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Daicel Code of Conduct

Introduction

This Code of Conduct gives shape to the Daicel Group Conduct Policy and clearly defines the code for carrying out corporate affairs for everyone working at Daicel. It is not just a matter of having a thorough understanding of the Code of Conduct. Each and every one of us has to actively put this Code into practice in our own everyday activities to create an even more favorable atmosphere within the Company and to create a company that gains society's trust. However, the items stated in the Code of Conduct do not cover all cases. It is important for everyone to carry out their daily activities while giving full consideration to Daicel Group Conduct Policy.

1. We shall not only comply with all laws and regulations but also act with high ethical standards and sound judgment.

1-1 Response with integrity to stakeholders
We shall respond with integrity, respect and gratitude to all people connected to Daicel —customers, shareholders, business partners, employees and local society.
1-2 Compliance with laws and ethics
Rigorously complying with legal rules and regulations, whether local or foreign, we shall act to be constantly trusted and respected by all in society by using sound social judgment in the performance of our duties.
1-3 Maintenance of effective internal systems and training
In order to further ensure that laws and corporate ethics are complied with, we shall constantly review and improve our internal rules and regulations to strengthen effective internal systems and shall thoroughly familiarize the entire organization through training sessions.
1-4 Response to antisocial influences
We, in cooperation with the police, industrial associations and regional entities, shall take a firm stand against anti-social influences and/or organizations that disturb civil order and safety. We shall have no connections with them in any way, either directly or indirectly.
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2. We shall contribute to the development of society as good corporate citizens.

2-1 Social contribution activities
We shall make social contributions from the viewpoint of trying to coexist in mutual prosperity with society through corporate activities, through cultural and sporting events, as well as by assisting in rescue and relief operations in the event of an emergency such as an accident or natural disaster.
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3. We shall offer safe, high-quality products and services that satisfy and gain the trust of our customers.

3-1 Offer of products and services that are of use to society
We shall always listen to the opinions of each of our customers, such as consumers and users, and shall develop and offer products and/or services that are of use to society.
We shall thereby contribute significantly to the realization of a society that is affluent and pleasant to live in.
3-2 Safety and quality assurances of products and services
With respect to the supply of our products and/or services, we shall be aware that safety and quality assurances are a corporate social responsibility. We shall strive for those assurances throughout the entire product life cycle, from product development and manufacture to distribution, sales and use.
3-3 Provision of product quality information
With respect to the supply of our products and/or services, we shall provide easily understandable product quality information, guides to safe usage, etc., as appropriate.
3-4 Response to incidents involving products
In the event of a safety or quality problem arising with a product supplied to a customer, we shall promptly respond with integrity to contain and prevent a recurrence of the problem.
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4. We shall contribute to the development of local communities by complying with international rules and each country's laws and regulations and by respecting local cultures and customs.

4-1 Compliance with international rules and the laws of each country
In conducting our international business affairs, we shall fully look into and comply with international rules and the laws of each country.
4-2 Coexistence with society at national and local levels
We shall respect cultures and customs in order to coexist with the national and local societies in which we operate our businesses.
4-3 Contribution to the development of local society
Companies overseas shall enter into local society and contribute to the development of the locality by means of local procurement and employment to the maximum possible extent.
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5. We shall willingly and justly disclose reliable corporate information.

5-1 Disclosure of corporate information
We shall actively disclose to actors in the financial markets, such as shareholders and investors, information concerning our corporate finances and the status of our business activities in an appropriate, timely and clear manner.
5-2 Fair accounting procedures
We shall accurately and properly record and store information on our corporate trading, asset and expense status by using fair accounting procedures based on legal and generally accepted accounting standards.
5-3 Prohibition of insider trading
We shall not buy or sell securities such as stocks or corporate bonds for the purpose of making personal profit, etc., by using undisclosed important information gained through business activities.
5-4 Communication with society
We shall strive to promote the understanding of our corporate activities by active communication with society.
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6. We shall conduct honest trade in accordance with the basic principles of fair and free competition.

6-1 Compliance with antitrust laws
We shall not act in breach of antitrust laws and shall compete equitably and freely.
6-2 Compliance with laws relating to imports/exports
As an importer and exporter of technology and products, we shall examine and comply with the laws and regulations relating to imports/exports. The export of our technology and products shall in no way be illegally connected to the development and manufacture of weapons, munitions or narcotics.
6-3 Advertisements
We shall advertise on an equitable basis without defaming or denigrating other companies or their products and without using socially discriminatory language.
6-4 Highly transparent political and governmental relationships
We shall not engage in behavior that could be mistaken as corrupt but shall foster highly transparent relationships with government agencies and political bodies, whether in local or overseas activities.
6-5 Procurement transactions
With respect to procurement transactions, we shall comply with the Corporate Procurement Transaction Guidelines, shall conduct business fairly and honestly based on economically rational measures and shall not engage in the pursuit of personal profit.
6-6 Business entertainment, etc.
With respect to entertainment and gifts given to or received from clients, we shall act with a clear distinction between public and private matters within the scope of sound commercial practice and judgment.
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7. We shall work positively to conserve the natural environment and to ensure safety.

7-1 Reduction of environmental impact
We shall address the reduction of environmental impact by such measures as preventing global warming through reduced energy consumption, activities aimed at saving natural resources, managing chemical substances, effective utilization of resources and reducing waste.
7-2 Realization of a sustainable society
With global environmental issues positioned as a major subject of our business activities, we shall strive to realize a sustainable society that can balance environmental protection with economic development.
7-3 Safe working environments
We shall not only comply with the laws in all of our activities, including research and development, manufacturing and distribution, but we shall also conduct our own assessments to promote all measures to ensure safety in our workplaces.
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8. We shall properly manage corporate assets and information.

8-1 Effective use of corporate resources
We shall not use corporate resources such as people, materials, financing, information and time for private purposes, and shall make effective use of them.
8-2 Handling of confidential information
We shall not acquire confidential information about our customers, business partners, etc. by illegal methods. We shall strictly control and shall not disclose or divulge without predetermined procedures any confidential information acquired from companies or third parties in the course of our business activities. We shall not use such information for anything other than the purpose intended.
8-3 Maintenance and protection of intellectual property (IP) rights
We shall strive to maintain and protect our corporate IP rights (covering patents, utility model rights, trademark and design rights) and shall not infringe IP rights held by third parties.
8-4 Control of personal information
We shall strictly control and shall not disclose, divulge or use for anything other than the purpose intended without the prior consent of the person concerned, any information of a personal nature acquired in the course of our business activities.
8-5 Appropriate use of information systems
We shall use in-house corporate information systems only for Company-authorized duties and shall pay particular attention to the prevention of theft or falsification of data. We shall enforce all the necessary information security measures to prevent any information leaks, etc.
8-6 Behavior causing damage to the Company
We shall not gain profit for ourselves or third parties and shall not harm the reputation of a company by using our business position or power or information acquired in the course of our business activities.
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9. We shall respect the diversity, personality and individuality of every member of the Daicel Group and shall maintain a healthy and comfortable work environment that is free from discrimination and harassment.

9-1 Human rights/discrimination, harassment
Our basic position shall be to respect humanity. We shall never violate human rights through such acts as discrimination on the grounds of ethnicity, nationality, creed, religion or gender, or through harassment.
9-2 Lively workplace environment
We shall strive to foster a lively workplace environment by promoting honest and open communication between employees.
9-3 Respect for individual ability
By establishing appropriate, fair methods and a range of human resource training procedures, we shall enable everyone to display his or her abilities to the fullest possible extent and mutually understand and respect all these diverse talents. Particularly overseas, we shall address employee skill development as a way of contributing to the development of local society.
9-4 Healthy workplace environment
We shall strive to create a workplace environment that is physically and mentally healthy by promoting all measures for health control.