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Clarion Group Codes of Conduct

The Clarion Group Codes of Conduct have been established as specific codes of conduct that apply to all companies of the Clarion Group. Under the leadership of top management, we will thoroughly implement the Codes of Conduct to ensure that all our business activities are conducted on the basis of corporate ethics and compliance, in accordance with “Basics and Ethics.”

Chapter 1 Sincere and Fair Business Activities

1.1 Provision of Safe High-Quality Products and Services

(1) We will satisfy customer needs and specifications. We will not only obey quality, safety and environmental laws and standards, but also set our own voluntary standards when necessary to ensure the quality of our products and services. We will strive to guarantee safety and realize the goal of zero product defects so that customers can use our products and services with a sense of security.

(2) We will respond quickly and sincerely to defects and customer complaints, and strive to determine the causes and implement thorough measures to prevent recurrence.

(3) We will construct and administer appropriate quality management systems.

1.2 Sales Activities

(1) We will carefully understand what customers seek from the customer’s viewpoint, and provide reliable, satisfactory products and services.

(2) We will observe domestic and overseas competition laws and regulations as a matter of course and act appropriately as a member of society under the basic principles of conduct according to the rule of law and ethical corporate integrity and fair, transparent and free competition.

(3) We will not engage in sales activities that place unreasonable pressure on customers, such as forcing customers to engage in transactions with the company or the Hitachi Group.

(4) We will build appropriate relations with retailers and other sales channels. We will not conduct trade under conditions that differ, without good reason, from our terms of trade with other parties, place any unlawful restraints on the sales prices of goods that we have supplied, or engage in any other unfair trading practices.

(5) We will observe laws and internal company regulations, avoid improper expressions in advertising and publicity activities of the company and our products and services, and use fair and appropriate representations and expressions in accordance with social justice and public order and good morals.

(6) When we collect information, we will use proper means and act fairly and appropriately in accordance with the applicable laws and regulations. We will strive to maintain the confidentiality of customers’ confidential and personal information.

(7) We will enter clear and lawful contracts in an appropriate and rational manner.

(8) When we enter contracts, we will examine individual transaction terms based on a solid understanding of the risks and costs with the assistance of relevant personnel and experts as necessary, and carry out the contract process in accordance with company procedural rules.

1.3 Procurement Activities

(1) We will strive to build good partnerships with suppliers, and to maintain and improve long-term relationships of mutual understanding and trust.

(2) We will strive to develop optimal suppliers from a broad view worldwide, and to maintain competition.

(3) We will select suppliers appropriately and fairly. In selecting suppliers, in addition to considering the quality, reliability, delivery dates and prices of materials as well as the management stability and technological development strengths of the suppliers, we will also give due consideration to their fulfillment of social responsibility including fair and highly transparent information disclosure, observance of laws and social norms, respect of human rights, elimination of unfair discrimination concerning employment and workplaces, elimination of child labor and forced labor, environmental protection activities, social contribution activities, creation of pleasant workplaces, and sharing of awareness about social responsibility with business partners.

(4) We will not accept any personal benefits from suppliers concerning procurement transactions.

(5) We will deal impartially and fairly with all suppliers. We will also strive to maintain the confidentiality of suppliers’ confidential and personal information.

(6) We will manage procurement activities through appropriate procedures in accordance with internal company regulations.

1.4 Respect of the Hitachi Brand and Clarion Brand

(1) We will position the brand as an important management asset, and take actions to protect and enhance the value of the Hitachi brand and Clarion brand, and have it recognized by society.

1.5 Observance of Engineering Ethics

(1) As engineers, when faced with a situation deemed contrary to our mission in the course of carrying out our work, we will give top priority to public safety, health and welfare. We will make every possible effort to guarantee product safety to ensure that product liability problems caused by products, systems and services do not occur, and strive to secure superior functions, performance and reliability.

(2) As engineers, we will work for global environmental protection and the effective utilization of resources to maximize the sustainability of human society.

(3) As engineers, we will always exercise judgment based on the facts from an objective perspective with honest, sincere and impartial responsibility. When we find it difficult to resolve problems as individual engineers, we will seek opinions from relevant persons inside and outside the company and knowledgeable third parties and experts, and jointly work to resolve the problems.

(4) As engineers, we will always strive to increase the transparency of information that affects the public, society and the environment, and to swiftly provide accurate information in cooperation with the relevant parties inside and outside the company.

(5) As engineers, we will observe our duty to maintain confidentiality. When confidential information includes information that might have a material effect on the public, society or the environment, however, we will work to disclose the information in a timely and appropriate manner.

(6) As engineers, we will respect other parties’ intellectual properties as well as our own intellectual properties. We will build smooth cooperative relations with other parties and work to establish a fair market environment.

(7) As engineers, we will respect the cultures, religions, customs, systems and diversity of value systems of other peoples, nations and regions, and strive to share joy with the people of the world through technology.

(8) As engineers, we will pursue self-improvement and continue to lead the world with technology in the future.

Chapter 2 Environmental Protection

2.1 Promoting Environmental Management

(1) We recognize the roles we should play and will carry out each of them to conduct monozukuri aimed at reducing the environmental burden of a product throughout its life cycle—from procurement of materials to production, distribution, use, and appropriate disposal—in order to realize a sustainable society in harmony with the environment.

(2) We will strive to conduct business management and operations observing environmental laws and regulations, as well as voluntary standards.

2.2 Promoting Environmentally Conscious Business Activities and Environmental Management

(1) We will actively develop environmentally conscious products and services that give consideration to the prevention of global warming, cyclical use of resources, and the preservation of ecosystems.

(2) We will actively pursue the prevention of global warming, cyclical use of resources, and the preservation of ecosystems at our plants and offices.

(3) We will evaluate the potential for environmental problems, strive to prevent the occurrence of environmental problems, and quickly implement appropriate measures that minimize the environmental load whenever environmental problems occur.

2.3 Communication with Stakeholders

(1) We will pursue information disclosure and dialogue regarding environmental activities to create a sustainable society together with stakeholders.

Chapter 3 Relations with Society

3.1 Disclosure of Company Information

(1) We will place importance on the process of dialogue with a wide range of stakeholders regarding information required by society, listen to various opinions and negative information about the company and Hitachi Group companies, respond to them sincerely on our own initiative, and promote two-way communication with society.

(2) We will respond sincerely to crises that occur and disclose information in a timely and appropriate manner, even when this information is negative or disadvantageous to the company.

3.2 Contribution to Local Communities

(1) We will carry out social contribution activities, centered on activities to foster personnel who will lead the reforms of the next era, to realize a vibrant society by making the greatest possible use of our resources. By implementing social contribution activities, we aim to be a respected and trusted global enterprise of the 21st century.

3.3 Relations with Politics and Government Administration

(1) We will establish sound relations with politics and government administration. In particular, we will observe ethical regulations concerning public servants.

(2) We will not engage in any bribery of public servants (including foreign public servants and parties legally regarded as public servants), or engage in any similar activities to propose, promise or provide unfair profits. We will also refrain from any conduct that might be construed as constituting bribery or similar activities.

(3) We will not engage in any activities that impair the fairness of public tenders.

(4) We will make donations and join outside organizations fairly and appropriately.

3.4 Prevention of Anti-social Transactions*

(1) We will have no relations whatsoever with anti-social forces such as organized crime groups, and we will never engage in anti-social transactions under any circumstances.

(2) We will prevent anti-social transactions through self-inspection of our transactions.

(3) We will oppose anti-social forces such as organized crime groups with firm resolve, and refuse any improper demands.

* Transactions with anti-social forces such as organized crime groups

3.5 Regarding Gifts, Business Entertainment, Etc.

(1) We will not ask suppliers, customers or other parties to make gifts of money or goods to employees or their families.

(2) We will not present gifts of money or goods to suppliers, customers, the employees of other companies, or other parties that have or might be viewed as having a direct influence on trading relations with our company.

(3) We will conduct business entertainment within the range of common practice.

(4) We will respond cautiously to offers of business entertainment from suppliers and customers, and report all such offers to our superiors for consultation in advance. We will decline on the spot any offers of extravagant or high-priced entertainment that transcend the bounds of conventional wisdom.

3.6 Observance of Laws and Regulations and Respect of the Culture and Customs of Each Nation and Region

(1) In our business activities in all nations and regions, we will respect the culture and customs of each nation and region, and pursue open and honest conduct in accordance with the relevant governing laws and regulations in each nation and region. We will also contribute to economic, social and environmental progress for the sustainable development of each nation and region. In nations and regions where domestic laws or their enforcement conflict with international standards of conduct, we will strive to give the greatest possible respect to international standards of conduct.

(2) We will not engage in or be involved with any improper commercial transactions in any nation or region. We will also exercise due caution to avert any relations with organized crime, and observe the laws and regulations governing money laundering (the laundering of illicit funds gained from criminal activities, etc.).

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