The Maxell Group Codes of Conduct have been established as specific codes of conduct that apply to all companies of the Maxell Group. Under the leadership of top management, we will thoroughly implement the Codes of Conduct to ensure that all our business activities are conducted on the basis of corporate ethics and compliance, in accordance with "Basics and Ethics."

Chapter5 Management Foundations

5.1 Management and Use of Information

  1. 1.We will conduct appropriate management of all processes related to the life cycle of confidential information including information production, acquisition, confidentiality management, sharing and disclosure, storage and preservation, use, and disposal, and observe the protection of confidential Information, and appropriate use of information equipment to prevent incidents from information leaks and improper information use.
  2. 2.We will protect information assets in accordance with the Information Security Policy.
  3. 3.We will manage confidential information appropriately in accordance with internal company regulations.
  4. 4.We will fully respect the rights and value of confidential information that belong to the company or other parties. We will observe these Codes of Conduct and related regulations, and appropriately manage and handle the company's confidential information and confidential information disclosed to us by other parties, to prevent any information leaks that might cause damages to the company or other parties or constitute breach of contract or legal violations.
  5. 5.We will follow the specified procedures and arrange appropriate measures for the maintenance of confidentiality such as nondisclosure agreements when disclosing the company's confidential information to other parties.
  6. 6.We will acquire confidential information that belongs to other parties only when necessary for the conduct of the company's business, using fair and appropriate methods (contracts, etc.) in light of fair business practices. We absolutely will not acquire such confidential information through improper means. When we have acquired other parties' trade secrets, we will strictly manage them as stipulated by the relevant contracts and implement the necessary measures after the relevant contracts have expired.
  7. 7.We recognize the importance of protecting personal information, and we will handle personal information appropriately in accordance with the company's Personal Information Protection Policy.
  8. 8.We will organize and store documents, electronic files, records and other types of information. We will appropriately store documents and electronic files whose processing is complete, and destroy them by suitable means when their storage periods have expired.

5.2 Use of Inside Information and Related Considerations

  1. 1.We will always take care to prevent leaks of company information. We will not disclose to third parties material confidential information regarding the company, our related companies or business partners (subsidiaries, affiliated companies, investee companies, contract partners, or companies with which we are negotiating contracts), or customers.
  2. 2.When we learn undisclosed information regarding the company, our related companies or business partners, and customers that might affect the judgment of investors (insider information), we will not trade shares of the company, our related companies or business partners, or customers until the insider information is disclosed. We will exercise discretion in stock and other transactions in cases when it is not clear if the information constitutes insider information.

5.3 Management and Preservation of Company Assets

  1. 1.We will actively create intellectual properties, protect them appropriately, and strive for their effective use. We recognize that the intellectual property rights to intellectual works created in relation with work duties at the company will all revert to the company as provided by the relevant laws, and we will follow the provisions of the related internal company regulations and the directions of the company for the appropriate protection of the company's rights, and for their use.
  2. 2.We will respect the intellectual property of other parties. We will prevent violations of other parties' intellectual property rights in advance and, for the smooth progress of business, we will investigate other parties' intellectual property rights beforehand when engaged in research, development, design, production and sales of new products or new technologies, and implement appropriate measures when any doubts arise.
  3. 3.We will not infringe other parties' copyrights regarding use of software and the Internet. For example, we will not install, use or duplicate software in violation of the terms of license agreements. We will manage software so that it is used correctly as a company asset.
  4. 4.We will use the company's tangible assets (land, buildings, facilities, equipment, products, office equipment, cash and deposits, negotiable securities, etc.) efficiently for business activities. We will observe company rules to prevent improper use, loss and theft.
  5. 5.We will not engage in any acts that damage the value of tangible or intangible company assets, including financial assets, through improper use, personal use, etc.
  6. 6.We will act to ensure that all business judgments and business activities are the best choices for the company, and we will not form any financial or other trading relations with suppliers, customers, or competitors that would conflict with the best interests of the company.
  7. 7.We will implement fair accounting practices and proper information recording and reporting. We will also accurately and clearly record and report research findings, inspection data, business performance and other documents on a factual basis.

5.4 Arranging a Work Environment That Draws Out Employee Strengths

  1. 1.We will comply with the relevant labor laws and regulations governing employment, personnel affairs, working conditions, wages and other employment terms, etc.
  2. 2.We will respect the human rights of individual employees, and manage personnel records strictly with close attention to protecting personal information and privacy rights. We will absolutely refrain from any sort of sexual harassment or power harassment that violates human rights.
  3. 3.We will strive to secure workplace safety based on the approach of giving priority to the protection of safety and health above all else.
  4. 4.We will act to promote physical and mental health. We will give consideration not only to our own health, but also to the health of those around us.
  5. 5.We will work to create workplaces where every individual employee can work with the sense that his or her work is worthwhile. We will support a work-life balance by realizing diverse working styles and using various types of vacation systems. We will also strive to create a workplace environment where employees can take leaves for pregnancy, childbirth, child-raising, and family nursing care as necessary.
  6. 6.We will always strive to pursue self-improvement and make our best efforts so that we can manifest our greatest potential. Superiors will give their subordinates appropriate management, guidance, and training to extend their capabilities.

5.5 Observance of Laws and Regulations Governing Imports and Exports

  1. 1.We will observe all related laws and regulations when conducting exports not only of products but also of all kinds of cargo and technologies.
  2. 2.We will conduct effective export control in accordance with internal company regulations by being certain to confirm the end-use and end-users, even for domestic sales.
  3. 3.We will observe all related laws and regulations when conducting imports.