Code of Conduct for Tokyo Components and Its Group Companies

This Code of Conduct applies to all officers and employees of Tokyo Components and its group companies, including seconded employees, contract workers, part-time workers, staff of overseas subsidiaries, and dispatched personnel.

１．　Compliance with Laws and Respect for Human Rights

1. We recognize our responsibility as members of a global company and comply with all laws and regulations both in Japan and abroad.
   We maintain high ethical standards and social responsibility, acting with integrity and professionalism.
2. We respect the cultures, customs, and histories of all nations and uphold human rights.
3. We do not tolerate discrimination based on race, color, age, sex, sexual orientation, gender identity or expression, ethnicity or nationality, disability, pregnancy, religion, political affiliation, union membership, military status, protected genetic information, or marital history.

２．　Workplace Environment and Prevention of Harassment

1. We foster a positive and open workplace where individual dignity, personality, and ability are respected.
2. We prohibit any acts that may constitute or be perceived as sexual harassment, physical or verbal abuse, corporal punishment, or inhumane treatment.
3. We uphold public morals and refrain from behaviors that disrupt workplace order or ethics.

３．　Strict Compliance with Antitrust Laws

1. We do not engage in agreements with competitors regarding prices, quantities, regions, or customers.
2. We do not engage in bid-rigging, such as colluding to decide the successful bidder or the winning bid price.
3. We do not participate in unfair trade practices such as boycotts, resale price maintenance, tying sales, and other improper transactions.
4. We prohibit abusive practices with subcontractors such as unjust price reduction, refusal of acceptance, unreasonable returns, or delayed payments.
5. We always promote fair, transparent, and free competition, and conduct proper business transactions.

４．　Avoidance of Conflicts of Interest

1. We do not engage in activities that conflict, or may appear to conflict, with the interests of the company, such as working for competitors or engaging in personal business with the company.
2. We do not use company assets or systems for non-business purposes.
3. We do not engage in secondary employment or acquire shares in non-public business partners or investees without prior company approval.

５．　Gifts and Entertainment

1. We do not offer money, gifts, or entertainment to public officials or equivalent persons in relation to their duties.
2. We do not offer bribes or benefits to foreign public officials for business advantage.
3. We avoid any payments to agents, advisors, or consultants that may be suspected of being used to influence public officials unlawfully.
4. We do not provide or receive money, gifts, or entertainment that exceed socially acceptable norms.

６．　Handling of Information

1. We strictly manage and protect confidential information, customer information, and personal data, and do not disclose or use such information for non-business purposes.
2. We treat third-party confidential information with equal care.
3. We do not commit intellectual property infringement such as unauthorized software copying.
4. We ensure that technology transfers respect intellectual property rights and that client and supplier information is protected.
5. We disclose company information fairly and proactively in accordance with laws and securities regulations.
6. We prohibit insider trading by refraining from trading shares based on undisclosed material information about the company or its partners.

(Prohibition of Insider Trading)

1. We do not engage in unfair competition through unauthorized acquisition or use of trade secrets.

７．　Compliance with Export/Import Laws and Industry Regulations

1. We comply with all relevant export/import regulations of applicable countries and do not trade in prohibited goods.
2. We follow internal security trade control policies to ensure compliance with laws and promote international peace and security.
3. We understand and follow the regulations, permits, and licensing procedures applicable to our products and services.

８．　Company Funds and Accounting Practices

1. We manage company funds and assets properly and use them only for legitimate business purposes.
   We do not maintain off-the-books assets or funds.
2. We ensure accounting is accurate, timely, and appropriate.
   We do not create false or misleading records.

９．　Donations and Political Contributions

1. We make political contributions or donations only in accordance with laws such as the Political Funds Control Act and through proper procedures.

１０．Social Contribution

1. As responsible corporate citizens, we aim to build trust with stakeholders and contribute to a prosperous and sustainable society.
2. We focus on areas such as international and community exchange, education (human resource development), and the environment, encouraging company-wide involvement beyond financial contributions.

１１．Environmental Protection

1. We comply with environmental laws and actively promote awareness of environmental conservation and efficient use of resources and energy.
2. We continuously improve our environmental impact assessment for new projects.
3. We contribute to the development and dissemination of environmentally friendly technologies with attention to safety.

１２．Response to Antisocial Forces

1. We respond firmly and do not resolve issues through financial settlements when faced with unreasonable demands from antisocial forces such as corporate extortionists or organized crime groups.
2. We do not engage in any transactions with such entities or related parties.

１３．Reporting and Disciplinary Action

1. If any employee discovers a violation of this Code of Conduct, they shall report or consult with their supervisor, director, or the General Manager of the Administration Department.
2. Employees may also report or consult anonymously with the Internal Audit Office, a director, or an auditor.
3. All employees must cooperate in investigations of potential violations.Violations will result in disciplinary action for the offender and their supervisor, in accordance with company rules.
4. No retaliation shall be taken against those who report or cooperate in investigations.
5. If any disadvantage arises from reporting, the employee shall promptly inform the General Manager of the Administration Department, who will investigate and respond immediately.

Enacted: September 1, 2009
Revised: February 7, 2012
Revised: May 7, 2019