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Code of Compliance and Ethics of Shinsho Corporation and its group companies

1. Basic Policy

● We are committed to sustaining a high standard of corporate ethics and conduct business practices that is trusted by society.
● We are committed to complying with the laws, regulations and company rules, and conduct fair and equitable business.

2. Code of Conduct

1)Fair Trading

Observe social rules, laws and regulations, and promote fair and free competition.

2)Compliance with International Laws and Regulations

Observe international laws and regulations, and respect the culture and customs of each nation and regions.

3)International Cooperation

Devote ourselves to international cooperation, and act with a global perspective.

4)Security Trade Control

Ensure strict compliance of security trade control, and contribute for the maintenance of international peace and security.

5)Disclosure of Corporate Information

Disclose corporate information in a timely and appropriate manner, and maintain transparency of management.

6)Ensure the Reliability of Financial Reporting

Maintain the fitness of financial statements and the reliable financial reporting to ensure the accuracy.

7)Protect Confidential Information

Strictly protect confidential information such as customer information, and honor confidentiality of information from being divulged to others without justifiable grounds.

8)Prevention of Insider Trading

Do not engage in any unfair stock trading or other similar act that may be perceived as insider trading.

9)Promotion of Environmental Preservation

Take an active approach to global environmental issues, and remain committed to the task of caring for the natural environment.

10)Respect for Intellectual Property Rights

Protect and respect intellectual proper ty rights.

11)Interaction with Local Communities

Conduct social contribution activities in the local communities as a good corporate citizen.

12)Respect for Human Rights

Respect the human rights of others, and do not engage in all forms of unfair discriminatory treatment.

13)Prevention of Political Corruption

Avoid any potential acts of briber y, and sustain decent relationships with government officials.

14)Confrontation with Antisocial Forces

Stand firmly against antisocial forces and organizations.

3. Date of Establishment

Date of Establishment August 1, 2003
Date of Revision April 1, 2008

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