Clarion Group Codes of Conduct

Chapter 4 Respect of Human Rights

4.1 Promoting Respect of Human Rights

(1) We will respect international standards of conduct regarding human rights, and strive to ensure that we do not engage in any conduct that obstructs or interferes with human rights.

4.2 Eliminating Discrimination

(1) We will respect every person’s character and individuality in the recruitment and

treatment of employees, the conduct of commercial transactions, and all other company activities, and not engage in any acts that impair individual dignity or discriminate on the basis of sex, age, nationality, race, ethnicity, ideology, belief, religion, social status, family origin, disease, disability, etc.

4.3 Respect of Human Rights in Information Management

(1) We will establish information ethics based on consideration of human rights and the maintenance of security in information handling, to prevent in advance the emergence of problems from personal information leaks, computer viruses, and unauthorized access.

4.4 Respect of Basic Rights at Work

(1) We will advance employment with proper consideration for corporate social responsibility. We will hire employees in accordance with the governing domestic, foreign and local laws in each country and region. We will not use child labor that employs children below the minimum working age or coerced labor that is against the will of the workers.

(2) We will conduct procurement with proper consideration for corporate social responsibility, and will not procure goods or services from enterprises that utilize child labor or forced labor.

(3) Considering the laws and regulations and labor practices in each nation and region, and respecting the basic rights of employees presented as the principles of the United Nations Global Compact, we will strive to have employees and managers better understand each other’s problems and resolve issues jointly through genuine and constructive dialogue.

Chapter 5 Management Foundations

5.1 Management and Use of Information

(1) We will conduct appropriate management of all processes related to the life cycle of confidential information including information production, acquisition, confidentiality management, sharing and disclosure, storage and preservation, use, and disposal, and observe the protection of confidential Information, and appropriate use of information equipment to prevent incidents from information leaks and improper information use.

(2) We will protect information assets in accordance with the Information Security Policy.

(3) We will manage confidential information appropriately in accordance with internal company regulations.

(4) We will fully respect the rights and value of confidential information that belong to the company or other parties. We will observe these Codes of Conduct and related regulations, and appropriately manage and handle the company’s confidential information and confidential information disclosed to us by other parties, to prevent any information leaks that might cause damages to the company or other parties or constitute breach of contract or legal violations.

(5) We will follow the specified procedures and arrange appropriate measures for the maintenance of confidentiality such as nondisclosure agreements when disclosing the company’s confidential information to other parties.

(6) We will acquire confidential information that belongs to other parties only when necessary for the conduct of the company’s business, using fair and appropriate methods (contracts, etc.) in light of fair business practices. We absolutely will not acquire such confidential information through improper means. When we have acquired other parties’ trade secrets, we will strictly manage them as stipulated by the relevant contracts and implement the necessary measures after the relevant contracts have expired.

(7) We recognize the importance of protecting personal information, and we will handle personal information appropriately in accordance with the company’s Personal Information Protection Policy.

(8) We will organize and store documents, electronic files, records and other types of information. We will appropriately store documents and electronic files whose processing is complete, and destroy them by suitable means when their storage periods have expired.

5.2 Use of Inside Information and Related Considerations

(1) We will always take care to prevent leaks of company information. We will not disclose to third parties material confidential information regarding the company, our related companies or business partners (subsidiaries, affiliated companies, investee companies, contract partners, or companies with which we are negotiating contracts), or customers.

(2) When we learn undisclosed information regarding the company, our related companies or business partners, and customers that might affect the judgment of investors (insider information), we will not trade shares of the company, our related companies or business partners, or customers until the insider information is disclosed. We will exercise discretion in stock and other transactions in cases when it is not clear if the information constitutes insider information.

5.3 Management and Preservation of Company Assets

(1) We will actively create intellectual properties, protect them appropriately, and strive for their effective use. We recognize that the intellectual property rights to intellectual works created in relation with work duties at the company will all revert to the company as provided by the relevant laws, and we will follow the provisions of the related internal company regulations and the directions of the company for the appropriate protection of the company’s rights, and for their use.

(2) We will respect the intellectual property of other parties. We will prevent violations of other parties’ intellectual property rights in advance and, for the smooth progress of business, we will investigate other parties’ intellectual property rights beforehand when engaged in research, development, design, production and sales of new products or new technologies, and implement appropriate measures when any doubts arise.

(3) We will not infringe other parties’ copyrights regarding use of software and the Internet. For example, we will not install, use or duplicate software in violation of the terms of license agreements. We will manage software so that it is used correctly as a company asset.

(4) We will use the company’s tangible assets (land, buildings, facilities, equipment, products, office equipment, cash and deposits, negotiable securities, etc.) efficiently for business activities. We will observe company rules to prevent improper use, loss and theft.

(5) We will not engage in any acts that damage the value of tangible or intangible company assets, including financial assets, through improper use, personal use, etc.

(6) We will act to ensure that all business judgments and business activities are the best choices for the company, and we will not form any financial or other trading relations with suppliers, customers, or competitors that would conflict with the best interests of the company.

(7) We will implement fair accounting practices and proper information recording and reporting. We will also accurately and clearly record and report research findings, inspection data, business performance and other documents on a factual basis.

5.4 Arranging a Work Environment That Draws Out Employee Strengths

(1) We will comply with the relevant labor laws and regulations governing employment, personnel affairs, working conditions, wages and other employment terms, etc.

(2) We will respect the human rights of individual employees, and manage personnel records strictly with close attention to protecting personal information and privacy rights. We will absolutely refrain from any sort of sexual harassment or power harassment that violates human rights.

(3) We will strive to secure workplace safety based on the approach of giving priority to the protection of safety and health above all else.

(4) We will act to promote physical and mental health. We will give consideration not only to our own health, but also to the health of those around us.

(5) We will work to create workplaces where every individual employee can work with the sense that his or her work is worthwhile. We will support a work-life balance by realizing diverse working styles and using various types of vacation systems. We will also strive to create a workplace environment where employees can take leaves for pregnancy, childbirth, child-raising, and family nursing care as necessary.

(6) We will always strive to pursue self-improvement and make our best efforts so that we can manifest our greatest potential. Superiors will give their subordinates appropriate management, guidance, and training to extend their capabilities.

5.5 Observance of Laws and Regulations Governing Imports and Exports

(1) We will observe all related laws and regulations when conducting exports not only of products but also of all kinds of cargo and technologies.

(2) We will conduct effective export control in accordance with internal company regulations by being certain to confirm the end-use and end-users, even for domestic sales.

(3) We will observe all related laws and regulations when conducting imports.

Chapter 6 Complete Observance of Codes of Conduct

6.1 Complete Observance of Rules

(1) We will strive to always provide our employees with information on the relevant laws and internal company regulations required for the conduct of business. Every section will implement employee education regarding the relevant laws and regulations. We will revise internal company regulations and inform employees when concerned laws or regulations are revised, and when the company advances into new businesses, or new nations or regions.

(2) We will always observe laws and regulations and act fairly under any conditions, in accordance with these Codes of Conduct.

(3) We will immediately report to or consult with our superiors or the relevant sections whenever we suspect we might be violating laws or internal company regulations, and devise the necessary corrective actions. Similarly, we will immediately report to or consult with our superiors or the relevant sections whenever we suspect that the actions of others may not be in accordance with laws or internal company regulations.

(4) We will always note that rules change with the times, and act with good common sense under the principle of “Basics and Ethics.”

(5) We will take strict measures whenever employees act in violation of relevant laws or regulations, including disciplinary dismissal in light of the reprimand provisions of the Employment Regulations.

6.2 Implementation of Self-Audits

(1) We will implement self-audits to confirm that internal company procedures are being properly executed in accordance with the relevant laws and internal company regulations.

6.3 Internal Reporting System

(1) We will establish a system for employee reporting of illegal, unfair and improper acts concerning the business of the company or its Group companies. When reports are made, we will examine the facts and implement corrective measures as necessary. We will use this system for complete observance of laws and regulations, and to conduct corporate activities with a high ethical viewpoint.

(2) We will not engage in any prejudicial treatment of individuals who submit reports, except in cases of bad-faith reports that are malicious slander or libel. When individuals who submit reports are involved in illegal activities, the individual concerned will not be exempted from responsibility through the provision of information, but the fact that the individual has provided information will be taken into consideration as extenuating circumstances.

Chapter 7 Responsibilities of Top Management

(1) Top management will personally take the lead in striving for business operations with corporate ethics and compliance as the main axis, in accordance with these Codes of Conduct. When violations of these Codes of Conduct occur, top management will personally devise corrective measures and strive to prevent recurrence. Top management will also fulfill responsibility for explanation and for swift and accurate information disclosure, and implement strict measures against illegal acts, including measures on itself. In addition, top management will encourage suppliers and other supply chain partners to promote business operations with corporate ethics and compliance as the main axis.

Supplementary Provision Hitachi Group Implementation of Codes of Conduct

The Clarion Group Codes of Conduct shall apply to all officers and employees of Clarion, Ltd. and its consolidated subsidiaries. All subject companies shall set or revise these Codes of Conduct as the “Hitachi Group Codes of Conduct” or as the codes of conduct of their own company at a board of directors meeting or other decision-making organ of the company, and take appropriate measures so that all their officers and employees accurately understand these Codes of Conduct.

Companies may also enact their own individual codes of conduct, incorporating the contents of these Codes of Conduct. Such individual codes of conduct can alter the contents in accordance with the legal systems, social customs and business characteristics of their respective nations or regions, or add stipulations that are not included in these Codes of Conduct. However, those individual stipulations may not under any circumstances contradict the stipulations of these Codes of Conduct or relax their contents.

When companies do establish individual codes of conduct, those codes of conduct must expressly stipulate that they have been prepared based on or referring to the Hitachi Group Codes of Conduct.

Enacted on March 8 , 2011

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