engage in other occupations without the approval of the company.
  • Return the assets of the company at the time of retirement/resignation.
  • Do not conduct personal activities that are unrelated to work duties at the workplace, such as those involving politics and religion.

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7. Regarding gift-giving and business entertainment, do not violate any laws or regulations, and appropriately perform business under normal social conventions.

  • Do not provide unfair business entertainment, presents, advantages, or other economic favors to public employees or persons who are in an equivalent position as a public employee, whether at home or abroad.
  • Do not complete payment if you learn that a part of our company’s payment to agents and consultants will or may be misappropriated by illegally using such in order to gain influence with public employees or persons who are in the equivalent position of public employees.
  • Avoid excessive gift-giving and business entertainment to client companies or executives and employees of client companies, and carry out any such activities under normal social convention.
  • Do not receive excessive business entertainment and gifts that are beyond the range of social convention. Moreover, obtain approval when you receive business entertainment according to company rules.

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8. Take resolute actions against antisocial forces and do not provide them with favorable treatment.

  • Do not try to solve issues using money without careful consideration when antisocial forces make unreasonable requests.
  • Be vigilant, since it is expected that antisocial forces will cunningly try to tap into usual trades.

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9. Regarding situations that do not comply with these rules, swiftly report to and consult on these cases with either your supervisors, the related departments within the company, the Corporate Ethical Committee, or a corporate lawyer who is in charge of corporate ethics, regardless of whether you discovered such actions or whether you committed them yourself through negligence.

  • Each executive and employee should provide any necessary cooperation, so that the company can confirm the facts and situations and can adequately respond to the situation, including taking preventive measures.
  • Supervisors, related departments within the company, and the Secretariat of the Corporate Ethical Committee (General Affairs Department), who are reported to and/or consulted with shall not disclose the information of informants, including their names, without their consent, and shall take necessary measures so that informants who reported or consulted on the issues do not suffer unreasonable treatment.
  • When informants are mistreated because of reporting cases of non-compliance, notify the Secretariat of the Corporate Ethical Committee immediately. The committee investigates and confirms the facts and handles such cases promptly.
  • You can use any method of reporting and consultation: Verbally, by telephone, letter, e-mail, or in-house mail.
  • Corporate lawyers who are in charge of corporate ethics do not disclose to the company the information of informants, including their names, without their consent.

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