Business Conduct Guidelines

3. Maintain Fair and Honest Transactions

(1) We shall observe both the letter and spirit of all applicable laws and regulations including antitrust laws.

• We shall comply with all laws and regulations to ensure the continued trust of our consumers, customers and society, and we shall improve our corporate reputation and brand image through fair competition. We shall recognize the purpose of the laws and regulations in the operation of our business and understand that antitrust and other related laws have been enacted to prevent the restraint of competition in the market. In particular, we shall note that free competition is not guaranteed unless everyone abides by these laws. Therefore, we shall not engage in any unfair action that limits free competition.
• We shall not engage in price agreements or cartels with other parties, resale price maintenance, monopolies, horizontal market divisions, unreasonable or discriminatory dealings or refusal of transactions, tie-in arrangements, reciprocal transactions, or other prohibited transactions that are contrary to applicable law. We shall not engage in anti-competitive dumping, the improper disturbance of competitors' transactions, false labeling or the excessive giving or receiving of free gifts.
• We shall encourage a full understanding of these laws and an appreciation that violations of antitrust or other related laws may result in criminal liability to both the company and any individual involved in such violations.
• These laws are applicable not only to the sale of products but also to other business activities, including the procurement of materials, attainment of licenses for technology and intellectual property, M&A activities, establishment of joint ventures and business alliances, and the activities of industry associations. Given the complexity of these laws, we shall seek advice from the Legal Department and/or from external legal advisors, and we shall not make decisions when we are uncertain about the law.

(2) We shall implement strict internal controls to prevent unlawful or unethical transactions.

• We shall implement lawful and ethical business transactions with other parties and strictly refrain from any conduct or improper interest that may promote misunderstandings or criticism of our company.
• When selecting a supplier, we shall make rational judgments on product quality, service quality and prices. We shall maintain fair and transparent relationships with suppliers with the standard practice being to compare and consider quotations from several suppliers.
• We shall maintain the integrity of all transactions for the procurement of products, raw materials and services by providing fair transactional opportunities to our suppliers, and by conducting regular competitive reviews of purchase terms and conditions. We shall diligently strive to prevent collusive relationships between the company and its suppliers by using two or more persons together, at the same time, to represent the company in negotiations with suppliers. We shall understand and comply with all laws related to procurement.
• In business transactions with other parties, we shall observe designated rules and standards and follow strict internal checking procedures to maintain a transparent decision-making process. When selecting a supplier, we shall not exert or attempt to exert undue influence on any particular supplier regardless of the degree of our relationship with them.

(3) We shall keep the receiving and giving of business gifts and entertainment within bounds that are recognized as acceptable business practice in order to avoid undue influence on business transactions or even the appearance of it.

• We shall comply with internal rules, and we shall follow necessary procedures to obtain prior internal approval and to submit proper reports. We shall take a simple approach; we may accept or provide business entertainment only as an opportunity to exchange information, and we may accept or provide gifts or money only when lawful and in relation to celebrations or condolences as an expression of appreciation or as a courtesy to our suppliers or customers. All gifts or money, given or received, should be of moderate value and suitable for the occasion under which it is given or received and, in order to maintain transparency, should be disclosed to the company in accordance with internal rules.
• We shall not receive or give any unlawful kickbacks in relation to business transactions.

(4) We shall engage in good faith mutual evaluation with our suppliers in order to continue to raise the level of quality of our respective businesses.

• We shall exchange necessary information with suppliers, and mutually evaluate the quality and prices of the materials, services, and each other's businesses.
• We shall take an interest in our suppliers' social responsibilities with respect to human rights, environmental protection and other matters, specify to our suppliers the social responsibilities we expect them to fulfill, and provide support in the fulfillment or monitoring of those responsibilities.