Corporate Code of Conduct and Employee Action Guidelines

Corporate Code of Conduct (1)

Sound business practices and sustainable growth

The Nisshin Seifun Group of companies (the “Group”) strives for sustainable growth by pursuing fair profits through sound business practices while properly distributing profits to stakeholders.

Employee Action Guidelines

1. Contribute to the sustainable growth of the Group

Employees of Group companies (“Employees”) are aware of their role to responsibly contribute to pursuing sustainable development and profits through free, fair and sound business practices.

2. Meet stakeholder expectations

Employees challenge themselves to enhance business performance and meet the expectations of stakeholders through diligence, ingenuity and continuous innovation.

Corporate Code of Conduct (2)

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

Group companies develop and provide 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, the Group enhances 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 their company manufactures, imports or sells. Providing safe and high-quality products for consumers is the Group’s first priority.

2. Store all pertinent data to ensure traceability

Employees only utilize raw materials that are verified as safe. This prevents harmful and/or foreign substances from entering the product. Records are 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 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 control and labor safety, namely, Sort-out (seiri), Set in order (seiton), Sweep and clean (seisou), Set a standard (seiketsu), and Sustain the standard (shitsuke).”

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

When a material accident affecting product quality occurs, Employees take proper and immediate action as determined by company rules and regulations, giving top priority to consumers’ health and safety.
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 need to act promptly and professionally to report such an accident and cooperate with the relevant departments.

Corporate Code of Conduct (3)

Respect humanity

Group companies endeavor to develop human resources based upon the practice of respecting the individuality of each of their Employees, and provide working environments where Employees can fully realize their potential. Group companies also strive to keep all work sites safe, clean and comfortable, which encourages Employees to engage in their work with satisfaction and pride.
Group companies apply fair and impartial treatment in human resource management while respecting each Employee’s individual aptitudes and abilities.
In conducting their respective business activities, Group companies respect human dignity and do not impair any basic human rights.

Employee Action Guidelines

1. Strive to improve one’s own abilities and foster growth of others

Employees do their work with a sense of pride and responsibility, and endeavor to improve their 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 take the initiative to mentor their subordinates to develop skills suited to their individual aptitude and abilities.

2. Keep a safe and clean work environment

Employees 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 do 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 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

Group companies comply with local cultural norms, laws, regulations, and respective internal rules and regulations in their efforts to promote the growth of their company and the Group in a fair and free competitive market.

Employee Action Guidelines

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

Employees comply with local norms, laws, regulations and corporate ethics expected of members of society and local organizations and make efforts to maintain these standards.

2. Observe working regulations and other internal rules

Employees comply with all work regulations and other internal rules, maintain order in the workplace, and draw appropriate boundaries between public and private life. Employees do not conduct themselves in a way that could cause damage to their company’s reputation or other such loss or damage.

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

Employees:

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

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

Regarding the importance of their company’s confidential information, Employees:

• keep confidential information under strict control, and prevent unfair or inadvertent use or disclosure of confidential information;
• 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 take particular care to prevent such confidential information from disclosure to the public; and
• take precautions to protect intellectual property rights including copyrights, trademarks and patents, and, in turn, do not infringe upon or wrongfully use intellectual property rights held by others.

5. Refrain from offering illegal payoffs

Employees:

• do not offer illegal payoffs, political contributions, entertainment or gifts to any public servants and always follow commonly accepted business practices when dealing with customers and the business community; and
• 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, or organized crime groups.

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 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 cooperation and communication, and promote the sharing of information of various types in conducting daily business.

2. Enhance the public image of their company

Employees always:

• act reasonably as members of a business organization; and
• when communicating with the public, enhance the image of their company by endeavoring to build understanding and confidence in the company’s business.

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 Group’s existence and activity in the future. With this understanding, Group companies endorse environmental protection activities whereby we may actively and voluntarily reduce waste and CO2 emissions and seek 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 comply with all applicable laws and regulations to prevent environmental contamination.

2. Use resources efficiently

Employees “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 are highly sensitive to their impact on the environment, 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

Group companies are committed to our responsibility to act as respectable corporate citizens. We are enthusiastic about getting involved in activities for the benefit of the local community and 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)

Promote overseas business in tune with local communities

Group companies respect the cultures and traditions of each country where they have business operations, comply with applicable laws and regulations, and contribute to the development of the local economy through their business activities.

Employee Action Guidelines

1. Comply with the laws and regulations of each country

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

2. Promote and maintain friendly relationships

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

3. Contribute to local economic development through business activities

Employees contribute to local economic development by creating employment opportunities through their business activities and developing human resources through skills training.

Corporate Code of Conduct (9)

The role and responsibility of management to achieve the purpose of the Corporate Code of Conduct and Employee Action Guidelines

The presidents and directors of Nisshin Seifun Group Inc. and each Group company are aware of their responsibility to uphold the Code and Guidelines and provide leadership in ensuring that all concerned are familiar with these requirements. In addition, managers and Employees always listen to stakeholders both inside and outside the Group, organize effective internal systems, and strive to thoroughly implement corporate ethics.
In the event of a situation that contravenes the Code and Guidelines, the president of the company concerned will communicate internally and externally (as appropriate) their efforts to resolve the issue, investigate the causes and prevent recurrences.

Accountability will be ensured through the timely disclosure of accurate information, and firm disciplinary actions will be taken (including against the president of the company concerned where necessary) upon clarifying the authority and responsibility of those concerned.