Corporate Code of Conduct and Employee Action Guidelines

Corporate Code of Conduct (1)

Seek continuous growth through sound business activities

The Nisshin Seifun Group seeks continuous growth as a company by pursuing a fair profit by practicing sound business activities, with the profits properly passed on to the stakeholders.

Employee Action Guidelines

1. Contribute to the continuous growth of the company

The employees of the Nisshin Seifun Group contribute to the continuous growth of the company by conducting themselves in a responsible and professional way. These persons represent the company and pursue fair profits for the company through free, fair and sound business practices.

2. Meet the expectations of the shareholders and other stakeholders

Employees will seek to enhance the company’s business performance and to meet the expectations of shareholders and other stakeholders by performing their duties with diligence through creativity and constant innovation.

Corporate Code of Conduct (2)

Develop and provide reliable, safe and high-quality products and services

The Nisshin Seifun Group develops and provides high quality products and services that are reliable and safe, and “contribute to a healthy and fruitful life for all”.
In addition to complying with applicable laws and regulations, we enhance quality management systems that give priority to the consumer, targeted at cultivating optimum levels of consumer satisfaction.

Employee Action Guidelines

1. Ensure safety of products and commodities

Employees strive to ensure safety at every stage, from R & D to production, storage, and the distribution of products and commodities that we manufacture, import or sell. Providing a safe and high quality product for consumers is our first priority.

2. Store all pertinent data to ensure “traceability”

Employees will utilize only those raw materials whose safety has been verified, in order to prevent harmful and/or foreign substances from entering the product. Records will be kept of all necessary data pertaining to raw materials, manufacture, distribution, etc, to provide comprehensive traceability of original sources.

3. Maintain sanitary conditions of the facility

By consistently practicing the “Five ‘S’ Activities”*, employees will properly manage and keep all machinery and equipment in a sanitary condition by preventing contamination from insects and animals that may enter the facilities, and avoiding the proliferation of bacterial or viral agents.

* The “Five ‘S’ Activities” refers to the most basic activities undertaken in quality management and labor safety, namely, “order (seiri), tidiness (seiton), cleanup (seisou), cleanliness (seiketsu), and discipline (shitsuke).”

4. Act promptly and properly when there is a material accident affecting product quality

When a material accident affecting product quality occurs, employees will take proper and immediate action as determined by company rules and regulations based on the consumers’ health and safety as a first priority concern.
Also, employees must recognize that a serious accident or incident affecting product quality has the potential to threaten the entire Group’s line of business, and therefore will act promptly and professionally to report such an accident and to cooperate with the relevant departments.

Corporate Code of Conduct (3)

Respect humanity

The Nisshin Seifun Group endeavors to develop their human resources based upon the practice of respecting “the individuality” of each employee , and to provide working environments where employees can fully realize their potential. The Nisshin Seifun Group also strives to keep all work sites safe, clean and comfortable, which encourages employees to carry out their work with satisfaction and pride.
The Nisshin Seifun Group applies fair and impartial treatment in its human resource management while respecting the employee’s individual aptitudes and abilities.
In conducting its business activities, the Nisshin Seifun Group respects human dignity and will not impair any basic human rights.

Employee Action Guidelines

1. Strive to improve their own abilities and foster growth of others

Employees will do their work with a sense of pride and responsibility, and endeavor to improve their own abilities through voluntary study and interaction with one another.
In addition to carrying out their regular duties, supervisors and persons in positions of greater responsibility will take the initiative to mentor their subordinates to develop skills, considering their individual aptitude and abilities.

2. Keep a safe and clean work environment

Employees will take good care of their health, both physical and mental, and always maintain a safe, comfortable, and clean work environment.

3. Respect human rights without discrimination

Employees will not engage in discrimination based on characteristics protected by applicable law, such as sex, nationality, age, ethnic origin, race, religion, belief or physical disability, nor engage in unlawful harassment such as sexual harassment.

4. Actively promote human rights

Employees will promote human rights and actively participate in human rights programs to contribute to forming an impartial and fair society.

Corporate Code of Conduct (4)

Comply with local cultural norms, laws and regulations, and promote fair business activities

The Nisshin Seifun Group will comply with local cultural norms, laws, regulations, and our internal rules and regulations in our efforts to promote the growth of the Group in a fair and free competitive market.

Employee Action Guidelines

1. Comply with local cultural norms, laws and regulations and maintain local social systems

Employees will comply with local cultural norms, laws, regulations, and corporate ethics as members of society and of a professional organization, and make efforts to maintain local social systems.

2. Observe working regulations and other internal rules

Employees will comply with all working regulations and other internal rules, maintain order in the work place, and draw appropriate boundaries between public and private life. Employees will not conduct themselves in a way that could cause the company to impair its corporate image or to suffer any loss or damage.

3. Comply with anti-trust laws and insider-trading regulations

Employees will conduct all business activities, including production, marketing and purchasing, in adherence with principles of fair and free competition, while complying with anti-trust laws.
Also, employees will handle important non-public information obtained through their jobs with care, and never personally trade the stock of the concerned companies on the basis of such non-public information.

4. Control the company’s confidential information thoroughly, and protect intellectual property rights

With regard to the importance of the company’s confidential information, employees will keep confidential information under strict control, and prevent unfair or inadvertent use or disclosure of confidential information.
Employees will properly manage all confidential information ascertained in all research and development sites, and any other sites, including all such information stored in personal computers, as valuable company assets, and will take particular care to prevent such confidential information from disclosure to the public.
Employees will also take precautions to protect intellectual property rights including copyrights, trademarks and patents, and, in turn, will not infringe upon or wrongfully use intellectual property rights held by others.

5. Refrain from offering illegal payoffs

Employees will not illegally offer payoffs, political contributions, entertainment (settai) or gifts to any public servants and will follow commonly accepted business practices when dealing with customers and the business community.
Employees will take a firm stance against unreasonable demands from antisocial forces that threaten the safety and order of society such as shareholders seeking an unlawful benefit (tokushu-kabunushi), or organized crime groups (Boryokudan).

Corporate Code of Conduct (5)

Promote fair and accurate corporate communication activities

The Nisshin Seifun Group promotes positive relations with investors and the public, and continually provides the public with accurate, timely and proper information about our business activities in order to gain the confidence, appreciation and trust of our stakeholders.

Employee Action Guidelines

1. Promote information sharing about business activities

Employees recognize the importance of mutual cooperation and communication, and will promote the sharing of information of various types in conducting daily business activities.

2. Enhance the public image of the company

Employees will always behave as reasonable members of a business organization, and will communicate with the public in order to further the public’s understanding and confidence in the company’s business and to enhance its image.

Corporate Code of Conduct (6)

Encourage environmental protection

The Nisshin Seifun Group understands that the impact of business activities on the environment is a matter of global significance, and that environmental protection plays an essential role in the company’s existence and activity in the future. With this understanding, The Nisshin Seifun Group endorses environmental protection activities whereby we may actively and voluntarily reduce waste and CO2 emissions and seeks more efficient utilization of resources and energy, in accordance with “The Nisshin Seifun Group Basic Policy for the Environment”.

Employee Action Guidelines

1. Prevent environmental pollution

Employees acknowledge the importance of environmental protection and will comply with all applicable laws and regulations to prevent environmental contamination.

2. Use resources efficiently

Employees will “reduce”, “reuse”, and “recycle” waste, and will efficiently utilize resources and energy used in their everyday activities.

3. Develop and manufacture products and commodities in a way that mitigates adverse effects on the environment

Employees will be highly sensitive to their impact on the environment, will promote “resource and energy conservation” and ”recyclable goods”, and will consider innovative plans to develop and manufacture products and commodities that have the least possible impact on the environment.

Corporate Code of Conduct (7)

Promote activities that contribute to society

The Nisshin Seifun Group is committed to its responsibility to act as a respectable corporate citizen, and is enthusiastic about getting involved in activities for the benefit, not only of the local community, but also of society as a whole, in order to promote the advancement of the human condition.

Employee Action Guidelines

1. Contribute to local communities and society at large

By taking part in local activities and cross-cultural opportunities, employees aspire to deepen community ties and cultivate bonds of friendship while endeavoring to contribute to society at large.

Corporate Code of Conduct (8)

Expand responsibly our overseas business in tune with local and social systems

The Nisshin Seifun Group respects the cultures and traditions of each country where it has business operations, and will respect and comply with their laws and regulations. The Nisshin Seifun Group hopes to contribute to the development of the local economy through its business activities.

Employee Action Guidelines

1. Comply with the laws and regulations of each country

Employees will comply with the applicable laws and regulations of each country while promoting sound business activities.

2. Promote and maintain friendly relationships

Employees will keep positive lines of communication open within communities where we have overseas operations by respecting the local communities' human rights, and appreciating and respecting their culture and traditions, thereby promoting and maintaining a mutually beneficial cross-cultural friendship.

3. Contribute to local economic development through business activities

Employees contribute to the economic development of local communities by creating employment opportunities through their business activities and by assisting in the personal development of local employees by encouraging employment skills training.

Corporate Code of Conduct (9)

Expand responsibly our overseas business in tune with local and social systems

The president and other management officers of Nisshin Seifun Group Inc. and each Group company recognize it is their responsibility to make certain that business activities and employees’ conduct comply with these Corporate Codes and Employee Guidelines. It is also senior management's responsibility to make these Corporate Codes and Employee Guidelines known to all responsible personnel, while establishing their own reputation by demonstrating exemplary conduct.
In addition, senior management will respond to stakeholders both inside and outside the Group by organizing an effective Group internal system that will contribute to the achievement of ethical corporate behavior.
If any situation occurs that violates the Corporate Codes and Employee Guidelines, the president of Nisshin Seifun Group Inc. and the president of the Group company concerned will openly express their determination to solve the problem and will work diligently to find the cause of the problem while taking proactive measures to prevent similar situations from recurring.
In addition, the president of Nisshin Seifun Group Inc. and the president of the Group company (individually himself or herself) concerned will be responsible for;