Maruho Hatsujyo Kogyo Compliance Code of Conduct

As a member of the Maruho Group, Maruho Hatsujyo Kogyo Co., Ltd. has established the Code of Compliance Standards, which directors and employees observe in their own actions and in their corporate activities.

Basic attitude

1. In conducting our business activities, we will comply with various business-related laws and regulations, including the Civil Code, the Companies Act, and the Antimonopoly Act, as well as with high ethical standards and decency, and each and every one of us will be aware of our mission and act accordingly.
2. We will be aware that we will bear the ultimate responsibility for outsourcing operations to group companies or subcontractors in various processes, such as research and development, manufacture, sales, and provision of products and services, and will respond with a sense of unity with group companies and subcontractors.
3. We will strive to grow together with individuals and the company by constantly working to improve productivity and further increase the added value of work per person.

Relationships with Stakeholders

1. We aim to be a company that develops together with society by strengthening corporate governance and establishing an internal control system that is a system for ensuring compliance with laws and regulations and the appropriateness of business operations.
2. We will strive to provide products and services that meet the needs of our customers and business partners with respect, in a spirit of integrity and fairness.
3. We will strive to contribute to the development of society by harmonizing our business activities with local residents and local communities and by earning mutual trust with our stakeholders.

Whistle-blowing

1. In the event of any violation or suspicion of any relevant domestic or overseas laws and regulations, industry voluntary codes, or company regulations, we will promptly make inquiries, consult with the superior of the department to which we belong, submit a report, or report to the help line.
2. We will respond appropriately to inquiries, reports, and internal reports concerning violations or suspicions of relevant domestic and overseas laws and regulations, industry voluntary codes, and internal regulations.
   In addition, the company will not unjustly search for anyone who has made a report, etc., nor treat such information disadvantageously for the reason that the person who has made the report, etc. cooperated with the investigation.
3. We will respond in good faith to inquiries and reports from retirees, business partners, and employees in accordance with laws and regulations regarding internal reports or whistle-blowing.

Research and Development

1. In order to contribute to the sustainable and prosperous lives of people, we analyze the business environment of society, the economy, industry, and other sectors, and actively engage in research and development of new products and services and production technologies that meet the needs of society.
2. When we conduct research and development, we will follow all relevant laws, regulations, and internal rules. We will collect and use accurate data to assess quality scientifically. If our group companies or partners conduct research and development, we will oversee and manage their work to ensure they also follow these guidelines and use accurate data.

Manufacturing, Export and Import

1. We are aware of the impact of our products on society. In manufacturing, we will comply with all relevant laws and regulations and in-house regulations in all processes, including those at group companies and subcontractors, and respect the spirit of ISO9001 and ISO13485, and ensure adequate quality in light of the product standards and quality standards stipulated in basic business contracts and quality assurance agreements with customers, and manage delivery times.　
2. In the event that a customer has any doubts about the quality of a product, we will promptly respond to such doubts after due consultation with the customer.
   In addition, we will strive to investigate the cause of the accident by scientific analysis in order to prevent a recurrence.
3. We place top priority on ensuring the safety of products that are essential to building a safe and secure society. We will make products with due consideration for the riskiness and hazards arising from our products.
4. We will ensure the proper and legal distribution, export, and import of products, raw materials, facilities, equipment, software, and more.

Marketing

We strengthen our marketing activities, including digital marketing using our website, in order to provide products and services that meet the true needs of our customers. In sales, marketing, and information provision activities, we will conduct fair sales activities in accordance with relevant laws, regulations, and corporate ethics.

Manufacture of medical-related products

1. In manufacturing medical-related products, we are aware of the fact that they are life-related products. We will conduct sufficient quality assurance activities in compliance with the Products and Medical Devices Law and other relevant laws and regulations throughout the entire manufacturing process, including the manufacturing process at Group companies and cooperating companies. We will also respond in good faith to the inspections of the authorities.
2. In the event of any doubt about the efficacy, safety, or quality of our products, we place the highest priority on the prevention of life-threatening hazards. We will take immediate measures such as recalls, and endeavor to investigate the causes of such problems in order to prevent recurrence.
3. We will promptly report to the authorities and investigate the cause of any direct danger to the body that may have been caused by our products in accordance with the relevant laws and internal regulations, such as the GVP, etc.
4. We will establish a system to quickly obtain information on direct hazards to the body related to our products that occur both domestically and internationally, and strive to prevent the damage caused by these.

Information activities for medical-related products

1. We will comply with the Pharmaceuticals and Medical Devices Law, the Regulations Governing Fair Competition in the Medical Devices Industry, and in-house regulations in our information activities with respect to medical institutions, etc. We will comply with corporate ethics and conduct fair and transparent information activities without disparaging or abusing other businesses or their products.
2. We will acquire the medical knowledge necessary for information activities and will provide appropriate information and collect information on our products in order to restore and improve the health of patients in accordance with the provisions of the Products and Medical Devices Law and other relevant laws and regulations.
3. When creating and using advertising media, we will comply with the Pharmaceuticals and Medical Devices Law and other relevant laws and regulations, as well as internal regulations, and make sure that the content and expression are not false or exaggerated.

Post-sales safety measures and investigations of medical-related products

1. We will comply with all relevant laws and regulations as well as in-house regulations, collect and examine information on the proper use of our products, and implement safety assurance measures and other safety measures.
2. We conduct post-sales safety management activities and post-sales surveillance in compliance with all ministerial ordinances and internal procedures to establish proper use of medical devices post-sales.
3. We will conduct investigations and tests in compliance with relevant laws, regulations, and company regulations for the collection and preparation of reexamination and reevaluation materials.

Prohibition of Offering to Public Officials, etc.

1. We will not provide, offer, or promise to provide illegal benefits (money, goods, entertainment, benefits, etc.) to public officials, deemed public officials, persons designated by the Special Law, and foreign public officials designated by the Unfair Competition Prevention Law, etc., by ourselves or through agents or contractors, etc. We will also resolutely reject requests for these services.
2. When requesting a public officer, deemed public officer, or a person designated by the Special Law to perform the services of a consultant, advisor, etc., we shall take care not to violate ethical laws and regulations, such as the National Public Service Ethics Code, or the ethical standards of the organization to which the requesting party belongs, and shall conclude an agreement in writing or in electronic writing without fail.

Donations to medical and academic institutions

When making donations to medical or academic institutions, we confirm that the donations are not illegal and make them pure donations.

Relations with Politics and Administration

1. We will strive to create sound and fair and transparent relationships with politics and government (including public facilities, public research institutes, and public medical institutions), and will not engage in any act or illegal donation that is suspected of being in contact with or being in contact with others.
2. We will respond in good faith to inspections and investigations by administrative organs.

Fair Transactions

1. We will conduct fair and lawful corporate activities in our relationships with customers, competitors, suppliers, business partners, etc., in accordance with the Antimonopoly Act, the Fair Competition Rules for Medical Devices Business, the Subcontract Act, and other domestic rules, as well as the legal systems of the countries and regions in which we operate.
2. We shall maintain fair and sound relationships with our suppliers, business partners, etc., and shall not use our position or authority to receive, demand, or promise illegal or unjust benefits (money, goods, entertainment, benefits, etc.).

Prohibition of Conflicts with Personal Interests

We will not engage in any conduct that is contrary to the interests of the Company and will not engage in any business that is in the interests of individuals at the expense of the Company.

Compliance with Labor Laws and Efforts for Safety and Health

1. We comply with the Labor Standards Law and other employment-related laws and regulations. We respect the human rights of all employees and do not discriminate in any way.
2. We comply with the Industrial Safety and Health Law and other labor-related laws and regulations. In addition, the Company will strive to prevent occupational accidents and maintain the mental and physical health of its employees by creating a comfortable and appropriate work environment that gives full consideration to safety and health.
3. We understand the purpose of the Health Promotion Law and provide support for activities aimed at actively promoting health, such as exercising, and to create an environment that encourages employees to take annual paid holidays in order to promote their health. In addition, we will promote the creation of an environment in which employees can work easily, such as thoroughly implementing measures to prevent passive smoking in workplaces and other areas, and reducing workloads through temperature control and noise control.
4. We comply with the labor contract and sincerely fulfill each of our obligations. We will comply with the Company Rules and Regulations, and act in accordance with good faith, both public and private.

Prohibition of unreasonable discrimination and harassment

1. We will never discriminate against or otherwise discriminate against or harass anyone on the basis of race, nationality, ethnicity, gender, age, religion, philosophy/belief, sexual orientation/self-recognition, academic background, disability, illness, social status, etc., inside or outside the Company, respecting the personality of all individuals.
2. We will not engage in sexual harassment, power harassment, or other forms of harassment in order to respect the personality of employees and create a pleasant working environment. In addition, as a company, we will prevent and eliminate harassment and will never tolerate it.
3. In the event of any harassment, we will respond promptly and appropriately and take immediate measures to prevent a recurrence.

Fair Implementation of Human Resources

1. We will strive to provide employees with opportunities to demonstrate their abilities and realize themselves. We will conduct fair evaluations in accordance with predefined evaluation standards, and promote transparent and acceptable personnel evaluations.
2. We will not treat ourselves or our officers or employees with any special advantage in recruitment, evaluation, transfer, promotion, salary increase, etc., because of personal relationships with them.

Enhancement of Training and Education

We conduct ongoing training and education on compliance. We also provide employees with fair opportunities for training and education in order to develop professional human resources.

Support for the Development of the Next Generation

1. We will strive to create and expand systems for flexible working styles that enable employees to balance work and life. At the same time, we will strive to create a rewarding work environment in which employees can maximize their abilities and experience.
2. We will strengthen our childcare and family-care leave programs to encourage employees, including men, to take childcare leave. At the same time, we will actively work to prevent leaving work for family care and work to realize a flexible working environment.

Compliance with the Road Traffic Law

We are deeply aware of the preciousness of life and the tragedy of traffic accidents, as well as the dangers of driving under the influence of alcohol and using mobile phones, dangerous driving, including uncontrollable driving, and obstructive driving. To realize a society free of traffic accidents, we will strive to ensure safe driving and comply with the Road Traffic Law in our workplaces, homes, and communities.

Prohibition of False Contracting

We do not engage in actions that treat dispatched employees as contractors (disguised contracting, disguised secondment).

Prohibition of provision of company funds and assets for illegal purposes and personal use

We will use the Company's funds, goods and other assets only for the performance of assigned duties and will not use them for illegal purposes such as illegal entertainment or bribery or for the benefit of ourselves or any third party.

In addition, employees shall not use their job positions or authority to fraudulently charge expenses or embezzle money and goods.

Handling of Intellectual Property

1. We recognize that the results (including inventions, devices, ideas, patents, utility model rights, trademark rights, design rights, copyrights, know-how, technical information, etc.) generated by our research, development, and other duties are our important property (intellectual property) and will always use them effectively for the performance of our duties.
2. We will respect the intellectual property rights of others and will not obtain the results or confidential information of others by fraudulent means. In addition, even if the information is rightfully obtained, it will not be improperly used without the prior consent of the other party in question.
3. We comply with the regulations on employee inventions (employee inventions regulations) and promote research and development activities.

Handling of Information Assets

1. We recognize the importance of information assets held by the Company and appropriately manage information from the viewpoint of confidentiality, integrity, and availability of information in accordance with relevant laws and internal regulations. In the event the Information Asset is Confidential Information, we will not disclose the Information Asset to outsiders without proper procedures and will not improperly use it for the benefit of ourselves and third parties even while in office or after retirement.
2. We will not illegally acquire, use, or disclose the confidential information of any third party, whether directly or indirectly.
3. We will file confidential information disclosed by others under the Confidentiality Agreement separately from our own information and strictly manage it in the same manner as our own confidential information.
4. We do not use the Company's personal computers or other information systems for any purpose other than business activities. In addition, do not install software, etc., that is not permitted by business on the company's personal computer or other information systems, or connect to networks outside the company without obtaining permission.
5. We will comply with information security regulations and telecommuting operation guidelines for remote work and telecommuting.

Management of Personal Information

1. We are deeply aware of the importance of protecting personal information and privacy, and we will rightfully and properly acquire and handle personal information, and will not disclose such information to any person outside the Company without the approval of such person. In addition, the Company shall not disclose such information to anyone other than those required for business purposes.
2. We will establish and operate an appropriate personal information management system to prevent the loss, leakage, and unauthorized access of personal information held by the Company.

Agreement and Document Control

1. When concluding agreements (including memorandums, agreements, confirmation letters, and other electronic documents) with customers, suppliers, and allied companies, we will conduct fair and appropriate discussions and negotiations in compliance with relevant laws and regulations after due consultation with relevant departments. In addition, the seal of the corporate seal shall be affixed to the contract after proper procedures have been completed.
2. We properly create, handle, store, and preserve all business documents, printed materials, and other records (including electronic documents), including contracts, drawings, minutes, correspondence, and vouchers.
   When disposing of these materials, we will reconfirm the terms of the contract, comply with the relevant laws and regulations, and follow the proper procedures.

Compliance with accounting laws and tax laws

1. We accurately record and prepare our transactions in our corporate accounting as books and accounting records in accordance with accounting principles and practices that are recognized as fair and appropriate. We will also comply with the Corporate Law, Foreign Exchange Law, Corporate Accounting Principles, and other accounting-related laws and regulations.
2. We will always be aware of and comply with domestic and overseas tax laws in our business activities.

Appropriate Use of Social Media

We will always be aware of responsible words and deeds, recognizing that the dissemination of information through social media may be an evaluation of the Company and may cause inconvenience to the Company and/or third parties. In addition, we will not make any words or actions that would harm the reputation or credibility of people inside or outside the Company.

Compliance with Human Rights, Treaties, and Overseas Laws and Regulations

1. In our international business activities, we understand each other's diverse values, personalities, and respect human rights such as race, nationality, ethnicity, and gender. In addition, we will comply with international rules such as conventions and local laws and regulations, and respect local cultures and customs.
2. We ask our domestic and overseas group companies to comply with international rules such as conventions and relevant local laws and regulations as well as respect local culture and customs when conducting international business activities.

Environmental Preservation

1. We fully understand that addressing environmental issues is a common issue for all mankind and is an essential requirement for the existence and activities of a company. To achieve a sustainable society, we comply with environment-related laws and regulations, and conduct our business activities with constant consideration for the impact on the global environment and local communities. In addition, we will place importance on environmental impacts such as climate-change, ozone-depletion, and acid rain. We will actively engage in environmental conservation in compliance with RoHS directives, REACH regulations, the Fire Defense Law, etc.
2. We will promote the creation of environmentally conscious products in all our business activities, including energy conservation, resource conservation, reduction of industrial waste, and recycling activities. Each plant establishes its own environmental objectives and targets based on ISO14001 and promotes a company-wide environmental management system.

Disaster Countermeasures

1. We place top priority on safety and strive to prevent accidents and fires. We will also strive to build a system for business continuity in preparation for natural disasters, fires, and other emergencies.
2. We actively participate in local disaster prevention organizations. In addition, the Company will support local disaster prevention activities through its own fire fighting organizations.

Response to Anti-Social Forces and Organizations

We will resolutely fight against any malicious claim, extortion, or harassment by any anti-social force or organization that threatens the order and safety of civil society, such as gangster organization, etc., and will strive to eliminate any and all relationships, including normal business relations.