MinebeaMitsumi Group Code of Conduct

Ⅱ. CODE OF CONDUCT

1. LABOR

The MinebeaMitsumi Group is committed to upholding the human rights of employees, and to treating them with dignity and respect. All MinebeaMitsumi Group companies shall adhere to the following standards regarding use of labor:

(1) Freely Chosen Employment

Forced, bonded, indentured, or involuntary and inhuman prison labor shall not be used. All work shall be voluntary, and MinebeaMitsumi employees shall be free to leave upon reasonable notice in compliance with applicable law, regulation, and contractual agreement. MinebeaMitsumi employees shall not be required to hand over government-issued identification, passports, or work permits as a condition of employment.

(2) No Child Labor

Child labor shall not to be used in any stage of manufacturing. The term "child" refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. MinebeaMitsumi supports the use of legitimate workplace apprenticeship programs which comply with all laws and regulations. MinebeaMitsumi employees under the age of 18 shall not perform hazardous work and may be restricted from night work with consideration given to educational needs.

(3) Discrimination

The MinebeaMitsumi Group is committed to a workforce free of harassment and discrimination. MinebeaMitsumi Group companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, employees or potential employees should not be subjected to medical/pregnancy tests that could be used in a discriminatory way.

(4) Harsh or Inhumane Treatment

MinebeaMitsumi Group companies shall not allow any harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of employees, nor shall the threat of any such treatment be allowed.

(5) Minimum Wages

Compensation paid to employees shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits. Any disciplinary wage deductions are to conform to applicable law and regulation. The basis on which employees are paid shall be clearly communicated to them in a timely manner.

(6) Working Hours

Work weeks are not to exceed the maximum set by applicable law and regulation. Employees should be allowed at least one day off per seven-day week.

(7) Freedom of Association

The MinebeaMitsumi Group respects the rights of its employees to associate freely, join labor unions, seek representation, and or join workers' councils in accordance with applicable law and regulation. Employees shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.

2. HEALTH AND SAFETY

The MinebeaMitsumi Group recognizes that the quality of its products and services, consistency of production, and employee morale are enhanced by a safe and healthy work environment. All MinebeaMitsumi Group companies shall adhere to the following standards regarding health and safety:

(1) Machine Safeguarding

Physical guards, interlocks and barriers for machinery used by employees shall be provided where appropriate, and shall be properly maintained.

(2) Industrial Hygiene

Employee exposure to chemical, biological and physical agents shall be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, employees shall be provided with appropriate personal protective equipment.

(3) Safety

Employee exposure to workplace safety hazards shall be identified, evaluated, and controlled through proper design, engineering and administrative controls, preventative maintenance, and safe work procedures. Where hazards cannot be adequately controlled by these means, employees shall be provided with appropriate personal protective equipment.

(4) Emergency Preparedness and Response

Emergency situations and events shall be identified and assessed, and their impact minimized by implementing emergency response and recovery plans and procedures.

(5) Occupational Injury and Illness

Procedures and systems shall be implemented to manage, track and report occupational injury and illness, including provisions to:
a) encourage worker reporting;
b) classify and record injury and illness cases;
c) provide necessary medical treatment;
d) investigate cases and implement corrective actions to eliminate their causes; and,
e) facilitate return of employees to work.

(6) Physically Demanding Work

Employee exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks shall be identified, evaluated and controlled. Employees shall be provided with appropriate equipment to perform such tasks.

(7) Dormitory and Canteen

Workers shall be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities. Worker dormitories provided by the MinebeaMitsumi Group shall be clean, safe, and provide emergency egress, adequate heat and ventilation, and reasonable personal space.

3. ENVIRONMENT

The MinebeaMitsumi Group recognizes that environmental responsibility is integral to producing world class products. In our operations, adverse effects on the environment and natural resources shall be minimized while safeguarding the health and safety of the public. All MinebeaMitsumi Group companies shall adhere to the following standards regarding the environment:

(1) Product Content Restrictions

All products shall adhere to applicable laws, regulations, and customer requirements regarding prohibition or restriction of specific substances, including labeling laws and regulations for recycling and disposal.

(2) Chemical and Hazardous Materials

Chemical and other materials posing a hazard if released to the environment shall be identified and managed to ensure their safe handling, movement, storage, recycling or reuse, and disposal.

(3) Wastewater and Solid Waste

Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities shall be monitored, controlled, and treated as required by applicable law and regulation.

(4) Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations shall be characterized, monitored, controlled, and treated as required by applicable law and regulation.

(5) Environmental Permits and Reporting

All environmental permits and registrations required by applicable law and regulation shall be obtained, maintained, and kept current. The operational and reporting requirements of all permits and registrations shall be followed.

(6) Pollution Prevention and Resource Reduction

Waste of all types, including water and energy, are to be reduced or eliminated to the extent practicable at the source or by practices such as modifying production, maintenance, and facility processes, materials substitution, conservation, recycling, and or re-using materials.

4. ETHICS AND BUSINESS PRACTICE

To meet our social responsibilities and to increase our corporate value, The MinebeaMitsumi Group are to uphold the highest standards of ethics including:

(1) No Corruption, Extortion, or Embezzlement

The highest standards of integrity shall be maintained in all business interactions. Any and all forms of corruption, extortion and embezzlement are strictly prohibited. Any such conduct may result in termination and legal action.

(2) Disclosure of Information

Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices.

(3) No Improper Advantage

Bribes or other means of obtaining undue shall not be offered or accepted.

(4) Fair Business, Advertising, and Competition

Standards of fair business, advertising, and competition are to be upheld. Customer information shall be safeguarded.

(5) Community Engagement and International Operation

Community engagement is encouraged to help foster social and economic development. The MinebeaMitsumi Group, as an international corporation, contributes to the development of the community in every country in which we operate by not only complying with the laws and rules of each country, but also by respecting its history, culture and customs.

(6) Protection of Intellectual Property

The MinebeaMitsumi Group respects intellectual property rights and implements proper measures to protect others' intellectual rights. To protect those rights, the Group also pays full attention to transferring and handling our or others' technologies or know-how.

(7) Fair Stock Trading

In accordance with applicable laws, regulations, and company rules, no insider information obtained in the course of work is to be used or leaked for improper advantage in stock trading. The MinebeaMitsumi Group does not engage in unfair or improper stock trading with shareholders or investors.

(8) Import/Export

Compliance with not only the laws and rules of each country but also all applicable international rules, regulations, and trade agreements shall be maintained when trading products or materials with, or providing technological assistance to, foreign countries. Appropriate management systems and procedures shall be maintained to assure compliance.

(9) Response to Antisocial Forces

The MinebeaMitsumi Group has no relations with any antisocial forces that may or will pose a threat to the public order and/or safety. At the same time, regarding unreasonable demands, if any, from such forces, without making compromises, the Group shall cooperate with external specialized institutions, including police and lawyers, and deal with such demands in a resolute attitude.

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