Compliance

Corporate Code of Conduct

Corporate Code of Conduct

This Standard stipulates fundamental items to be observed in executing daily business, based on the recognition that it is indispensable for healthy development of the company to have everyone-including directors, auditors, operating officers, senior advisers, employees and those contracted employees (hereinafter referred to as "we" including temporary staff)-be deeply aware of the social responsibilities of Toyo Seikan, thoroughly observe the corporate ethics, relevant laws and company regulations, and "always take the right action" in all business activities.

Fundamental Attitudes in the Corporate Code of Conduct

The following five items represent our fundamental attitude in the Corporate Code of Conduct to "always take the correct action". We will execute our daily businesses, and set up the action policy and specific targets for the "Corporate Code of Conduct" based on this attitude.

1.	We will always maintain awareness as full-fledged members of society and act with the highest of ethics and good social sense.
2.	We will always comply, not only with the relevant laws and company regulations, but with contracts and promises made to the stakeholders, and endeavor to make all business activities conform to regular commercial practices and company ethics.
3.	We will promote open communication and respect each person's fundamental human rights and personality in all aspects of our business activities.
4.	We will be sincere to all stakeholders, conduct fair transactions, and maintain fair, just and transparent relationships.
5.	We will never act counter to the fair interest of Toyo Seikan or impair the trust and honor of Toyo Seikan.

Obligation and responsibility to comply with in the Corporate Code of Conduct

We bear the following obligations and responsibilities

1.	We are responsible for complying with the provisions in the Corporate Code of Conduct, and executing them with sincerity. Directors and managers, in particular, are responsible for taking the initiative in leading the way.
2.	Directors and managers must instruct and supervise all employees in their responsible divisions, and all employees under their respective management structure must comply with this Corporate Code of Conduct.
3.	All our divisions have established a “Compliance Guideline” action manual based on the Corporate Code of Conduct that includes relevant laws, company regulations and a business manual that assures execution of company activities in accordance with the Corporate Code of Conduct. The divisions make its members thoroughly become aware of the Corporate Code of Conduct, and review its content periodically.

Items of the Corporate Code of Conduct

The Corporate Code of Conduct lists the following eight items