​Article 1 (Sensible Business Activities)​

1. We will strive to act as a sensible corporate citizen not only by compliance with laws and regulations but also by respecting social norms.
2. We will observe domestic and overseas laws and regulations.
3. We will fully recognize corporate ethics expected of us, and conduct ourselves in thoughtful and responsible manners as members of society.

​ Article 2 (Contribution to Society)​ ​

As a responsible corporate citizen, we will actively participate in social contribution activities and contribute to the progress of society. We will fulfill all the responsibilities expected of a corporate citizen through continuous contribution and cooperation to local and international communities.

Article 3 (Compliance with Business Laws and Regulations) ​

We will comply with all laws and regulations relevant to our products and services, and take all necessary procedures for obtaining required licenses and permits, and for making notifications and registration, etc.

​ Article 4 (Regulations on Act of Endowment and Political Contribution)

1. All political contribution and endowment to various organizations shall be made in accordance with the authorized procedures by observing the relevant laws and regulations, including the Public Office Election Law and the Political Funds Control Law.
2. Prior to making any contribution and endowment, proper approvals shall be obtained in accordance with the relevant internal regulations.
3. We are determined to refrain from performing any acts that may be misconstrued as collusive relationships with political/administrative authorities, let alone bribery, provision of benefits, and illegal political contributions, and to construct sound and transparent relationships.

​ ​Article 5 (Elimination of Relationship with Antisocial Forces)​ ​

1. We will endeavor to take a sensible course of action through our efforts to acquire basic legal/regulatory knowledge, socially accepted manners, and strong sense of justice, not to be involved in any illegal or antisocial behaviors..
2. We will reject any relationship with antisocial forces, and strongly refuse any unlawful demands from antisocial forces, never solving the matters by paying them off.
3. We will not resort to any antisocial forces to protect the company's profits or our own profits.
4. We will not have any business relationship with any antisocial forces or any entity associated with such forces.

​ ​Article 6 (Environmental Preservation and Protection)​

1. For researching, developing, manufacturing, selling, and disposing of products, we will always recognize the importance of environmental protection, comply with all environmental treaties, laws and regulations, etc., and endeavor to offer environmentally friendly products. In addition, based on the concept of the extended producer responsibility, we will endeavor to reduce generation of wastes throughout the entire lifecycle of each product.
2. We will enhance awareness about environmental preservation among all the personnel, and actively implement environmental protection programs by, for example, saving paper resources through purchases of recycled products and promotion of the paperless office environment.

​ Article 7 (Security Trade Control)​ ​

1. We will not engage in any export of arms and weapons, including the related technologies, which may threaten international peace and security.
2. For all export, we will conduct thorough evaluations of our trade partners and their operations to confirm that our exporting freights/technologies will not be used for development or manufacture of weapons of mass destruction, or any other similar activities.
3. For export of freights/technologies and provision of services regulated by the relevant laws and regulations, we will make thorough studies about acceptability of each transaction while considering international situations, and take necessary steps in accordance with the relevant laws and regulations.

​ Article 8 (Compliance with Trade-related Laws and Regulations)

1. When importing and exporting goods, we will take appropriate customs clearance in accordance with the relevant laws and regulations.
2. As a general rule, we will not export or import any goods that are prohibited from exportation or importation.

Article 9 (Product Safety)​ ​

1. In manufacturing, developing, importing, storing, selling, transporting, exporting, repairing, and servicing products, we will always pay close attention to the safety, and fully understand and comply with laws concerning product safety and the relevant safety standards so that we can attain higher levels of safety.
2. When we obtain any information about product safety, we will immediately confirm the facts. If any problem is detected, we will notify the relevant departments of the facts, and take appropriate steps.

​ ​Article 10 (Compliance with the Antitrust Law)

1. Under any circumstances, we will promote fair and free competitions, without engaging in any act that may infringe on the Antitrust Law, such as cartels, bid-rigging, maintenance of resale price, abuse of superior bargaining position, etc.
2. We will not engage in any unfair restrictive business practice concerning discussions and arrangements about prices, amounts, or production facilities, as well as collusive bidding, etc., among entities in the same industry and industrial organizations.
3. We will not refuse to transact with particular entities (discount retailers, etc.) or newcomers, place certain restrictions on sales prices at retailers, or perform other unfair trade practices, in collusion with other entities in the same industry or industrial organizations.

​ ​Article 11 (Proper Transactions with Suppliers and Compliance with Subcontract Act)

1. ​ ​We will conduct business transactions with suppliers in integrity and good faith, and treat them fairly and equally.
2. ​ ​In selecting suppliers among multiple candidates, we will fairly compare and evaluate their quality levels, prices, delivery periods, technological development capabilities, abilities to sustain stable supplies, etc. to determine the best business partners.
3. ​ We will not exert any influence to provide any particular supplier with favorable treatments, whether or not we are in such an influential position as to affect selections or evaluations of suppliers.
4. ​When we contract out production, repair or creation of information deliverables to any business partner, we will fulfill contractual or other business obligations by fully complying with the Subcontract Act, to prevent any payment arrears, etc.

​Article 12 (Prevention of Unfair Competition)​ ​

1. Under any circumstances, we will not acquire or utilize any business secrets of other companies through thefts and other illicit means.
2. We will not acquire or utilize any business secrets of other companies with the knowledge that they have been or might have been acquired through illicit means.

​ Article 13 (Gift and Entertainment) ​

1. We will not provide any public servants or anyone in similar status with any gift or entertainment.
2. We will provide our business partners with gifts or entertainment only within the scope of common sense.
3. We may receive gifts or entertainment from our business partners only within the scope of common sense.

​ ​Article 14 (Prohibition of Bribes to Overseas Public Servants)

We will not provide, or promise or offer to provide, overseas national or local government officials with money or other favors to obtain unfair business profits or in return for business-related favors.

​Article 15 (Proper Advertisement and Public Relations)

We will not use any slanderous or defamatory expressions against competitors and any terms to lead to social discrimination in our documents or information provided for advertisement or public relations purposes. We will confirm that all advertisement/PR materials and data are based on facts, complete, accurate, and beyond misapprehension at the time of public releases.

​ ​Article 16 (Disclosure of Management Information)

We will disclose accurate management information, including our financial status and operation conditions, etc. to our stockholders and investors. We will also clearly convey our management philosophy and policies, and take opinions and criticisms on them seriously.

​Article 17 (Prohibition of Insider Trading)

If we become aware of any inside information of the Company, its related parties or our business partners, we will not trade stocks and bonds, etc. of these companies, until such information is publicly disclosed. When we intend to purchase or sell stocks of the Company, companies related to us in terms of business operations, we will first check whether we possess such inside information. We will not be involved in these so-called insider trading practices that are strictly prohibited, even if they are intervened by certain agents or if they do not entail any personal profits.

​ Article 18 (Respect for Human Rights and Prohibition of Discrimination)

1. We will endeavor to maintain sound work environment, respect human rights of each individual, and never tolerate any acts regarded as discriminatory.
2. We will not tolerate any unreasonable discriminatory acts, based on births, nationalities, races, ethnic origins, creeds, religions, sexes, ages, various disabilities, personal preferences, and educational backgrounds, etc.
3. We will not tolerate encroachments on human rights, including violence, profanity, defamatory and slanderous expressions, coerced business operations by intimidation, bullying, etc.

​ Article 19 (Sexual Harassment)

1. We will not tolerate any sexual harassment or any acts that may be mistaken as sexual harassment.
2. We will not tolerate any sexually suggestive acts and remarks giving discomforts to others, and take thorough measures to prevent anyone from getting involved in these acts or remarks.

​ Article 20 (Power Harassment) ​

Power harassment means any behavior that someone in a position of authority inflicts mental or physical pain on his or her subordinates, or harms their working environment by abusing power or authority in the workplace beyond the proper range of the job description. We will not tolerate the following behavior based on this definition:

1. ​ ​To use abusive language, and resort to violence of hitting, kicking, etc. to subordinates
2. ​ ​To force them to do any acts of legal violation
3. ​ ​To insistently blame them for job mistakes
4. ​ ​To criticize them in front of other colleagues
5. ​ ​To yell at them or bang on a desk
6. ​ ​To provide no work at all or neglect them
7. ​ ​To assign unnecessary work
8. ​ ​To spread rumors which they are afraid of
9. ​ ​To bully them
10. ​ ​To excessively demand their retirement
11. ​ ​To force them to do his or her private things
12. ​ ​Other behavior based on the above

​ ​Article21 (Protection of Privacy)

We will utilize personal information obtained in the course of business operations about our officers, employees or any external persons only for business purposes, and apply strict and thorough controls to such information, not to be externally divulged.

​ Article 22 (Workplace Safety and Health)​ ​

With workplace safety and health treated as top priority, we will endeavor to construct safe and healthy work environment, and to understand and comply with laws and regulations related to workplace safety and health. In case of fire at a workplace, we will implement the specified procedures, including immediate reports, to minimize the effects and to prevent any recurrence.

​Article 23 (Compliance with Labor-related Laws and Regulations)

1. We will fully comply with labor-related laws and regulations to maintain sound work environment in which employees can work comfortably.
2. We will thoroughly manage workdays and work hours to observe provisions of the Labor Standards Act.
3. We will never coerce employees to work excessively or overtime, etc.
4. The managerial personnel will pay close attention to both physical and mental health of their subordinates.

Article 24 (Compliance with Employment Regulations)

1. Officers and employees will always comply with the Employment Regulations
2. We will not perform any acts prohibited in the Employment Regulations.
3. We will not perform any illicit or dishonest acts which may be contrary to the principles of the Employment Regulations.

​ ​Article 25 (Proper Accounting)​

All entries to accounting books or bills will be made accurately in accordance with the relevant laws and regulations, as well as the internal rules. We will not tolerate any false or fictitious entries or build up off-the-book assets.

​Article 26 (Prohibition of Conflict of Interests)

1. We will not be engaged in any activities that may conflict with interests of the Company.
2. We will not work for, or have any monetary relationships with, our competitors or business partners as their officers, employees or consultants.
3. We will not be engaged in any business operations as business partners of the Company.

​Article 27 (Prohibition of Political and Religious Activities)

1. We will not be engaged in any political or religious activities during work hours.
2. We will not solicit participation in political groups or particular voting actions, or perform any other election campaigns during work hours.
3. We will not solicit participation in religious groups, or impose any creeds, solicit for contributions, or distribute solicitation brochures, etc. during work hours.

​ ​Article 28 (Management of Company Secret)

1. We will properly manage company secrets, and not disclose or divulge such secrets outside of the Company without proper authorization of the Company.
2. We will strictly manage business secrets of the Company or other companies, refrain from divulging them out of the Company, or from utilizing them for non-business purposes.
3. ​ ​If any company secrets need to be disclosed outside of the Company, unintended leaks shall be prevented through conclusion of confidentiality agreements, etc.
4. We will not steal any business secrets from other companies, or utilize such secrets for purposes other than permitted by the disclosing parties.
5. Even after leaving the Company, we will not divulge company secrets of the Company or other confidential information obtained from outside, or utilize them for any purposes.

​Article 29 (Proper Handling of Corporate Assets)

We will utilize all Company assets efficiently, and recognize the importance of their constant availability. We will handle both tangible and intangible assets properly to prevent any damage or theft. We will not utilize any Company assets, including financial ones, for any personal purposes.

​ Article 30 (Proper Handling of Information Systems)

1. We will utilize the corporate information system only for business purposes, not using the system for personal purposes.
2. We will handle IDs or passwords for the corporate information system carefully to prevent any inadvertent leaks.
3. We will not utilize IDs or passwords of others without their knowledge or hack others' computer systems.

​ ​Article 31 (Protection of Intellectual Property Rights)

1. Based on the recognition that the intellectual property rights of the Company are important corporate assets, we will endeavor to utilize them properly and to protect the rights.
2. We will take proper protective measures for our intellectual property rights, for example, by filing patent applications without delay, for inventions in our manufacturing and development activities.
3. We will not perform any acts infringing on intellectual property rights of other companies, such as unauthorized copying of computer software of these companies.
4. We will use intellectual property rights of our business partners only after conclusion of proper agreements, and never be engaged in any unauthorized use of these rights.

​ ​Article 32 (Scope of this Manual)

1. This Manual shall apply to all officers and employees of the Company, and also apply mutatis mutandis to those contracted as temporary workers or part-timers.
2. Kawata Group companies should change some of the content of this standard according to the laws and regulations of the country and region, business practices, labor practices, values, etc., the business style of the company, the type of transactions, the content of products and services, etc. You can, but you can not define contrary to this standard.

​ ​Article 33 (Revision and Abolishment of this Manual)​

This Manual may be revised or abolished only through approvals of the Board of Directors.

​ Article 34 (Consultation or Reporting)​

1. Any question concerning the contents or interpretations of this Manual shall be directed to the General Affairs and Human Resources Department.
2. Any violation, or an act that may lead to a violation, of the provisions of this Manual, whether it is detected or committed, shall be immediately and appropriately reported to the supervisor, the General Affairs and Human Resources Department and the Audit and Supervisory committee of Kawata Japan.
3. The reporter shall not be inconvenienced, whatsoever, by his/her act of reporting.

​Article 35 (Penalties)

A person who has committed any act violating any provision of this Manual or has left any violation as it is shall be penalized in accordance with the Employment Regulations or other internal rules.