The Nihon Parkerizing Group Principles of Ethics and Conduct

We, the directors and employees of Nihon Parkerizing Group (Nihon Parkerizing Co., Ltd. and its consolidated subsidiary companies and equity-method affiliates) will comply with the following Principles of Ethics and Conduct as the basis of our daily work to build a corporate culture in which we act with integrity and fairness.

1. Customer Focus
   
   1. 1) Quality First
      We will always adhere to Nihon Parkerizing's quality policy, and strive to improve customer satisfaction when providing our products and services to our customers.
   2. 2) Duty of Confidentiality
      Protection of customers’ confidentiality is our most basic rule.
   3. 3) Principles of Accountability and Suitability
      When offering a product or service to customers, we will always give an overview and explain the risks in an understandable manner. In addition, in case our products and services are deemed not suitable for customers, we will refrain from even offering them.
   4. 4) Provision of Information to Customers
      We will endeavour not to mislead our customers when providing them with information. In addition, we will not make false reports, conceal information or anything of that nature.
   5. 5) Sincere Manner
      We will act sincerely when communicating with our customers. In addition, we will deal with complaints and make customer reports honestly based upon the facts. Furthermore, we will not commit misconduct or any conduct of that nature, including fabrication and falsification of data concerning safety, performance, and tests and other matters.
   6. 6) Elimination of Collusion
      We will not accept any request from a customer that would create uncertainty as to the status of the customer and the company, regardless of what is asked.
   7. 7) Elimination of Favoritism
      In case we want to make a contract with close associates, friends, or any customers with a personal stake, we will report it to our manager and follow the manager’s appropriate instructions.
   8. 8) Accurate Records
      We will accurately record quality information in accordance with laws and regulations, customer requirements, and anything of that nature, and retain it for the required period of time in a traceable manner.
2. Vendor Focus
   1. 1) Fair Competition in Vendor Selection
      We will evaluate and select vendors based on their quality, service, price, track records, and reliability in a comprehensive manner.
   2. 2) Prohibition of Asking for Kickbacks, etc..
      We will not ask our vendors for money, goods, entertainment, or anything of that nature. We will refrain from any action that might be considered unnatural or misleading by a third party, even if such action seems acceptable.
   3. 3) Prohibition of Excessive Gifts and Entertainment
      We will refrain from receiving excessive gifts and entertainment beyond the bounds of common sense.
   4. 4) Prohibition of Bribery to Public officials
      We will not offer, promise, or provide bribes or any other unfair benefit to public officials including quasi-public officials and foreign public officials. We will refrain from actions which may cause misunderstanding by others.
3. Investor Focus
   1. 1) Disclosure of Information
      We will correctly disclose in an understandable manner important information which may influence investment decisions.
   2. 2) Accurate Records
      We will accurately record information in accordance with laws and regulations, and retain it for the required period of time.
   3. 3) Importance of Internal Audit
      We will develop an appropriate internal audit system to protect the interests of our investors.
4. Society Focus
   1. 1) Observation of Related Laws and Regulations
      We will make efforts to understand correctly and comply with laws and regulations which apply to our businesses. We will follow necessary procedures to obtain relevant permissions and authorizations, and to submit notifications.
   2. 2) Observation of Antimonopoly Act
      We will not negotiate and conclude any agreements with our industry peers. We will refrain from any words and actions which may be seen as antimonopoly acts by others.
   3. 3) Observation of Insider Trading Regulations
      We will not engage in insider trading. If we obtain important non-public information of others, we will not trade their stocks. We also will not trade stocks of Nihon Parkerizing Group and its competitors if we obtain material facts of our company. We must be cautious in stock trading in cases where we do not know for sure whether our actions can be seen as insider trading or not.
   4. 4) Observation of Tax Laws
      We will faithfully follow necessary paperwork which is required for tax payment and refrain from any actions which may be referred to as tax evasion.
   5. 5) Respect for Intellectual Property Right
      We will respect the intellectual property rights of others, and refrain from illegal duplication of computer software and published material in particular.
   6. 6) Ban on Any Relationships with Antisocial Groups
      We must not have any relationships with antisocial groups such as organized crime groups, and must act resolutely against them. (Never be afraid. Do not pay money. Do not utilize them.)
   7. 7) Disaster Prevention and Response
      We will prepare appropriate disaster prevention procedures, and in the event of a disaster, we will follow the predetermined rules, such as disaster response manuals to ensure the safety of people in a timely, appropriate manner and to try to resume our business.
5. Ethical Workplace
   1. 1) Prohibition of Discrimination
      Regarding hiring and working conditions, we will fairly evaluate our people based on their performance and achievements. In addition, we will not engage in or tolerate discrimination based on gender, nationality, religion, principles, and mental or physical disability.
   2. 2)Prohibition of Sexual Harassment
      We will not make any sexual comments, engage in actions or anything of a sexual nature against another person's wishes. In addition, we will not adversely affect another person's working conditions as a result of their reaction to any such comments or actions. We will not take any action that may adversely affect the working environment, such as repeating jokes that may be offensive to another person.
   3. 3) Prohibition of Power Harassment
      We will not, beyond the reasonable scope of our work, engage in any conduct that may cause mental or physical harm to our colleagues, or adversely affect the working environment, by abusing our own superior position or personal relationships in the workplace.
   4. 4) Prohibition of Any Other Forms of Harassment
      We will not engage in any conduct that adversely affects the working environment, including but not limited to sexual or power harassment.
   5. 5) Protection of Privacy
      We will keep all personal information about directors and employees held by the company strictly confidential, and will not use such information for any purpose other than that originally intended. We will not disclose such information to any third party without the consent of the individual.
6. Responsibility as a Member of the Organization
   1. 1) Observation of Internal Rules
      We will strictly observe all articles of internal rules and office regulations, and carry out our duties in a faithful manner considering whether our actions give merit to the company.
   2. 2) Ethical Conduct
      We will strive to ensure that our own conduct is ethical based on social norms, the Principles of Conduct, and other codes of conduct. We will also take immediate action in the face of any situation that may cause us to have an ethical dilemma.
   3. 3) Safe and Healthy Workplace
      We understand and comply with laws and regulations regarding industrial safety and health, and will strive to prepare a safe and healthy working environment.
   4. 4) Prohibition of Acts Involving Conflicts of Interest
      We will refrain from any actions which may involve conflicts between self-interest and company interest. We will not pursue self-interest using any opportunities arising through our duties.
   5. 5) Proper Use of Company Assets
      We will strictly separate private and public matters, respect company assets, and refrain from personal use of office supplies and company’s devices such as personal computers and mobile phones. We will also refrain from using company email systems for non-work-related messages.
   6. 6) Proper Expense Processing
      We will accurately report our travel expenses, commuting expenses, working hours, vacations and the like.
   7. 7) Handling of Non-public Information
      We will comply with laws and regulations, guidelines and internal rules on information security, and maintain confidentiality of non-public information which we obtain through our duties. We will handle such non-public information with great care to avoid careless information leakage.
   8. 8) Public Relations
      We will disclose company information through our public relations department/division. In case news media or analysts ask for interviews with us, we will consult our managers and PR department/division and follow their instructions.
   9. 9) Consultation or Reporting about Illegal or Unethical Conduct
      We will promptly consult with or report to our own manager or the compliance counter about any conduct that violates the Principles of Conduct, whether we observe it being committed by another member or we have inadvertently committed it ourselves.
      In addition, we will not engage in any act of retaliation or unfair treatment of a whistleblower who has acted in good faith.

1. Compliance with laws and regulations
   In addition to observing the laws, regulations, and rules of the countries and regions where we conduct business activities, we will also comply with standards released by an international organization (Organization for Economic Co-operation and Development, or OECD) and strive to pay taxes appropriately by respecting the spirit of the standards.
2. Tax-related corporate governance
   We provide internal and external training to improve employees’ tax-related knowledge. At the same time, we execute businesses appropriately under the taxation system and internal regulations, thus enhancing the quality of accounting and tax processing.
3. Tax risks
   We will manage tax risks appropriately, use external specialists, seek advance rulings from tax authorities, and take other measures necessary to minimize tax risks.
4. Relationship with tax authorities
   We will strive to build, maintain, and develop sincere, sound, and cooperative relationships with the tax authorities of the respective countries and regions where we operate businesses. We will also appropriately disclose information requested under applicable laws and regulations, ensuring transparency.