Compliance Guiding Principles

I. Business Activities

Observing Antimonopoly Laws

Employees shall not engage in private monopolization, unreasonable restraint of trade or unfair trade practices.

Compliance with Applicable Laws

Employees shall become familiar with the applicable laws relevant to their individual business responsibilities in order to have an appropriate understanding of such laws, and shall refrain from engaging in any conduct that violates such laws.

Information Management

The company's confidential information, including without limitation customer information, know-how, is a valuable corporate asset of the company.

Employees shall treat the company's confidential information with great care and keep it in strict confidence. Confidential information received by the company's from a third party shall be treated with the same degree of care.

Preservation of the Environment

Employees shall give the consideration to preservation of the global environment.

Respecting and Protecting intellectual Property Rights

Employees shall not engage in actions that may infringe the intellectual property rights of others and shall protect the intellectual property rights of the Company, which are among its valuable corporates aseets.

Oversea's Business Activities

When conducting business overseas, employees shall familiarize themselves with the local laws and regulations governing their activities and act in compliance with these laws and regulations.

II. Corporate Citizen as a Member of Society

Confrontation with Antisocial Forces

Employees shall not yield to any antisocial forces.

Prohibition on Giving Bribes

Employees shall not engage in any conduct which would constitute, or has the appearance of, the offering of any bribes.

Employees are also prohibited from giving or offering entertainment to governent officials.

III. Maintenance of a Good Working Environment

Respect for Human Rights

Employees shall respect human rights and shall not engage in any unfair discrimination.

Prohibition of Sexual Harassment

Prohibition on Abuse of Authority

Shimoda Iron Works Co.,Ltd. All Rights Reserved.