The Oji Group Behavior Standard.

I. Toward the materialization of the spirit of the Oji Group Corporate Code of Conduct, the Oji Group Behavior Standard is adopted as a standard to be followed in the daily activities of all management and employees.

II. All management and employees should recognize to be responsible for following this Behavior Standard and must not act against this standard.

Relationship with Society(See also paragraphs 13 and 15.)
1. Compliance with Relevant Business Laws

We will comply with business laws related to our business activities, and appropriately perform the legally stipulated procedures for licensing, notification, reporting, etc.

2. Environmental Conservation
In addition to complying with the laws and regulations related to the environment, we will implement the “The Oji Group Environmental Charter.”

3. Ensuring Safety
At all stages of our business activities, we will always consider safety to be the top priority, and reliably ensure the safety of our products and services, appropriately control chemical agents, and manage the security and disaster prevention of our operating facilities and equipments. When a problem is discovered, we will respond to it with ensuring safety as the top priority.

4. Sensible Action
We will always use good sense in our actions, always being aware of our relationship with society. We will strive to participate as good members of society in activities designed to contribute to make a better society.

5. Wholesome Relationship with Politics and Government
We will always maintain a proper and wholesome transparent relationship with politics and government. We will not engage in illegal contributions, donations or bribery.

6. Severance of Relationships with Antisocial Groups and Organizations
We will resolutely refuse all relationships with antisocial groups and organizations.

7. Coexistence with the International Community
In addition to complying with the laws of each country, we will respect the norms, culture, and customs of that society, and contribute to the development of the local community. We will never engage in the utilization of child labor or forced labor.

Relationship with Customers, Business Partners, and Competitors(See also paragraphs 3, 4, and 15.)

8. Seeking a Relationship of Trust with Customers
We will do our best for the customer and protect the bond of trust with the customer through honest interaction. We will appropriately manage information related to the customer, including corporate secrets and personal information.

9. Maintenance of an Honest, Wholesome Relationship with Business Partners
Along with honest interaction, we will maintain moderate, wholesome relationships with our business partners and local communities. We will limit gifts and business entertainment to a sensible level, whether they are given or received.

10. Compliance with Laws and Regulations Related to the Anti-monopoly Act and the Act Against Delay in Payment of Subcontract Proceeds Etc., to Subcontractors
We will comply with the Anti-monopoly Act and other related laws and regulations, and will engage in fair trade without committing illegal actions such as participating in cartels or collusion, etc. We will comply with the Act Against Delay in Payment of Subcontract Proceeds, Etc., to Subcontractors and other related laws and regulations, and will maintain appropriate trade relations with subcontractors.

11. Prohibition of Unfair Competition
We will comply with the Unfair Competition Prevention Act and other related laws and regulations, and will not make unauthorized use of the corporate secrets of other companies or engage in sales activities which would damage the trust of others. We will respect the patents, copyrights, and other intellectual property of third parties.

12. Compliance with laws and regulations related to importing and exporting
We will comply with laws and regulations and international treaties related to trade, as well as company rules related to the procurement of raw materials, and conduct appropriate import and export transactions.

Relationship with shareholders and investors

13. Disclosure of Management Information
Along with striving for transparency in our management, we will disclose our management policy, business activities, and other corporate information related to economic, social, and environmental issues, in a timely and appropriate manner.

14. Prohibition of Insider Trading
We will not engage in insider trading using unreleased company information, or actions which would evoke such suspicion.

Relationship with Employees(See also paragraphs 1 and 3.)

15. Respect of Human Rights
We will respect the fundamental human rights of all people, and will not unfairly discriminate or harass individuals according to their philosophy and beliefs, nationality, birthplace, religion, race, sex, disability, social status, status within the company, etc., and will not invade their privacy. We will not allow others to do so.

16. Ensuring Safety and Health in the Workplace
With “safety as the top priority,” we will ensure safety and health in the workplace and engage in safe behavior, and ensure the safety and health of all parties involved in our business. We will be fully mindful of mental and physical health control.

17. Fulfillment of Duties and Self-development
We will fully understand the spirit of the Corporate Code of Conduct and comply with its standards, diligently work to fulfill our individual duties, and always pursue better performance. We will strive for self-development to gain knowledge and to improve skills.

Relationship with the Company

18. Compliance with Company Rules
We will comply with employment regulations and other regulations related to human resources. In the execution of duties, we will comply not only with relevant laws and regulations and articles of incorporation, but with, regulations, working manuals, and other company rules.

19. Management of Company Secrets
In addition to the company’s customer information, confidential information regarding sales, manufacturing, research and development, and others are important assets of the company. We will manage such information appropriately and will not provide it to third parties or use it for non-work purposes without authorization. We will respect the confidential information disclosed by third parties and handle it in the same manner as the company’s confidential information.

20. Appropriate Records and Accounting
We will correctly record the company’s transactions and activities, and appropriately manage and store the records in accordance with relevant laws and regulations and company rules. We will conduct accounting in accordance with generally accepted accounting standards.

21. Appropriate Use of Computer Systems
We will use company computer systems appropriately, in accordance with company rules. We will not destroy, tamper with, or alter data, make unauthorized use of software, or engage in other such misconduct.

22. Maintenance of Company Assets
We will keep necessary records of company assets (equipment, intellectual property, supplies, money, etc.), regardless of whether they are tangible or intangible, and use and manage them appropriately. We will not utilize such company assets for personal use.

23. Prohibition of Conflicts of Interest
We will not engage in behavior which would adversely affect the profit of the company, using our duty-related position or authority, or based on knowledge we have acquired in the course of the execution of duties. We will not engage in or be involved in activities which have a possibility of adversely affecting the profit of the company, without the authorization of the company.

24. Prohibition of Political and Religious Activities in the Workplace
We will not conduct personal activities in the workplace to solicit participation in political or religious organizations, request voting in elections, etc., without the authorization of the company.

Proactive communication

25. Open Working Environment
We will always do our best to achieve and maintain a working environment which makes it possible to openly discuss work and workplace issues. We will not keep to ourselves problems that cannot be resolved in the workplace, but we will consult with supervisors and relevant departments and strive toward a resolution.