ROHM Group Business Conduct Guidelines

We act with virtue and fairness based on good social sense. We are fully conscious of our social responsibility, that the company is a public entity of society, and with the awareness that we as individuals represent the company.

We always conduct our business faithfully in strict compliance with the laws and business ethics. We continually work to collect, manage and understand the laws and regulations of each country that are relevant to our business.
We will also introduce and organize in-house rules corresponding to relevant laws and regulations.

We will show fortitude against anti-social powers and/or groups and will not bow to unreasonable demands.

In the event where we suspect that our business activity may be in violation of the law or of any business ethics, we will report this to each superior or to the appropriate related division (e.g. compliance hotline). Moreover, in case the violation or possible violation of the law is discovered, we will promptly correct the condition, plan for the prevention of recurrence (or occurrence) and deal strictly with the act of violation.
Accordingly, we 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.

We understand and agree with the importance and necessity of preventing corruption, as dictated by international agreements and standards, such as the United Nations Global Compact (UNGC), ISO26000, or Responsible Business Alliance (RBA) Code of Conduct, etc.
As result, we do not 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. Any corruption, extortion, and/or embezzlement are also strictly prohibited.

We observe the company policies and regulations and do not provide gifts, meals or other channels of financial advantage to our customers or other business associates beyond the bounds of what is socially acceptable.
Furthermore, we are most cautious with any offer of entertainment or gifts from our suppliers and will not accept anything which may result in personal profit.

We effectively use and maintain the company’s tangible and intangible assets.
We do not commit any acts, illegal or personal, that may otherwise damage or diminish the value of our assets.

We will not commit any act that may bring conflicting interests between the company and individuals.

In order to preserve the global environment and contribute to achieve a sustainable society, we develop our business activities, products and services based on a series of international environmental management standards (ISO14000).
We also openly disclose information regarding our environmental activities and maintain open communications. Should any environmental problem occur, we will take appropriate action to minimize any impact on the environment.

We aim to avoid waste of limited resources and energy, and try to reduce and recycle waste in our business activities such as procurement of materials, development, production, and sales.
We also aim to have factories and offices environmentally friendly and comfortable for people working there, and make energy-saving efforts.

We strive to develop helpful technologies, such as energy-saving technologies, that aid in the preservation of the global environment. We also make use of these technologies in our products, process and facilities.
Furthermore, we appropriately control chemical substances used in our production processes as defined by laws and regulations and cease or reduce the use of hazardous substances.

We attempt to preserve the global environment not only in our business activities but also in our private life as citizens of society.

We disclose timely, fairly and actively our corporate information in accordance with both legal requirements and our company policies.
This includes relevant information on corporate principles, management policies, business activities and social contributions of the ROHM Group to our stakeholders.

We aim to enhance transparency in management and obtain trust from the public by properly informing the ideas and substance of the management of the ROHM Group.
At the same time, we take the opinions from the public seriously, and incorporate the feedback into our business activities to enhance our corporate value.

We appropriately record and report information based on fair and valid accounting principles and facts. Accordingly, we pay tax obligations in compliance with the applicable tax laws.
We aim to pay attention to the interests of all stakeholders and hold in high esteem the other party’s position. Our aim is to establish and foster a relationship of mutual trust through the disclosure of information.

We aim to contribute to social development and soundness as good corporate citizens by harmonizing with the local community.
Moreover, we actively participate in --and support volunteer activities--, building close relationships with the local community, in turn, activating the community and creating a better social environment.

We contribute to the promotion and progress of art and science through our cultural activities and support for such activities.
We also support cultural activities through support of public institutions, such as foundations.

In responding to the community as well as social needs, we support contribution and sponsorship of solving social issues, social development, progress, and improvement of culture.

We always maintain the standpoint of our customers, make every effort to grasp their needs, and strive to provide them with solutions. We endeavor to develop world- leading products, and aim to make our new technologies the industry standard.
In addition, we make every effort that these products can achieve customer satisfaction, and that the goods incorporating our products can be environmentally friendly and help contribute to the further development of mankind.

We strive to improve our own technology in every division. We establish and accumulate the results of our development as our intellectual property, and utilize these effectively in growing our business.
We hold great value for intellectual property rights. As such, we will not use third parties’ rights without their permission, nor abuse our own rights.

We establish development facilities at the best location from a global perspective.
Moreover, we efficiently solve any problems we face in the course of our development activities in cooperation with these facilities all over the world.

We will comply with research ethics and will not engage in fraudulent activities in research and development activities such as forgery, falsification, theft, or any other acts that violate laws and regulations in research and development activities. We also recognize that many of the public research expenditures are funded by valuable taxes and that their improper use is an act that significantly impairs the trust of society. When receiving public research expenditures, we will conduct appropriate management in compliance with laws and regulations, internal rules, the terms of receipt of each public research expenditure, and their contract provisions.

Throughout every process, to ensure product quality we establish strict standards and procedures and perform production activities in accordance with the established standards and procedures.
We will never be satisfied by the status quo. We will strive to continuously achieve increased competitive and efficient production and reduce costs while maintaining our policy of “Quality is our top priority at all times.”

We always strive to consider our customers’ point of view and produce products following changes in customers’ needs.
Therefore, we strive to achieve customers’ satisfaction in quality, performance, safety, and price.

In order to meet supply obligations to our customers, we globally establish and maintain our Business Continuity Management (BCM) system, so that under any difficulty in supplying our products due to natural disasters or any other reason, we can continue our business and, if it is disrupted, we can strive to get the business back to normal as fast as possible.

We strive to understand our customers’ needs and demands as well as the market trends precisely and to actively propose our high-value-added products and services accordingly. To accomplish this, we will make every effort to acquire broad knowledge -- not only of our products and services, but also of the market, to inform customers of the function and performance of those products, and to pursue the development of those products and services that better serve our customers. We also establish global sales and distribution networks in order to supply the products effectively.
Through all of these activities, we aim to contribute to reducing and resolving various societal challenges.

We seek to obtain customer satisfaction and confidence by continuing to supply our high-quality products and services in a timely and appropriate manner. We also strive to interact with customers with solid social sense and decorum, and to have customers understand the view of the ROHM Group while paying attention to customers’ opinions and providing feedback internally.

In line with the globalization of business, we value free-market competition and practice fair sales activities. We pursue neither sales nor profit unless we comply with the law, social ethics, and contractual obligations. We 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, we comply with import/export laws and regulations in order to contribute to a peaceful and safe international community.

We will conduct procurement activities for suppliers with fairness, equal footing, and modesty during purchasing material, component and equipment etc. and getting any type of service. We will never enforce unfair trading with a superior position.

We will globally and broadly open a trade opportunity to realize an equal business opportunity. During the processing of suppliers’ selection, we will consider many aspects including quality, technology, delivery, and price. Additionally, we will consider factors like enthusiasm, management, ethics, human rights, risk management, environment protect, health and safety, removal of anti-social forces etc.

We will make an effort to penetrate CSR procurement with mutual understanding between suppliers and ROHM in order to promote CSR procurement based on ROHM Group Supply Chain Management Guidelines. We will also make an effort to secure environmentally friendly procurement based on Green Procurement Guidelines.

We strive for the protection of human rights, as such, we will make an effort not to use conflict minerals that benefit armed groups in designated regions whose activities are linked to human rights violations as raw materials. Further, we will disseminate the ROHM Group’s policy to suppliers and request them to promote actions so that they can observe such policy.

We purchase materials, semi-products, and equipment and outsource operations from our business partners who comply with the human rights laws and regulations of each country. In addition, we will periodically check the status of compliance with laws and regulations with our business partners and request compliance with the laws and regulations as necessary.

The Corporate Brand represents the existence of our company and is an important business resource that can provide trust to stakeholders. We comprehend and practice the philosophy of the management policy and aim to enhance the value of the corporate brand.

We release fair and appropriate content in our public relations activities based on accurate, fact-based information in accordance with applicable laws and regulations.
We observe public order and morality and do not express anything unjust which may lead to falsehood, slander, social discrimination, infringement of human rights, and so on.

We aim to enhance trust in our technology, products, and brand recognition through our public relations efforts and activities and improve the corporate brand value.

We strive to conduct our development, production, and sales activities with full attention to quality and safety as our top priority in accordance with the legal requirements, contract terms of our customers, and our internal rules and standards.
We strive to secure high functioning, high performance and reliability while assuring no product liability issue can arise.

In order to prevent misuse, improper use and accidents, we provide our customers with “information about safety” including usage environment and usage patterns using comprehensible displays and explanations.

If we receive information concerning the safety of our products, we will immediately conduct an investigation to uncover the facts.
In the event we discover problems in the safety of our products, we will faithfully and promptly investigate the root cause and will act to prevent the expansion and recurrence of the problem.

We hold the appropriate management of information in line with international standards (ISO27001). These include confidential information as well as management data.
We acquire information by lawful means and handle it with necessary care, to prevent leakage, and/or illegal use of the information.

We thoroughly consider the necessity of obtaining the other party’s confidential information and will not receive third party confidential information beyond the necessary extent. We also strictly protect and establish safeguards designed to prevent any leakages ofsuch confidential information.

We will never engage in insider trading, using unannounced or confidential information obtained through our business dealings. We will never convey such information to others within or outside the company, including to our immediate families, relatives and/or friends.

We consider the importance of individual information acquired throughout our business, and will acquire, record, use, and discard it with the appropriate method so that there will be no loss, falsification, or leakages.

We strive to transmit and receive appropriate information effectively and efficiently via the system of information networks. When using the information network system, we pay close attention to potential plagiarism and/or falsification of information by third parties, as well as the leakage of information. By doing so, we make efforts to prevent any damage to the third parties. Further, we recognize that cyber-attacks are threats that may significantly affect our business activities and we make efforts to ensure cyber security in ensuring business continuity and preventing loss of trust.

When we use social media privately as an individual, we do so with moral integrity and in compliance with the law and in-house rules. Through the use of social media or other exchange, we will not send any confidential information or individual information obtained via our business.

We value the individuality of each and every employee. We aim to build diversified systems to handle personnel and employment as well as improve working conditions, in order for employees to feel affluent and comfortable.

We strive to prevent work-related accidents by implementing managerial measures based on the identification of hazard sources in our workplace and their severity. We also comply with relevant laws and regulations, and in line with international standards (ISO 45001), make every effort to maintain occupational health and safety management programs.
If any accident occurs in the workplace, we will promptly take appropriate measures, and strive to prevent the expansion and recurrence.

We realize that there are diverse working styles. We support work-life balance and strive to maximize possibilities in promoting job satisfaction.

We respect the privacy of individuals. We pay close attention when dealing with personal data and ensure the appropriate management of it.

We respect human rights and other rights of everyone. We do not allow discriminatory words, behavior or treatment.

We respect the diversity of cultures, customs and other values of each country and region.

We will not tolerate or overlook any harassment, including unacceptable behaviors and practices, or threats that result in physical, psychological, sexual, or economic harm.
We also will maintain good human relations and strive to make our workplace fair.

We comply with labor laws and regulations related to employment, wage, and other labor conditions. We will prohibit labor of children and will not engage employees under the age of eighteen (18) in jobs that may endanger their health and safety. We understand that all work will be voluntary, and will not allow any forced or unfair labor unwanted by employees.

We consider the development of human resources as a foundation for permanent prosperity of our company. Any person in the position of leadership will serve as a model of good behavior and positive attitude. He/She will make every effort to encourage colleagues, toward professional growth as employees and positive growth as individuals of society.
Accordingly, we continue to seek capable human resources and look for means to foster their humanitarianism, intellect, broad knowledge, deep insight, specialty and an international sense.

We always behave with decency, perform our responsibilities with the utmost integrity, continuously work to develop ourselves, and strive for self-improvement through every opportunity.

We assume and analyze every risk in our business activities and strive to prevent their increase on a daily basis.