Code of Conduct

1.

Naturally, we will act in full compliance with all applicable laws and regulations of each country and region as well as with company rules. We will also act in accordance with societal norms fostering higher ethical standards. To that end, we will seek to foster corporate culture to "express, encourage others to express and listen to" own/their opinions and questions, so that we can immediately share information and issues.

2.

In carrying out all aspects of our corporate activities, we will keep in mind our goal of contributing to the improvement of life for people around the world.

1.

We will seek to deliver products and services that satisfy customers, always acting in consideration of the points of view of our customers generally.We will seek to deliver products and services that satisfy customers, always acting in consideration of the points of view of our customers generally.

2.

We will seek to put first priority on delivery of safe products to customers, and will seek to realize products and services which are safe and can be used with ease and comfort.

1.

We will seek to comply with the antitrust and fair-competition laws and regulations of all countries and regions in which we operate, striving to ensure fair and free competition.

2.

We will seek to select business partners in fair and nondiscriminatory ways and engage in honest and fair transactions.

3.

We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, customers or their representatives.

4.

In case of donations and political contributions, we will first consider the necessity and appropriateness carefully, and then we will make only appropriate donations and political contributions in accordance with applicable laws and regulations and company rules.

5.

To participate in activities of maintaining international peace and security, we will comply with the laws and regulations governing export controls for each country and region in which we operate.

6.

We will conduct advertisement and publicity activities under industry ethical guidelines relying on facts.

7.

We will manage the company’s tangible and intangible assets appropriately, refraining from unintended uses which conflict with proper business activities.

8.

We will record and report financial and accounting-related information in an appropriate and correct manner. To avoid actions that may lead to any inaccurate records, we will comply with company rules and other relevant laws or regulations relating to our own duties.

9.

We will refrain from any actions intended to result in personal gain or to the gain of third parties which are inconsistent with the rightful gains of the OKI Group.

10.

We will resolutely confront antisocial groups and criminal organizations that pose a threat to the order and security of civil society and all contact with such entities is strictly forbidden.

1.

We will seek to promote good communications with our stakeholders to help build mutual trust.

2.

We will seek to ensure the accuracy of the OKI Group company information and to communicate such information in a timely and appropriate manner.

3.

We will neither buy nor sell stock or other securities based on insider information, or information not publicly released from the OKI Group or other companies, nor provide any such information to other parties.

1.

We will diligently protect the rights for intellectual property created in the course of business activities and seek active use of such property. We will seek to respect the intellectual property rights of others and seek to avoid deliberate infringement of such rights.

2.

We will manage, in an appropriate manner, confidential information belonging to our company, our customers or business partners, or other parties.

3.

We will handle personal information in appropriate ways, taking actions to safeguard such information.

4.

Recognizing the importance of information security, we will seek to prevent incidents such as information leaks.

1.

In all aspects of our business activities, we will always seek to respect basic human rights, and discourage any language that discriminates against anyone or fails to acknowledge the personal dignity of any individual.

2.

We will not allow child labor nor forced labor.

1.

Respecting laws, regulations, and company rules concerning occupational safety and health, we will endeavor to maintain a safe and clean working environment.

2.

Respecting the diversity of employees, we will endeavor to realize a comfortable working environment for all employees.

1.

We will seek to create a working environment in which employees respect each other's individuality and are encouraged to express their own opinions, and to be creative and successfully take on challenges they may face.

2.

We will seek to improve our abilities as needed for carrying out our business activities.

1.

We will seek to provide environmentally-conscious products and services in all business processes, from product planning through manufacture, maintenance, and operations.

2.

In our business activities, we will seek to conserve resources and energy while reducing waste.

3.

We will work on the conservation and sustainable use of biodiversity.

4.

We will seek to comply with the environmental laws and regulations of each country and region in which we operate, as well as requirements agreed upon with customers and other requirements, and strive to prevent pollution.

1.

Recognizing the importance of social contribution activities, we will seek to respect the mind of persons who take initiative roles voluntarily to contribute the society.

1.

We will seek to understand and respect the cultures, customs, and other aspects of the countries and regions in which we operate.

2.

Recognizing that the OKI Group is a member of the local community, we will seek to build and maintain long-lasting relationships of trust in the communities in which our business facilities are located.

1.

Each executive of the OKI group will take the initiative showing compliance behaviors with this Code of Conduct and fully inform employees for the thorough implementation through education etc. If any incidents that contravene this Code of Conduct occur, we will immediately investigate causes and implement measures for preventing a recurrence as well as clarifying where responsibilities lie.

2.

An employee becoming aware of any actions that contravene or could contravene this Code of Conduct shall immediately report his/her supervisor or respective window to whistle blowing in his/her company. Each company of the OKI group will not impose any unfair treatment on an employee who makes a report to the window in accordance with the whistle-blowing regulations.

3.

An employee who is involved in any actions that contravene this Code of Conduct could be subject to a punishment for the action with reference to relevant laws or regulations or the Work Rules.

1.

The Board of Directors of Oki Electric Industry Co., Ltd. shall make decisions regarding the establishment, amendment, and abolition of this Code of Conduct.

2.

As determined by resolution of the board of directors of each company of the OKI Group, this Code of Conduct shall apply to all executives and employees.

3.

When necessary in light of the laws, regulations, and practices of the countries in which it operates or of the nature of its businesses, each company of the OKI Group may modify the content of this Code of Conduct by resolution of its board of directors as long as such modification does not conflict with this Code of Conduct.

4.

CSR Division of Oki Electric Industry Co., Ltd. shall be responsible for maintaining this Code of Conduct.