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Behavior Guidelines for Management and Employees of MinebeaMitsumi

Ⅰ.Declaration

As a corporate citizen, MinebeaMitsumi formulated the Code of Conduct for MinebeaMitsumi in 2005 to maintain appropriate behavior. While requiring all management personnel (directors, supervisors, and senior executives, hereinafter the same) and employees to adhere to it, MinebeaMitsumi widely disclosed the purpose and measures committed to the Code of Conduct to shareholders, customers, employees, local communities, and business partners.

The Behavior Guidelines for Management and Employees of MinebeaMitsumi have been newly formulated as detailed rules in the Code of Conduct of MinebeaMitsumi. The purpose is to emphasize that it is the responsibility of all managers and employees to ensure the company’s compliance with laws and regulations. Besides taking corporate actions, each management personnel and employee should be more cautious and responsible for their own behaviors than ever before. We should be acutely aware that such an era has arrived. On this premise, all management personnel and employees of MinebeaMitsumi should share the values and ethics advocated in the Code of Conduct of MinebeaMitsumi so as to better practice these guidelines in specific actions.

I hereby declare that as the person with the highest responsibility for compliance, I will lead by example. In addition, all management personnel and employees of our company are required to follow my lead and strictly adhere to these Behavior Guidelines based on a full understanding of the above purpose.

August 12, 2020

 

MinebeaMitsumi Inc.

President and Executive Director

Yoshihisa Kainuma

Ⅱ.Behavior Guidelines

The Behavior Guidelines for Management and Employees of MinebeaMitsumi (hereinafter referred to as the “Behavior Guidelines”) are formulated as a standard of conduct that all management personnel and employees of MinebeaMitsumi should abide by. All management personnel and employees of MinebeaMitsumi (hereinafter referred to as “we”) shall carefully read, understand, and abide by these Behavior Guidelines.

1. Abiding by laws, regulations, company rules, etc., and completing ethical business activities

Complying with the laws, regulations, and rules of all countries and regions where our business activities are carried out and conducting ethical business activities is one of the important business policies of MinebeaMitsumi. On this basis, we should confirm, understand, and abide by all laws, regulations, rules, and company regulations related to our operations. At the same time, we shall refrain from engaging in any business that violates corporate ethics.

2. Maintaining the credit and reputation of MinebeaMitsumi

Endeavoring to protect MinebeaMitsumi's credit and reputation, we shall refrain from any act that is adverse to or harmful to the credit and reputation.

3. Respecting the cultures and customs of various countries and regions

Conducting business globally, we strive to carry out our business activities while respecting the culture, customs, and history of each country and region.

4. Respecting fundamental human rights

During our tenure at the company, we must respect the basic human rights of all relevant personnel and shall not discriminate against them due to gender, age, place of birth, nationality, race, ethnicity, belief, religion, disease, physical disabilities, etc.

5.  Prohibiting harassment

We shall not harass others in any way (including but not limited to sexual harassment, office harassment, etc.).

6. Achieving work-life balance

We should respect each other’s ways of working that align with our personal lifestyles, striving to achieve a balance between work and life.

7.  Maintaining a healthy and safe working environment

We should adhere to labor-related laws and regulations, strive to maintain a sound working environment, and comply with company rules related to job safety and health. We aim to prevent industrial injuries and occupational diseases. In the event of a disaster, we must report it quickly according to established procedures. By respecting each other’s opinions and fostering smooth communication, we can prevent mental health disorders.

8. Conducting environmentally sensitive enterprise activities

We should comply with environmental laws, regulations, and company policies. At all stages of our business activities, we strive to minimize environmental impact and risks, such as pollution and environmental load, caused by energy and resource consumption.

9.  Timely and appropriate disclosure of information

We should disclose enterprise information (business status, product information, etc.) to customers, shareholders, and investors in a timely and appropriate manner.

10. Protecting confidential and personal information

We must use the company’s confidential information, confidential information of other companies obtained from related parties, and personal information of customers and employees in accordance with laws, regulations, rules, and company policies. We  will not disclose any confidential or personal information.

11. Prohibiting improper reception and gifts

We shall not grant any reception or gift beyond a reasonable range, and it is prohibited to accept any similar reception or gift. Additionally, it is prohibited to provide members of parliament, civil servants, or foreign civil servants with improper benefits that violate laws, regulations, or sound business practices in order to obtain improper business interests.

12. Fair and free competition and trade

We abide by the laws and regulations (including but not limited to anti-monopoly law, subcontracting law, etc.) related to fair and free competition and transactions in all countries and regions, and carry out fair and just business activities.

13. Protecting intellectual property rights

We understand the importance of intellectual property in modern society and strive to protect the rights and interests of the company. At the same time, care should be taken not to infringe upon the rights and interests of others.

14. Preventing insider trading

We shall not engage in insider trading or the buying and selling of stocks, corporate bonds, and other negotiable securities suspected of insider trading.

15. Going through relevant formalities for import and export

We should abide by relevant laws and regulations (including but not limited to import and export management laws and regulations) and company rules when signing import and export contracts and technology licensing contracts for products, materials, mechanical equipment, etc., and go through proper formalities.

16. Dealing with anti-social forces

We should take a resolute attitude towards anti-social forces and groups that threaten the order and safety of civil society, and cut off all ties.

17. Protecting company assets

We shall cherish the company’s assets and funds in accordance with its rules and regulations, and shall not waste or divert them for personal use.

18. Prohibiting behaviors detrimental to the interests of the company

We shall not sacrifice the legitimate interests of the company for personal gain or that of a third party.

19. Providing socially useful products

While promoting technological innovation to reduce resource and energy input, we should devote ourselves to developing and manufacturing products with excellent durability, reusable products, and products that help maintain the earth’s environment and contribute to sustainable social and economic development. Additionally, we should sincerely listen to the “voice” of customers and consumers, and strive to ensure the safety and quality of products and services.

20. Committed to contributing to society

As a responsible corporate citizen, we should work towards building a better society. Each of us should think from our own perspective and strive to contribute to society.

21. Compliance with international rules and contribution to local communities

When we carry out relevant activities in other countries and regions outside Japan, we must naturally abide by international rules and local laws and regulations, and strive to understand the local social conditions and contribute to the development of the local society.

22. Internal reporting

When we are informed of violations of various rules and regulations of MinebeaMitsumi, including laws and regulations, behavior guidelines, etc., or violations of corporate ethics, or suspected acts, we must promptly report the situation to our internal reporting window for consultation.

Ⅲ. Penalties

Violations of the Behavior Guidelines may result in disciplinary action in accordance with the Code of Conduct for Employees at each subsidiary of MinebeaMitsumi.

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