TOYO's Code of Conduct

Comply with laws and regulations of the countries of business operation and with internal corporate rules, with the highest standards of honesty, integrity and fairness.

1)	We realize and comply with applicable laws, regulations and the highest ethical standards in performing our global business to achieve our customer’s satisfaction and our own continued growth.
2)	We observe internal corporate rules and maintain good communication with supervisors and co-workers to achieve corporate success.
3)	We uphold the highest ethical standards to enhance the social trust which is essential to achieve our business goals.

Respect humanity of the people in the world, free from discrimination and harassment.

1)	We realize and respect the history, culture and customs of each country in which we operate.
2)	We respect human rights and refrain from discrimination by race, religion, creed, gender, social status, nationality, age, disability, etc.
3)	We maintain a work environment that is free from discrimination and harassment. Great care is taken not to cause recourse to legal proceedings as a consequence of discrimination, harassment, abuse of power, etc.

Comply with international arrangements governing global business operations.

1)	We realize and comply with international agreements pertinent to our global operations including, inter alia, export and import regulations and tax laws.
2)	We recognize the differences in business practices and legal structures in each country in which we operate and conduct our business with the highest standards of integrity and ethics.

Comply with international treaties and laws and regulations for environmental conservation and protection, and place the highest priority on health, safety, security and environment.

1)	We recognize that environmental conservation is given high priority in the 21st Century. We endeavor to minimize the environmental impact from our global engineering business and aim to harmonize industrial and economic development with environmental conservation.
2)	We shall endeavor to develop technologies and products that contribute to environmental conservation.
3)	We are committed to the standards of quality, health, safety and security that are essential for Toyo-Japan to be recognized as a socially reliable company.

Respect intellectual properties, patented or otherwise, of customers, partners and others and protect those of Toyo-Japan.

1)	We recognize the value of confidential and proprietary information of Toyo-Japan. We protect such information in accordance with our Information Security Policy.
2)	We shall not divulge confidential information of Toyo-Japan to any third parties. We shall not use confidential and proprietary information for personal interests or any purposes against the interests of Toyo-Japan.
3)	We treat the intellectual property as well as confidential and proprietary information of our customers, partners and others with the greatest care in accordance with applicable laws and regulations.

Do not commit unfair business transactions such as insider trading of stocks, in compliance with laws and regulations of the countries of business operation.

1)	In the event we obtain confidential information relating to Toyo-Japan, our customers or partners, both domestic and abroad, we shall not trade stocks/shares/securities of the entity to which the confidential information relates, (insider trading) until such information becomes the public domain.

Keep accurate, complete and timely financial and accounting records, in compliance with laws and regulations of the countries of business operation.

1)	We keep accurate, complete and timely financial accounting records. Fraudulent or misleading records are strictly prohibited.
2)	We disclose our corporate information on a timely basis in accordance with applicable laws and regulations to protect investors.

Do not stand against the overall interests of Toyo-Japan, and with the highest standards of ethics draw a line between public and private.

1)	We do not act against the interest of Toyo-Japan for the purpose of pursuing personal or any third party's interests.
2)	We place the highest priority to the continued growth of Toyo-Japan and to our contribution to the societies. We shall not put private interests ahead of the interests of Toyo-Japan.

Comply with laws and regulations of countries of business operation in dealing with customers, partners and stakeholders, and observe the highest standards of ethics in conducting business anywhere in the world.

1)	We observe the highest ethical standards and the applicable laws and regulations that prohibit offering benefits, including, inter alia, money, gifts, meals and entertainment to any government officials or any other persons who have similar capacities.
2)	We observe the highest ethical standards and shall not offer excessive benefits including, inter alia, money, gifts, meals and entertainment to our customers, partners and stakeholders that are beyond ethical business practice.
3)	We shall not accept any benefits from our customers, partners and stakeholders that are beyond ethical business practice or may impair the interests of Toyo-Japan.

10.

Oppose resolutely any antisocial influences and do not submit to their demands.

1)	We resolutely oppose any unlawful or unethical practices, for example corporate racketeering, and shall not make unlawful or unethical settlements, financial or otherwise, as a consequence of such practices.

11.

Report immediately and in good faith to General Affairs and Corporate Secretary Division General Manager of any known or suspected violation of this Code of Conduct.

1)	All the Personnel have a duty to report, immediately and in good faith, any known or suspected violation of this Code of Conduct to the General Affairs and Corporate Secretary Division General Manager (Unit Director of Corporate Planning and Administration Unit). In this case, the personnel may report to the external contact point that is TEC’s Advisory Law Office, if access to the in-house contact point is not possible. Prior to reporting, all the Personnel may consult with supervisors, related division general managers (General Affairs and Corporate Secretary Division General Manager, Human Capital Development Division General Manager or Auditing Department General Manager) or Auditors. In this case, the personnel may consult with the external contact point that is TEC’s Advisory Law Office, if access to any in-house contact point is not possible.
2)	We are responsible for cooperating in the fact-finding investigation related to the reported violation.
3)	In the event that a serious violation is proven, the offender and his or her supervisor may be subject to disciplinary action.
4)	It is the responsibility of the management of Toyo-Japan to ensure that no retaliation of any kind shall be taken against those Personnel who reported a violation or cooperated, in good faith, with the fact-finding investigation.

Note:	Each operation, unit and division shall consult with the General Affairs and Corporate Secretary Division General Manager prior to making decisions whenever there are any uncertainty or doubts with regard to compliance with applicable laws to avoid any violation as a consequence of discretionary misjudgments.