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The TBM Code of Conduct (hereinafter referred to as "this Code") sets forth the rules that all directors, executive officers, and employees (hereinafter referred to as "we") must adhere to in their daily business activities.
We will act with high ethical standards and good judgment in accordance with these guidelines.
Furthermore, if we notice any behavior that violates or is suspected of violating these standards, we will not ignore it but will promptly report and consult with our supervisor or the relevant department. TBM will not allow anyone who reports or consults to suffer any disadvantage.

Application

The Code applies to all board directors, executive officers, and employees of TBM Co., Ltd. and its subsidiaries. The subsidiaries shall establish their own code of conduct by adopting or revising The Code at their decision-making body, ensuring that their board directors, executive officers, and employees fully understand the provisions of the code of conduct.
Each subsidiary may enact their own code of conduct, incorporating the contents of The Code. Such code of conduct may vary in accordance with legal systems and social customs by country or region, or business characteristics, or may include provisions that do not exist in The Code. Under no circumstances, however, may they contradict the provisions of or weaken the effectiveness of The Code.
When a subsidiary establishes their own code of conduct, it shall expressly stipulate that the code of conduct has been developed based on or with reference to the “TBM Code of Conduct.”

1. Compliance with Laws and Respect for International Norms

We comply with the laws applicable in the countries or regions where we operate and respect international norms^*.

*International norms refer to expectations of socially responsible organizations to behave in accordance with customary international law, generally accepted principles of international law, or universally or nearly universally recognized intergovernmental agreements (including treaties and agreements).
For example, the United Nations' "Guiding Principles on Business and Human Rights" and the "Sustainable Development Goals (SDGs)," the Organisation for Economic Co-operation and Development (OECD)'s "Guidance on the Conduct of Multinational Enterprises," and the International Labour Organization's (ILO) "Declaration on Multinational Enterprises" are examples of international norms.

2. Respect for Human Rights

We respect human rights as defined in the "International Bill of Human Rights" and the  "Declaration on Fundamental Principles and Rights at Work" by the International Labour Organization (ILO).

1. Respect for Diversity and Prohibition of Discrimination

   We respect the "differences" among each other, such as gender, gender identity, sexual orientation, age, family status, origin, disability, illness, language, nationality, ethnicity, and religion, and do not engage in any discrimination.

2. Prohibition of Harassment

   We do not engage in acts that harm others, such as sexual harassment, power harassment, and moral harassment.

3. Prohibition of Forced Labor and Child Labor

   We do not tolerate forced labor or child labor under any circumstances.

4. Ensuring Occupational Safety and Health and Disaster Prevention

   We create a safe and hygienic workplace environment and strive to maintain the physical and mental health of each other. We also establish disaster prevention systems.

3. Provision of Products and Services

1. Safety and Quality of Products and Services

   We prioritize the safety and quality of products and services, strive for product improvement and enhancement of customer satisfaction.

2. Appropriate Display and Advertising

   We do not engage in displays and advertising of products and services that are contrary to or misrepresent the facts.

4. Environmental Conservation

1. Reduction of Environmental Impact

   We comply with all environmental laws and regulations applicable to our business. We are aware of the relationship between our operations and their impact on the environment, and we are committed to activities that aim to reduce environmental impacts. Furthermore, to make appropriate judgements concerning environmental laws and the environmental impacts, we strive to improve our understanding of environmental issues.

2. Promotion of environmentally friendly products and services

   We aim to contribute to solving environmental issues by promoting the use of products and services that have a low environmental impact. Additionally, we conduct activities to reduce environmental impacts while being mindful of the entire lifecycle of our products and services - including research, development, procurement, production, sales, transportation, use, recycling, and disposal.

5. Ethics

1. Corruption Prevention

   We comply with all laws and regulations regarding bribery prevention applicable to our business. We do not engage in any form of bribery, rebates, corrupt practices, extortion, money laundering, or embezzlement. We also do not promise, offer, permit, or receive bribes or other unfair or illegal means of gaining benefits.

2. Gifts and Entertainment

   We maintain appropriate relationships with all stakeholders, including public officials and politicians, and do not engage in acts that could be considered bribery. We also do not accept bribes.

3. Fair Business Competition

   We recognize the importance of fair competition in business and do not engage in unjust acts such as corruption, collusion, coercion, or fraudulent activities.

4. Promotion of Responsible Procurement

   We recognize that issues related to the environment, society, and corporate governance should be addressed throughout the entire supply chain and conduct procurement activities.

5. Conflict of interest

   We will not engage in any activities that damage TBM’s interests in order to personally benefit ourselves or any third party. Promptly report the matters to one’s supervisor and refrain from making decisions on our own in the event that a situation involving a conflict of interest occurs or is perceived to have occurred.
   Not act in conflict with the interests of the company without advance permission, which includes holding concurrent positions serving as an officer or employee at a competitor company or business partner.

6. Prohibition of Insider Trading and Similar Activities

   We do not leak insider information obtained in the course of our duties or use it for personal financial gain.

7. Separation between Personal and Professional Matters

   We always strictly maintain a separation between personal and professional matters and do not use our positions or duties for personal gain. Furthermore, unless explicitly authorized by the company, we do not engage in political activities, religious activities, solicitation of products or services, or any other activities unrelated to our duties on company premises.

8. Partnerships

   As responsible corporate citizens, we actively participate in social contribution activities and strive to contribute to the development of society and the community.

9. Rejection of Relationships with Anti-Social Forces

   We will not have any relationships with anti-social forces or organizations. If we receive demands for unfair transactions from anti-social forces or organizations, we firmly refuse them.

6. Information Security

1. Handling of Personal Information

   We handle personal information of customers, shareholders, business partners, officers, and employees with sufficient care to prevent leakage to both inside and outside the company, not only while employed but also after retirement.

2. Protection of Confidential Information

   We strictly manage confidential information of the company and business partners and do not disclose or leak it inside or outside the company for purposes other than legitimate ones. We also do not obtain confidential information by unlawful means.

3. Protection of Intellectual Property

   We do not infringe on the intellectual property rights of third parties such as patents or copyrights. Additionally, we recognize that intellectual property created in relation to business belongs to the company and protect and utilize rights appropriately.

4. Disclosure of Information

   All commercial transactions are conducted transparently and accurately reflected in the accounting books. We disclose information about labor, safety and health, environmental activities, business activities, organizational structure, financial condition, and performance in accordance with applicable regulations and current industry practices. We do not engage in record tampering or false disclosure regarding conditions and practices.

5. Prevention of Information Leakage and Disclosure

   We take defensive measures against threats such as cyberattacks that could cause damage to ourselves and others and strive to prevent information leakage and disclosure.