Shindengen Group Guideline for Action

Staying true to its management philosophy of “together with society, together with our customers, and together with our employees,” Shindengen Electric Manufacturing Co., Ltd. has made it a corporate mission to maximize energy conversion efficiency for the benefit of humanity and society.
Based on our management philosophy and corporate mission, we, all officers and employees* of Shindengen Electric Manufacturing Co., Ltd. and Shindengen group companies, act in compliance with the following Guidelines for Action in order to further contribute to society:

*the term “employees” as used in this guideline refers to any persons who are employed by the company, including associate officers, corporate advisors, full-time employees, non- full time employees, contract employees, part-time workers and temporarily transferred employees.

1. Compliance with legislation and other regulations

1) Compliance with legislation and regulations

We act to honestly comply with relevant legislation and company regulations and rules, etc.

2)Fair competition and transactions

We conduct business transactions through fair, just, and free competition.
Above all, in our daily business activities, we observe the Japanese Antimonopoly Act and Subcontract Act, as well as the U.S.
Antitrust Act, EU Competition Act, and antimonopoly laws of other countries, while also strictly complying with the following items of our company group:

①We do not exchange the following information with other companies in the same business: information on product prices, production amounts, manufacturing capabilities, selection of customers, and other conditions of competition. Nor do we make arrangements regarding such matters (for example, price fixing, market allocation, bid rigging, and order adjustments).

②We do not participate in meetings of organizations and companies in the same business where we may be requested to exchange such information or make such arrangements. We act in accordance with established company rules, etc. when having contact with our competitors.

③We do not commit acts that may hinder fair competition toward distributors and dealers, including restricting resale prices and abusing privileged position.

④We act honestly toward all our business partners and carry out fair and appropriate transactions.

3) Preventing conflicts of interests

We do not act against the interest of our company to promote our own or third parties’ interests.

4) Prohibiting bribery and excessive entertainment and gifts

①We comply with the rules of different countries that prohibit giving bribes to government officials of Japan and other countries. In addition, we also comply with the rules of different countries that prohibit bribery between private companies and between individuals.
We do not offer, propose, or promise to give bribes (money, goods, entertainment, gifts, or other interests) not only to government officials of Japan or other countries but also to private citizens for the purpose of gaining or maintaining preferential treatment in business. We do not allow those who act on our behalf, including dealers and consultants, to be involved in such acts.

②We do not provide or receive economic benefits exceeding the range of sound business customs and social conventions, including gifts and meals, when entertaining or being entertained by customers or exchanging gifts with them. Nor do we receive personal economic benefits from them.

5) Preventing confidential information disclosure

We keep confidential information under strict control and never disclose it to other parties.

6)Prohibiting insider trading

We do not conduct insider trading or stock trading that may be suspected of being insider trading.

2.Respect of Human Rights

We always respect human rights in any of our corporate activities and do not condone or tolerate any behavior including sexual harassment, power harassment, discrimination and/or harm to personal dignity.

3. A healthy workplace environment

1)A safe workplace environment

We create a workplace environment that provides safety and job satisfaction to employees.

2) Attention to health

We pay attention to healthy lifestyles, including eating healthy meals, getting enough sleep, taking sufficient rest, and living fulfilling lives every day.

4. Our relationship with society

1) Customer satisfaction

We provide products and services that meet customers’ needs, bring them satisfaction, and gain their trust.

2)Contribution to society

We proactively contribute to society as members of local communities.

3) Environmental protection

We strive to develop, produce, and sell products that contribute to protecting the global environment.

4)Attitude toward anti-social groups

We stand firm in our resolve to fight against anti-social groups and organizations that threaten public order and safety and have no relationship with such groups.

In the event of a violation of these Guidelines for Action, business executives themselves work to resolve problems, to identify their causes, and to prevent recurrence. We also publicly disclose information promptly and appropriately both inside and outside the company.

Revised on April 22,2019

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