Efforts on Compliance

Taikisha has set out the “Taikisha Ltd. Code of Conduct” as a code for ethics and compliance of all officers and employees. In accordance with the Mission Statement: “Customers First”, Taikisha is making efforts to enhance a system to conduct fair and sound business activities and contribute to society.

To raise the awareness of corporate ethics and compliance among all officers and employees and to enhance compliance management, Taikisha has established the Compliance Policy Review Meeting, the Compliance Committee, and the Corporate Compliance Department. Taikisha has also assigned Compliance Officers and established a Whistle-blowing Contact Window.
The Compliance Policy Review Meeting is held twice a year attended by all Directors and Audit & Supervisory Board Members to examine the annual policy and plan for compliance activities and response to compliance issues, and to validate the implementation status thereof. The Representative Director reports a summary of the results of examination and validation at the Compliance Policy Review Meeting to the Board of Directors.
The Corporate Compliance Department, an independent department under the direct control of the Representative Director, prepares and distributes compliance manuals, disseminates information via the corporate intranet, makes the Whistle-blowing System well known, implements compliance education, monitors status of compliance with laws and regulations, and provides guidance on improvement on an going basis, based on the annual policy and plan for compliance activities approved by the Compliance Policy Review Meeting. The Department, in addition, reports on the status of its activities to the Compliance Committee.
Compliance Officers, who engage in compliance activities in collaboration with the Corporate Compliance Department, are assigned to each division/headquarters in the Head Office and each branch/affiliate in Japan and overseas. Compliance Officers at overseas affiliates share information regarding applicable local laws and regulations with the Corporate Compliance Department, disseminate information regarding compliance and carry out education/enlightenment activities.

Taikisha works to enhance tax compliance and properly pays taxes in accordance with applicable tax-related laws and regulations of each country and region and international rules.

The Corporate Compliance Department regularly visits branches and affiliates in Japan and overseas to monitor the status of compliance with laws and regulations. The Corporate Compliance Department evaluates each branch and affiliate on a three-point-grading of A, B, and C, and provides guidance on recognition of issues and improvement.
In the monitoring in Japan, the Corporate Compliance Department broadly checks and validates the status of compliance with and application of laws and regulations, including the Antimonopoly Act, and internal rules, as well as the status of dissemination of its Corporate Philosophy and the Whistle-blowing System, and issues such as work environments. In the monitoring of overseas affiliates, the Corporate Compliance Department checks and validates risks specific to each affiliate based on the conditions of the country and region, the status of development and operation of the management system for the purpose of complying with laws and regulations related to such as bribery, cartels and bid rigging, and the status of dissemination of the Whistle-blowing System.

Taikisha distributes the Compliance Manual that summarizes the standards of practice for compliance to all employees, in an effort to familiarize them with compliance and thoroughly enforce compliance among them. Having designated October of each year as the Compliance Promotion Month, Taikisha strives to spread and instill compliance awareness by holding read-through sessions of the Compliance Manual targeting all employees, and calling for entries of compliance slogans internally, The entries involve inviting Taikisha Group’s employees broadly to display the best slogans in Japan and overseas in the form of awareness-raising posters at branches and overseas affiliates in Japan and overseas respectively.
As part of efforts to instill its Corporate Philosophy and Taikisha Ltd. Code of Conduct as well as to implement compliance education, Taikisha conducts e-learning targeting all employees three times a year. E-learning covers matters that employees should understand, and is shaped to improve its effectiveness in terms such as the timing and method.

Principles of Behavior

1. 1.We will act in compliance with laws, ordinances, regulations, ethics, dictates of good sense, and internal rules.
2. 2.We will pursue a highly transparent management on the basis of fair and reasonable standards.
3. 3.We will act giving first priority to our customers, business partners, shareholders,, communities/society, and the global environment and will also give appropriate consideration to the human rights of employees.
4. 4.We will make efforts not to destroy the trust we have built over the years or to undermine our business profits, while working to enhance our corporate value.

Ethical Standards

1. 1.Respect for fundamental human rights and maintenance of a healthy work environment
   1. (1)We will respect the fundamental human rights of all employees and supervisors in our corporate activities and will not discriminate on the basis of matters irrelevant to the business of the Company, such as race, religion, belief and creed, national origin, gender, disability, physical features, or age.
   2. (2)We will prohibit all forms of sexual harassment or abuse of position or status in the workplace, whether intentional or unintentional.
   3. (3)We will pay close attention to construction safety standards and work to prevent accidents.
   4. (4)We will implement measures such as physical checkups in order to maintain the mental and physical health of employees.
   5. (5)We will respect the privacy and protect the personal information of employees. We will also protect the personal information of people outside of the Company.
2. 2.Maintaining a good relationship with our stakeholders

   We will establish and advance the following objectives for both the satisfaction of our stakeholders (customers, business partners, shareholders, employees, communities/society, and the global environment) and the enduring development of the Company:

   1. (1)To obtain the satisfaction and trust of our customers by developing excellent technologies and providing high-quality equipment.
   2. (2)To appropriately distribute the ensured profit to dividends, investment, personnel expenses, etc., and to properly pay taxes.
   3. (3)To strive to improve the transparency of the management, including corporate accounting, and to disclose corporate information appropriately in accordance with laws, ordinances, and regulations. To prohibit employees from any wrongful trading of shares, etc. on the basis of insider information.
   4. (4)To perform equal and fair transactions, enhance the transparency of contracts, and comply with relevant laws and ordinances in pursuit of coexistence and co-prosperity with our suppliers and sub-contractors.
   5. (5)To give consideration to the residents in the neighborhoods of our branch offices, construction sites, and laboratories, and to comply with arrangements with the residents.
   6. (6)To strive for the conservation of the global environment through activities such as natural resource saving, energy saving, waste reduction, reusing, and recycling. To disclose our environmental conservation activities to society through appropriate channels of public relations.
3. 3.Maintenance of trust
   1. (1)Officers and employees must respect the trust and reputation of the Company and act in accordance with the dictates of social good sense.
   2. (2)We will refuse to have anti-social forces, including organized crime groups(Boryoku-dan), involved in our business, and will reject any demands made by them. We will prohibit employees from having any relation with members of said groups.
4. 4.Free competition, fair trading, business entertainment and gifts
   1. (1)We will comply with laws and ordinances including the Anti-Monopoly Law in order to realize fair competition and fair tender.
   2. (2)We prohibit any bribery, unfair profit sharing, or facility offering, and will comply with relevant laws and ordinances including the Political Funds Control Act and the Public Offices Election Act.
   3. (3)Business entertainment and gifts should be provided or received on the basis of social good sense; therefore, receiving business entertainment or gifts that may affect judgment on the performance of certain business is prohibited.
5. 5.Asset management and respect for property rights
   1. (1)The employee’s use of any assets of the Company for purposes other than pursuit of profit of the Company is prohibited.
   2. (2)We will respect the rights of property owned by any corporate or individual persons other than the Company and will never damage or infringe such property and rights. This includes intangible rights such as intellectual property rights.
6. 6.Handling of confidential information
   1. (1)Employees must not leak any information obtained in the course of business activities except for facts that have already become publicly known. In particular, information provided by other companies must be kept under strict control.
   2. (2) Employees must not access internal or external information using wrongful means.
   3. (3)Such handling of information as noted above will apply equally to our retired employees, temporary employees, employees on subcontracts, and business partners.