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ALS Co., Ltd. is building the power to lead with cutting-edge technology.

Ethical Management

Chapter 1: General Provisions

Article 1 (Purpose)

The Regulations expresses the commitment of ALS Co., Ltd. (hereinafter referred to as “Company”) to practice ethical management. The purpose is to practice ethical management by establishing the Principles for Ethical Decision-making and Behavior and ensuring that they are strictly followed so that members can properly understand and practice the Code of Ethics.

Article 2 (Scope of Application]

The Regulations applies to all employees, suppliers, and employees of suppliers who reside and work within the Company.
However, if there are matters separately stipulated in the collective agreement and employment rules, such provisions shall prevail.

Article 3 (Organization)

  • 1 To apply the Regulations, the Company establishes the ‘Ethics Committee’.
  • 2 The ‘Personnel Committee’ Regulations applies with necessary changes to the composition, appointment of members, and operating procedures of the Ethics Committee.
  • 3 Violations occurring in relation to the Regulations must be handled basically in accordance with the Personnel Committee Regulations, but matters not specified in the Regulations may be determined separately.

Article 4 (Principles for Ethical Decision-making and Behavior)

  • 1 Members shall reject any unethical behavior in their daily lives and while performing their duties.
  • 2 If a member finds himself or herself in an ethical conflict situation related to the performance of his or her duties, he or she must make judgments and act based on the ethical standards and practice guidelines. However, if the judgment criteria are not clearly defined in the practice guidelines, they must judge and act in accordance with the following decision-making principles. If they are unsure of their own judgment, they must act according to the advice of the organization’s team leader or ethics management department (hereinafter referred to as “Ethics Department”).
    • 1. Does it violate the Company’s code of ethics or guidelines?
    • 2. Is it legal?
    • 3. Will it reflect negatively on you and the Company?
    • 4. Who else will be affected by it (others in the Company, customers, etc.)?
    • 5. What impression will people have if this is published in the newspaper?
    • 6. Will you be embarrassed when others find out about the action you have taken?
    • 7. Are there alternatives to avoid ethical conflict?
    • 8. What would a reasonable person think?
    • 9. Does it seem right?
    • 10. Do you feel any discomfort or hesitation?

Chapter 2 Members’ Attitude

Article 5 (Faithful Performance of Work)

Members must clearly recognize their authority and responsibilities and perform their duties in accordance with the principle of good faith.

Article 6 (Resolution of Conflicts of Interest)

  • 1 Members must do their best to avoid situations where there is a conflict of interest with the Company in relation to the performance of their duties.
    If a situation arises where there is a conflict of interest with the Company, they must give priority to the interests of the Company and act accordingly.
  • 2 Conflicts of interest to be aware of are as follows. However, this does not list all cases of conflict of interest, so strict judgment and application by members is required in actual situations.
    • 1. Use the Company’s assets or management information for personal gain for personal gain.
    • 2. Abuse your position at work to exert unfair influence on a supplier, etc., such as making personnel requests and demanding various conveniences.
    • 3. Side job activities that require a level of effort that interferes with diligent performance of work, etc.

Article 7 (Protection and Appropriate Use of Company Assets and Information)

Members must protect and properly use the Company’s tangible and intangible assets.

  • 1 They must not use the Company’s assets for personal gain or transfer or lend them to a third party without permission.
  • 2 They must not use the Company’s budget for personal purposes, but must spend it in accordance with the purposes set by the Company and record it accurately in the accounting books.
  • 3 They should not excessively use PCs, the Internet, e-mail, telephones and faxes for personal purposes.
  • 4 They must actively protect the Company’s intellectual property rights, such as patents, goodwill, trademarks, copyrights, and other valuable information.
    In addition, they must equally protect the intellectual property rights of third parties and, in particular, must not use illegal software
  • 5 They must strictly manage the Company’s information assets, including business information and technical information, in accordance with information management regulations. The disclosure and scope of information assets are determined in accordance with relevant laws, company regulations, and company policies, and this also applies to interviews with external media.

Article 8 (Receiving Gifts, Entertainment, etc.)

  • 1 Members must demonstrate fairness and transparency in performing all management activities.
    Therefore, money, valuables, entertainment, etc. must not be provided to stakeholders for the purpose of receiving unfair and unfair benefits.
  • 2 Members must not receive money, entertainment, or other personal conveniences from business partners such as suppliers with a superior interest.
    However, in order to maintain a healthy relationship with each other, they may exchange gifts or entertainment at a reasonable level within the scope recognized by social norms, and detailed guidelines for this may be established and operated at the organizational level.

Article 9 (Mutual Respect among Members)

  • 1 Members must respect each other and maintain basic etiquette necessary for work life and dignity as members of the Company.
  • 2 They should not discriminate against any other member on the grounds of gender, education, region of origin, marriage, religion, etc.
  • 3 They must not engage in any acts of sexual harassment that may violate personal human rights and disrupt the working atmosphere.

Chapter 3 Compliance with Laws and Company Management Policies

Article 10 [Compliance]

Members must clearly understand the laws and company policies and regulations related to the Company’s management activities and perform their duties in accordance with them.

Article 11 (Protection of Customer Information)

Members who handle customer information must safely protect customer information by establishing protection procedures and guidelines in accordance with relevant laws, company policies, and company regulations.

Article 12 (Mutual Respect between Members)

  • 1 Members must accurately record and maintain accounting information in accordance with generally accepted accounting principles, related laws, and company regulations, and must not distort or hide accounting information.
  • 2 All of the Company’s management information, including financial information, must accurately reflect related facts or transaction details to support the senior management’s decision-making.
  • 3 Transparency and fairness must be demonstrated in disclosure of management information to external stakeholders in accordance with relevant laws and company regulations.

Article 13 (Fair Trade and Competition]]

  • 1 Fair trade-related laws and regulations must be clearly understood and complied with.
  • 2 Matters that may be interpreted as violations of fair trade laws must be handled after sufficient consultation with the responsible department in advance, and decisions must not be made based on arbitrary interpretation.

Chapter 4 Operation of Practice Guidelines

Article 14 (Responsibilities)

  • 1 All members are responsible for complying with the Code of Ethics and the Practice Guidelines, and for any questions they may have, they must inquire or consult with the organization’s leader or Ethics Department and act according to their interpretation.
  • 2 The leader of an organization is responsible for actively supporting and managing its members and business-related stakeholders to properly understand and comply with the Company’s Code of Ethics and Practice Guidelines. In addition, they must set an example for others by complying with the Code of Ethic and the Practice Guidelines through sincere and responsible decision-making and action.

Article 15 (Reporting of Violations and Protection of Informants]

  • 1 Members who become aware of violations of the Code of Ethics and the Practice Guidelines must actively protect the Company and its members from such acts by reporting them to the organization’s leader or Ethics Department so that they can be resolved as soon as possible.
  • 2 Members will not suffer any disadvantages for legitimate reporting.

Article 16 (Handling of Violators]

  • 1 If a violation of the Regulations is discovered, the Ethics Department shall report this fact to the Ethics Committee by preparing related documents and investigation details in writing.
  • 2 The Ethics Committee reviews violations and decides whether to handle them in accordance with the Personnel Committee Guidelines.
  • 3 Appropriate measures, such as suspension of business relationship, will be taken against the involved suppliers, taking into account the seriousness of the case, and compensation will be taken for thecompany’s losses.
  • 4 For employees of suppliers, we request appropriate measures fromthe relevantcompany and compensate the company or the supplier for any losses.

Article 17 (Disciplinary Action for Violation of Ethical Standards)

  • 1 Disciplinary action for violations of the Code of Ethics shall basically be handled in accordance with the Personnel Committee Regulations, but matters for which there are no applicable or specific Personnel Committee Regulations provisions shall be handled in accordance with these guidelines.
  • 2 The main disciplinary targets and details are as follows.
    • 1. Subject to disciplinary action
      - Acceptance of money or valuables from suppliers, requests for money or valuables using employees, requests for favors using position, exerting pressure, etc.
      - Acceptance of money or valuables from company members, requests for money or valuables using employees, requests for favors using positions exerting pressure, etc.
    • 2. Details of disciplinary action
      - Receiving money or valuables from suppliers: Failure to report, disciplinary action against the employee, suspension of business with the supplier
      - Requesting money or valuables from an employee: Disciplinary action against the employee concerned
      - Requesting or exerting pressure using position: Decision on disciplinary action after deliberation by the Personnel Committee

Chapter 5 Composition and Operation of the Ethics Committee

Article 18 (Composition of the Ethics Committee)

The composition and appointment of the Ethics Committee shall be the same as of the ‘Personnel Committee’.

Article 19 (Holding Ethics Committee)

  • 1 If an ethics-related violation occurs, the relevant department must prepare relevant supporting materials and specific facts in writing and immediately notify the Ethics Department.
  • 2 The Ethics Department reviews the notified matters and decides whether to convene the Ethics Committee.

Article 20 [Ethics Committee Operation]

Ethics-related disciplinary action shall basically be decided through deliberation by the Ethics Committee.

Article 21 [Follow-up Management]

In relation to the Code of Ethics, regular audits are conducted once a year, and disciplinary action is taken for matters found.