MinebeaMitsumi Group Code of Conduct

Ⅲ. MANAGEMENT SYSTEM

1. ROLE OF THIS CODE OF CONDUCT

This Code of Conduct is one of the important tools for practicing Compliance based on the company policy. We assure all the stakeholders that, by practices based on the system described below, we will carefully follow the guidelines set out in This Code of Conduct.

2. STRUCTURE OF COMPLIANCE

(1) Chief Officer of Compliance

Representative Director, Chairman CEO of MinebeaMitsumi Inc. takes a role of the chief officer of the compliance system of MinebeaMitsumi group.

(2) Compliance Committee

The Compliance Committee, a body to promote Compliance including This Code of Conduct, is established directly under the President of MinebeaMitsumi Inc.
The Compliance Committee assumes the operation of this Code of Conduct, approved by the Board of Directors, and takes a role of making decisions to address urgent requirements when a serious violation of the compliance occurs.
A secretariat for the Compliance Committee shall be the Compliance Office. The secretariat functions as an organ to execute and promote measures approved by the Compliance Committee. It also function as the secretariat for the body that makes decisions to address urgent requirements when a serious violation of the compliance occurs.

(3) Application to Each Company of Our Group and Supply Chain

This Code of Conduct is to be circulated by the MinebeaMitsumi Inc. to each company of our group. Each company is required to take necessary compliance measures in accordance with This Code of Conduct.
Moreover, efforts shall be made to voluntarily observe this Code of Conduct in the MinebeaMitsumi Group's supply chain, and each Group company shall request as appropriate that its suppliers and subcontractors agree to and implement this Code of Conduct.

(4) Addition of Detailed Guidelines

When putting This Code of Conduct into practice, while some detailed guidelines have been already stipulated, new detailed guidelines may be added according to specific requirements. We must comply not only with This Code of Conduct but also with such new detailed guidelines.

(5) Duty to Report

When you are not sure if your acts or decisions violate This Code of Conduct, it is your duty to consult your superiors, the responsible departments or the consultation service separately designated by the company.
Also, when you notice any violation of This Code of Conduct by a director or an employee, you must immediately report to your supervisors, the responsible departments, and the Personnel & General Affairs Division or the consultation service designated by the company.
We ensure that every aspect of the privacy, such as his/her name and the content of the above-mentioned consultation, will be kept secret. We also ensure that he/she will not be disadvantaged due to such consultation.

(6) Penalty

In case of violating This Code of Conduct, one will be subjected to disciplinary action according to the company rules. When the act of violation causes damage to the company, he/she may be required to indemnify the company for the loss.
One who violates This Code of Conduct for the following reasons will not be exempt from responsibility.

1. Lack of knowledge on laws and regulations
2. Absence of intention to violate the laws and regulations
3. Intention to act for the benefit of the company

(7) Education and Training

Based on This Code of Conduct, education and training concerning compliance are conducted for the following purposes. The employees who are ordered to participate in the training by the Compliance Committee, the secretariat, or an immediate supervisor must not refuse or fail to attend the training without legitimate reasons.

1. To increase the awareness of overall compliance issues such as laws and regulations as well as corporate ethics.
2. To provide accurate knowledge of This Code of Conduct and various office regulations.

(8) Audit

Each company of our group is required to conduct regular internal audits in accordance with This Code of Conduct to ensure none of the company activities violates the compliance manual.
With the cooperation of each related department, the secretariat, according to the specific requirements, is to conduct audit to find out if there is any acts of violation of the compliance within our group. The secretariat is then required to report the result of the audit to the Compliance Committee. It also orders the concerned department/section to correct its inadequate operation if necessary.

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