Kyosan Electric Manufacturing Co., Ltd. and its affiliates (“Kyosan Group”) are striving for the realization of fair business activities with sincerity and high ethical standards in the course of our business expansion.
Kyosan Group has established the “Basic Policy for the Prevention of Bribery of Public Officers” as below to promote sound corporate activities eliminating unlawful or corrupt practices involving public officers, which would be in addition to the “Kyosan Corporate Code of Conduct / Action Guideline” and the “Standards for Business Activities” setting forth action guidelines for fair corporate activities:

1. Kyosan Group will comply with the Penal Code of Japan, the Unfair Competition Prevention Act of Japan, the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act and all other anti-bribery related laws and regulations of each country, and will not be carried away by the immediate profit in front of us.
　 　
2. Kyosan Group and all of our officers and employees will strictly refrain from performing any unlawful acts such as making attempts to acquire or maintain business or receiving a special favor, by providing, or offering or promising to provide money, etc. to public officers or through any other act of bribery aimed at public officers, nor should we respond to any of such requests.
　
3. Only to the extent appropriate and considered reasonable under social norms and subject to compliance with our strict internal procedures will Kyosan Group entertain, give gifts to, make donations to or provide financial support to any third party.
　
4. Kyosan Group will not make any payment which may be used for exercising any unlawful or illegal influence, to any of the distributors, agents, etc. we use in our business.
　 　
5. Kyosan Group will properly record all transactions in accordance with accounting rules, etc.
　 　
6. Kyosan Group will not appreciate any conduct of gaining any profit through use of bribery, etc. Rather, we will strictly punish such conduct as an unlawful act.
　 　
7. Kyosan Group will treat in the same manner so-called “commercial bribes” between private corporations, which are subject to bribery regulations in certain countries.

April 1, 2022