COMPLIANCE

• All directors, officers, and employees shall comply with all domestic and foreign laws and regulations related to our business and the operations they perform. In addition, all officers and employees shall understand and comply with the Compliance Policy and other rules, standards, criteria, and notices established by Minebea to ensure compliance with such laws and regulations.
• All officers and employees who intend to start a new business shall verify whether or not there are any laws and regulations pertaining to the relevant business, and shall comply with the relevant laws and regulations, if any.
• Directors and employees will ensure that procedures for obtaining, submitting, and renewing licenses and permits related to the business under their control are carried out, and will comply with all regulations based on laws and regulations.

• Directors and employees shall properly manage information in accordance with laws, regulations, and company rules pertaining to information management.

• Directors and employees shall respect the copyrights, patents, trade secrets, and other intellectual property rights of customers and other companies, and shall not use them without permission.
• Directors and employees shall use legitimate means to collect information. We will not use or take information about customers or other companies without obtaining their permission.
• Directors and employees shall comply with any agreements they have entered into to license or acquire copyrights, patent rights, trade secrets, or other intellectual property rights of customers or other companies. They shall not use such information for any purpose other than the prescribed purposes.

• Directors and employees will not engage in antisocial transactions (direct or indirect transactions with groups or individuals who pursue economic benefits through unreasonable demands).

• Directors and employees shall not forge documents related to rights and obligations such as contracts and approved documents, nor shall they misuse their seals.

• Officers and employees will make accurate entries in the accounting books and vouchers, and will not engage in fraudulent transactions such as intentionally manipulating costs to be different from the facts.

• Directors and employees shall not engage in any acts that benefit themselves or third parties or cause damage to the Company.

• Directors and employees shall be aware of the importance of establishing a work environment that emphasizes work performance in order to act responsibly and prevent misconduct when conducting business activities, and shall actively work to improve the quality of the work environment in the departments to which they belong.

• Directors and employees shall not engage in any irrational discrimination based on birth, nationality, race, ethnicity, creed, religion, gender, age, disability, hobbies, or educational background. Furthermore, officers and employees shall not engage in human rights abuses such as violence, abuse, slander, defamation, coercion through intimidation, bullying, or other forms of harassment.

• Officers and employees will not engage in sexual harassment or conduct that could be misconstrued as sexual harassment.

 

If it is found that the counterparty falls under any of the following or has made a false declaration based on the exclusion of antisocial forces, all transactions will be suspended or the contract terminated without any notice to the counterparty. In addition, the Company shall assume no responsibility for any damages resulting from such suspension or termination.

1. in the case of being or having been a member of a crime syndicate, a member of a crime syndicate, a person related to a crime syndicate, a group related to a crime syndicate, a person related to a crime syndicate, or other anti-social force (hereinafter “crime syndicate, etc.”), a group engaged in activities against the public welfare, or an actor thereof.
2. if he/she or a third party has interfered with the business of the other party, or has committed an act that is likely to interfere with the other party’s business.
3. uses violent, fraudulent, or threatening words or deeds against the other party by using himself/herself or a third party.
4. In the event that the Participant, by using himself/herself or a third party, defames or threatens to defame the honor, credit, etc. of the other Party.
5. If the Participant, by using himself/herself or a third party, acts or behaves in a manner that is likely to cause the other party to recognize that he/she or the other party is a Boryokudan or other related person.

May 23, 2016 Enacted.

 

We conduct our business under thorough risk management to ensure that we do not engage in funding conflicts, terrorism, human rights violations, or money laundering. Additionally, we take appropriate measures in compliance with the “Act on Prevention of Transfer of Criminal Proceeds,” the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,” and other relevant domestic laws. We also collaborate with relevant government agencies to implement effective measures.

Regarding the procurement of materials (such as gold, silver, platinum, and palladium) in the precious metals business, we implement the following measures:

 

1．Compliance with the guidelines listed in Annex II of the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”

If we determine that there is a risk of involvement in the following activities within our supply chain, we pledge to suspend the relevant transactions and implement stringent management systems to ensure that we are not directly or indirectly involved in such activities.

• Human rights violations related to the mining, transportation, and trading of minerals
• Direct or indirect support to non-governmental armed groups
• Direct or indirect support to public or private security forces
• Bribery and falsification of mineral origin
• Money laundering
• Non-payment of taxes, fees, and mining royalties to governments

 

2．Identification of high-risk material procurement transactions

We identify high-risk transactions as defined by the “Act on Prevention of Transfer of Criminal Proceeds” and will cease transactions if applicable. Additionally, in accordance with the guidelines of the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,” we will not engage in transactions involving materials that we determine to be sourced from conflict-affected or other high-risk areas. (For details, please refer to our Purchase Terms and Conditions.)

 

3．Evaluation of materials and suppliers.

We regularly evaluate precious metal materials and our supply chain, and if we determine that the procurement of precious metal materials is high-risk, we will cease transactions.

 

4．Implementation of education and training

We provide the necessary education and training to all personnel involved in the procurement and management of precious metal materials.

 

5．Monitoring and recording of transactions

We monitor to ensure that the received precious metal materials (such as gold, silver, platinum, and palladium) are consistent with the information obtained from suppliers, and we properly store and manage these records. Additionally, we monitor and record transactions within the supply chain to ensure they are not directly or indirectly involved in high-risk transactions or any criminal activities such as human rights violations or money laundering.

 

6．Conducting due diligence audits of the supply chain by independent third parties

In accordance with the guidelines of the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,” we regularly conduct audits by independent third parties to verify the effectiveness of our due diligence practices and management systems.

 

7．Establishment of internal reporting and grievance mechanisms

We establish proper procedures for handling consultations or reports regarding organizational or individual violations of laws and company regulations, aiming for the early detection and correction of misconduct. In dealing with complaints, we develop internal reporting regulations to protect the personal information and confidentiality of the consultees and whistleblowers, and create an appropriate environment to ensure they do not suffer any disadvantages from their consultations or reports.

 

Revised on July 1, 2024.