Compliance Basic Policy and Code of Conduct_TOA SEIKI

Basic Policy

TOA SEIKI CO., LIMITED. [TOA SEIKI] and its affiliates (collectively "we", "us", or "our") contribute to a sustainable society through fair and ethical business practices. To fulfill our corporate philosophy and uphold social trust, compliance is our fundamental principle—all executives and employees must adhere to domestic/international laws, social norms and corporate ethics, acting with integrity and high ethical awareness at all times.

Code of Conduct

All executives and employees shall follow and implement the below Code of Conduct in line with the Basic Policy.

1. Fair Transactions and Competition

Antimonopoly Act Compliance: We uphold fair, free competition and prohibit acts violating the Antimonopoly Act, such as cartels, bid rigging and unreasonable trade restraints.
Anti-Bribery and Improper Benefits: We neither offer nor accept improper benefits or favors from suppliers or other stakeholders.
Import and Export Controls: We strictly manage the import/export of products and technologies in compliance with relevant laws to support international peace and security.
Rejection of Antisocial Forces: We maintain no ties with antisocial forces or organizations that threaten civil order and safety.

2. Rigorous Information Management and Security

Confidential and Personal Information Protection: We strictly manage confidential and personal information of customers, suppliers and our own in line with laws and internal regulations to prevent unauthorized access, leakage or loss.
Intellectual Property Respect: We respect our own and others’ intellectual property rights (patents, trademarks, copyrights, etc.) and prohibit unauthorized use or infringement.
IT Security Assurance: We rigorously implement information system and network security measures, enhancing preparedness against cyberattacks and system failures.

3. Respect for Human Rights and a Sound Working Environment

Human Rights Respect and Anti-Discrimination (see separate "Human Rights Policy"): We prohibit discrimination or harassment based on race, gender, nationality, religion, disability or similar grounds, and respect individual diversity.
Occupational Safety and Health: We comply with occupational safety and health laws, striving to create a safe, comfortable workplace that supports employees’ physical and mental well-being.
Fair Treatment and Talent Development: We ensure fair evaluation and treatment, supporting employee development and self-improvement to help them fully realize their potential.

4. Global Environmental Consideration

Environmental Compliance and Impact Reduction: We comply with environmental laws, regulations and customer requirements. As an electronics trading company, we handle eco-friendly products and promote resource conservation and energy efficiency in business operations.

5. Transparency and Communication

Timely Information Disclosure: We disclose accurate, timely information on management, financial status and corporate activities to investors and society.
Transparent Organizational Management: We clearly separate public and private matters, strictly prohibit conflicts of interest, and conduct business with high transparency.
Communication Promotion: We engage in constructive dialogue with customers, suppliers, shareholders, local communities and employees to build cooperative social relationships.

6. Crisis and Risk Management Systems

Early Issue Detection and Correction: To address risks (compliance violations, misconduct, disasters, quality issues), we establish daily reporting channels and response procedures for prompt action. We also promote the internal whistleblowing system to detect and correct problems early.

7. Local Community Contribution

Active Social Contribution: Respecting local cultures and customs, we actively participate in social contribution and community engagement as a responsible corporate citizen.

Compliance Basic Policy and Code of Conduct