SANKI ENGINEERING CO.,LTD

Environmental and CSR Activities

Code of Conduct and Action Guidelines

The Sanki Engineering Group's Code of Conduct and Action Guidelines

Formulated on December 1, 2002
Revised on May 1, 2012
Revised on June 2, 2014

Contribution to Society Through Business Activities

[Code of Conduct]

1
Always taking our customers' perspective, we will provide safe and useful products and services that satisfy our customers and earn their trust, and we will contribute to the development of society through Total Engineering.

[Action Guidelines]

  1. Taking our customers' needs seriously, we will present solutions based on our superior technological capacity as engineering professionals, enabling us to provide safe and useful products and services.
  2. We will strictly manage confidential information belonging to our customers that we have access to in the course of our work, and we will only use such information for legitimate purposes.
  3. In the course of our business activities, we will present accurate information concerning our products and services, and we will not make any statements that might potentially be misunderstood by our customers.
Disclosure of Company Information

[Code of Conduct]

2
Recognizing our social responsibility as a listed corporation, we will disclose the company information necessary to increasing our management transparency in an appropriate and timely manner, improving our level of communication with our stakeholders and earning their trust.

[Action Guidelines]

  1. We will disclose company information, including information concerning our business activities and our financial status, to our stakeholders in a timely and appropriate manner.
  2. We will prioritize communication with our stakeholders in order to live up to the trust placed in us by society.
  3. We will not engage in insider trading or any form of buying or selling of shares, etc. that may arouse suspicions of insider trading.
Fair Market Competition and Trading

[Code of Conduct]

3
In seeking to win contracts, we will observe the rules of fair market competition, and in issuing contracts we will build fair, equal and transparent business relationships with all of our business partners,* and we will conduct honest transactions, in accordance with the stipulations of the related laws and regulations and the relevant contracts.
*Business partners: Subcontractors and companies from which we purchase materials, etc.

[Action Guidelines]

  1. We will pursue profits by means of free and fair competition, observing the stipulations of the Anti-Monopoly Act and other relevant laws and regulations.
  2. We will not make decisions based on discussion of prospective recipients of contracts or the method of selection of prospective recipients of contracts with companies involved in the contract bidding process, and we will not exchange information concerning the granting of contracts.
  3. We will always adopt a fair and unbiased viewpoint in our dealings with business partners, and we will conduct honest transactions in accordance with the stipulations of the related laws and regulations and the relevant contracts.
  4. We will not exploit our position as the contracting party in order to coerce our business partners to engage in any improper actions.
  5. In negotiating the offering of contracts, etc., we will not pursue individual profit.
  6. We will not accept any entertainment, gifts, or other economic benefits from our business partners that exceed the bounds of ordinary social etiquette.
Respect for Human Rights

[Code of Conduct]

4
In all of our business activities, we will respect the human rights of every individual with whom we have dealings, and we will eliminate discrimination and any actions that impair the dignity of the individual.

[Action Guidelines]

  1. We will ensure that every individual is able to work safely and healthily at all of our worksites, including construction sites.
  2. We will not discriminate or perform any action that impairs the dignity of the individual on the basis of sex, age, place of birth, nationality, race, ethnicity, creed, religion, physical characteristics, disabilities, etc.
  3. We will not benefit from child labor or forced labor in our business activities.
  4. In the course of our business activities, we will consider our impact on human rights, and we will deal with any potential human rights violations.
  5. We will eliminate sexual harassment and power harassment from the workplace, and we will prevent any deterioration in the working environment.
  6. We will respect the privacy, individuality, and diversity of each person, and we will work to harmonize work and life.
Management of Company Finances

[Code of Conduct]

5
We will work to manage and protect company rights and assets, both tangible and intangible, and will not use these for inappropriate purposes such as personal use; in addition, we will respect the rights and assets of others.

[Action Guidelines]

  1. We will manage company assets appropriately and in accordance with the rules, and we will not use them for other than business purposes.
  2. We will secure and preserve company rights and assets, including intellectual property rights, and we will also respect the rights and assets of others and avoid violating those rights.
  3. We will manage information appropriately, based on our information system guideline.
  4. In addition to protecting information provided by customers, we will treat all personal information that we receive appropriately and manage it safely.
  5. We will strictly manage company confidential information; during their period of employment our employees will ensure that there are no leaks or disclosures of information, and will continue to do so after having left employment without observing fixed procedures. The same holds true for the confidential information of others.
Protection of the Global Environment

[Code of Conduct]

6
We will make active efforts for the protection of regional environments and the global environment.

[Action Guidelines]

  1. In our design of facilities, etc., we will contribute to the realization of a low-carbon society by actively proposing means of conserving resources and energy.
  2. In our respective workplaces, we will strive to prevent pollution and environmental contamination, and we will work to promote conservation of resources and energy, reduction of industrial waste, and recycling.
  3. In our business activities, we will always consider our impact on the environment, and we will respect environment-related laws and regulations and actively work towards the resolution of environmental problems.
Prevention of Association with Anti-social Elements

[Code of Conduct]

7
We will resolutely reject advances from anti-social elements that threaten the order and safety of civil society, and we will have no association with such elements.

[Action Guidelines]

  1. If we receive improper requests or demands from anti-social elements or groups that represent a threat to the order and safety of civil society, we will not yield to these demands, but will resolutely reject them. In addition, we will not conduct any transaction with anti-social elements or groups, or individuals associated with such elements or groups, for any reason whatsoever, and will break off any contact with such elements or groups.
Respect for Social Rules

[Code of Conduct]

8
Maintaining a constant awareness that we are members of society, we will follow social rules and actively contribute to society, working to win the trust of the community.

[Action Guidelines]

  1. In the performance of our work duties, we will observe the stipulations of the Construction Business Act and other relevant laws and regulations, our Code of Conduct and Action Guidelines, and our company regulations, and we will follow social rules, maintaining a constant awareness that we are members of society.
  2. When we stand to gain from such activities, we will not offer any favors such as entertainment or gifts to public officials or any equivalent person (including foreign public officials), and even when we do not stand to gain we will not offer entertainment, gifts, etc. to such persons that exceed the bounds of ordinary social intercourse. We will not provide any economic benefits such as entertainment or gifts that exceed the bounds of ordinary social common sense to the executives or employees of our customers. In addition, when the company rules of our customers prohibit the provision of entertainment, we will follow those rules.
  3. We will not perform any actions that damage the good name or prestige of our company.
  4. We will work to contribute to society as a good corporate citizen and member of society, seeking to contribute to the development of local communities.
  5. When we engage in business activities overseas, we will respect international norms of behaviour, while adhering to the principle of respect for the rule of law.
  6. We will make our business partners aware of this Code of Conduct and these Action Guidelines, and we will request their observance of them.
  7. All personnel in managerial positions will actively practice the precepts of this Code of Conduct and these Action Guidelines, and will provide instructions and engage in supervision to ensure that the personnel under their management also observe them.
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