SANKI ENGINEERING CO.,LTD

SUSTAINABILITY

Code of Conduct and Action Guidelines

Sanki Engineering Group's Code of Conduct and Action Guidelines

Formulated on December 1, 2002
Revised on May 1, 2012
Revised again on June 2, 2014
Revised again on April 1, 2017
Revised again on April 1, 2022

Contribution to Society Through Business Activities

[Code of Conduct]
1

From the customer’s point of view, we will widely contribute to the development of society by providing safe and useful products and services that obtain customer satisfaction and trust and aim to maintain a balance between the strong management foundation of Sanki Engineering Group and a sustainable society based on our Sustainable Policy.

[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. In addition to financial information, we will disclose corporate information to stakeholders in a timely and appropriate manner, which includes non-financial information such as management strategies, risks, governance, social and environmental issues, etc.
  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【Sanki Engineering Group Human Rights Policy】

[Code of Conduct]
4

We will respect the human rights of all people in all our business activities, including throughout the supply chain, eliminate discrimination and acts that undermine individual dignity, and conduct human rights due diligence (which identifies, prevents, and addresses impacts on human rights).

[Action Guidelines]
  1. We will ensure that all people in all workplaces are able to work safely and in a healthy manner.
  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 eliminate child labor and forced labor.
  4. We will consider the impact on the human rights of local communities and individuals and engage in dialogue with stakeholders regarding the risk of violation of human rights.
  5. We will eliminate harassment (including but not limited to sexual harassment, power harassment, and harassment related to maternity leave and childcare or nursing leave) 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.
  7. We will conduct human rights due diligence.
  8. We will work on education to respect human rights.
  9. We will disclose our human rights activities in a timely and appropriate manner.
  10. We will comply with relevant laws and regulations and respect international codes of conduct, including the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises.

Management of company assets

[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 systems use standards.
  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【Sanki Engineering Group Environmental Policy】

[Code of Conduct]
6

The Sanki Engineering Group strives to conserve the global environment in all our business activities, including the supply chain, with the intention of realizing a decarbonized society, a recycling oriented society, and a society in harmony with nature.

[Action Guidelines]
  1. We will promote energy-saving and the use of renewable energy in all our business with a view toward carbon neutrality.
  2. We will strongly promote the "SANKI YOU Eco Contribution Point" system, whereby we conduct environmental conservation activities according to the amount of CO2 emissions reduction from our facilities and contribute to decarbonization of our clients.
  3. We will aim to realize a recycling oriented society by thoroughly controlling the generation of waste, recycling resources, and proper disposal of waste.
  4. [Action Agenda on Biodiversity] As we recognize that biodiversity is an important foundation for a sustainable society, we aim to realize a society in which nature and humans can coexist in harmony by working toward preserving biodiversity.
  5. We will disclose information on conservation of the global environment in a timely and appropriate manner.
  6. We will continue to consider the impact of our business activities on climate change and biodiversity, prevent environmental pollution, comply with environment-related laws and regulations, and actively promote global environmental conservation activities.

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 requests or 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 Industry 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 both the rules of the area in which we are conducting business and the international code of conduct.
  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.