Code of Conduct

1. General Provisions

This SII Code of Conduct sets forth basic rules to be observed by all SII group*1 directors/ officers*2 and employees*3 in order to put the provisions of the SII Group Charter of Corporate Behavior into practice and to fulfill SII group’s commitments to all stakeholders as well as society at large.

*1 “SII group” means Seiko Instruments Inc. (“SII”) and its consolidated subsidiaries.
*2 “Directors/Officers” mean all directors, statutory auditors, operating officers and those in other similar positions.
*3 “Employees” mean all full-time, occasional, temporary, dispatched and part-time employees.

2. Basic Rules of Conduct