Corporate Philosophy

Corporate Philosophy

  1. 1Customer First

    We are committed to supplying our customers with products of superior quality and features in response to their needs while continuing to strive for more competitive costs and improved customer services.

  2. 2Development of New Technology

    We focus on manufacturing excellence with a competitive edge in the global market while pursuing more advanced technology.

  3. 3Maximizing Human Capital

    We are committed to creating a pleasant and vigorous work environment, embracing a diverse workforce with various talents to achieve their full potential.

  4. 4Challenge for the Future

    We welcome any challenge with passion and creativity to respond confidently to ever-changing world markets.

  5. 5Contribution to Society

    Our management that is based on compliance contributes on progress of society through the business activities with environmental consideration.

Mitsubishi Steel Group Code of Conduct

The purpose of the "Mitsubishi Steel Group Code of Conduct " is to ensure that the company is in line with expectations of society while retaining its flexibility to accommodate demands from a rapidly changing business environment to pursue sustainable global endeavors. All executives and employees of the group's companies share the responsibility to abide by the Code of Conduct.

Business Activities

  1. 1Supply high quality and functional products along with excellent services consistently to satisfy customer needs to play a part in the progress of society.
  2. 2Focus on developing unique and advanced technology by mobilizing various areas of expertise developed within the organization to strive for profit and improved corporate value through efficient operation.
  3. 3Cultivate a corporate culture that encourages people to take on a challenge without fear of failure for continuous growth.
  4. 4Dedicate ourselves to improvement of society through business conduct, tapping into the opinions of all stakeholders.

Compliance

  1. 5Comply with the laws and regulations or code of ethics in society for transparent, fair, and equitable transactions under free competition.
  2. 6Never be involved with destructive forces that pose a threat to peace and safety of civic society.

Disclosure

  1. 7Disclose corporate information in a timely and appropriate manner to ensure transparency while protecting privileged information pertaining to employees and customers.

Respect for employees

  1. 8Respect human rights, character, and the individuality of employees along with diversity in the workforce, and never discriminate on the basis of difference in characteristics.
  2. 9Galvanize the company by fostering human resources as well as ensuring a safe and pleasant work environment.

Environmental conservation

  1. 10Get actively involved in protecting the environment in all aspects of business activities with a heightened awareness that conservation of the global environment is one of the most crucial challenges facing mankind.

Globalization

  1. 11Respect local culture and customs as well as comply with all international rules and local laws and regulations when conducting global business.

Detailed Rules for Mitsubishi Steel Group Code of Conduct

These Rulesare based on Our Corporate Philosophy and the MSM Group Code of Conduct and are guidelines forhow we shouldconduct ourselves in order to maintain the reputation of the MSM Group as a corporate group of the highest integrity and ethical standards. In these Rules, "MSM Group" refers to Mitsubishi Steel Mfg. Co., Ltd. and all its consolidated group companies.

All MSM Group executives and employeesmust act in accordance with these Rules as described below.Note that all references herein to "executives and employees" include reference to temporary employees, etc.

Business Activities

  1. 1Human Rights and the Workplace Environment

    The MSM Group respectshuman rights, personality and diversity,and does not engage in discrimination. We respect employees,and secure a safe and comfortable working environment, while also aimingto maintain and improve our corporate vitality.

    1. 1Respect all human rightsand donot engage in any form of harassment. Donot discriminate on the basis of race, color, creed, religion, gender, national origin, age, sexual orientation or disability.
    2. 2Do not forcibly compel anyone to work or make anyone work against theirwill, and do not employ anyone who is under the legal workingage.
    3. 3Do not distribute or post documents or engage in speeches, etc. on MSM Group property without permission.
    4. 4Possessionor use of illegal drugsis not permitted. Do not consumealcohol at the office without the permission of the MSM Group. Do not enter the workplace or engagein company businesswhile under the influence of alcohol.
  2. 2Safety and Health

    Ensuring safety is the responsibility of all executives and employees of MSM Groupand we are all responsible for compliance withhealth and safety standards in the workplace.

    1. 1Aim to achieve zero injuries with the commitment of all executives and employees working together. Comply with workplace health and safety guidelinesand procedures, work in safe way that doesnot put ourselves in danger. These rules, guidelines and procedures shall be constantly reviewed and improved according to the work environment.
    2. 2Guide and support associate companies and other related parties so that they too will follow the rules, standards and proceduresrelating to workplace healthand safety.
  3. 3Fair Competition

    In order to avoid impeding fair and sound market competition, we do not engage in conduct that contravenesthe competition laws of Japan or those of any other country.

    1. 1Do not make agreements, whether express or implicit, with competitors about price, cost information, orcontractual conditions. Donot exchange information regarding these matters.Also, do not discuss other confidential information with competitors.
    2. 2Do not engage in any unfair trade practices prohibited by the antitrust law,such as resale price maintenanceor abuse of superior bargaining position, nor any conduct that may give rise to suspicion or appearance of such arrangements.
  4. 4MaterialsProcurement

    When conducting materialsprocurement, we provide fair and equal opportunityto all suppliers.

    1. 1When selecting suppliers, do so sincerely and in good faith, based on comprehensive and fair evaluation of quality, cost, technology, delivery date, etc.
    2. 2When conducting materialsprocurementactivities, properly manage and protect the confidential information, intellectual property and other assets, etc.of the supplier.
  5. 5International Trade

    In conducting global business activities, we do so not only in compliance with international rules and local laws, but also with respect for local cultures and customs.

    1. 1For import and export transactions, carry out the appropriate proceduresin accordance with the rules, regulations, internal rules and policies concerning international trade and import and export.
      In addition, confirm that the product does not fall under the category of products and technologies which can be diverted to military use or that areimport-prohibited items.
    2. 2Comply with the regulations relating to customstaxes and clearance, and properly carry out the local customsprocedures.
    3. 3Do not participate in any actions that constitute restraint of fair and sound competition and trade,such as agreements forunfair prices, orrestrictions on supply volumes or on trade, etc.
  6. 6Anti-Corruption and Elimination of Relationships withAnti-social Forces

    International rules against corruption and bribery are rapidly being strengthened. MSM Group does not tolerate bribery inany form. Also, we willnever have relations withany anti-social forces, which pose a threat to the order and safetyof civil society.

    1. 1Do not engage in bribery, provision or receipt of illegal economic benefits, or other corrupt activity,of any kind, for any purpose, whether directly or indirectly, and irrespective of whether such activity pertains to government officials or to private persons.
    2. 2Do not have contact with any anti-social forces. To avoid such contact, conduct investigation, either directly or via third-party bodies, prior to entering into transactions with counterparties in order to verify their qualifications, reputation and integrity.
    3. 3Maintain accurate recordsof all payments tothird parties, and ensure that all fees and expenses, etc.paid to thirdparties constitute appropriate and justifiable remuneration for legitimate services.
    4. 4Do not provide any gift, entertainment, cash,or any other economic benefitto counterparties' executives, management, employees, or other related persons, in excess of accepted business and social norms.
    5. 5All executives, employees and their families must not accept any gifts, entertainment, cash, or any other economic benefit, in excess of accepted business and social norms, from any organization, company, or person, etc.who has a business relation with MSM Group. In addition, if such persons receive any economic benefitfrom a company or organization rendering services to MSM Group, according to the rules of each company,if such rules exist, they shall obtain the relevant manager's approval in advance.
    6. 6Do not have any involvement in terrorism, drug dealing, or money laundering, or other individual or organized crimes. .For all transactions, conduct due investigation into the counterparties and obtain expert opinions, etc., and pay sufficiently close attention so as to ensure that we do not, even inadvertently, become involved in criminal activities.
  7. 7Insider Trading

    We do not engage in improper or illegal trading in shares, etc. using shall internal information of the MSM Group or our counterparties.

    If, directly or indirectly, you become aware of a "material fact" relating to the MSM Group or any of our counterpartiesthat would have a significant effect on an investment decision, do not purchase or sell shares of the MSM Group or our counterparty until said fact is publicly announced.

  8. 8Products and Services

    We provide products and services appropriate to satisfy customer needs in accordance with laws and regulations, and the relevant instructionsand agreements with customers.

    We pay close attention to product quality and guaranteesof safety at all stages of the manufacturing process, from the purchase of materialsto final inspection.

  9. 9Environmental Conservation

    We are conscious of environmental conservation as one of our utmost important tasks, and we positively endeavorto protect the environment in all our business activities, and contribute to the development of a sustainable society.

    1. 1Comply with treaties and legal regulations concerning the environment,and give full consideration to environmental matters in conducting our business.
    2. 2Make effortsto use resources and energy efficiently, minimize waste to the extent possible, and reuse, efficiently-use,andrecycle.
  10. 10Conflicts of Interest

    All business activities should be conducted in the best interests of the MSM Group,and not in the personal interest of anyexecutive or employee. Avoid situations in which the interests of the individual and MSM Group conflict with each other.

    1. 1Do not, without authorization from theMSM Group, engage in activities,such as side business,for the purpose of personal profit contrary to the interestsof the MSM Group.
    2. 2In the event that you have a personal interest directly or indirectly in a planned transaction or project of MSM Group, you shall immediately declare this to your manager.
  11. 11Protection of Assets

    All MSM Group assets are used only for valid business purposes, in accordance with MSM Group guidelines and procedures and in the best interestsof the MSM Group.For all assets, we put in place the necessary safeguards to prevent loss.

    1. 1Do not use tangible or intangible assets for one's own benefit.
    2. 2All executives and employees shall return all assets of the MSM Group at the expiry or termination of their employment contract or retirement. This includesnot only materials and equipment, but also files and documents used while at work.
  12. 12Intellectual Property

    We protect the intellectual property and confidential information owned by the MSM Group andinformation shared with other companies, and respect the intellectual property rights of third parties.

    1. 1To conduct business activities smoothly, comply with the applicable intellectual property rulesandour use of the intellectual propertyof third partiesshall be via the proper and correct procedures.
    2. 2Executives and employees who make new discoveries, inventions, improvement of technology, manufacturing processes, etc. from research, development, other operations are to immediately report to the department in charge of intellectual property.
      In addition, all executives and employees shall comply with employmentregulations,and cooperate to facilitate the smooth transfer of rightsto the MSM Group.
    3. 3Do not use software licenses acquired illegally that infringe the intellectual property rights of third parties, such as via unauthorized copying of computer software. Before using software, make sure that it has not been obtained illegally.
  13. 13Information Security

    It is necessary to thoroughly protect and manage various types of information as prescribed by the fundamental policy, etc.on information security of the MSM Group.

    1. 1Technical secrets and trade secrets means secret information that is sufficiently valuable and is actually or potentially superior to that of others. Take precautionary measures to prevent unauthorized access, loss, destruction, and leakage of suchinformation, and take appropriate management measures to ensure business continuation (including recovery if possible).
    2. 2When disclosing technical secrets and trade secrets to third parties, confirm that a nondisclosure agreement has been entered into with the third party, and do not disclose such information for improper purposes.
    3. 3We are responsible for protecting research and development plans,ideas and design drawings, specifications, manufacturing methods and product plans, financial data, prices, computer programs, andany other confidential information,such as files, e-mails and photographs. Do not appropriate or use any these materials, etc. after retirement.
    4. 4Appropriately manage the information that is to be internally managed in the company, counterpartyinformation, personal information, etc. and do not use such information for illegalor improperpurposes.
  14. 14Financial Integrity

    We ensure that accounting and financial information is timely and accurately recorded and reported, and shall not falsify records or use creative accounting.

    1. 1Submit and approve expensestimely and accurately.
    2. 2Store all necessary documents safely and securely in order to maintain our compliance with internal and legal requirements.
    3. 3All accounting processesshould follow the accounting principles adopted by the relevant MSM Group company.
    4. 4Do not falsify records or use creative accounting.
    5. 5Avoid exaggeration, guesswork, and derogatory expressions in business records and other documents, and not mislead those who receive such information.
  15. 15Reporting Violations

    Report all violations(including cases in which there is a likelihoodof violation) of theseRules,whether these relate to oneself, or to other employees or executives, immediately to one'smanager, compliance manager or the whistle-blowing helpline.

    1. 1Each of MSM Group companies shallinvestigate violations to confirm the facts of relevant violations and take the proper preventive measures. All information related the report of violations of theseRulesmust be treated as confidential to the extent necessary to carry out the investigation.
    2. 2We do not subject whistleblowersto disadvantage due to the reporting of a violation of theseRules. If,as a whistleblower,you believe that you have been disadvantaged, please report thisfact to the representative of the relevant MSM Group company,your manager, the compliance manager or the whistle-blowing helpline.
  16. 16Sanctions

    Violation of these Rulesmay result in disciplinary action. Moreover, we recognize that acts that violate the laws and regulations, etc.of Japan or other countries may result in criminal prosecution.

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