Code of Conduct

3. Corporate Activities with Integrity

(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) 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) 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) 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) 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) 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) 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) 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) 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