Business Conduct Guidelines

10. Draw a Distinct Line between Business and Private Matters

We shall always establish a clear line between business and private matters to prevent conflicts of interest. Personal profit or advantage shall not be pursued through the use of company assets or information, or through work-related authority and position.

(1) We shall not engage in insider trading.

• We shall not utilize internal confidential information about the company, suppliers, or customers in pursuit of personal profit. We shall understand that the buying or selling of shares of stock and other securities of the company, suppliers, or customers on the stock exchange by using material non-public information is illegal as insider trading, in which we shall not participate. In addition to being a serious crime, insider trading is antisocial conduct that betrays the trust of investors, and it is strictly prohibited.
• Until the company makes an official public announcement concerning internal confidential information, we shall treat such information carefully and not disclose it to any third parties other than representatives or advisers of the company, unless required in the course of business activities. Information about M&A activities, business alliances, new product launches, technological development, major variations in sales and income, and other material confidential information is regarded as insider confidential information until an official public announcement is made by the company.
• If we obtain confidential insider information about the company, affiliates, suppliers, or customers through our duties, we shall not trade their securities until such confidential information has been publicly announced. If we intend to trade securities of the company, affiliates, suppliers, and customers, we shall confirm whether we have material insider information about the relevant party beforehand.

(2) Political activities shall only be performed on a personal basis.

• We may support political campaigns or related activities only as private individuals, outside working hours, and not on company premises.

(3) Involvement in ideological and religious activities shall be allowed only on a personal basis.

• Although each individual's freedom of ideology and religion shall be respected, we shall devote ourselves to our duties during working hours. We shall not engage in missionary work during working hours, and we shall not seek in the workplace to persuade other employees to join ideological or religious activities and shall maintain a proper workplace atmosphere. However, an individual's religious behavior will not be denied in the company's facilities unless such behavior affects the individual's job performance or other employees. In some countries, the company or its affiliates follow the local common practice of locating religious facilities on company premises for employees, and provide financial support for religious events. In each case, the company respects the local customs and culture, but does not support, encourage or force particular religions on its employees.

(4) We shall strive to avoid conflicts of interest.

• Employees' personal lives basically belong to themselves. However, we shall understand that conflicts of interest may occur when any conduct in an employee's personal life goes against the company's interest and benefits his or her own personal interest. Therefore, we shall strive to avoid such acts and conflicts of interest as much as possible.
• We shall recognize that conflicts of interest are caused by the following conduct: 1) involvement in activities that compete with the company's business without the company's authorization, 2) becoming a supplier or commercial customer of the company, 3) obtaining personal benefits and privileges in the course of one's duties, and 4) engaging in personal activities such as side jobs, volunteer activities, political activities or religious activities, during working hours. When engaging in any of the above activities, employees shall obtain the company's permission, report to the company or take other appropriate actions as necessary.