MinebeaMitsumi Group Code of Conduct

MinebeaMitsumi Group Officer and Employee Compliance Guidelines

Ⅰ. Declaration

We established the "Minebea Group Code of Conduct" ("the Code of Conduct") in 2005, with the goal of maintaining proper conduct as a corporate citizen. We have requested the officers and employees of the Minebea Group to comply with the Code and have expressed our attitude widely to our shareholders, customers, employees, local communities and clients.

We further establish detailed rules regarding the "the Code of Conduct"in 2010. With these rules, we intend to even more strongly assure that all officers and employees of the Minebea Group share the values and morals provided for in the "the Code of Conduct" and put the Code into practice, with the recognition that compliance in a corporation is sustained by each of its officers and employees and that this is an era when more and more consciousness and responsibilities are required of each member of a corporation in addition to actions by the corporation itself.

To begin with, I, as a person in charge of compliance for our group, hereby declare that I will comply with these rules and become a good example to the officers and employees of the MinebeaMitsumi Group. I request all the MinebeaMitsumi Group officers and employees to understand the spirit of these rules and comply with them in accordance with my declaration.

October 6, 2023
MINEBEA MITSUMI Inc.
Representative Director, Chairman CEO
Yoshihisa Kainuma

Ⅱ. Compliance Guidelines

These "MinebeaMitsumi Group Officer and Employee Compliance Guidelines" ("the Guidelines") are provided as the standards of conduct with which all officers and employees of the MinebeaMitsumi Group must comply. All officers and employees of the MinebeaMitsumi Group ("We") shall read, understand and comply with the Guidelines.

Compliance

1. Compliance with laws and regulations and internal company rules, and conduct of ethical business activities

We shall confirm, understand and comply with all laws and regulations, internal company rules relevant to our business operations based on the fact that one of the primary management policies of the MinebeaMitsumi Group is to conduct ethical business activities while complying with applicable laws and regulations in each country or region where we conduct the business activities. In addition, we shall not carry out business operations that are contrary to corporate ethics.

2. Maintenance of credibility and reputation of the MinebeaMitsumi Group

We shall endeavor to maintain the credibility and reputation of the MinebeaMitsumi Group, and shall not carry out any act that would lead to the damage of its credibility or reputation.

Diversity

3. Respect for culture and customs in each country and region

The MinebeaMitsumi Group has been expanding its business globally. We shall endeavor to conduct business operations respecting the culture, customs and history of each country and region.

Labor

4. Respect for fundamental human rights

In performing our duties for the Company, we shall respect the fundamental human rights of all related persons, and shall not discriminate against those persons based on their sex, age, birthplace, nationality, race, ethnicity, creed, religion, disease, disability or other personal attributes.

5. No harassment

We shall not commit any kind of harassment (including sexual harassment and power harassment (harassment by supervisors).

6. Realization of work-life balance

We shall mutually respect ways of working that suit individual life styles, and shall aim to realize work-life balances.

Health and safety

7. Maintenance of healthy and safe workplace

We shall comply with laws and regulations related to labor, and endeavor to maintain a healthy workplace environment. In addition, we shall comply with internal company rules regarding safety and health in the workplace and endeavor to prevent occurrence of occupational injury and illness, and if any injury or illness should occur, we will immediately report it in accordance with the prescribed procedures. We shall endeavor to prevent mental health problems by respecting each other's opinions and creating a workplace with an open atmosphere.

Environment

8. Business activities that consider the environment

We shall comply with environmental laws and regulations and internal company rules, and endeavor to reduce as much as possible, at all stages of business activities, environmental risks such as environmental burdens and pollution problems resulting from consumption and other uses of energies and resources.

Ethics and business practice

9. Timely and appropriate disclosure of information

We shall appropriately disclose company information (including business conditions and product information) to our customers, shareholders and investors on a timely basis.

10. Protection of confidential and personal information

We shall use confidential information of the Company, confidential information of other companies that we obtain from business partners, and personal information of our customers, employees, and other persons, solely in accordance with laws and regulations, internal company rules, and shall not divulge confidential or personal information.

11. No offering of bribes

We shall not offer bribes or other means of obtaining undue favor and we shall also not accept them. In addition, we shall not commit any act of bribery or any other act that is against the law or in violation of good business morals and practice for the purpose of obtaining illicit profits in business from persons with public positions such as members of the National Diet, public officials or foreign public officials.

12. Ensuring fair trade and competition

We shall comply with laws and regulations regarding free and fair competition and trade in each country and region, and shall conduct fair business activities.

13. Protection of intellectual property

We understand the importance of intellectual property in modern society and shall endeavor to protect the Company's rights and take great care not to infringe on the rights of other companies.

14. Prevention of insider trading

We shall not sell or purchase shares, corporate bonds or other securities through insider trading or in any other way that could be misconstrued as insider trading.

15. Appropriate procedures for import and export, etc. of products and materials, etc.

We shall comply with relevant laws and regulations (including import and export laws and regulations) and internal company rules and follow appropriate procedures when we export and import products, materials, machinery equipment, etc., and when we execute technical license agreements.

16. Response to antisocial forces

We shall take a resolute attitude toward antisocial forces and groups that pose a threat to the order and safety of civil society, and shall sever any relations with those forces and groups.

17. Protection of company assets

We shall carefully use company assets and expenses in accordance with internal company rules, and shall not use them wastefully or for personal purposes.

18. No conflicts of interest

We shall not commit any act from which we or third parties would benefit at the sacrifice of the fair profits of the Company.

Social contribution

19. Provision of useful products for society

We shall endeavor to develop and provide products that will contribute to the (sustainable) development of (the economy and) society including maintenance of the global environment, such as products that promote technical innovation to reduce input of resources and energies, products with excellent durability, and recyclable products. In addition, we shall take a stance to faithfully listen to the voice of our customers and consumers, and endeavor to ensure the safety and quality of our products and services.

20. Contribution to local community

The Company, as a good corporate citizen, shall endeavor to realize a better society. Every one of us shall consider social contribution, and endeavor to contribute to society.

Coexistence with international society

21. Compliance with international rules and contribution to local community

When we are involved in businesses in other countries and regions, we shall not only comply with international rules and local laws and regulations, but shall also understand the circumstances in their local communities and endeavor to contribute to their development.

Compliance structure

22. Internal reporting

If we recognize (i) any act in breach of laws or regulations, internal company rules or any of the similar regulations of the MinebeaMitsumi Group including the Guidelines, (ii) any act that is problematic for corporate ethics, or (iii) any act suspected to be (i) or (ii), we shall immediately report to or consult our superiors, the responsible departments, or other internal avenues of communication services regarding the matter.

Ⅲ. Penalties

A breach of the Guidelines may be subject to disciplinary action under each MinebeaMitsumi Group Company's internal rules such as the Employee Handbook.

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