Ethics charter

The Group will give satisfaction to and gain reliability from its customers by developing and providing high-quality products and services with good and creative design, which are useful for comfortable and abundant living, with due consideration for the safety and protection of personal and customer information, as well as making efforts to improve Sangetsu Group’s brand value.

The Group will disclose company information in an appropriate and fair manner, communicating with customers, business partners, stockholders and investors, people in the community, and employees. The Group will conduct active social contribution activities as a “good corporate citizen.” The Group will comply with laws, regulations and rules, compete in a fair, transparent and free manner, conduct fair transactions, and have a sound and normal relationship with politics and government, and will not have any relationship with antisocial forces and organizations which might pose a threat to the order and safety of civil society.

The Group will secure the accurate operation of the personnel system where every employee can maximize his / her abilities as a key person for the management of the company and a safe, sound, comfortable, and pleasant working environment, respecting employees’ diversity, personality, and individual characters.

The Group will act in a voluntary and active manner, acknowledging that efforts towards global environment issues are essential for companies and their activities.

The top management of Sangetsu Group acknowledges that it is responsible for the realization of the spirit of this Charter and will take the lead in realizing the same and keep everyone informed thereabout. Such top management will enforce thorough corporate ethics as well as develop an effective system in the Company, listening to opinions within and outside the Company.
In the case of any event in violation of this Charter, the top management of Sangetsu Group will seek to identify the cause thereof and prevent a recurrence, demonstrating to those within and outside the Company that such top management is engaged in resolving the same. Such top management will disclose information to society in a rapid and appropriate manner and fulfill accountability thereabout and take strictly fair actions (including those for such top management), making the authority and responsibility clear.

Article 4 Environmental Conservation

Article 5 Social Contribution and Endowment Act

1. We seek to proactively conduct social contribution activities as not only a business person but also a member of society or member in the community, as well as to contribute to the realization of abundant housing through business as a social contribution.
2. When conducting an endowment act, we comply with relevant laws and regulations, with due consideration for the necessity and validity thereof.

Article 6 Transparent and Fair Relationship with Politics and Government

1. We comply with relevant laws and regulations, including but not limited to political laws and competition law, with respect to political funds / donations, election and political activities.
2. We will not, with respect to members of the Diet, the head and members of local government, executives and regular officials of public offices or local government (including deemed public servants who are executives and regular employees of a legal entity or body), etc., give any entertainment which might be deemed as the illegal provision of benefits or facilities, give any gift or conduct any act without reasonable grounds for the purpose of gaining unfair business advantages, or conduct any act of bribery.
3. We will not, with respect to foreign public officials, etc. including but not limited to executives and regular officials of a foreign or local government, conduct any act which might be deemed as the illegal provision of benefits for the purpose of gaining unfair business benefits, or conduct any act of bribery.

Article 7 Prohibition Against Antisocial Forces

1. We take a firm attitude against antisocial forces and organizations that might pose a threat to the order and safety of civil society, and will not have any relationship therewith.
2. We will not conduct any act which might promote activities by antisocial forces and organizations.

Article 8 Customer Satisfaction; Ensuring of Safety of Products and Services

Article 9 Free Competition and Fair Transactions

1. We conduct fair transactions with all business partners, complying with relevant laws and regulations, including but not limited to competition law, based on free competition principles.
2. We will not conduct any unfair restrictive trade practices with competitors, including but not limited to cartels and bid-rigging. We will not attend any meeting or exchange information that leads or is suspected to lead to the limitation of fair and free competition, and will secure thorough fair and transparent behavior at all times.
3. We conduct transactions with customers, business partners and competitors, etc. faithfully based on social ethics, ensuring that the relationship with them is transparent and fair at all times.
4. We act according to sound commercial practices and social common sense with respect to entertaining business partners, etc. and the giving and receiving of gifts.

Article 10 Transactions with Suppliers and Collaborating Companies

1. We conduct transactions with suppliers and collaborating companies faithfully in accordance with relevant laws, regulations and contracts, taking an equal and fair attitude toward them.
2. We will not conduct any transaction with suppliers and collaborating companies that might cause unreasonable disadvantage to them by using our advantageous position.
3. We will not, in connection with procurement operations, etc., pursue benefits on an individual basis, including but not limited to the receipt of benefits and facilities.

Article 11 Transactions with Vendors

1. We conduct transactions with vendors faithfully in accordance with relevant laws, regulations and contracts, taking an equal and fair attitude toward them.
2. We will not conduct any dishonest or unfair act toward vendors, including but not limited to foreclosing behavior, discriminatory treatment, and business activities by constraint.

Article 12 Compliance with Laws and Regulations, etc. in Overseas Business Activities

1. We conduct business activities in the market abroad respecting the culture, customs and history of the relevant country or community, and comply with national, local, and international laws, regulations and rules.
2. We conduct export and import transactions with respect to products, technologies, and labor services, etc. appropriately in accordance with procedures provided for in our Company’s Regulations, etc., complying with relevant laws and regulations whether domestically or abroad.

Article 13 Proper Representation in Promoting and Advertising

Article 14 Understanding of Consumer Protection System

Article 15 Accurate Accounting Records and Reports

Article 16 Reception and Transmission of Company Information

1. We seek to ensure that Sangetsu Group’s business activities are understood, disclosing its company information including but not limited to business details and the state of business activities to stockholders and investors, in accordance with the relevant laws and regulations.
2. We secure the accuracy of transmitted company information at all times, and transmit information in a timely, appropriate, and fair manner, with consideration for the necessity of confidentiality.
3. We handle received company information, etc. in an appropriate manner, after careful examination.

Article 17 No Insider Trading

Article 18 No Illegal Provision of Benefits

Article 19 Attitude toward Performance of Business Operations

1. We perform business operations in a faithful manner, expressing our gratitude with the spirit of dedication, to embody our Company’s corporate philosophy
2. We seek to improve ourselves at all times, aiming to be a group of employees with expertise, creativity and a challenging will who can think and act by ourselves. We as individuals and Company perform business operations together, with common interests and aspirations.
3. We will not conduct any transaction which might result in a conflict of interests for our Company or any act which might commingle business and private affairs.

Article 20 Respect for Human Rights; No Discriminatory Treatment

1. We respect and defend international standards for human rights (the Universal Declaration of Human Rights, etc.) and international standards for labor (ILO Core Labor Standards, etc.).
2. We will not unjustly discriminate by reason of sex, age, nationality, race, ethnic group, creed, religion, social status, physical disability, gender identity, sexual orientation, etc., with respect to labor conditions or words and actions exchanged, respecting individual human right.
3. We will respect and defend fundamental labor rights, and will not infringe the same.
4. We will not allow forced or child labor.
5. We seek to prevent industrial accidents, complying with occupational health and safety laws, regulations and rules, and seek to establish a working environment and system where health and safety are ensured.
6. We handle personal information with extreme caution and seek to manage it in an appropriate manner, respecting individual privacy.
7. We seek to act in a moderate way as a good member of society and good family member with common sense and abundant humanity.

Article 21 Elimination of Power Harassment and Sexual Harassment, etc.

1. We seek to create a workplace with a comfortable and friendly atmosphere, where we will not commit or cause anyone to commit sexual or power harassment, etc., upon the understanding and cooperation of all members.
2. We will not pretend not to see harassment, including but not limited to the utilization of the Harassment Helpline, etc.

Article 22 Establishment of Working Environment; Boss’s Responsibilities

1. We seek to maintain and improve working conditions, operating a personnel system where self-fulfillment is realized.
2. We seek to secure a safe, healthy, comfortable and easy-to-work working environment and to improve a promotion system aimed at building both physical and mental health.
3. We acknowledge that it is the most important responsibility to cultivate human resources and the boss in the office organization seeks to cultivate his / her subordinates through daily work.
4. We seek to make assessments in a fair and evenhanded manner, as well as motivate an individual employee, give him / her a place to use his / her skills and allow him / her to maximize his / her abilities.
5. We seek to fulfill our job responsibilities in anticipation of the improvement of subordinates’ qualifications and sense of humanity, bearing in mind that we must set an example to others first and improve ourselves.

Article 23 Management and Proper Use of Corporate Property and Information

Article 24 Handling of Confidential Information

1. We will manage our Company’s confidential information in a strict manner and will not, during our tenure of office or after our retirement, disclose or divulge the same without going through procedures provided for in our Company’s Regulations, etc. We manage information-processing equipment with due care, and in the case of a loss thereof, we immediately take appropriate action.
2. We will not, during our tenure of office or after our retirement, use our Company’s confidential information in an unauthorized or unjust manner.
3. We will not use information about customers, suppliers, vendors, or other business partners obtained in the course of business operations for other than legitimate purposes and will manage the same in a strict manner so that it is not disclosed or divulged, in accordance with our Company’s Regulations, etc.
4. When using information-processing equipment and other information systems, we give thorough protection against infringing behaviors from the outside, and prevent the careless divulging of information, observing rules including but not limited to codes of security, in a strict manner. We will not access or obtain information in the possession of customers, suppliers, vendors, or other business partners and competitors, etc., by unauthorized means.

Article 25 Handling of Personal Information

Article 26 Protection and Utilization of Intellectual Property Rights

1. We seek to protect, maintain and actively utilize results derived from intellectual activities including but not limited to research and development, using intellectual property rights (including but not limited to patent rights, utility model rights, design rights, trademark rights, and copyright). We treat these rights in accordance with our Company’s Regulations, etc.
2. We will respect a third party’s legitimate intellectual property rights and will not intentionally infringe or use in an unauthorized manner the same.

Article 27 Proper Use of Social Media, etc.