Procurement policy

Seikoh Giken Group "Clean Procurement Guidelines"

　Procurement departments of Seikoh Giken Group execute their operations in accordance with the following "Clean Procurement Guidelines" based on the business ethics standards and code of conduct of Seikoh Giken Group in order to conduct with their transacting business partners fair and sound procurement activities.

１．Ethic Codes 「Fair Competition and Trading」

　Seikoh Giken Group in one of its business ethics standards makes reference to fair competition and fair dealing. Stipulated in the provisions of this standard are the following ethical behavior maxims concerning procurement activities.

• ■　Do not seek profits by unlawful means or secret (covert) act.
• ■　During business transaction, be aware that all business counterparties are good partners with equal position as our company, and shall keep impartial and honest in business communication.
• ■　Do not take any money or valuable article from any business counterpart, and do not accept extravagant entertainment or excessive benefits from the counterpart.
• ■　Do not use any implicit way to demand the business counterparty to provide money, article, entertainment or advantage.
• ■　Observe the principles of modesty and self-restriction, and be careful when giving gift or entertainment. Do not go beyond the reasonable scope of gift and entertainment.

２．Clean Procurement Guidelines

　In order to ensure fair and sound procurement activities with transacting business partners, Seikoh Giken Group has based on its business ethics standards and code of conduct established the following "Clean Procurement Guidelines" which will be applied at all times to all procurement activities.

• ■　Accept no seasonal gifts or other presents from transaction counterparties.
• ■　Accept no cash, checks, gift certificates, beer coupons, book tokens, or other money and goods from transaction counterparties.
• ■　Accept no dining invitations from transaction counterparties unless the event is hosted by Seikoh Giken group.
• ■　Accept no golf or travel invitations from transaction counterparties unless the event is hosted by Seikoh Giken group.
• ■　Accept no sponsorship money or sponsorship goods from transaction counterparties at events hosted by Seikoh Giken group.
• ■　Engage in no trading in shares (whether publicly traded on not) of transaction counterparties based on insider information.
• ■　Accept no offer to purchase at a discounted price (such as through company-internal sales or sales by intermediation, etc.) any product of a transaction counterparty.
• ■　Engage in no barter trade with a transaction counterparty.
• ■　Engage in no other action that involves accepting grants of personal benefits.

Responsible Mineral Procurement Policy

　Some of the minerals such as tin, tantalum, tungsten, gold, cobalt, and mica, mined in the Democratic Republic of the Congo and its neighboring countries, as well as in high-risk areas (CAHRAs), may become a source of funding for armed groups in conflict areas through illicit mining and trading, and may lead to child labor, forced labor, or other labor problems and violations of human rights.
　These are now major international issues, and avoiding them is one of the social responsibilities demanded of business.
　We view the issues of minerals as an important social problem, and have made it our basic policy not to procure minerals that clearly contribute to human rights violations or conflict in high-risk areas or conflict zones, and work with our procurement partners in order to avoid procuring such materials for use.
　In the event that we discover a severe risk in our supply chain, we will request that our partners cooperate with our efforts to avoid using such materials, switch to low-risk supply chains, and engage in responsible mineral procurement.
　We ask that our partners understand the international situation regarding conflict minerals, consent to avoid their use, and work with the Seikoh Giken group to engage in responsible mineral procurement.