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Ethics Management System

Basic Ethics Policy

"Respect for International Standards, and Compliance with Laws, Business Ethics, and in-house rules"

The ROHM Group will conduct its business observing the laws, business ethics, and in-house rules in order to continue to gain the trust of various stakeholders as a company in compliance with the laws. The Group will also, in line with the globalization of business activities, respect international standards of conduct.

1. Conduct guidelines:
The ROHM Group will act as specified below in accordance with this Policy.
・1.1 Fair action:
The ROHM Group will act with virtue and fairness based on good social sense. The ROHM Group will be fully conscious of its social responsibility, that the Group is a public entity of society, and with the awareness that each individual employee represents the Group.
・1.2 Compliance with laws and business ethics:
The ROHM Group will always conduct its business faithfully in strict compliance with the laws and business ethics. The Group will continuously work to collect, manage and understand the laws and regulations of each country that are relevant to its business. The Group will also introduce and organize in-house rules corresponding to related laws and regulations.
・1.3 Compliance hotline and whistle-blower protection:
The ROHM Group will, by following the provisions of in-house rules, establish a contact point (e.g. compliance hotline) to which Group employees may report business activities that, they suspect, may be in violation of related laws and regulations or business ethics. Moreover, in case the violation or possible violation of the law is discovered, the ROHM Group will promptly correct the condition, plan for the prevention of recurrence (or occurrence), and will deal strictly with the act of violation. Accordingly, the Group will not tolerate any negative treatment against any person or group who reports possible illegal activity, violation of the law and/or of business ethics, on the grounds of such reporting.
・1.4 Prevention of bribery:
The ROHM Group will not, by following the provisions of in-house rules and agreeing with the importance and necessity of preventing corruption as dictated by international agreements and standards, engage in any form of bribery or action, which may be otherwise deemed as bribery or invite suspicion, to any country's governmental agency, to members in official positions, nor to politicians for the purpose of gaining improper benefit or advantage, in order to continue transparent and honest business activities.
・1.5 Prohibition of excessive business entertainment:
The ROHM Group will not, by following the provisions of in-house rules, provide gifts, meals or other channels of financial advantage to its customers or other business associates beyond the bounds of what is socially acceptable. Furthermore, the Group will be most cautious with any offer of entertainment or gifts from its suppliers and will not accept anything which may result in personal profit.
・1.6 Disclosure of information:
The ROHM Group will disclose timely, fairly and actively its corporate information in accordance with both legal requirements and its company policies. This includes relevant information on company missions and policies, business activities and social contributions of the ROHM Group to its stakeholders.
・1.7 Intellectual property rights:
The ROHM Group will strive to improve its own technology in every division. The Group will establish and accumulate the results of its development as its intellectual property, and utilize these effectively in growing its business. The Group will hold great value for intellectual property rights. As such, the Group will not use third parties' rights without their permission, nor abuse the Group's own rights.
・1.8 Implementation of fair sales activities:
In line with the globalization of business, the ROHM Group will observe the provisions of in-house rules and value free market competition and practice fair sales activities. The Group will pursue neither sales nor profit unless the group will comply with the law, social ethics, and contractual obligations. The Group will not violate any law, social ethics or contractual obligations nor engage in any unlawful or unethical conduct, such as anticompetitive behavior (cartel), collusive bidding, fictitious transactions, restraining of selling prices, etc. Moreover, the Group will comply with import/export laws and regulations in order to contribute to a peaceful and safe international community.
・1.9 Fair and appropriate expression:
The ROHM Group shall use fair and appropriate expressions in public relations and advertising activities in compliance with related laws and regulations and based on the facts at all times. In addition, the Group shall observe public order and morality, and shall not use any unjust expressions that constitute false information, slander, social discrimination, or infringement of human rights
・1.10 Non-use of conflict minerals:
The ROHM Group will strive for the protection of human rights, as such, the Group will aim not to use conflict minerals as raw materials, that benefit armed groups in disputed regions whose activities are linked to human rights violations.
・1.11 Management of Confidential and individual information:
The ROHM Group will thoroughly and securely manage information acquired through its business activities including confidential information of the ROHM Group, third parties, and privacy information of individuals concerned, in accordance with the provisions of in-house rules.
・1.12 Fair accounting and disclosure:
The ROHM Group will appropriately record and report information based on fair accounting principles and facts. Accordingly, the Group will pay tax obligations in compliance with the applicable tax laws. The Group aim to pay attention to the interests of all stakeholders and hold in high esteem the other party's position. The Group's aim is to establish and foster the relationship of mutual trust through disclosure of information.
2. Management System:
The ROHM Group will build a management system to observe this Policy and work on the continual improvement of this Policy. The management system will be designed to ensure compliance with applicable international standards of conduct and related laws and regulations, and the identification and mitigation of operational risks related to this Policy.
・2.1 Responsibility:
The ROHM Group will operate the management system in accordance with the provisions of in-house rules and this Policy.
・2.2 Identification of representative:
The ROHM Group will identify an internal representative responsible for ensuring implementation of the management system and related items. The top management will review the status of the management system on a regular basis.
・2.3 Legal and customer requirements:
The ROHM Group will define the procedures for identifying, monitoring, and understanding international standards of conduct, related laws and regulations, and customer requirements.
・2.4 Risk assessment and risk management:
The ROHM Group will define the procedures for identifying risks involved in the Group's business activities, determining the relative significance of each risk, managing the identified risks, and ensuring regulatory compliance.
・2.5 Improvement objectives:
The ROHM Group will define improvement objectives and implementation plans, and periodically assess the achievement of those objectives in order to fulfill its social responsibilities.
・2.6 Training:
The ROHM Group will provide training to employees to achieve the improvement objectives and to meet the requirements of international standards of conduct and related laws and regulations in accordance with this Policy.
・2.7 Communication to employees, etc.:
The ROHM Group will define the procedures for communicating this Policy, improvement objectives, and the assessment of the achievement thereof to employees, suppliers, and customers in a clear and accurate way.
・2.8 Feedback and participation of employees:
The ROHM Group shall define the procedures for assessing employee comprehension of matters provided for in this Ethics Policy, obtaining employees feedback effectively, and making sustained improvements to this Policy based on those assessment results.
・2.9 Audits and assessments:
The ROHM Group will conduct periodic self-assessments to ensure conformity with international standards of conduct, related laws and regulations, and customer requirements.
・2.10 Corrective and preventive action:
The ROHM Group will define procedures for correcting and preventing within an appropriate period of time the recurrence of defects/inadequacies detected in the course of internal or external audits.
・2.11 Documentation and records:
The ROHM Group will create and retain records related to the management system in accordance with the provisions of in-house rules and related regulations.
・2.12 Supplier responsibility:
The ROHM Group will define procedures for communicating requirements provided for in this Policy to suppliers and monitoring the compliance of the suppliers with this Policy.