1. General Provisions

2. Basic Rules of Conduct

1. (1) Complying with All Applicable Laws and Rules

   We comply with all international rules, national and municipal laws and regulations and internal rules which are applicable to our activities.

2. (2) Approaching Services with Integrity

   We approach our services with integrity at all times and conduct sound business activities based on correct understanding of social norms and corporate ethics.

3. (3) Establishing and Maintaining Trust

   Each of us understands that he/she is responsible for establishing and maintaining the trust of our customers, business partners, shareholders, directors/officers and employees, community and other stakeholders, and always conducts himself/herself keeping in mind that he/she should contribute to enhancement of the reputation and value of SII group.
   We will not commit any act that may undermine the trust of our customers, business partners, shareholders, directors/officers and employees, community and other stakeholders or any act that may damage the reputation or credit of SII group.

4. (4) Having a Spirit of Appreciation

   When serving our customers, business partners, shareholders, directors/officers and employees, community and other stakeholders, we always act in a spirit of appreciation of these stakeholders.

5. (5) Working with Diligence and Creativity

   We set high ideals and goals and dedicate ourselves to and strive for achievement and attainment of such ideals and goals. We also strive to create and provide new value as well as exciting products and services by staying one step ahead of the times.

6. (6) Providing Excellence in “QCDS” Which Will Create Value

   We strive to enhance the trust of our customers by achieving excellence in quality (Q), cost (C), delivery (D), safety and service (S), which will create value for customers.

7. (7) Improving Customer Satisfaction

   We always give careful attention to our customers’ opinions and take prompt and appropriate measures in response to customers’ inquiries, complaints and requests. We also strive to understand our customers’ and markets’ needs quickly and appropriately and to provide products and services which satisfy such needs.

8. (8) Consulting and Reporting

   If any of us should violate the SII Code of Conduct, he/she will consult with his/her supervisor immediately.
   If any of us find any actual or potential violation of the SII Code of Conduct or any law or regulation within the company, he/she will immediately report it to his/her immediate supervisor, SII’s compliance department or other information addressee predesignated for this purpose.
   The identity of any employee who blew the whistle permitted by law shall be kept strictly confidential, and such employee shall not be subjected to any disadvantage due to his/her whistle-blowing.

3. Corporate Activities with Integrity

1. (1) Complying with Laws and Internal Rules

   1. Complying with Various Laws and Regulations
      Each of us complies with all laws and regulations applicable to our products and services, ensures to obtain all necessary permits and licenses, submit all necessary reports and otherwise complete all necessary procedures, and otherwise complies with all laws and regulations and internal rules applicable to our own activities. In our operation of international business, we comply with not only domestic laws but also applicable international conventions and foreign import/export control laws, competition laws, environmental laws and other laws and regulations, as well as respecting international business practice which is in conformity with such laws and regulations.
      
      
   2. Complying with Working Regulations
      We comply with our working regulations and abide by the office regulations set forth in the working regulations. We will not commit any misconduct or act of dishonesty which may go against the working regulations.

2. (2) Appropriate Recording and Reporting

   1. Complying with Rules and Ensuring Accuracy
      We abide by applicable laws and regulations and internal rules and ensure accuracy and correctness in making entries in our books, records and vouchers as well as in making applications, reports and announcements both in and outside the company.
      
      
   2. Prohibition of Inappropriate Recording or Reporting
      We will not make any false or fictitious registration, entry, application, report or announcement, falsify any records, or suppress any fact.

3. (3) Management of Information

   1. Protecting Trade Secrets
      We will provide strict and proper protection of our and other companies’ trade secrets in accordance with the media on which they are recorded (paper, HDD, CD, DVD, etc.) or even if they are not recorded at all, and we will not, without the company’s consent, make any unauthorized use of such trade secrets or disclose them to any person outside the company or any of our employees who has no need to know them, both during office and after retirement. In order to protect such trade secrets from theft, loss or other accidents, we comply with internal and other rules related to the handling of IT devices in which trade secrets are stored and handle these IT devices in an appropriate manner.
      
      
   2. Protecting Privacy and Personal data
      We respect the privacy of our customers, business partners, shareholders, directors/officers, employees and other individuals. In our collection, use, storage, disclosure, destruction and other disposal of personal data, we comply with all applicable laws and regulations as well as internal and other rules, and we will handle all personal data in an appropriate manner and will not, without the company’s consent, use or disclose such data to any person outside the company or any of our employees who has no need to know them, both during office and after retirement.
      
      
   3. Prohibition of Insider Trading
      If we obtain any material non-public information (important inside information) on our own company or any of our subsidiaries, affiliates or business partners, we will not sell or purchase any shares or other securities of such company or engage in similar transactions before such information is officially published. We will not provide any important inside information to any other directors/officers or employees or any of our customers, family members, friends, or solicit any such persons to engage in such sale or purchase or any other transactions.

4. (4) Appropriate Management and Use of Corporate Assets

   1. Appropriate Management
      We manage our company assets, whether tangible or intangible, in an appropriate manner in accordance with internal and other rules and handle them appropriately so as to protect them from divulgence, loss, theft or other accidents.
      
      
   2. No Misuse
      We will not use or spend any company assets for private purposes or any other purposes than our business activities.
      
      
   3. Appropriate Use of Our Information System
      We use the company’s information system only for our business activities and not for private purposes.
      We control IDs and passwords strictly to prevent divulgence to persons outside the company.

5. (5) Fair Trade and Free Competition

   1. We serve all our business partners on an equal footing with them at all times in a sensible and faithful manner and treat them all fairly and equally. We comply with all laws, regulations and rules related to prohibition of private monopoly, fair competition and fair trade applicable to each country and region where we engage in business activities.
      We will not participate in or be involved in any cartel or bid-rigging. We will not commit any act which restricts sales prices or otherwise unfairly restricts business activities of our business partners.
      We will not impose any conditions on our business partners which are unfairly disadvantageous to them by taking advantage of our superior position.
      
      
   2. Appropriate Advertising and Promotional Activities
      In our advertising and promotional activities, we will not make any false or misleading representation on the quality, performance or other aspects of our products and services, or provide any excessive premiums or prize monies. We will not include any expression which may be taken as disparagement or defamation against any other person or any term which may be associated with social discrimination, in any document or information distributed by us in our advertising and promotional activities.
      
      
   3. Prohibition of Unfair Competition
      We will not give or distribute any false information which may damage our competitors’ goodwill, or commit any act which may cause misidentification or confusion for our customers or any other act which constitutes an act of unfair competition.
      We will not obtain any other company’s trade secret by improper means or knowing that it was or may have been obtained by improper means.
      
      
   4. Fair Trade
      When we select a supplier from two or more suppliers, we will compare and evaluate them in terms of quality, price, delivery, technological development capacity, stable supply and other aspects in a fair manner before determining the best supplier.
      Regardless of whether or not we have influence over the selection or evaluation of suppliers, we will not exert any influence on such selection or evaluation in a manner which may give favorable treatment to a specific supplier.
      
      
   5. Appropriate International Trade
      In importing and exporting products and services, we comply with all import/export laws and regulations and complete all appropriate import, export and customs clearance procedures in accordance with such laws and regulations as well as internal rules.
      In order to maintain international peace and security, we will carefully judge whether or not our products to be exported are subject to any restriction under relevant laws and regulations and whether or not they may be used for development or production of weapons.

6. (6) Avoiding Conflict of Interest

   We will not commit any act to promote our or any other person’s interests at the cost of SII group’s legitimate interests. We will not work for any of our competitors or business partners as their director/officer, employee, consultant or whatever, and will avoid being involved in any activity which may result in a conflict of interest with our duty to SII group.
   If any of our activities seems to constitute a conflict of interest with our duty to SII group, we will consult with appropriate department in advance.

7. (7) Ensuring Quality and Safety of Products and Services

   1. Preventing Accidents
      We strive to prevent accidents by ensuring high quality and safety of our products and services, and will not market any product or service of uncertain quality or safety.
      We will provide explanation and information on our products and services in a timely, accurate and easy-to-understand manner.
      
      
   2. Improving Quality and Safety
      We strive to maintain and improve the quality and safety of our products and services by making the best use of scientific methods.
      
      
   3. Complying with Regulations and Standards
      We comply with domestic and international laws, regulations and rules related to quality and safety of our products and services and provide products and services which conform to domestic and international standards on their quality and safety.
      
      
   4. Responding Quickly
      We will respond quickly to any accident or trouble and will not suppress any fact or make any false report or announcement in or outside the company.

8. (8) Respecting and Protecting Intellectual Property Rights

   1. Respecting Intellectual Property Rights
      We respect other persons’ intellectual property rights. To prevent an infringement of any intellectual property right, we will conduct investigation during planning, designing or other preliminary phase before commercialization of a product or service, and if we find any intellectual property right which may be infringed upon, we will strive to take appropriate measures to avoid infringing it and will avoid committing any act which may result in infringement of it. In addition, we will not copy without permission or otherwise make any unauthorized use of any other person’s computer software or other work.
      
      
   2. Protecting as Intellectual Property
      We will provide proper protection as intellectual property for any invention or other production obtained from our research and development and other business activities, by applying for protection under intellectual property rights or, if the relevant production should be protected as know-how, by managing as trade secrets.
      
      
   3. Appropriately Protecting Intellectual Property
      We will appropriately manage and preserve our intellectual properties as part of the company’s important assets, by conducting periodic review in terms of whether individual intellectual property rights must be maintained and if our intellectual property rights are appropriately held and our know-how is appropriately managed.
      
      
   4. Actively Using Intellectual Property Rights
      We will make strategic and active use of our intellectual property rights by finding effective use of them in individual businesses and products in order to contribute to our business activities.

9. (9) Sound Relationship with Business Partners and Society

   1. Prohibition of Inappropriate Entertainment or Gifts
      Any entertainment and/or gifts provided to or received from our business partners must be kept within the bounds of sound business practice and common sense. We will not receive any gift or entertainment from our suppliers in connection with our procurement of materials and services.
      We will not provide, offer or promise any money or other valuables or entertainment to any public official or similar employee of any domestic or foreign government, local public body or other public organization in order to obtain unfair advantage in our business activities or in exchange for providing any special favors to us in our business activities.
      No gift or entertainment will be exchanged between directors/officers, between employees, or between directors/officers and employees of SII group.
      
      
   2. Cutting off Relations with Antisocial Forces
      In order to avoid being involved in illegal or antisocial activities, we keep basic knowledge in law, common sense and a sense of justice and strive to conduct ourselves sensibly at all times.
      We take a stringent, resolute posture against antisocial forces and avoid being involved in them in any way. We take a stringent, resolute attitude toward any unreasonable demands from antisocial forces and will not attempt a quick fix by providing money or other valuables.
      We will not do any business with any antisocial force or any entity involved in any antisocial force.
      
      
   3. Appropriate Donations and Political Contributions
      We will make any donations and contributions after giving sufficient consideration to their necessity and appropriateness and obtaining prior approval in accordance with applicable internal rules.
      We strictly refrain from any behavior which may give false impression that the company has a collusive relationship with governmental or administrative authorities, not to mention refraining from offering any bribe, illegal profit or illegal political contribution, and will strive to make sound and clear relationship with them.
      
      
   4. Prohibition of Political or Religious Activities
      During our working hours, we will not engage in any political activities such as soliciting others to join a political organization, soliciting votes for a particular candidate in an election, or any election campaign activities.
      During our working hours, we will not engage in any religious activities such as soliciting others to join a religious organization, forcing our creed on others, requesting donations, or distributing promotional leaflets.
      During our working hours, we will not otherwise engage in any solicitation activities which would promote the interests of any particular individual or organization without the company’s permission.

4. Respecting Human Rights

1. (1) Respecting Human Rights without Discrimination

   1. Respecting Human Rights
      We respect the human rights of all persons involved in our business activities as well as of our employees, and will not commit any violence, violent or abusive language, disparagement, defamation, harassment, contempt and/or forcing on any person to work by use of intimidation.
      
      
   2. Prohibition of Discrimination
      We do not engage in unreasonable discrimination against any person on the basis of origin, nationality, race, color, ethnicity, creed, religion, gender, age, disability, hobby, academic background, political orientation, union affiliation, marital status or whatever in our recruitment, employment, promotion, compensation, training or the like.
      
      
   3. Prohibition of Harassment
      We strive to maintain a healthy workplace environment at all times, and will not engage in any speech or conduct of a sexual nature which is offensive or annoying to others nor will we commit any act which may be mistaken for harassment.
      We do not engage in any unjust coercion or similar act by taking advantage of our superior position over our subordinates or business partners.
      
      
   4. No Unfair Labor Practice
      We do not allow any forced labor or child labor in any country or region.

2. (2) Ensuring Industrial Safety and Health

   1. Ensuring Industrial Safety and Health
      We strive to create a safe and healthy workplace environment, and understand and comply with all applicable laws and regulations and internal rules related to industrial safety and health. We do not bring any hazardous materials into the company’s premises without permission.
      
      
   2. Preventing Accidents and Recurrence
      We strive to prevent accidents. In case of any accident, we report it immediately and complete prescribed procedures without fail in order to minimize damage and prevent recurrence.

3. (3) Creating and Maintaining Comfortable Working Conditions

   1. Respecting Individuality and Ensuring Fair Assessment
      We respect diversity, personality and individuality of our employees and create a working environment where various personnel can demonstrate their ability.
      We strive to assess employees’ performance fairly and objectively and to treat employees according to results of such assessment.
      
      
   2. Maintaining Healthy Working Conditions
      We ensure that the number of days and hours of work is kept within the bounds permitted by applicable laws and regulations in each country and region.
      Under no circumstances will we force employees to work excessively or overtime. 
      Supervisors will pay attention to their subordinates’ mental and physical health at all times.

5. Creating Harmony with the Environment

1. (1) Preventing Environmental Pollution

   We strive to prevent environmental pollution by complying with all laws, regulations, conventions and other rules related to the environment.

2. (2) Reducing Environmental Load

   In order to reduce our environmental load continuously, we voluntarily and actively work on the following:
   
   
   • ・Provide products and services that, throughout their lifecycle, minimize their impact on the environment;
   • ・Save energy, save resources and practice the 3R’s (Reduce, Reuse and Recycle); and
   • ・Reduce environmental risks of chemical substances and promote the disuse of harmful substances.

3. (3) Promoting Green Purchasing

   We promote the purchase of materials and services with reduced environmental load from environmentally-conscious suppliers.

4. (4) Improving Environmental Consciousness

   We strive to improve environmental consciousness by providing environmental education and enlightenment. Each of our directors/officers and employees strives to pay attention to environmental conservation at all times and to engage in environmental conservation activities in his/her personal life.

6. Establishing a Constructive Coexistence with Society

1. (1) Disclosing Management Information

   We disclose our financial standing, business activities and other management information to our shareholders, investors and other stakeholders in accordance with applicable laws, regulations and rules in a timely and accurate manner.
   
   We strive to deepen understanding between us and our stakeholders by conveying clear information on our management principles and business activities to all stakeholders and by accepting opinions on and criticisms of such information in a sincere manner.

2. (2) Contributing to Society

   We strive to actively contribute to society at large by supporting art and culture, cooperating with communities, participating in volunteer activities, contributing to the global community, and engaging in social activities for the environment.

3. (3) Respecting Local Cultures and Customs

   In our international business activities, we respect the culture and custom of each country in which we engage in business activities and strive to promote business activities based on mutual trust with the local community.

7. Operating System

1. (1) Establishment, Revision and Abrogation

   The establishment and any revision or abrogation of the SII Code of Conduct will be approved by the president of SII after deliberation by the SII Compliance Committee.

2. (2) Application to SII Group Companies

   For each SII group company, its representative shall decide to adopt the SII Code of Conduct as the company’s code of conduct and shall apply it to the company’s directors/officers and employees.
   Any SII group company may make an addition or change to the SII Code of Conduct upon its representative’s approval if such addition or change is necessary due to applicable laws and regulations or the custom of the country or region or due to the company’s business activities, unless such addition or change would create any provisions contradictory to, or less restrictive than, the corresponding provisions of the SII Code of Conduct. Any change or addition to the SII Code of Conduct must be referred to the SII’s Compliance Department in advance.

3. (3) Familiarizing Employees with This Code

   SII’s Compliance Department shall be responsible for familiarizing all directors/officers and employees with the SII Code of Conduct. Each director/officer and supervisor shall provide guidance and supervision to ensure that all employees in his/her charge comply with the provisions of the SII Code of Conduct. If any employee violates the SII Code of Conduct, his/her supervisor shall immediately report it to the compliance department and conduct investigation of such violation as well as taking measures necessary to eliminate consequences and prevent recurrence.

4. (4) Reference

   We strive to clear any doubt as to any provisions or interpretation of the SII Code of Conduct by referring it to SII’s Compliance Department.

5. (5) Sanctions

   Any person who violated or ignored any violation of the SII Code of Conduct will be subject to sanctions in accordance with the working regulations and to other discipline in terms of personnel evaluation and treatment, depending on the nature of the violation.